ML15216A363

ASME Section XI Inservice Inspection Program Relief Requests for Limited Coverage Examinations Performed in the Fourth 10-Year Inspection Interval

ML15216A363
Person / Time
Site:	Millstone
Issue date:	07/30/2015
From:	Mark D. Sartain Dominion, Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
15-313
Download: ML15216A363 (76)

Text

Dominion Nuclear Connecticut, Inc. D mno 5000 Dominion Boulevard, Glen AMien, VA 23060 -~UE~EE Web Address: www.dom.com July 30, 2015 U.S. Nuclear Regulatory Commission Serial No.15-313 Attention: Document Control Desk NLOS/WDC R0 Washington, DC 20555 Docket No. 50-423 License No. NPF-49 DOMINION NUCLEAR CONNECTICUT. INC.

MILLSTONE POWER STATION UNIT 3 ASME SECTION Xl INSERVICE INSPECTION PROGRAM RELIEF REQUESTS FOR LIMITED COVERAGE EXAMINATIONS PERFORMED IN THE THIRD 10-YEAR INSPECTION INTERVAL The Millstone Power Station Unit 3 (MPS3) third 10-year interval for the inservice inspection program began on April 23, 2009. During the first inspection period of this interval, the components identified in Attachments 1 through 5 received less than the required examination coverage. Accordingly, pursuant to 10 CFR 50.55a(g)(5)(iii),

Dominion Nuclear Connecticut, Inc. requests relief on the basis that the required examination coverage was impractical due to physical obstructions and limitations imposed by design, geometry and materials of construction of the subject components.

Attachments 1 through 5 contain the specific relief requests and the individual basis for each request. These relief requests have been reviewed and approved by the station's Facility Safety Review Committee.

If you have any questions or require additional information, please contact Wanda Craft at (804) 273-4687.

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering

Serial No.15-313 Docket No. 50-423 Page 2 of 2 Attachments:

1. Relief Request IR-3-19 - Examination Category B-A, Pressure Retaining Welds in Reactor Vessel

2. Relief Request IR-3 Examination Category B-D, Full Penetration Welded Nozzles in Vessels - Inspection Program B.

3. Relief Request IR-3-21, Examination Category C-A, Pressure Retaining Welds in Pressure Vessels.

4. Relief Request IR-3-22, Examination Category C-F-i, Pressure Retaining Welds in Austenitic Stainless Steel High Alloy Piping.

5. Relief Request IR-3-23, Examination Category C-F-2, Pressure Retaining Welds in Carbon or Low Alloy Steel Piping.

Commitments made in this letter: None cc: U.S. Nuclear Regulatory Commission Region I 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 R. V. Guzman Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-C 2 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station

Serial No.15-313 Docket No. 50-423 ATTACHMENT 1 RELIEF REQUEST IR-3-19 EXAMINATION CATEGORY B-A PRESSURE RETAINING WELDS IN REACTOR VESSEL DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3

Serial No.15-313 Docket No. 50-423 Attachment 1, Page 1 of 6 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)

Inservice Inspection Impracticality 1.ASME Code Components Affected:

ASME Code Class: Code Class 1 Examination Category: B-A, Pressure Retaining Welds in Reactor Vessel Item Numbers: RI1.40, Head-to-Flange Weld Component Identification: Listed in Table 1 Material: SA533, GR B, CL 1/SA508, CL 1 2, Applicable Code Addition and Addenda ASME Section Xl, 2004 Edition, No Addenda

3. Applicable Code Requirement ASME Section XI, 2004 Edition, Examination Category B-A requires volumetric examination of 100 percent (%) of the weld volume as defined in ASME Section XI Table IWB-2500-1 and shown in Figure IWB 2500-5. The alternative requirements of ASME Section Xl, Code Case N-460, approved for use in Regulatory Guide 1.147, Rev. 17, allows credit for essentially 100% coverage of the weld provided greater than 90% of the required volume has been examined.

4, Impracticality of Compliance Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the 100%

volumetric examination coverage requirement of the subject weld due to the design of the reactor vessel head with the geometric configuration and permanent obstructions which limit the volumetric coverage that can be obtained.

The reactor vessel head-to-flange weld was examined with a manual ultrasonic technique using pulse echo ultrasonic instruments and search units to achieve the maximum examination coverage practical. No alternative techniques or advanced technologies were considered capable of obtaining complete coverage of the examination volume.

Serial No.15-313

,, Docket No. 50-423 Attachment 1, Page 2 of 6 The geometric configuration and permanent obstructions limit the volumetric examination of the subject weld to approximately 81.2 % coverage using the most current examination technology. Access to this weld is limited on one side due to the taper of the flange that is within close proximity to the weld.

There is not sufficient distance from the weld to the flange to perform complete scanning on this side of the weld. Additionally, obstructions exist on the top side of the weld due to three permanently attached head lifting lugs that are 8.25 inches wide and located 10.75 inches from the centerline of the weld that restrict scanning on this side of the weld. Based on the configuration and the permanent obstructions, relief is requested from complying with 100% required examination coverage of this weld.

Additionally, a surface magnetic particle examination was performed. One hundred percent coverage was obtained with one recordable indication detected that was evaluated as acceptable in accordance with the acceptance standards of ASME Section Xl, IWB-351 0.3.

Isometric drawing(s) and coverage calculations are provided in this attachment.

Serial No.15-313 Docket No. 50-423 Attachment 1, Page 3 of 6 TABLE 1- Examination Category B-A Weld with Limited Volumetric Coverage Surface Weld Code Examination Angle Limitations and Examination Examination Identification Item # Configuration and Wave Mode Results Coverage (%) Results 101-101 B1.40 Closure Head-to- 00 Longitudinal Wave Examination limited 81.2% Magnetic particle Flange Weld 450 Shear Wave due to the flange examination 600 Shear Wave taper and performed obtaining permanently attached 100 percent lifting lugs that restrict coverage. One scanning in these indication was areas. No recordable detected that was indications were evaluated as detected. acceptable per ASME Section XI, IWB-351 0.

Serial No.15-313 Docket No. 50-423 Attachment 1, Page 4 of 6

5. Burden Caused by Compliance To increase examination coverage on the subject weld would require a significant design modification or replacement of the component with a different design to eliminate the noted obstructions. This option to meet the 100% Code examination requirement is considered impractical due to the cost, increased radiation exposure and impact to plant equipment.

6. Proposed Alternative and Basis for Use The subject weld received a volumetric examination on the accessible portions of the welds to the maximum extent practical given the limitations caused by the geometric configuration and permanent obstructions. Additionally, a surface examination was performed with 100% coverage obtained, and a visual (VT-2) examination is performed at the end of each refueling outage during the system leakage tests as required by Section Xl, IWB-2500-1, Category B-P.

Based upon the examination volume that was obtained with acceptable results, a surface examination obtaining 100% coverage, and the visual (VT-2) examination performed each refueling outage, it is reasonable to conclude that service induced degradation would be detected. Therefore, these proposed alternatives will provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds.

7. Period for Which Relief is Requested The relief is requested for the third ten-year inspection interval for Millstone Power Station Unit 3, which began on April 23, 2009 and will end April 22, 2019.

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Serial No.15-313 Docket No. 50-423 Attachment 1, Page 6 of 6 Component ID: 101-1.01 l.irting I.uus loxtcd at approx. 0", 120' & 24(1" 8.25" wide 10(.75" l~om weld ¢eetcrllne.

