LaSalle County Station, Units 1 and 2 - Relief Request CR ...contained in Request for Relief CR-26, Parts A through Fat LSCS, Units 1 and 2 for the Second 1O-year ... pressure tests

UNITED STATES NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20555-0001

September 21, 2009

Mr. Charles G. Pardee President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT: LASALLE COUNTY STATION, UNITS 1 AND 2 - RELIEF REQUEST CR-26, INSERVICE INSPECTION PROGRAM RELIEF REGARDING EXAMINATION COVERAGE FOR THE SECOND 10-YEAR INSERVICE INSPECTION INTERVAL (TAC NOS. MD9817 - MD9818)

Dear Mr. Pardee:

By letter to the Nuclear Regulatory Commission (NRC) dated October 1, 2008 (Agencywide Documents Access and Management System (ADAMS) ML082760276), as supplemented by letters dated November 18, 2008 (ADAMS Accession No. ML083260525), May 26, 2009 (ADAMS Accession No. ML091540385), and August 25, 2009 (ADAMS Accession No. ML092380634), Exelon Generation Company, LLC (the licensee) submitted relief request CR26, for the LaSalle County Station (LSCS), Units 1 and 2. Specifically, CR-26 requested approval to use a proposed alternative to the existing American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," on the basis that compliance with the specified requirements is impractical due to plant design.

The NRC staff has completed its review of CR-26. The details of the NRC staff's review are included in the enclosed safety evaluation. The NRC staff has determined that the ASME Code requirements are impractical in the licensee's Request for Relief CR-26 Parts A through F. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(g)(6)(i), and is in compliance with the ASIVIE Code's requirements. Therefore, the NRC staff grants relieffor the subject examinations of the components contained in Request for Relief CR-26, Parts A through Fat LSCS, Units 1 and 2 for the Second 1O-year Inservice Inspection Interval.

C. Pardee - 2

All other ASME Code, Section XI requirements for which relief was not specifically requested and approved in the subject requests for relief remain applicable, including third-party review by the authorized Nuclear Inservice Inspector.

SincerelYJ r ~-).~

Stephen J. Campbell, Chief Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket Nos. 50-373 and 50-374

Enclosure: Safety Evaluation

cc w/encl: Distribution via ListServ

UNITED STATES NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20555·0001

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

ON THE SECOND 10-YEAR INTERVAL INSERVICE INSPECTION

REQUEST FOR RELIEF CR-26

EXELON GENERATION COMPANY, LLC

LASALLE COUNTY STATION, UNITS 1 & 2

DOCKET NOS. 50-373 AND 50-374

1.0 INTRODUCTION

By letter to the Nuclear Regulatory Commission (NRC) dated October 1, 2008 (Agencywide Documents Access & Management System (ADAMS) ML082760276), as supplemented by letters dated November 18, 2008 (ADAMS Accession No. ML083260525), May 26, 2009 (ADAMS Accession No. ML091540385), and August 25, 2009 (ADAMS Accession No. ML092380634), Exelon Generation Company, LLC (the licensee) submitted relief request CR26, for the LaSalle County Station (LSCS), Units 1 and 2. Specifically, CR-26 requested approval to use a proposed alternative to the existing American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," on the basis that compliance with the specified requirements is impractical due to plant design.

2.0 REGULATORY REQUIREMENTS

Inservice inspection (lSI) of the ASME Code Class 1, 2, and 3 components is to be performed in accordance with Section XI of the ASME Code, and applicable addenda, as required by Title 10 of the Code of Federal Regulations (10 CFR) Part 50.55a(g}, except where specific relief has been granted by the Commission pursuant to 10 CFR 50.55a(g}(6}(i}. The regulation at 10 CFR 50.55a(a}(3} states that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if the licensee demonstrates that (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Pursuant to 10 CFR 50.55a(g}(4}, ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code, Section XI, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code, which was incorporated by reference in 10 CFR 50.55a(b} 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The ASME Code of record for

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the LSCS, Units 1 and 2 second 1O-year interval inservice inspection programs, which ended on October 1, 2007, is the 1989 Edition, no Addenda, of Section XI of the ASME.

3.0 EVALUATION

The information provided by the licensee in support of the request for relief from, or alternative to, ASME Code requirements has been evaluated and the bases for disposition are documented below. For clarity, the licensee's request has been evaluated in several parts according to ASME Code, Section XI, Examination Category.

3.1 Request for Relief CR-26, Part A, ASME Code, Section XI, Examination Category 8-A, Items 81.12 and 81.21 (LCS-1) and 81.22, 81.30, and 81.40 (LCS-1 and LCS-2), Pressure Retaining Welds in Reactor Vessel

3.1.1 ASME Code Requirement

ASME Code, Section XI, Table IW8-2500-1. Examination Category 8-A, Items 81.12,81.21, 81.22 and 81.30 require essentially 100 percent volumetric examination, as defined by ASME Code, Section XI, Figures IW8-2500-2, -3 and -4, of the length of reactor pressure vessel (RPV) longitudinal shell welds, circumferential and meridional head welds, and shell-to-flange welds, respectively. In addition, ASME Code, Section XI, Item 81.40 requires essentially 100 percent volumetric and surface examination, as defined by ASME Code, Section XI, figure IW8-2500-5, of the length of RPV head-to-flange welds. "Essentially 100%", as clarified by ASME Code Case N-460, Alternative Examination Coverage for Class 1 and Class 2 Welds, is greater than 90 percent coverage of the examination volume, or surface area, as applicable. ASME Code Case N-460 has been approved for use by the NRC in Regulatory Guide (RG) 1.147, Revision 15, "Inservice Inspection Code Case Acceptability."

3.1.2 Licensee's ASME Code Relief Request

In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from examining 100 percent of the ASME Code-required inspection volumes for the RPV pressure retaining welds shown in Table 3.1.1.