Weld Coverage Base Material Coverage 1-ead Side Weld Head Side Base Material o deg.=100% 0 deg,=92.6%

45 deg.=100% 45 dee.=99.5%

60 deg.=95.4% Total.Weld  :*'** To~la(W~d&overage in two directions 60 deg.-'93.6%

176 ' -'N4 6 8y sq" inches Flange Side Weld / \ --... /*,Qsverage 38.,% Flange Side Base Material 0 deg.=100% 0 deg.=92.6%

45 deg. -'53.0% 45 dcg,= 51.1%

60 deg.=38.9% 60 deg."' 31.9%

CW Weld CW Blase Material 0 deg.=100% 0 degr92.6%

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45 deg.=100%

Total Arca /.x '\ B/a* Material in 60 deg.=92.6%

60 deg.=100%

82.77 sq~jnclses, j "> '... I /6drcto 20 sq. inches CCWV Weld * /*'*,2}", *,* /./Covrag 9.2 CCW Base Material 0 deg.='92.6%

0 deg.""100%

45 deg.--92.6%

45 deg.=100% 60 deg.=92.6%

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0 deg. Weld and Base Material Area Flaense III!*

iTotal Coveragewi th 0deg.

leatd 100.46 sq. inchea 93.1 sq. inches 1 / \ _ Coverage 92.6%

Examination Coverage Sunmmary Weld Volume =[3 8.9% (Perpendicular scan)+100% (Parallel scan)]/2=69.4%

Base Material Volume=[93 .6%(Perpendicular scan)+92.6%(Paral lel scan)]/2=93.lI%

Total Coverage =81.2%

Serial No.15-313 Docket No. 50-423 ATTACHMENT 2 RELIEF REQUEST IR-3-20 EXAMINATION CATEGORY B-D FULL PENETRATION WELDED NOZZLES IN VESSELS -

INSPECTION PROGRAM B DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3

Serial No.15-313 Docket No. 50-423 Attachment 2, Page 1 of 20 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)

Inservice Inspection Impracticality

1. ASME Code Components Affected:

ASME Code Class: Code Class I Examination Category: B-D, Full Penetration Welded Nozzles in Vessels -

Inspection Program B Item Numbers: B3.110, Pressurizer, Nozzle-to-Vessel Welds B3.130, Steam Generator (Primary Side), Nozzle-to-Vessel Welds Component Identification: Listed in Table I Material: Pressurizer: Head - SA533, GR A, CL2 Carbon Steel Nozzle - SA508, CL2 Carbon Steel Internal surface clad with stainless steel Steam Generator: Head - SA533, GR B, CLI Carbon Steel Nozzle - SA508, CL2 Carbon Steel Internal surface clad with stainless steel

2. Applicable Code Addition and Addenda ASME Section Xl, 2004 Edition, No Addenda

3. Applicable Code Requirement

mm m ASME Section Xl, 2004 Edition, Examination Category B-D requires volumetric examination of 100 percent (%) of the weld volume as defined in Table IWB-2500-1 and shown in figures IWB-2500-7(a) - (d). The alternative requirements of ASME Section Xl, Code Case N-460, approved for use in Regulatory Guide 1.147, Rev. 17, allows credit for essentially 100% coverage of the welds provided greater than 90%

of the required volume has been examined.

Serial No.15-313 Docket No. 50-423 Attachment 2, Page 2 of 20

4. Impracticality of Compliance Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the 100% volumetric examination coverage requirement of the subject welds due to the geometric configuration which limit the volumetric coverage that can be obtained.

The steam generator nozzle-to-head welds, and the pressurizer spray and safety nozzle-to-head welds were examined with a manual ultrasonic technique using pulse echo ultrasonic instruments and search units to achieve the maximum examination coverage practicable. Limitations imposed by the nozzle configuration preclude obtaining 100% coverage. This configuration with the nozzle outside radius within close proximity of the weld prevents complete scanning in these areas due to lift-off of the search unit that occurs causing a loss of contact between the search unit and the component.

No alternative techniques or advanced technologies were considered capable of obtaining complete coverage of the examination volume.

Isometric drawing and coverage calculations are provided in this attachment.

Serial No.15-313 Docket No. 50-423 Attachment 2, Page 3 of 20 TABLE 1- Examination Category B-D Welds with Limited Volumetric Coverage Examination Weld Code Examination Angle and Coverage Identification Item # Configuration Wave Mode Limitations and Results (%)

03-003-SW-U B3.130 Steam Generator Outlet 00 Longitudinal Wave Scan limitations due to nozzle 70.5%

Nozzle-to-Head Weld 450 Shear Wave configuration restricting the scans 60° Shear Wave from the nozzle side. No recordable indications were detected.

03-003-SW-V B3.130 Steam Generator Inlet 00 Longitudinal Wave Scan limitations due to nozzle 70.5%

Nozzle-to-Head Weld 450 Shear Wave configuration restricting the scans 600 Shear Wave from the nozzle side. No recordable indications were detected.-

03-004-SW-U B3.130 Steam Generator Outlet 0° Longitudinal Wave Scan limitations due to nozzle 70.9%

Nozzle-to-Head Weld 450 Shear Wave configuration restricting the scans 600 Shear Wave from the nozzle side. No recordable indications were detected.

03-004-SW-V B3.130 Steam Generator Inlet 00 Longitudinal Wave Scan limitations due to nozzle 70.9%

Nozzle-to-Head Weld 450 Shear Wave configuration restricting the scans 600 Shear Wave from the nozzle side. No recordable indications were detected.

03-007-SW-A B3.1 10 Pressurizer Safety 0° Longitudinal Wave Scan limitations due to nozzle 82%

Nozzle-to-Head Weld 450 Shear Wave configuration restricting the scans 600 Shear Wave from the nozzle side. No recordable indications were detected.

Serial No.15-313 Docket No. 50-423 Attachment 2, Page 4 of 20 Examination Weld Code Examination Angle and Coverage Identification Item # Configuration Wave Mode Limitations and Results (%)

03-007-SW-E B3. 110 Pressurizer Spray 00 Longitudinal Wave Scan limitations due to nozzle 82%

Nozzle-to-Head Weld 450 Shear Wave configuration restricting the scans 600 Shear Wave from the nozzle side. No recordable indications were detected.

Serial No.15-313

• - Docket No. 50-423 Attachment 2, Page 5 of 20

5. Burden Caused by Compliance To increase examination coverage on the subject welds would require a significant design modification or replacement of components with a different design to eliminate the noted obstructions which is considered to be impractical due to the cost, additional radiation exposure and impact to plant equipment.

6. Proposed Alternative and Basis for Use The subject welds received a volumetric examination using the best available techniques on the accessible portions of welds to the extent practical. Additionally, a visual (VT-2) examination is performed at the end of each refueling outage during the system leakage tests as required by Section XI, Table IWB-2500-1, Category B-P.

Based upon the examination volumes that were obtained with acceptable results and the visual (VT-2) examination performed each refueling outage, it is reasonable to conclude that service induced degradation would be detected. Therefore, these proposed alternatives will provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds.

7. Duration of Proposed Alternative The relief is requested for the third ten-year inspection interval for Millstone Power Station Unit 3, which began on April 23, 2009 and will end April 22, 2019.

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Weld ID: 03-O03-SW--U O0°,45°, & 600 45°0 600 Nozzle Weld Coverage Total Weld Examination Base Material Coverage Head Side Weld Area 3.9438 square inches H-ead Side Base Material 00 =100% 00 = 64.5% 17.6404 sq. in 450= 100% 450 = 91.3% 24.9781 sq. in.

60 = 100% 600 94.5% 25.8427 sq. in.

Nozzle Side Weld Nozzle Side Base Material 00 = 100% 00 64.5% 17.6404 sq. in.

450 = 36.5% 1.4402 sq. in. 450 = 31.5 % 8.6319 sq. in.

600 22.9% 0.9037 sq. in. 600 17.2% 4.7 133 sq. in.

CW Weld GW Base Material 00 = 100% 00 = 64.5% 17.6404 sq. in.

450 = 100% Total Weld Examination and Base 450 64.5% 17.6404 sq. in.

60°0= 100% Material Area 600 = 64.5% 17.6404 sq. in.

31.2987 sq. in.

CCW Base Material >

CCW Weld 00 = 100% 00 = 64.5% 17.6404 sq. in.

2" 450 = 100% 450 = 64.5% 17.6404 sq. in.

CD 600=100% 60° = 64.5% 17.6404 sq. in. CDC,)

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01 Weld Volume = [22.9% (Perpendicular scan) + 100% (Parallel scan)]/2=61.5%

Base Material Volume =[94.5% (Perpendicular scan) + 64.5% (Parallel scan)]/2.79.5%

Total Coverage =70.5% Coverage

Weld ID: 03-O0~3-SW-U 0°, 450, & 600 450 600 due to radius Weld metal examination coverage with the beam direction perpendicular to the weld axis.

Complete coverage is limited due to the nozzle radius.

Weld metal coverage requires the combination of two angles from two directions.

Total weld cross section examination area = 3.9438 sq. in.

Area effectivly examined with two angles in two directions = 0.9037 sq. in. =22.9%

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Weld ID: 03-003-SW-U 00, 450, & 600 45°0 60° due to radius Base Material examination coverage with the beam direction perpendicular to the weld axis.

Base material coverage requires the combination of two angles.

Total base materiat cross section area. 27.3549 sq. in.

Percent of base material examined in the perpendicular beam direction =25.8427 sq. in. =94.5%

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Weld ID: 03-U03-SW-UJ 450, & 600 Nozzle Head due to radius Examination coverage with the beam direction paralte to the weld axis.

Complete coverage is limited due to the nozzle radius.

Weld metal and base coverage requires the combination of two angles fr'om two directions.

Total cross section examination area of weld = 3.9438 sq. in.

Weld volume effectivly examined with two angles in.two directions = 3.9438 sq. in. = 100%

CD" Total cross section examination area of base material =27.3549 sq. in. - DC Base material effecti~vly examined with two angles in two directions =17.6404 sq. in. = 64.5%

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Weld ID: 03-00)3-SW-V 00, 450, & 600 45 0 600 Nozzle Head Weld Coverage Base Material Coverage Total Weld Examination Area 3.943 8 square inches Head Side Weld Head Side Base Material 0°0=100% 00 64.5% 17.6404 sq. in 45° = 100% 450 = 91.3% 24.9781 sq. in.

600= 100% 600 = 94.5% 25.8427 sq. in.

Nozzle Side Weld Nozzle Side Base Material 00 = 100% 00 = 64.5% 17.6404 sq. in.

450 = 36.5% 1.4402 sq. in. 450 = 31.5 % 8.6319 sq. in.

600 = 22.9% 0.903 7 sq. in. 600 = 17.2% 4.7 133 sq. in.

CW Weld CW Base Material 0o = 100% 00 64.5% 17.6404 sq. in.

450 = 100% Total Weld Examination and Base 450 = 64.5% 17.6404 sq. in.

600 -- 100% Material Area 600 = 64.5% 17.6404 sq. in.

31.2987 sq. in.

CCWV Weld CCW Base Material 00 = 100% 0° = 64.5% 17.6404 sq. in.

450= 100% 450 = 64.5% 17.6404 sq. in.

CD 600 = 100% 600 = 64.5% 17.6404 sq. in.

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Weld Volume = [22.9% (Perpendicular scan) + 100% (Parallel scan)]/2=61 .5%

Base Material Voltune =[94.5% (Perpendicular scan) + 64.5% (Paralle scan.)]/2=79.5%

Total Coverage = 70.5% Coverage

Weld ID: a3-003-sw-V 00, 450, & 600 450 600 due to radius Weld metal examination coverage with the beam direction perpendicular to the weld axis.

Complete coverage is limited due to the nozzle radius.

Weld metal coverage requires the combination of two angles from two directions.

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Total weld cross section examination area = 3.943 8 sq. in.

Area effectivly examined with two angles in two directions = 0.9037 sq. in. =22.9%

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Weld ID: 03-003-SW-V 00, 450, & 600 45°0 600 Base Material examination coverage with the beam direction perpendicular to the weld ax~is.

Base mnateriat coverage requires the combination of two angles.

Total base material cross section area. 27.3549 sq. in.

Percent of base material examined in the perpendicular beam direction =25.8427 sq. in. =94.5%

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Weld ID: [13-O03-SW-V 450, & 600 Nozzle Head due to radius Examination coverage with the beam direction paralle to the weld axis.

Complete coverage is limited due to the nozzle radius.

Weld metal and base coverage requires the combination of two angles from two directions.

Total cross section examination area of weld =3.9438 sq. in.

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Weld volume effectivly examined with two angles in two directions = 3.9438 sq. in. = 100%

0ooo Total cross section examination area of base material = 27.3 549 sq. in.

Base material effectivly examined with~ two angles in two directions = 17.6404 sq. in. =64.5%

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Weld ID: 03-O0f4-SW-U 450 & 60' 450 600 x

Total Weld Coverage Base Mate~rial Coverage Total Weld Area in two directions Weld Coverage 3.9438 square inches 0.9061 Head Side Base Material Head Side Weld square inches 0 deg.=69.3% 21.94 sq.in 0Odeg.=100% Coverage 22.9% 45 deg.=91.5% 24.98 sq. in 45 deg.=100% 60 deg. 94.5% 25.85 sq. in 60 deg. =100%

Nozz'le Side Base Material Nozzle Side Weld -* Total Base Material Coverage 0 deg.=69.3% 21.94 sq. in 0 deg,=~100% 45 deg.= 3 1.5% 8.63 sq. in 45 deg. =36.5% in one direction 25.35 sq. inches 60 deg.=. 17.2% 4.71 sq. in Total Area 27.68 sq. inches 60 deg.,::22.9% missed coverage 2.33 sq. inches 91.5% Coverage CXV Base Material CW Weld 0 deg.,69.3% 21.94 sq. in 0 deg.- 100% 45 deg.=69.3% 21.94 sq. in 45 deg.=100% 60 deg.=:69.3% 21.94 sq. in 60 deg..100%

CCW Base Material CCWV Weld -* Total Coverage withl 0 deg. 0 deg.="69.3% 21.94 sqt. in 0 deg.=100% 45 deg.=69.3% 21.,94 sq. in 45 deg.=100% 0 deg. Weld, and Base Material Area 21.94 sq. inches Total Area 31.62 sq. inches 60 deg.=69.3% 21.94 sq. in 60 deg.=100% S.

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69.3 % Coverage 2 CD Examination Coverage Summary Weld Vohune =[22.9% (Perpendicular scan)+100% (Parallel scai)1i2=6 1.5%

Base Material Volumeo491 .5%(Perpendicular scan)+/-69,3%(Parallel scan)]/2='80.4% Crl Total Coverage 70.9% "Jo, CD 0

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Weld ID: 03-004-SW-V 45 & 6(y' 45' 60' Total Weld Coverage Base Material Coverage Total Weld Area in. two directions Weld Coverage 3.9438 square inches 0.9061 Head Side :Base Material tHead Side Weld square inches 0 deg.=6%93% 21.94 sq, in 0 deg.=100% Coverage 22.9% 45 deg,=91,5% 24.98 sq. in 45 deg.=100% 60 deg.=94.5% 25.85 sq. in 60 deg.=100%

Nozzle Side Base Material Nozzle Side Weld 0 deg,-=69,3% 21.94 sq. in 0 degA=10% Total Base Material Coverage 45 deg.331.5% 8.63 sq. in 45 deg. "36.5% in one direction 25.35 sq. inches 60 deg.=: 17.2% 4.71. sq. in Total Area 27.68 sq. inches 60 deg.=.22.9% misscd coverage 2.33 sq. inches 91.5% Cover~age CWV Base Mvaterial CW Weld 0 deg.=69.3% 21.94 sq. in 0 deg.=-100% 45 deg,=69.3% 21.94 sq inl 45 deg,=100% 60 deg,=69,3% 21.94 sq. in 60 deg.=100%

CCWV Base Material CCW Weld 0 deg.=69.3% 21.94 sq. in Total Coverage with 0 deg.