Table 3.1.1 - ASME Code, Section XI, Examination Category B-A ASME Weld ID Weld Type Coverage Obtained Code Item

81.12 LCS-1-8G 1 RPV Shell Vertical Welds 75.3%

81.12 LCS-1-8H 1 RPV Shell Vertical Welds 88.8%

81.21 GEL-1006-AJ 1 RPV 80ttom Head-to-Shell Weld 19.0%

81.22 GEL-1009 1 RPV Top Head Meridional Welds 77.2% DM

81.22 GEL-1009 1 RPV Top Head Meridional Welds 77.2% DP

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Tabla1,.;fii-I',$i\!IE Q2de~ ~;~'E WeldlD I

iTtlrr ina"f;ln Cateaorv ij,.A C0verage</~9tained

Item

81.22 GEL-1009DR

1 RPVTop Head Meridional Welds 68.0%

81.22 GEL-1009DT

1 RPVTop Head Meridional Welds 68.0%

81.22 GEL-1061DA

2 RPV 80ttom Head Meridional Welds

66.0%

81.22 GEL-1061DE

2 RPV 80ttom Head Meridional Welds

66.0%

81.22 GEL-1061-DF 2 RPV 80ttom Head Meridional Welds

66.0%

81.30 LCS-1-AF 1 RPV Shell-to-Flange Weld 55.4%

81.30 LCS-2-AE 2 RPV Shell-to-Flange Weld 58.0% (0-180 deg) 54.6% (180-360 deg)

81.40 GEL-1009AG

1 RPV Top Head-to-Flange Weld 71.9% (0-180 deg) 49.0% (180-360 deg)

81.40 GEL-1060AG

2 RPVTop Head-to-Flange Weld 65.3% (0-180 deg) 80.6% (180-360 deg)

3.1.3 Licensee's 8asis for Relief Request (as stated)

RPV Shell Vertical Welds (LCS-1-8G and LCS-1-8H)

During the ultrasonic examination of two of the vertical shell welds, LCS-1-8G and [LCS1-8H,l approximately 75 percent and 89 percent coverage was obtained respectively. Scanning is limited in both the parallel direction and transverse directions. Vertical weld LCS-1-8G scanning is limited on both sides as well as above and below the welded pad area surrounding instrument nozzle N12-A. The ultrasonic transducers cannot contact the weld or the surrounding base material as the N12-A nozzle pad is welded directly over the vertical weld. Vertical weld LCS-1-8H scanning is limited on both sides, as well as above and below due to the presence of the LCS-1-N68 nozzle forging. During fabrication, the installation of the nozzle forging proceeded directly through the vertical weld area. The presence of the forging and the associated nozzle to shell weld does not allow contact by ultrasonic transducers of the vertical weld or the surrounding base material. Scanning of the intersecting portions of circumferential welds LCS-1-AD and LCS-1-AC above and below respectively, vertical weld LCS-1-8H was completed with minor interference on the upper right side of the vertical weld due to the presence of welded thermocouple brackets. In order to scan all of the required volume for these two vertical welds, the instrument nozzle, the LCS-1-N68 nozzle forging, and the

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thermocouple brackets would need to be redesigned and relocated to for allow additional scanning, which is impractical.

RPV Bottom Head to Shell Weld (GEL-1006-AJ)

The RPV shell to bottom head weld obtained approximately 19 percent coverage. No scanning can be performed from the bottom side of the weld due to the presence of the reactor support skirt and the welded pad to which it is attached. Scanning is limited from the top side of the weld in both the parallel and transverse directions for the same reason. The ultrasonic transducers cannot physically contact all of the required areas due to the pad and skirt attachment in the area of the weld. In order to scan all of the required volume for this weld, the RPV support skirt attachment would need to be redesigned to allow complete scanning of the weld, which is impractical.

RPV Top Head Meridional Welds (GEL-1009-DM, GEL-1009-DP. GEL-1009-DR, and GEL-1009-DT)

The VOlumetric examinations of the RPV head meridional welds were limited in the parallel and transverse directions due to the presence of 6.5 inch wide, 24 inch long lifting lugs. The lugs are welded to the shell plates directly over these four meridional welds. The ultrasonic transducers cannot physically access the adjacent surfaces of the welds and base metal allowing approximately 68 percent to 72 percent coverage of the weld volume. In order to scan all of the required volume for these welds, the head and associated lifting lugs would need to be redesigned to allow access to [100 percent] of the welds, which is impractical.

RPV Bottom Head Meridional Welds (GEL-1061-DA. GEL-1061-DE. and GEL-1061-DF)

The RPV bottom head meridional welds obtained approximately 66 percent coverage. No scanning can be performed from the bottom side of the weld due to the presence of the reactor support skirt and the welded pad to which it is attached. Scanning is limited from the top side of the weld in both the parallel and transverse directions for the same reason. The ultrasonic transducers cannot physically contact all of the required areas due to the pad and skirt attachment in the area of the weld. In order to scan all of the required volume for this weld, the RPV support skirt attachment would need to be redesigned to allow complete scanning of the weld, which is impractical.

RPV Shell-to-Flange Weld (LCS-1-AF and LCS-2-AE)

Ultrasonic examinations of the RPV shell-to-flange weld are limited in both the parallel and transverse directions. The ultrasonic transducers cannot maintain contact due to the curvature of the flange base material in the area of the weld. In order to scan all of the required volume for this weld, the shell-to-flange joint would need to be redesigned to allow scanning from the flange side of the weld, which is impractical.

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RPV Top Head-to-Flange Weld (GEL-1009-AG and GEL-1060-AG)

Ultrasonic examination for RPV top head-to-flange weld is limited in the parallel direction. The ultrasonic transducers cannot maintain contact due to the curvature of the flange base material in the area of the weld. In order to scan all of the required volume for this weld, the head-to-flange joint would need to be redesigned to allow scanning from the flange side of the weld, which is impractical.

3.1.4 Licensee's Proposed Alternative Examination

No additional volumetric examinations were proposed by the licensee.

3.1.5 Staff Evaluation

The ASME Code requires essentially 100 percent volumetric examination of pressure retaining welds in the RPV. However, the design configuration of the RPV longitudinal shell welds, circumferential and meridional head welds, shell-to-flange welds, and head-to-flange welds limits complete examinations due to adjacent components such as instrument nozzles, support skirts and welded pads, lifting lugs, and the geometric configuration of the flange-to-head and flangeto-shell welds. In order to effectively increase the examination coverage, the RPV and adjacent components would require design modifications or replacement. This would place a burden on the licensee; thus, examining essentially 100 percent of the ASME Code-required volumes is impractical.

As shown in the sketches and technical descriptions1 included in the licensee's submittal, examinations of the welds listed in Table 3.1.1 above have been performed to the extent practical, with the licensee obtaining coverage ranging from approximately 19 percent to 88 percent of the ASME Code-required inspection volumes. The RPV shell longitudinal weld examinations (LCS-1-BG and LCS-1-BH) were restricted by instrumentation nozzles which are located directly over the longitudinal welds. The RPV bottom head-to-shell weld (GEL-1006-AJ) and RPV bottom head meridional welds (GEL-106'I-DA, GEL-1061-DE, and GEL-1061-DF) could only be scanned from the top side of the weld because of interference caused by the reactor support skirt and the welded pad to which it is attached. In the case of the RPV top head meridional welds (GEL-1009-DM, GEL-1009-DP, GEL-1009-DR, and GEL-1009-DT), volumetric coverage was limited due to the presence of lifting lugs located directly over the meridional welds. For the RPV shell-to-flange welds (LCS-1AF and LCS-2-AE) and RPV top head-to-flange welds (GEL-1009-AG and GEL-1060-AG), the curvature of the flange restricted coverage of the ASME Code-required volumes. Many of the examinations were conducted with equipment, procedures and personnel that where qualified by performance demonstration initiative (PDI) to the process outlined in ASME Code, Section XI, Appendix VIII. Certain welds were examined prior to these PDI requirements; therefore, these examinations were conducted using ASME Code-required technical guidance at the time of the examinations. All indications detected were evaluated as being acceptable per ASME Code. In addition, the licensee completed the ASME

1 Sketches and technical descriptions provided by the licensee are not included in this report.

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Code-required surface examination for the RPV head-to-flange welds with no indications being detected.

The licensee has shown that it is impractical to meet the ASME Code-required 100 percent volumetric examination coverage for the subject welds due to their geometrical design and proximity of integral RPV components. 8ased on the volumetric coverage obtained, along with the full ASME Code-required surface examination completed for the head-to-flange weld, it is reasonable to conclude that if significant service-induced degradation were occurring, evidence of it would have been detected by the examinations that were performed. Therefore, the examinations performed provide reasonable assurance of structural integrity of the subject components listed in Table 3.1.1 above.

3.2 Request for Relief CR-26, Part 8, (LCS-1 and LCS-2) ASME Code, Section XI. Table IW8-2500-1, Examination Category 8-0, Item 83.90, Full Penetration Welded Nozzles in Vessels, RPV Nozzle-to-Vessel Welds


ASME Code, Section XI, Table IW8-25001, Examination Category 8-0, Item 83.90 requires 100 percent vOlumetric examination, as defined by ASME Code, Figures IW8-2500-7(a) through (d), as applicable, of RPV nozzle-to-vessel welds. ASME Code Case N-460 as an alternative approved for use by the NRC in RG 1.147, Revision 15, states that a reduction in examination coverage due to part geometry or interference for any Class 1 and 2 welds is acceptable provided that the reduction is less than 10 percent, Le., greater than 90 percent examination coverage is obtained.


In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from examining 100 percent of the ASME Code-required inspection volumes for the RPV nozzle-to-shell welds shown in Table 3.2.1.

Tapfe"$.2.1.~A;ME Cod~;;~~tion XI, Examination Category S-O

~E~e, m

Weld tIS> LCS Unit

Reactor Recirculation Nozzle-to-RPV








Coverage Ci':)btained

83.90 LCS-1-N1A 1 57.94%

83.90 LCS-1-N18 1 58.60%

83.90 LCS-1-N2A 1 83.10%

83.90 LCS-1-N28 1 70.90%

83.90 LCS-1-N2C 1 70.90%

83.90 LCS-1-N20 1 70.90%

83.90 LCS-1-N2E 1 70.90%

83.90 LCS-1-N2F 1 70.90%

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ASUiGodeiS~Qtion XI Examinatioh s8-D~2. Les,ASt\1IE eld Type <~~'ll~rage Obtainedco~~, ~r~tS+G:::Item