0 deg.=100% 45 deg,=69.3% 21.94 sq. in 0 deg. Weld and Base Material Area 21.94 sq. inches C) 45 deg.=1l00% Total Area 31.62 sq. inches 60 deg,=69,3% 21.94 sq. in 60 deg.-1 00%

69.3 % Coverage t'D Examination Coverage Summary UDo Weld Volume 1=22.9%. (Perpendicular scan)+ 100% (Parallel scan)1I2'=61 .5%

Base Material Volulne=[91I.5%(Perpendicular scan)+69.3%(Parallel scan0i!2=80.4%

09 z0 Total Coverage =70.9%

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Weld ID: 03-007-SW-A j j..~

Weld Coverage Base Material Coverage Head Side Weld Head Side Base Material o deg.=100% Total Weld Coverage. in two directions

.9059 sq. inches 0 deg.=88,0% 8.79 sq~in 45 degt.= 100% 45 deg.=96.7% 9.58 sq. in 60 deg:=100% 43.7% coverage 60 deg.=98.1% 9.72 sq. in Nozzle Side Weld Nozzle Side Base Material 0 deg.=100% 0 deg.*88.0% 8.79 sq. in 45 deg . 58 .5% 45 deg.= 55.4% 5,49 sq. in 60 deg.=43.7% Total Base Material Coverage in one direction 60 deg.= 32.4% 3.21 sq. in 9.21 sq. inches CW Weld CW Base Material 0 deg.=100% 96.7% Coverage 0 deg.=88,0% 8.79 sq.in 45 deg.=l100% 45 deg.-.88.0% 8.79 sq. in 60 deg. 100% 60 deg.=88.0% 8.79 sq. in CCW Weld CCW Base Material 0 deg.=100% 0 deg.=88.0% 8.79 sq.in 45 deg.=100% Total Coverage with t) deg. 45 deg.=88.0% 8.79 sq. in 8.79 sq; inches 60 deg.= 100% 60 deg.=88,.0% 8.79 sq. in 85% Coverage ro o03 oCJJ Examination Coverage Summary Co Weld Volume 4=43.7% (Perpendicular scan)+/-1 00% (Parallel sean)I/2=71.8%

Base Material Volume-.[9627%(Perpendietlar sean)+88.0%(Parallel sean)]I/292.3% C.D 0 0 Total Coverage =82.0% oC .*-

Co

.CC;.

0O IX -..

C

Weld ID: 03-O07-SW-E

,sp. *.v2or~rr Weld Coverage Base Material Coverage Head Side Weld Head Side Base Material o deg.=1l00% Total Weld Coverage in two directions

,9059 sq. inches 0 deg.=88.0% 8.79 sq~in 45 deg.=100% Tbtal Weld Area 45 deg.=96.7% 9.58 sq. in 60 deg.r100% 13.7% coverage 60 deg.=98. I% 9.72 sq. in Nozzle Side Weld Nozzle Side Base Material 0Odeg.-100% 0 deg.=88.0% 8.79 sq. in 45 deg. =58.5% 45 deg.= 55.4% 5.49 sq. in Total Base Material Coverage in one direction 60 deg;=43.7% 60 deg.= 32A4% 3.21 sq. in Total Area 9.58' sq. inches 9.21 sq. inches CW Weld missed coverage CW Base Material 0 deg.=100% .3685 sq. inches 96.7% Coverage 0 deg,=88.0% 8.79 sq.in 45 deg.=100% 45 deg.88.0%879s.i 60 deg.AO0% 60 deg.=88.0% 8.79 sq. in CCW Weld CCW Base Material 0 deg.=100% 0 deg.=88.0% 8.79 sq.in 45 deg.= 100% Total Coverage with 0 deg, 45 deg.=88.0% 8.79 sq. in 8.79'sq, inches 60 deg.=' 100% 60 deg.=88.0% 8.79 sq. inl 85% Coverage 0 0)

Examination Coverage Summary ctz CD Weld Volume *[43.7% (Perpendieular sean)+l 00% (Parallel sean)I/2=71.8%

Base Material Vol umelC=[96.7%(Perpentdicular scan)+88.0%(Parallel sean)]!>.92.3% 0 Total Coverage = 82.0%

Oi' CX' oi

Serial No.15-313 Docket No. 50-423 ATTACHMENT 3 RELIEF REQUEST IR-3-21 EXAMINATION CATEGORY C-A PRESSURE RETAINING WELDS IN PRESSURE VESSELS DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3

Serial No.15-313 Docket No. 50-423 Attachment 3, Page 1 of 7 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)

Inservice Inspection Impracticality

1. ASME Code Components Affected:

ASME Code Class: Code Class 2 Examination Category: C-A, Pressure Retaining Welds in Pressure Vessels Item Numbers: C1.10, Shell Circumferential Welds Component Identification: Listed in Table 1 Material: SA 533, GR A, CL 2

2. Applicable Code Addition and Addenda ASME Section Xl, 2004 Edition, No Addenda

3. Applicable Code Requirement

ASME Section Xl, 2004 Edition, Category C-A requires volumetric examination of 100 percent (%) of the weld length as defined in Table IWC-2500-1 and shown in Figure IWC 2500-1. The alternative requirements of ASME Section Xl, Code Case N-460, approved for use in Regulatory Guide 1.147, Rev. 17, allows credit for essentially 100% coverage of the welds provided greater than 90% of the required volume has been examined.

4. Impracticality of Compliance Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the 100% volumetric examination coverage requirement of the subject welds due to the geometric configuration and permanent obstructions which limit the volumetric coverage that can be obtained.

The Steam Generator shell-to-transition cone weld 03-053-SW-G was examined with a manual ultrasonic technique using pulse echo ultrasonic instruments and search units to achieve the maximum examination coverage practical. No alternative techniques or advanced technologies were considered capable of obtaining complete coverage of the examination volume.

The configuration of the weld joint has an angular surface transition between the

Serial No.15-313

• " Docket No. 50-423 Attachment 3, Page 2 of 7 shell and transition cone that limits the contact of the search unit in this area for the parallel scans, limiting coverage of the weld volume to 96.8% and base metal volume to 81.7% for a combined total examination coverage of 89.3%.

Isometric drawing and coverage calculations are provided in this attachment.

TABLE 1- Examination Category C-A Welds with Limited Volumetric Coverage Examination Weld Code Examination Angle and Limitations and Coverage Identification Item # Configuration Wave Mode Results (%)

03-053-SW-G 01.10 Shell-to-Transition 00 LongitudinalIWave Examination 89.3%

Cone 450 Shear Wave limited due to the 600 Shear Wave angular transition of the weld joint.

No recordable indications were detected.

5. Burden Caused by Compliance To increase examination coverage on the subject weld would require a significant design modification or replacement of the component with a different design to eliminate the noted obstructions. This option to 'meet the 100% Code examination requirement is considered impractical due to the cost, increased radiation exposure and impact to plant equipment.