LCS-1-N2G83.90 1 Reactor Recirculation Nozzle-to-RPV 83.10%

83.90 LCS-1-N2H 1 Reactor Recirculation Nozzle-to-RPV 83.10%

83.90 LCS-1-N2J 1 Reactor Recirculation Nozzle-to-RPV 70.90%

LCS-1-N2K83.90 1 Reactor Recirculation Nozzle-to-RPV 70.90%

LCS-1-N3A83.90 1 Main Steam Nozzle-to-RPV 59.95%

83.90 LCS-1-N38 1 Main Steam Nozzle-to-RPV 59.95%

83.90 LCS-1-N3C 1 Main Steam Nozzle-to-RPV 59.95%

83.90 LCS-1-N3D Main Steam Nozzle-to-RPV 59.95%1

83.90 LCS-1-N4A 1 Feedwater Nozzle-to-RPV 72.30%

LCS-1-N48 1 Feedwater Nozzle-to-RPV 72.30%83.90

Feedwater Nozzle-to-RPV 83.90 LCS-1-N4C 1 72.30%

Feedwater Nozzle-to-RPV 72.30%LCS-1-N4D 183.90

Feedwater Nozzle-to-RPV 72.30%LCS-1-N4E83.90 1

Feedwater Nozzle-to-RPV 72.30%LCS-1-N4F 183.90

85.50%Low Pressure Core Spray Nozzle-to-RPV 83.90 LCS-1-N5 1

Residual Heat Removal Nozzle-to-RPV 69.50%LCS-1-N6A 183.90

Residual Heat Removal Nozzle-to-RPV 83.70%LCS-1-N68 183.90

Residual Heat Removal Nozzle-to-RPV 69.50%LCS-1-N6C83.90 1

Reactor Core Isolation Cooling 87.0% Nozzle-to-RPV

183.90 LCS-1-N7

Reactor Head Vent Nozzle-to-RPV 79.0%LCS-1-N8 183.90

Control Rod Drive Nozzle-to-RPV 72.40%1LCS-1-N1083.90

85.50%High Pressure Core Spray Nozzle-to-RPV 83.90 LCS-1-N16 1

87.0%Spare Nozzle-to-RPV LCS-1-N1883.90 1

64.70%Reactor Recirculation Nozzle-to-RPV LCS-2-N1A 283.90

Reactor Recirculation Nozzle-to-RPV 60.40%2LCS-2-N1883.90

Reactor Recirculation Nozzle-to-RPV 70.50%2LCS-2-N2A83.90

70.0%Reactor Recirculation Nozzle-to-RPV LCS-2-N28 283.90

70.0%Reactor Recirculation Nozzle-to-RPV LCS-2-N2C 283.90

70.30%Reactor Recirculation Nozzle-to-RPV 2LCS-2-N2D83.90

70.50%Reactor Recirculation Nozzle-to-RPV 2LCS-2-N2E83.90

70.0%Reactor Recirculation Nozzle-to-RPV LCS-2-N2F 283.90

70.0%Reactor Recirculation Nozzle-to-RPV LCS-2-N2G 283.90

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It

83.90 LCS-2-N2H 2 Reactor Recirculation Nozzle-to-RPV 70.0%

83.90 LCS-2-N2J 2 Reactor Recirculation Nozzle-to-RPV 70.0%

83.90 LCS-2-N2K 2 Reactor Recirculation Nozzle-to-RPV 70.0%

83.90 LCS-2-N3A 2 Main Steam Nozzle-to-RPV 68.0%

83.90 LCS-2-N38 2 Main Steam Nozzle-to-RPV 68.0%

83.90 LCS-2-N3C 2 Main Steam Nozzle-to-RPV 62.10%

83.90 LCS-2-N3D 2 Main Steam Nozzle-to-RPV 62.10%

83.90 LCS-2-N4A 2 Feedwater Nozzle-to-RPV 78.1%

83.90 LCS-2-N48 2 Feedwater Nozzle-to-RPV 78.1%

83.90 LCS-2-N4C 2 Feedwater Nozzle-to-RPV 78.1%

83.90 LCS-2-N4D 2 Feedwater Nozzle-to-RPV 78.1%

83.90 LCS-2-N4E 2 Feedwater Nozzle-to-RPV 78.1%

83.90 LCS-2-N4F 2 Feedwater Nozzle-to-RPV 78.1%

83.90 LCS-2-N5A 2 Low Pressure Core Spray Nozzle-to-RPV 70.50%

83.90 LCS-2-N6A 2 Residual Heat Removal Nozzle-to-RPV 68.40%

83.90 LCS-2-N68 2 Residual Heat Removal Nozzle-to-RPV 70.50%

83.90 LCS-2-N6C 2 Residual Heat Removal Nozzle-to-RPV 68.40%

83.90 LCS-2-N7 2 Reactor Core Isolation Cooling 63.20% Nozzle-to-RPV

83.90 LCS-2-N8 2 Reactor Head Vent Nozzle-to-RPV 64.10%

83.90 LCS-2-N9A 2 Jet Pump Instrument Nozzle-to-RPV 82.90%

83.90 LCS-2-N98 2 Jet Pump Instrument Nozzle-to-RPV 82.90%

83.90 LCS-2-N10 2 Capped Control Rod Drive Return 68.0% Nozzle-to-RPV

83.90 LCS-2-N16 2 High Pressure Core Spray Nozzle-to-RPV 70.50%

83.90 LCS-2-N18 2 Spare Nozzle-to-RPV 63.20%

3.2.3 Licensee's 8asis for Relief Request (as stated)

Ultrasonic examination of these nozzle-to-shell welds is limited in both the parallel direction and transverse directions. The ultrasonic transducers cannot maintain contact due to the curvature of the nozzle base material in the area of the weld. Scanning from the nozzle forging side of the welds is not possible due to tapered areas in the forgings. In order to scan all of the required volume for this weld, the nozzles would need to be redesigned to allow scanning from the nozzle side of the welds, which is impractical.

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No additional volumetric examinations were proposed by the licensee


The ASME Code requires 100 percent volumetric examination of full penetration welded nozzles in the RPV. However, examinations of the nozzles listed above in Table 3.2.1 above are limited by the curvature of the nozzle design and tapered ends of the nozzle forgings. In order for the licensee to obtain 100 percent of the ASME Code-required examination coverage of the subject nozzle-to-vessel welds, the nozzles and/or the RPV would need to be redesigned and modified. This would place a burden on the licensee; therefore, the ASME Code volumetric examination requirements are considered to be impractical for the components listed in Table 3.2.1 above.

As shown on the sketches and technical descriptions2 included in the licensee's submittal, examination of the subject nozzles has been performed to the extent practical with the licensee obtaining vOlumetric coverage ranging from approximately 57 percent to 87 percent. These nozzles are of the "set-in" design which essentially makes the welds concentric rings aligned parallel with the nozzle axes in the through-wall direction of the RPV shell. This design geometry limits ASME Code-required ultrasonic angle beam examinations to be performed only from the shell side of the welds. In addition, the curvature for the nozzle radius forging or a combination of the nozzle configuration and adjacent components (such as other nozzles and thermocouples) precludes ultrasonic examination to the extent required by the ASME Code for each of the nozzles listed in Table 3.2.1 above.

Many of the examinations were conducted with equipment, procedures and personnel that where qualified by POI to the process outlined in ASME Code, Section XI, Appendix VIII. Certain welds were examined prior to these performance demonstration requirements; therefore, these examinations were conducted using ASME Code-required technical guidance at the time of the examinations. Ultrasonic examinations on these carbon steel nozzle welds included O-degree longitudinal, and 45-degree, 60-degree and 70-degree shear and longitudinal waves from the shell side. These examinations encompassed most of the weld and base materials near the inside surface of the vessel, which is the area where one would expect service degradation to initiate, if occurring. Additionally, although ultrasonic scans were primarily limited to the shell side only, recent studies have found that inspections conducted through carbon steel are equally effective whether the ultrasonic waves have only to propagate through the base metal, or have to also propagate through the carbon steel weldmenf All indications detected were evaluated as being acceptable per ASME Code.

The licensee has shown that examining the full ASME Code-required volumes for the subject RPV nozzle-to-vessel welds is impractical. However, based on the volumetric coverage that was


3 P. G Heasler, and S. R. Doctor, 1996. Piping Inspection Round Robin, NUREG/CR-5068, PNNL-10475, U.S. Nuclear Regulatory Commission, Washington, DC.

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obtained on the these nozzles, it is reasonable to conclude that, if significant service-induced degradation were occurring, evidence of it would have been detected by the examinations that were performed. Therefore, the examinations performed provide reasonable assurance of structural integrity of the subject components listed in Table 3.2.1 above.

3.3 Request for Relief CR-26, Part C, (LCS-1 and LCS-2) ASME Code, Section XI. Table IWB-2500-1, Examination Category B-H, Item B8.1 0, Integral Attachments for Vessels, Reactor Pressure Vessel


ASME Code, Section XI, Table IWB-2500-1, Examination Category B-H, Item B8.10 requires essentially 100 percent surface examination, as defined by ASME Code, Section XI, Figures IWB-2500-13 through 15, as applicable, of the length of ASME Code, Class 1 integral attachment welds. "Essentially 100%," as clarified by ASME Code Case N-460, is greater than 90 percent coverage of the examination volume, or surface area, as applicable. ASME Code Case N-460 has been approved for use by the NRC in RG 1.147, Revision 15.


In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from examining 100 percent of the ASME Code-required inspection surfaces for integral attachment welds RPV-SS-1 and 2RPV-SS-2, on the RPV at LSCS, Units 1 and 2, respectively.

3.3.3 Licensee's Basis for Relief Request (as stated)

There are six RPV stabilizer support bracket attachment lugs equally spaced around the outside circumference of the RPV at the upper intermediate shell course elevation. The attachment lugs and the shell course are constructed of carbon steel, A-533 Grade B, Class 1 material. The attachment lugs are 14 inches wide by 7 inches high, and full penetration welded to the RPV shell. [During the required surface examination of the attachment weld, RPV-SS-1, reduced coverage was obtained due to other plant structures and components.] Accessibility to [100 percent] of the examination areas for these welds is limited due to the proximity of the bioshield wall, the stabilizer assembly bar, and vessel insulation. The entire 14 inches of the lower horizontal length of the weld is inaccessible for surface examination due to the biological shield wall and the stabilizer assembly bar. The 14 inches of the top horizontal length and both 7 inch side weld lengths are inaccessible for surface examination without cutting and then repairing the insulation. The surface examination coverage obtained was approximately [66% and 52% for LCS-1 and LCS-2, respectively] of the entire weld surface. Due to the vessel insulation being panel-type and linked by several small screws which are inaccessible for the subject panels due to the stabilizer bars and brackets, the ability to remove the insulation is not practical due to the tight clearances and potential to damage the fasteners and insulation joints. To provide even limited surfaced examination coverage, the insulation must be cut and then repaired. These activities must be done in an elevated dose rate field.

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3.3.4 Licensee's Proposed Alternative Examination (as stated)

No additional surface examinations are proposed [by the licensee.] All components received the required examinations applicable to the extent practical due to the limited or lack of access available.


The ASME Code requires essentially 100 percent surface examination of the attachment welds on the subject RPV stabilizer lugs. However, surface examinations are limited due to partial inaccessibility caused by their proximity to the bio-shield wall and other RPV appurtenances. In order for the licensee to obtain 100 percent of the ASME Code-required examination coverage of the subject integral attachment welds, the stabilizer lugs, adjacent bio-shield, and RPV insulation would need to be redesigned and modified. This would place a burden on the licensee; therefore, the ASME Code examination requirements are considered impractical.

RPV-SS-1 (LSCS, Unit 1) and 2RPV-SS-2 (LSCS, Unit 2) are one of six stabilizer lugs on the RPVs at LSCS, Unit 1 and 2. These are essentially 14-inch by 7-inch carbon steel plates welded to the RPV that connect to a stabilizer assembly for support of the vessel. The lugs are located on the external surface of the RPV in the bio-shield wall annulus. Because of their location, existing stabilizer brackets, and RPV insulation access to the lower portions of the lugs are limited for performance of the ASME Code-required surface examinations. A liquid penetrant examination was performed on the accessible portions of these integral attachment welds with surface coverage of approximately 66 percent and 52 percent, for integral attachments RPV-SS-1 and RPV-SS-2, respectively. No recordable indications were detected on the examined areas. In addition, a VT-1 visual examination covering 100 percent of the required examination areas was performed to augment the limited surface examinations with no recordable indications being observed.

The licensee has demonstrated that examination of the subject integral attachment welds was performed to the extent practical. Based on the surface and VT-1 visual coverage(s) that were obtained on these welds, it is reasonable to conclude that, if significant service-induced degradation were occurring, evidence of it would have been detected by the examinations performed. Therefore, the examinations performed provide reasonable assurance of structural integrity of the subject components.

3.4 Request for Relief CR-26, Part D, (LCS-1) ASME Code, Section XI. Table IWC-2500-1 , Examination Category C-B, Item C2.21, Pressure Retaining Nozzle Welds in Vessels ASME Code Requirement

ASME Code, Section XI, Table IWC-2500-1, Examination Category C-B, Item C2.21 requires 100 percent surface and volumetric examination, as defined by ASME Code, Section XI, Figure IWC-2500-4(a) or (b), as applicable, for ASME Code, Class 2 nozzle-to-shell (or head) welds. ASME Code Case N-460, as an alternative approved for use by the NRC in RG 1.147, Revision 15, states that a reduction in examination coverage due to part geometry or interference for any Class 1 and 2 weld is acceptable provided that the reduction is less than 10 percent, i.e., greater than 90 percent examination coverage is obtained.

- 12


In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from examining 100 percent of the ASME Code-required inspection volume for nozzle-to-vessel Weld RH-HX1 B-1, on Residual Heat Removal Heat Exchanger 'I B.


The heat exchanger shell head and nozzle materials are carbon steel. During the ultrasonic examination of the shell head to nozzle, reduced coverage was obtained. The coverage reported represents the aggregate coverage from all scans performed on the weld and adjacent base material. Scanning is limited in the transverse direction. The ultrasonic transducers cannot maintain contact due to the curvature of the nozzle base material in the area of the weld. Scanning from the nozzle forging side of the welds is not possible due to tapered areas in the forgings. Due to the cladding on the inside diameter, two directional coverage from one side is not possible. In order to scan all of the required volume for this weld, the nozzles would need to be redesigned to allow scanning from the nozzle side of the welds, which is impractical.