6. Proposed Alternative and Basis for Use The subject weld received a volumetric ultrasonic examination using the best available techniques on the accessible portions of weld to the maximum extent practical. Additionally, a visual (VT-2) examination is performed during each inspection period during the system leakage tests as required by Section Xl, Table IWC-2500-1, Category C-H.

Based upon the examination volume that was obtained with acceptable results along with the visual (VT-2) examination performed each inspection period, it is reasonable to conclude that service induced degradation would be detected. Therefore, these proposed alternatives will provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject weld.

7. Duration of Proposed Alternative The relief is requested for the third ten-year inspection interval for Millstone Power Station Unit 3, which began on April 22, 2009 and will end April 23, 2019.

Serial No.15-313 Docket No. 50-423 , Page 3 of 7

60Os Weld ID: 03-O53-SW-G 450%

O° 45°s, & 60 0s 450 s 60°s Weld Coverage Total Weld Examination Base Material Coverage Area 5.1071 square inches Transition Cone Side Base Material Transition Cone Side Weld 00= 1.00%

00°= 1.00%

450 = 1.00%

450=100%

600= 100% 600 = 100%

Lower Cone Side Weld Lower Cone Side Base Material 00 = 100% 00°= 100%

450= 100% 450 = 1.00%

600 = 100% Total Weld Examination and Base 600 -- 100%

Material Area CW Weld CW Base Material 00 = 93.6% 4.7829 sq. in. 12.727 sq. in. 00 = 63.4% 4.8355 sq. in.

450 = 63.4% 4,8355 sq. in.

450 93.6% 4.7829 sq. in.

600 = 93.6% 4.7829 sq. in. 60° 63.4% 4.8355 sq. in.

0>

CCWV Base Material CCW Weld 00 = 63.4% 4.8355 sq. in. CD 450 = 63.4% 4.8355 sq. in. 1.C) 00 = 93.6% 4.7829 sq. in. CD 450 = 93.6% 4.7829 sq. in. 600 = 63.4% 4.8355 sq. in.

600 = 93.6% 4.7829 sq. in.

z O

CD 01 Examination Coverage Summary: -.1 03l Weld Volume = [100% (Perpendicular scan) +/-. 93.6% (Parallel scan)I/2=96.8% 0)

Base Material Volume-..[100% (Perpendicular scan) + 63.4% (Parallel scan)]/2=81 .7%

Total Coverage = 89.3% Coverage

W~1A Tn- fl~fl~W.-(~

60Os .. . . . . ..

~4505 Transition Cone * -

5Os6060O 45,,

" - Shell Weld metal examination coverage with the beam direction perpendicular to the weld axis.

Weld metal coverage requires the combination of two angles fi'om two directions.

Total weld metal cross section examination area = 5.1071 sq. in.

Area effeetivly examined with two angles in two directions = 5.11071 sq. in. = 1.00%

(Dow

~.O

~oo

• -o [*. .a

Weld ID: 03-053-SW--G 60°s

, -._..* 45°s

\-0o~, 450 s, & 60°s45s6s Base Material examination coverage with the beama direction perpendicular to the weld axis.

Base material coverage requi~res the combination of two angles.>

Total base material cross section area. 7.6199 sq. in. o Percent of base material examined in the perpendicular beam direction = 7.6199 sq. in. =100% ::

3.CDm Co.

mo

Weld ID: 03-053-SW-G Transition Cone *4°,&6O Shell Examination coverage with the beam direction paralie to the weld axis.

Complete coverage is limited due to transition from. shell to transition cone.

Weld metal and base coverage requires the combination of two angles from two directions.

Total cross section e xamination area of weld = 5.1071 sq. in.::

Weld volume effectivly examined with two angles in two directions = 4.7829 sq. in. = 93.6%

Total cross section of base material = 7.61.99 sq. in. * --,

_

Base material effectivly examined with two angles in two directions = 4.835 5 sq. in. = 63.4% "Ozz a

-.o oa

Serial No.15-313 Docket No. 50-423 ATTACHMENT 4 RELIEF REQUEST IR-3-22 EXAMINATION CATEGORY C-F-i PRESSURE RETAINING WELDS IN AUSTENITIC STAINLESS STEEL HIGH ALLOY PIPING DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 1 of 28 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)

Inservice Inspection Impracticality

1. ASME Code Components Affected:

ASME Code Class: Code Class 2 Examination Category: C-F-I, Pressure Retaining Welds in Austenitic Stainless Steel High Alloy Piping Item Numbers: C5.11, Circumferential welds: Piping welds >3/8 in.

(10mm) Nominal Wall Thickness for Piping >NPS 4 (DN 100)

C5,21, Circumferential welds: Piping Welds >1/5 in.

(5mm) Nominal Wall Thickness for Piping > NPS 2 (ON

50) and < NPS 4 (ON 100)

Component Identification: Listed in Table 1 Material: Listed in Table 1

2. Applicable Code Addition and Addenda ASME Section Xl, 2004 Edition, No Addenda

3. Applicable Code Requirement

ASME Section Xl, Examination Category C-F-i requires 100 percent (%) volumetric examination coverage for circumferential piping welds. The alternative requirements of ASME Section Xl, Code Case N-460, approved for use in Regulatory Guide 1.147, Rev. 17, allows credit for essentially 100% coverage of the weld provided greater than 90% of the required volume has been examined.

10 CFR 50.55a(b)(2)(xv)(A), requires the following examination coverage criteria when applying Supplement 2 to Appendix VIII:

(1) Piping must be examined in two axial directions and when examination in the circumferential direction is required, the circumferential examination must be performed in two directions, provided access is available.

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 2 of 28 (2) Where examination from both sides is not possible, full coverage credit may be claimed from a single-side for ferritic welds. Where examination from both sides is not possible on austenitic welds, full coverage credit from a single-side may be claimed only after completing a successful single sided Appendix VIII demonstration using flaws on the opposite side of the weld.

10 CER 50.55a(b)(2)(xvi)(B) requires that examinations performed from one side of a ferritic or stainless steel pipe weld must be conducted with equipment, procedures, and personnel that have demonstrated proficiency with single-side examinations. To demonstrate equivalency to two-sided examinations, the demonstration must be performed to the requirements of Appendix VIII as modified by this paragraph and

§50.55a(b) (2)(xv) (A).

4. Impracticality of Compliance Pursuant to 10 CER 50.55a(g)(5)(iii), relief is requested from the essentially 100%

volumetric examination coverage requirement for austenitic piping welds with single-side access.

The subject welds were examined with a manual ultrasonic technique using pulse echo ultrasonic instruments and search units to achieve the maximum examination coverage practical. Examinations were performed using personnel, equipment and procedures qualified in accordance with ASME Section XI, Appendix VIII as implemented by the Performance Demonstration Initiative (PD I).

There are currently no PDI qualified single-side examination procedures that demonstrate equivalency to two-sided examination procedures on austenitic piping welds. Current technology is not capable of reliably detecting or sizing flaws on the far side of an austenitic weld for configurations common to US nuclear applications.

PDI Performance Demonstration Qualification Summary (PDQS) certificates for austenitic piping list the limitation that single-side examination is performed on a best effort basis. The best effort qualification is provided in place of a complete single-side qualification to demonstrate that the examiners qualification and the subsequent weld examination is based on application of the best available technology.

When the examination area is limited to one side of an austenitic weld, examination coverage does not comply with 10 CER 50.55a(b)(2)(xv)(A) and proficiency demonstrations do not comply with 10 CER 50.55a(b)(2)(xvi)(B) and full coverage credit may not be claimed.

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 3 of 28 The ASME code required volume of these welds was interrogated ultrasonically to the maximum extent possible. No alternative methods or advanced technologies were considered capable of obtaining complete coverage of the examination volume.