The ASME Code surface examination was completed on weld RH-HX'I B-1. There were no limitations and no indications identified during the 1996 examination. The magnetic particle examination data sheet for weld RH-HX1 B-1 (Le., data sheet # 96-230) is provided in Attachment 24

.

The components within the scope of Relief Request CR-26 were examined during the second Inservice Inspection interval, which encompassed the period from October 17, 1994, through September 31,2007. Accepted inspection technologies for that time period were utilized to complete these examinations. These included updated equipment based on computer modeling of the Residual Heat Removal Heat Exchanger nozzles, and technology resulting from advances in ultrasonic examinations due to the [POI]. At the time, phased array technology was not generally developed by the industry to the point where it could be utilized to perform qualified examinations. Specifically, Exelon Generation Company, LLC's (EGC's) inspection vendor does not yet have a qualified phased array technique for examination of vessel welds. When such advances are available to deliver qualified examinations, they will be assessed to determine whether they can achieve increased inspection coverage.


No additional surface and volumetric examinations have been proposed. The licensee stated that the required examinations have been performed to the extent practical.

4 Attachment 2 provided by the licensee is not included in this report.

- 13


The ASME Code requires 100 percent surface and volumetric examination of ASME Code Class 2 nozzle-to-shell (or head) welds. However, for Residual Heat Removal Heat Exchanger nozzleto-shell Weld, RH-HX1 B-1, complete volumetric examination is restricted by the nozzle configuration and the cladding on the inner diameter. In order to achieve greater volumetric coverage, the nozzle and/or vessel would need to be redesigned and modified. Imposition of this requirement would create a burden on the licensee; therefore, the ASME Code-required 100 percent vOlumetric examination is considered impractical.

As shown on the sketches and technical descriptions5 included in the licensee's submittal, examination of nozzle-to-shell Weld RH-HX1 B-1 has been performed to the extent practical, with the licensee obtaining 80 percent of the ASME Code-required volumetric coverage on this carbon steel weld. Ultrasonic examinations included 45-degree shear wave examinations, oriented both circumferentially and axially to the weld, as performed from the head side. No examinations could be performed from the nozzle side of the weld due to the nozzle configuration. No reportable indications were observed.

The licensee has shown that it is impractical to meet the ASME Code-required volumetric examination coverage for nozzle-to-head weld RH-HX1 B-1, due to the nozzle configuration. However, based on the volumetric coverage obtained, it is reasonable to conclude that, if significant service-induced degradation were occurring, evidence of it would be have been detected by the examinations that were performed. Therefore, the examinations performed to the extent practical provide reasonable assurance of structural integrity of the subject components.

3.5 Request for Relief CR-26, Part E, (LCS-1 and LCS-2) ASME Code, Section XI, Table IWC-2500-1, Examination Category C-C, Items C3.1 0 and C3.30, Integral Attachments for Vessels, Piping, Pumps, and Valves


ASME Code, Section XI, Table IWC-2500-1, Examination Category C-C, Items C3.10 and C3.30 require 100 percent surface examination, as defined by Figures IWC-2500-5a through d, as applicable, for integral attachment welds to Class 2 pressure vessels and pumps, respectively. ASME Code Case N-460, as an alternative approved for use by the NRC in RG 1.147, Revision 15, states that a reduction in examination coverage due to part geometry or interference for any Class 1 and 2 weld is acceptable provided that the reduction is less than 10 percent, i.e., greater than 90 percent examination coverage is obtained.


- 14


In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from examining 100 percent of the ASME Code-required surface examinations for integral attachment welds on the pressure vessels and pumps shown in Table 3.5.1.

Ta E Code, Section XI, T C-2500-1, Examination Cate ASME

0

LCS Weld Coveragze Code Unit Obtained Item

C3.10 IRH-HX1 B-08A 1 Residual heat removal HX attachment 76%

C3.10 IRH-HX2B-08D 2 Residual heat removal HX attachment 74%

C3.30 IHP-PU1-04 1 High Pressure Core Spray Pump 16% attachment

C3.30 ILP-PU-04 1 Low Pressure Core Spray Pump 24% attachment

C3.30 IRH-PU1 C-04 1 Residual Heat Removal Pump attachment 21%


There are four welded attachments to the 1Band 2B Residual Heat Removal (RHR) Heat Exchangers, one in each quadrant of the vertically oriented vessel in the lower middle shell course. The attachment lugs and the shell course are constructed of carbon steel, SA-516 Grade 70, material. Only one of the four lugs at this location is required to be examined. The attachment lugs are constructed of two horizontally oriented plates 26.5 inches apart, full penetration welded to the vessel shell. The upper plate is 28 inches long and 1 inch thick. The lower plate is 30 inches long and 2.50 inches thick. Connecting the two horizontal plates are three equally spaced, vertically oriented gusset plates, each 1 inch thick and 26.5 inches long. The three gussets are vertically full penetration welded to the vessel, and horizontally full penetration welded to the upper and lower horizontal plates. The lower horizontal plate sits atop and is bolted to the upper flange of a structural beam. During the ASME Code Case required surface examination of the attachment weld, reduced coverage was obtained due to the presence of the structural beam. Its location makes the entire 30 inch length of the lower horizontal plate to vessel shell inaccessible for surface examination. The surface examination coverage obtained was approximately 76 [and 74 percent, respectively] of the entire attachment weld surface. Due to the design and construction of the attachment and structural beam, removal of the beam is not practical. The beam provides support of the vessel and its removal would require design and installation of alternative temporary supports so the structural integrity of the vessel would not be negatively affected. Removal of the beam and installation of any temporary supports would be done in an elevated dose rate field.

The High Pressure Core Spray (HPCS), Low Pressure Core Spray (LPCS), and RHR pumps are vertical shaft pumps and are all encased in concrete. The pressure retaining shell portions of the pumps are welded to the bottom of base plates that are bolted to

- 15

and rest on concrete foundations. The foundations are raised above the floor and the casings extend below floor level into concrete vaults. Each concrete foundation has an opening in one side that allows the suction piping to attach to the pump suction flange just above the floor level. The base plates and the shells are constructed of carbon steel, A-516 Grade 70, material. The base plates are 3.5 inches thick. During the ASME [Code required] surface examination of the attachment weld, reduced coverage was obtained due to the presence of the concrete foundations. The opening in the foundations allow for between 16 and 24 percent of the attachment weld length to be examined. No indications were recorded during these limited examinations. The remaining lengths of the welds are inaccessible as they are beneath and behind the concrete foundations. Due to the design and construction of the attachments and concrete foundations, removal of the pump to perform the ASME [Code required] surface examination is not practical. The foundation provides support to the pump shell and also the pump discharge head and motor. This would necessitate removal of the motor and surrounding interferences in order to lift the pump shell out of the vault and foundation, destruction of the concrete components, or their redesign. All of these activities would be done in an elevated dose rate field.


No additional surface examinations are proposed. All components received the required examinations applicable to the extent practical due to the limited or lack of access available.


The ASME Code requires 100 percent surface examination of the subject ASME Code, Class 2 integral attachment welds. However, surface examinations are limited due to partial inaccessibility caused by their design and proximity to structural steel, and portions of concrete foundations. In order for the licensee to obtain 100 percent of the ASME Code-required examination coverage for the subject integral attachment welds, the associated pumps and concrete foundations would have to be redesigned and modified. This would place a burden on the licensee; therefore, the ASME Code examination requirements are considered impractical.

As shown on the sketches and technical descriptions6 included in the licensee's submittal, examination of the subject integral attachment welds has been performed to the extent practical, with the licensee obtaining surface coverage of 76 percent and 74 percent for IRH-HX1 B-08A and IRH-HX2B-08D, respectively. Interference from a structural beam (IRI-i-HX1 B-08A) and structural support (IRH-HX2B-08D) caused the limited access. No reportable indications were found for IRH-HX1 B-08A. One indication (acceptable per ASME Code, Section XI, Table IWC3510-3) was found on the edge of the plate for IRH-HX2B-08D.


- 16

Magnetic particle examinations were also performed for integral attachment Welds IHP-PU1-04, ILP-PU-04, and IRH-PU1C-04 on the plate-and-shell designed pumps listed in Table 3.5.1. However, due to the concrete pedestals surrounding these pumps, only 16 percent (IHP-PU 104),24 percent (ILP-PU-04) and 21 percent (IRH-PU1C-04) of the required examination surface areas were achieved. No recordable indications were observed.

The licensee has shown that it is impractical to meet the ASME Code-required surface examination coverage for the subject Class 2 integral attachment welds. However, based on the surface coverage obtained, it is reasonable to conclude that, if significant service-induced degradation were occurring, evidence of it would be have been detected by the examinations that were performed. Therefore, the examinations performed provide reasonable assurance of structural integrity of the subject components.

3.6 Request for Relief CR-26, Part F, (LCS-1 and LCS-2) ASME Code, Section XI, Table IWC-2500-1, Examination Category C-G, Item C6.10, Pump Casing Welds


ASME Code, Section XI, Table IWD-2500-1, Examination Category C-G, Item C6.1 0 requires 100 percent surface examination, as defined by Figure IWC-2500-8, of the length of Class 2 pump casing welds. ASME Code Case N-460, as an alternative approved for use by the NRC in RG 1.147, Revision 15 states that a reduction in examination coverage due to part geometry or interference for any Class 1 and 2 weld is acceptable provided that the reduction is less than 10 percent, Le., greater than 90 percent examination coverage is obtained.


In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from examining 100 percent of the ASME Code-required inspection surfaces for the pump casing welds shown in Table 3.6.1.

Table 3.6.1 - ASME Code, Section XI, Table IWC-2500-1, Examination Cateaorv C-G ASME Code Item

WeldfD LCS, Unit

\\fv'eld Type Coverage Obtained

C6.10 HP-PU1-05 1 High Pressure Core Spray Pump weld

72.00%

C6.10 IHP-PU1-7A 1 High Pressure Core Spray Pump weld

-0%

C6.10 IHP-PU1-7B 1 High Pressure Core Spray Pump weld

0%

C6.10 IHP-PU1-7C 1 High Pressure Core Spray Pump weld

eO%


0%


0%

- 17

I aOle)3*~&,Ja . Nho:Xrt' COele XI Tabl~/'V'UC-250Q";'1, y C-G

~§:::.~,~~~eld rT/fil Unit

.\Nt.lp Type /Cbverag@ ObtaineCl


0%

C6.10 IHP-PU1-9 1 High Pressure Core Spray Pump weld

0%

C6.10 ILP-PU-7 1 Low Pressure Core Spray Pump weld

0%


0%


0%

C6.10 IRH-PU1C7A

1 Residual Heat Removal Pump weld 0%

C6.10 IRH-PU1C7B


C6.10 IRH-PU1C7C


C6.10 IRH-PU1C8A


C6.10 IRH-PU1C8B


C6.10 IRH-PU1C8C


C6.10 IRH-PU1C-9 1 Residual Heat Removal Pump weld 0%


0%


0%


0%


0%


0%


0%

C6.10 IHP-PU2-9 2 High Pressure Core Spray Pump weld

0%

C6.10 ILP-PU2-7 2 Low Pressure Core Spray Pump weld

0%

- 18

Table 3.6. SME Code, Section XI Table IWC-2500-1, Examination CateQorv C-G ASME. .Weld ID LCS, Weld Type Coverage Code Item Unit Obtained

C6.10 ILP-PU2-8 2 Low Pressure Core Spray Pump 0% weld

C6.10 ILP-PU2-9 2 Low Pressure Core Spray Pump 0% weld

C6.10 IRH-PU2C 2 Residual Heat Removal Pump weld 0% 7A

C6.10 IRH-PU2C 2 Residual Heat Removal Pump weld 0% 7B

C6.10 IRH-PU2C 2 Residual Heat Removal Pump weld 0% 7C

C6.10 IRH-PU2C 2 Residual Heat Removal Pump weld 0% 8A

C6.10 IRH-PU2C 2 Residual Heat Removal Pump weld 0% 8B

C6.10 JRH-PU2C 2 Residual Heat Removal Pump weld 0% 8C

C6.10 IRH-PU2C-9 2 Residual Heat Removal Pump weld 0%


The HPCS, LPCS, and RHR pumps [with the exception of HP-PU1-05] are vertical shaft pumps and are all encased in concrete. The shells are constructed of carbon steel, A516 Grade 70, material. The design of the pumps makes the welds inaccessible for inservice inspection. Therefore, it is impractical to perform the surface examination of these welds without destruction of the concrete resulting in unnecessary engineering and installation costs and radiation exposure without a compensating increase in safety. Additionally, due to the design of the subject pumps, access to the affected welds can only be achieved through disassembly of the pump, removal of the pump internals, and the required surface examinations performed from the inside surface of the welds. This effort, in the absence of any other necessary pump maintenance, represents a significant expenditure of man-hours and radiation exposure to plant personnel, without a compensating increase in plant safety. All of these activities would be done in an elevated dose rate field.