Since the configuration of the piping limits access to a single side, relief is requested on complying with the essentially 100% required examination coverage for the piping welds listed in Table 1. Note that the examination coverage listed is that which was obtained during the examination with no credit taken for the far side of each weld in which the examination from that side could not be performed.

Supplemental scanning was performed to provide additional best effort (non-code) coverage as documented on the enclosed coverage calculation for each weld.

Coverage calculations are provided in this attachment.

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 4 of 28 Table 1- Examination Category C-F-I Welds with Limited Volumetric Coverage System Ultrasonic Examination Surface Code Configuration Examination Angle Coverage Examination Weld Number Item # Material and Wave Mode Limitation and Results (%) Results CHS-31-FW-1 C5.21 Chemical And 450 Shear Wave Limited examination performed 50% Liquid penetrant Volume Control 600 Shear Wave from the pipe side only due to examination 60° Longitudinal Wave taper of the valve within close performed 4" Pipe-To-Valve proximity of the weld. There is obtaining 100 Type 316 not sufficient distance between percent coverage.

Stainless Steel, the weld and valve to perform No recordable Schedule 160 any scanning on the valve side indications of the weld. No recordable detected.

indications were detected.

CHS-31-FW-3 C5.21 Chemical And 450 Shear Wave Limited examination performed 50% Liquid penetrant Volume Control 600 Shear Wave from the pipe side only due to examination 600 Longitudinal Wave taper of the reducer within performed 3" Reducer-To- close proximity of the weld. obtaining 100 Valve There is not sufficient distance percent coverage.

Type 316 between the weld and reducer No recordable Stainless Steel, to perform any scanning on the indications Schedule 160 reducer side of the weld. No detected.

recordable indications were detected.

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 5 of 28 System Ultrasonic Examination Surface Code Configuration Examination Angle Coverage Examination Weld Number Item # Material and Wave Mode Limitation and Results (%) Results CHS-32-1-SW-D 05.21 Chemical And 450 Shear Wave Limited examination performed 50% Liquid penetrant Volume Control 600 Shear Wave from the elbow side only due to examination 600 Longitudinal Wave the close proximity of an performed 4" Pipe-To-Elbow adjacent piping weld. There is obtaining 100 Type 316 not sufficient distance between percent coverage.

Stainless Steel, the welds to perform any No recordable Schedule 160 scanning on the pipe side of indications the weld. No recordable detected.

indications were detected.

CHS-32-FW-1 05.21 Chemical And 450 Shear Wave Limited examination performed 50% Liquid penetrant Volume Control 600 Shear Wave from the pipe side only due to examination 4"Pp-oVle 600 Longitudinal Wave taper of the valve within close performed 4"Pp-oVleproximity of the weld. There is obtaining 100 Type 316 not sufficient distance between percent coverage.

Stainless Steel, the weld and valve to perform No recordable Schedule 160 any scanning on the valve side indications of the weld. No recordable detected.

indications were detected.

CHS-33-1-SW-13 C5.21 Chemical And 450 Shear Wave Limited examination performed 50% Liquid penetrant Volume Control 600 Shear Wave from the pipe side only due to examination 600 Longitudinal Wave taper of the flange within close performed 4" Flange-To-Pipe proximity of the weld. There is obtaining 100 Type 316 not sufficient distance between percent coverage.

Stainless Steel, the weld and flange to perform No recordable Schedule 160 any scanning on the flange indications side of the weld. No detected.

recordable indications were detected.

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 6 of 28 System Ultrasonic Examination Surface Code Configuration Examination Angle Coverage Examination Weld Number Item # Material and Wave Mode Limitation and Results (%) Results CHS-33-FW-1 C5.21 Chemical And 450 Shear Wave Limited examination performed 50% Liquid penetrant Volume Control 600 Shear Wave from the pipe side only due to examination 4"Pp-oVle 600 Longitudinal Wave taper of the valve within close performed 4"Pp-oVleproximity of the weld. There is obtaining 100 Type 316 not sufficient distance between percent coverage.

Stainless Steel, the weld and valve to perform No recordable Schedule 160 any scanning on the valve side indications of the weld. No recordable detected.

indications were detected.

CHS-33-FW-17 C5.21 Chemical And 450 Shear Wave Limited examination performed 50% Liquid penetrant Volume Control 600 Shear Wave from the pipe side only due to examination 600 Longitudinal Wave taper of the flange within close performed 4" Flange-To-Pipe proximity of the weld. There is obtaining 100 Type 316 not sufficient distance between percent coverage.

Stainless Steel, the weld and flange to perform No recordable Schedule 160 any scanning on the flange indications side of the weld. No detected.

recordable indications were detected.

CHS-33-FW-4 C5.21 Chemical And 450 Shear Wave Limited examination performed 50% Liquid penetrant Volume Control 600 Shear Wave from the pipe side only due to examination 3"VleT-ie 700 Shear Wave taper of the valve within close performed 3"VleT-ieproximity of the weld. There is obtaining 100 Type 316 not sufficient distance between percent coverage.

Stainless Steel, the weld and valve to perform No recordable Schedule 160 any scanning on the valve side indications of the weld. No recordable detected.

indications were detected.

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 7 of 28 System Ultrasonic Examination Surface Code Configuration Examination Angle Coverage Examination Weld Number Item # Material and Wave Mode Limitation and Results (%) Results RHS-9-2-SW-K C5. 11 Residual Heat 45' Shear Wave Limited examination performed 50% Liquid penetrant Removal 70' Shear Wave from the pipe side only due to examination 14" Pipe-To- taper of the flange within close performed proximity of the weld. There is obtaining 100 Flange not sufficient distance between percent coverage.

Type 304 the weld and flange to perform No recordable Stainless Steel, any scanning on the flange indications Schedule 40 side of the weld. No detected.

recordable indications were detected.

RHS-9-3-SW-B C5. 11 Residual Heat 45' Shear Wave Limited examination performed 50% Liquid penetrant Removal 70' Shear Wave from the pipe side only due to examination 14" Flange-To- taper of the flange within close performed proximity of the weld. There is obtaining 100 Pipe not sufficient distance between percent coverage.

Type 304 the weld and flange to perform No recordable Stainless Steel, any scanning on the flange indications Schedule 40 side of the weld, No detected.

recordable indications were detected.

RHS-9-FW-2 C5. 11 Residual Heat 45' Shear Wave Limited examination performed 50% Liquid penetrant Removal 70' Shear Wave from the pipe side only due to examination 1"Pp-oVletaper of the valve within close performed 1"Pp-oVleproximity of the weld. There is obtaining 100 Type 316 not sufficient distance between percent coverage.

Stainless Steel, the weld and valve to perform No recordable Schedule 40 any scanning on the valve side indications of the weld. No recordable detected.

indications were detected.

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 8 of 28 System Ultrasonic Examination Surface Code Configuration Examination Angie Coverage Examination Weld Number Item # Material and Wave Mode Limitation and Results (%) Results SIL-157-FW-3 C5.11I Safety Injection 450 Shear Wave Limited examination performed 50% Liquid penetrant 600 Shear Wave from the pipe side only due to examination 10" Valve-To-Pipe 7Q0 Shear Wave taper of the valve within close performed Type 316 600 Longitudinal Wave proximity of the weld. There is obtaining 100 Stainless Steel, not sufficient distance between percent coverage.

Schedule 140 the weld and valve to perform No recordable any scanning on the valve side indications of the weld. No recordable detected.

indications were detected.

SIL-43-FW-1 C5.11 Safety Injection 450 Shear Wave Limited examination performed 50% Liquid penetrant 600 Shear Wave from the pipe side only due to examination 6" Valve-To-Pipe 600 Longitudinal Wave taper of the valve within close performed Type 316 proximity of the weld. There is obtaining 100 Stainless Steel, not sufficient distance between percent coverage.

Schedule 160 the weld and valve to perform No recordable any scanning on the valve side indications of the weld. No recordable detected.

indications were detected.

SIL-43-FW-16 C5.1 1 Safety Injection 450 Shear Wave Limited examination performed 50% Liquid penetrant 600 Shear Wave from the pipe side only due to examination 6" Pipe-To-Valve 700 Shear Wave taper of the valve within close performed Type 316 600 Longitudinal Wave proximity of the weld. There is obtaining 100 Stainless Steel, not sufficient distance between percent coverage.

Schedule 160 the weld and valve to perform No recordable any scanning on the valve side indications of the weld. One indication detected.

was detected that was evaluated as acceptable root

____ ___ ___

___ ___

____ ____

___ ___geometry.

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 9 of 28 System Ultrasonic Examination Surface Code Configuration Examination Angle Coverage Examination Weld Number Item # Material and Wave Mode Limitation and Results (%) Results SIL-504-1-SW-7 05.11 Safety Injection 450 Shear Wave Limited examination performed 50% Liquid penetrant 600 Shear Wave from the pipe side only due to examination 6" Reducer-To- 7Q0 Shear Wave taper of the reducer within performed Pipe 600 Longitudinal Wave close proximity of the weld. obtaining 100 Type 316 There is not sufficient distance percent coverage.

Stainless Steel, between the weld and reducer No recordable Schedule 160 to perform any scanning on the indications reducer side of the weld. No detected.

recordable indications were detected.

SIL-504-FW-15 C5.11 Safety Injection 450 Shear Wave Limited examination performed 50% Liquid penetrant 600 Shear Wave from the pipe side only due to examination 6" Pipe-To-Valve 600 Longitudinal Wave taper of the valve within close performed proximity of the weld. There is obtaining 100 Type 316 not sufficient distance between percent coverage.

Stainless Steel, the weld and valve to perform One recordable Schedule 160 any scanning on the valve side indication was of the weld. No recordable detected that was indications were detected. evaluated as acceptable per ASME Section Xl, IWB-351 4 acceptance standards.

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 10 of 28 System Ultrasonic Examination Surface Code Configuration Examination Angle Coverage Examination Weld Number Item # Material and Wave Mode Limitation and Results (%) Results SIL-8-FW-3 C5.11I Safety Injection 450 Shear Wave Limited examination performed 50% Liquid penetrant 600 Shear Wave from the pipe transition piece examination 10" Transition 600 Longitudinal Wave side only due to taper of the performed Piece-To-Valve valve within close proximity of obtaining 100 Type 316 the weld. There is not percent coverage.

Stainless Steel, sufficient distance between the No recordable Schedule 160 weld and valve to perform any indications scanning on the valve side of detected.

the weld. No recordable indications were detected.

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 11 of 28

5. Burden Caused by Compliance Compliance with the Code requirements would require extensive modification or replacement of components with a design that would allow examination from both sides of the weld. This option to meet the 100% Code examination requirement for coverage is considered to be impractical based on the cost, additional radiation exposure and impact to plant equipment.

6. Proposed Alternative and Basis for Use The subject welds received a volumetric examination to the maximum extent practical using the best available techniques, as qualified through the PDI for Supplement 2 with demonstrated best effort for single sided examination, from the accessible side of the weld. Additionally, a surface examination was performed with 100% coverage obtained, and a visual (VT-2) examination is performed each inspection period during the system leakage tests as required by Section Xl, Table IWC-2500-1, Category C-H.

Based on the volumetric coverage that was obtained with acceptable results, a surface examination obtaining 100% coverage, and the visual (VT-2) examination performed each inspection period, it is reasonable to conclude that service induced degradation would be detected. Therefore, these proposed alternatives will provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds.

7. Period for Which Relief is Requested The relief is requested for examinations performed during the third ten-year inspection interval for Millstone Power Station Unit 3, which began on April 23, 2009 and will end April 22, 2019.

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 12 of 28 Flow

.53" .52" .50 t.58t .67" Requird Examination Volume -,210 sq. inches Far Side Required Examination Volume-. 103 sq. inches V/ / /

Volume Examined on the far side- ,01 (9.7%) [

Examination Volume Dimensions: Length

• x Width 1.20" x Height .19" Weld Thickness= .67__" Weld Length= 13j6__* Weld Width= .70" (US-100%+DS-O%.CW-50O CCW-50%)/4=50%

Coverage Summary- Weld # CHS-31-FW-1 Required Scans- each has a,weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream- Circ. Downstream Axial Downstream Oirc.

45/60 100% ,, 100% ....

60 RL ... "- 9.7%(Best Effort)....

Code Coverage Total 50%

100+100++0+-,9.714-s0%= Best

.. Effort Coverage (Max 25%) Total 2.4% ..........

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined In the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage ..

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 13 of 28 Flow

.56" .49" .44" .49" .57" Reducer Valve Requird Examination Volume -. 1887 sq. inches Far Side Required Examination Volume-. 103 sq. inches Volume Examined on the far side- .01 57 (15.2%)

Examination Volume Dimensions: Length 11.0" x Width 1.1_."_ x Height .19" Weld Thickness= .57" Weld Length= 11.0" Weld Width= .60" (US-100%+DS-0%+CW-50%+CCW-50%)/4=SO%

Coverage Summary- Weld # CHS-31-FW-3 Required Scans- each has a weighing factor of 100% for complete coverage Angle Upstream-Axial! Upstream- Circ. ..... Downstream Axial Downstream Circ.

45/60 100% I 100% ________

60 RL ...... 15.2%(Best Effort)

Code Coverage Total 50%

10o+100o+o15.21l5.2/4-5o%= Best Effort Coverage (Max 25%) Total 4%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 14 of 28

• .51" .66" .50"

.57" 4,3o Pipe Flow Elbow Requiredl exaxr volume- ,3346 sq. inches *_

Far" sicde r'equir'ec exaxm volume-,1606 sq. inches Volume examinecd on £xr- sicde-,0492 sq. inches(30,64Z)

Examination Volume Dimensions: Length 16~.37 x Width 1.66" x Height .177'_._*

Weld Thickness= .66__" Weld Length= 16.7_, ...... Weld Width= .70"

,.. (US-O%+DS-100%+cW-50%+CCW-50%)/4=50% ....... .

Coverage Summary- Weld # CHS-32-1-SW-D Required Scans- each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream- Circ. Downstream Axial Downstream Circ.

45/60 I 100% 100%

.............. Code Cove rage Total 50% I

......... 30.6230.6/4 .... Best Effort Coverage. (Max 25%) Total 7.6%*

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 15 of 28

.540" .540" .500" .680" .800" 450 Pipe Fo Vc lve Required exam volume-,28741 sq. inches Far' siole required exam volume- ,0974 sq. inches VoLume examined on Far side-,0144 sq.

inches(14.78Y.)

Examination Volume Dimensions: Length 16.37___" x Width 1.62" x Height .177" Weld Thickness= .68" Weld Length= 16.37" Weld Wldth= .70" (US-10O0%+DS-%C-50%+CCW-S0%)/4=50%...

Coverage Summary- Weld # CHS-32-FW-1 Required Scans- each has a weighing factor of 100 for complete coverage

...

Angle UPstream-Axial Upstream- Circ. Downstream Axial Downstream Circ.