For the third 1O-year lSI interval, the following approved alternative examination requirements will be implemented. In the event the subject welds become accessible upon disassembly of anyone of the pumps, the welds will be surface examined from the inside surface, or a VT-1 visual examination will be performed for that particular pump group to the maximum extent practicable based on the obstructions and geometric

- 19

constraints detailed in this relief request. The examination method will be determined based on radiation environment data at the time access is enabled.


The ASME Code requires 100 percent surface examination of selected ASME Code, Class 2 pump casing welds. However, examinations of the casing welds listed in Table 3.6.1 above are limited by the design of the components, which essentially have the subject welds encased in concrete. In order for the licensee to obtain 100 percent of the ASME Code-required examination coverage for the subject pump casing welds, the associated pumps and concrete vaults would have to be redesigned and modified, or the pumps would require disassembly to access the welds form the inside diameter surface. This would place a significant burden on the licensee; therefore, the ASME Code examination requirements are considered impractical.

As shown on the sketches and technical descriptions? included in the licensee's submittal, examination of the subject welds could not be performed due to the pumps' design, which places the casing welds within vertical concrete vaults, making the welds inaccessible from the outside surface. One exception is Weld HP-PU1-05, which allowed limited examination covering for approximately 72 percent of the ASME Code-required surface of the weld. No recordable indications were observed on this weld. The remainder of these ASME Code, Section XI, Table IWC-2500-1, Examination Category C-G components consist of high and low pressure core spray pumps and RHR pumps, for which the casing welds are all encased in concrete; therefore, the required surface area was not accessible for examination. The licensee has proposed that, if for any reason, disassembly of these pumps is required during the upcoming interval, an examination of the pump casing welds will be performed from the inside surface of the pump. In addition, VT-2 visual examinations are performed on these pumps during each inspection period and during startup after a refueling outage.

The licensee has shown that it is impractical to meet the ASME Code-required surface examination coverage for the subject Class 2 pump casing welds. However, based on the VT-2 visual examinations that are being conducted, and the proposed surface examination of the welds if any pump is disassembled, it is reasonable to conclude that, if significant serviceinduced degradation occurs, evidence of it will be detected by the examinations that are being performed. The staff has determined that VT-2 visual examinations provide reasonable assurance of leak tightness of the pumps.

4.0 CONCLUSION

As set forth above, the NRC staff determined that the ASME Code requirements are impractical in the licensee's Request for Relief CR-26 Parts A through F. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(g)(6)(i), and is in compliance with the ASME Code's requirements. Therefore, the NRC staff grants relief for the subject examinations of the components contained


- 20

in Request for Relief CR-26, Parts A through Fat LCS, Units 1 and 2 for the Second 1O-year lSI interval.

The NRC staff has further determined that granting Request for Relief CR-26 Parts A-F pursuant to 10 CFR 50.55a(g)(6)(i) is authorized by law and will not endanger life or property, or the common defense and security, and is otherwise in the public interest given due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.


Principal Contributor: T. McLellan, NRR

Date: September 21, 2009

LASALLE COUNTY STATION UNITS 1 AND 2 Second 10-Year lSI Interval

TA8LE 1 SUMMARY OF RELIEF REQUESTS

Page 1 of 1

Relief Request Number

TLR RR

Sec. System or

Component Exam.

Category Item No. Volume or Area to be

Examined Required Method

Licensee Proposed Alternative

Relief Request Disposition

CR-26, Part A 3.1 Class 1 RPV Pressure Retaining Welds

8-A 81.12 81.21 81.22 81.30 81.40

100% of longitudinal shell welds, circumferential and meridional welds, shell-toflange and head-to-f1ange welds

Volumetric and Surface, as applicable

Use volumetric and surface (as applicable) coverage achieved

Granted 10 CFR 50.55a(g)(6)(i)

CR-26, Part 8 3.2 Class 1 RPV Nozzle-to-Vessel Welds

8-D 83.90 100% of RPV nozzle-tovessel Welds

Volumetric Use volumetric coverage achieved


CR-26, Part C 3.3 Class 1 RPV Integrally Welded Attachments

8-H 88.10 100% of integral attachment welds

Surface Use surface coverage achieved


CR-26, Part D 3.4 Class 2 Nozzle Welds in Vessels

C-8 C2.21 100% of nozzle welds Volumetric and Surface

Use volumetric coverage achieved


CR-26, Part E 3.5 Class 2 Integral Attachments for Vessels, Piping, Pumps and Valves

C-C C3.10 C3.30

100% of integrally welded attachments for pressure vessels and pumps

Surface Use surface coverage achieved


CR-26, Part F 3.6 Class 2 Pressure Retaining Welds in Pumps and Valves

C-G C6.10 100% of pump casing welds

Surface Use surface coverage achieved and VT-2 visual examinations


Attachment 1

C. Pardee -2


Sincerely,

IRA!

Stephen J. Campbell, Chief Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket Nos. 50-373 and 50-374

Enclosure: Safety Evaluation

cc w/encl: Distribution via ListServ

DISTRIBUTION: PUBLIC LPL3-2 R/F RidsNrrDorlLpl3-2 Resource RidsNrrPMLaSalie Resource RidsNrrLATHarris Resource RidsNrrDorlDpr Resource RidsOgcRp Resource RidsRgn3MailCenter Resource RidsAcrsAcnw_MailCTR Resource

ADAMS Accession No. ML092570321 I\lRR-028

OFFICE LPL3-2/PM LPL3-2/LA LPL3-2/BC

NAME CGoodwin THarris SCampbell

DATE 9/18/09 9/18/09 9/21/09

OFFICIAL RECORD COpy