45(60 100% 100% 10%

60 RL 14.78%(Best Effort) ________

Code Coverage Total ' 50%

100+100+0+-14.7=Z14.714-50%=' Best Effort Coverage (Max 25%) Total 3.6% "

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix Viii demonstrated procedure for single sided coverage

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 16 of 28

,64" .55" .52" .52" Klo,nge Pipe Flow Required exaim vo~ume- .3099 sq. inches For' side required exam volume-,.1571 sq. inches Volume examined on F or side- .0086 sq. inches (5,4Z)

Examination Volume Dimensions: Length 143" x Width 1.72" x Height .13_*

Weld Thickness= .64_." Weld Length= 14,3 Weld Width= .72__"

...... (US-0%+DS-100%+CW-50%+CCWSO%)/4=50%

Coverage Summary- Weld # CHS-33-1-SW-B Required Scans- each has a weighing factor of 100% for complete coverage Angle Upstream-Axial .. Upstream- Clrc. Downstream Axial Downstream Circ.

....

45/60 io10% 100%

60 RL "5.4%(Best Effort) ...............

...... Code Coverage Total 50% "

5.4+0+.100+1004.07/4-50 Best Effort Coverage (Max 25%) Total 1,3%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 17 of 28

.53" .53" .56" .64"

.6O° *,

Pipe Flow Vc Lve Requ~ir'ed exam voWume-,*4804 sq, inches For side requirecd exam votume- ,2375 sq, inches Volume examined on far side- .0 138 sq. inches (5.8) t*

Examination Volume Dimensions: Length 14.3" x Width 1.2 x Height .173" Weld Thickness= .64"__* Weld Length= 14.3__" Weld Width= .72"

,, ~(US-100%+DS-0%+CW-50%+CCW5O%)14=50% .....

Coverage Summary- Weld # CHS-33-FW-1 Required Scans- each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream- Circ. Downstream Axial Downstream Circ.

45/60 100% 100% 0%

60 RL 5.8%(Best Effort)

Code Coverage Total 50%

1oo+10oo.S.84o0205.8/-so Best Effort C*overage (Max 25%) Total 1.4%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined In the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 18 of 28

,68" .54" .54' .54' 6016ORL 4,59 FLoinge Pipe Flow Required exam volume- .3188 sq. inches Far side requW'ed exam volume-,.1667 sq. inches V///

VoLume examined on ar' side - .0304 sq, inches (18,2%)

Examination Volume Dimensions: Length 14.37" x Width 1.57r x Height .179"*

Weld Thickness= 68" Weld Length= 14.37" Weld Width= .57" (US-0%+DS100%+CW-50%+CCW50%)/4=50%

S~ Coverage Summary- Weld # CHS-33-FW-17 SRequired Scans- each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream- Circ. Downstream Axial Downstream Clrc.

45/60 100% 100%

70 18.2%( Best Effort)

Code Coverage Total 50%

18.2 0+100+100=218.2/400-50 Best Effort Coverage (Max 25%) Total 4.5%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 19 of 28

.58" .4¢8" .42" .42"

• .,fo70o 45° Pipe Flow Required exo, m vottume- ,3791 sq, inches Fxr" sicde requiWrecd excxm votume- 2P333 sq. inches Volume examined on far side- .1591 sq inches (68.1%)

Examination Volume Dimensions: Length 11.25" x Width 1.60" x Height .15__"

Weld Thickness= .58" Weld Length= 11.25" Weld Width= .60 (US-O%+DS1OO%+CW-50%+CCW5O%)/4=50%

Coverage Summary- Weld # CHS-33-FW-4 Required Scans- each has a weighing factor of 100% for complete coverage Downstream Circ.

Angle 45/60 70 Upstream-Axial 68.1%(Best Effort) 1 Upstream- Clrc.

0%

Downstream Axial 100% 100%

Code Coverage Total 50%

68.1+0+100+100='268.1/4-50 Best Effort Coverage (Max 25%) Total 17%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 20 of 28 2

U-0 30 0 U-

,I "2

T2 2

2 V -J 4:

I~)

b4 4

~4I 4) q)

i 7 2 a- t0d 4:

1-i-S

'-4 NOTE: An additional 25% total best effort (non-code) coverage was obtained for the flange side axial scan using a 70 degree shear wave search unit.

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 21 of 28

,2

-:, ~

-~

9 01 ooc:~o 9 0

~1 00

- -

2Z7 2 2 v')

V)

J. -I

'U I'- A A

><:* 0 42 2 2

'-I U-

'I O3 NOTE: An additional 25% total best effort (non-code) coverage was obtained for the flange side axial scan using a 70 degree shear wave search unit.

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 22 of 28

-J Cw 7 I'

'I

/

0 00 7

V 7 2 7

(

Li)

V*

2 C"

3:. I.- U) 0- C. 0 O-4 2

3:l*..

NOTE: An additional 25% total best effort (non-code) coverage was obtained for the valve side axial scan using a 70 degree shear wave search unit.

Serial No,15-313 Docket No. 50-423 Attachment 4, Page 23 of 28 1.033' 1.040" Far side required examination volume- .36 sq. inches Volume examined on far side-0 sq. inches (0%)

50% Coverage achieved using 70° Shear Examination (US-100% + DS-0% + CW-50% + CCW-50%)/4=50%

Examination Volume Dimensions: Length 34" x Width 1.8_..0" x Height .383 Weld Thickness= 1.15" Weld Length= Weld Width= 1.3" Coverage Summary- Weld # SIL-157-FW-3_

60 _______ 100% 0% i0%

70 100% _________ _ _ __ _ _ _

60RL. __ _ _ _ _ _ _ _______ 0% (best effort) _______

Code Coverage Total i 50%

Best Effort Coverage (Max 25%) Totali 0%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage . .....

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 24 of 28 Valve Flow 1.16"

,68" .79" Required examination volume- .55 sq. inches Far side required examination volume- .35 sq. inches / /.

Volume examined on far side-.05 sq. inches (14.3%)

50% Coverage achieved using 60" Shear Examination (US-O% + DS-1000% + CW-50% + CCW-50%)/4=50%

Examination Volume Dimensions: Length 21" x Width 1.50" x Height .296"_.*

Weld Thickness= .89' Weld Length= Weld Width= 1.0" Coverage Summary- Weld # SIL-43-FW-1.

___ Required Scans- each has a weighing factor of 100% for complete coverage

-Angle.. Upstream-Axial Upstream- airc. .DownstreamA~x*..ia Downstrem Crc. ..

60 ..... i,____ 0% 100% i100%

70 __ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

60RL 14.3% (best effort) _________________ _______

Code Coverage Total i 50%

Best Effort Coverage (Max 25%) Total 143%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination period

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated....de o ng sided.......................................coverage..........

procedureeure for singleco

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 25 of 28 Flow Required examination volume- .44 sq. inches Far side required examination volume- .24 sq. inches Volume examined on far side-.04 sq. inches (16.6%)

50% Coverage achieved using 60° Shear Examination (US-100% + DS-0% + cW-5O% + CCW-50%)/4=50%

Examination Volume Dimensions: Length 21" x Width 1.5" x Height .28"_

Weld Thickness= .84" Weld Length= Weld Width= i0 ..

Coverage Summary- Weld # SlL-43-F W-16 Required Scans- each has a weighing factor of 100% for complete coverage Angle-..... Upsteam-Axia.....i.... Upstrea

..... ........ Dow streamAxial_! Downstream Circ.

- c...

60 100% 100oo _________ 0%

60RL _________________16.6% (best effort) ________

"Code Coverage Total ! 50%

Best Effort Coverage (Max 25%) Total 16.6%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination period

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage .. ...................................... ......

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 26 of 28 Required examination volume- .75 sq. inches Far side required examination volume- .53 sq. inches Volume examined on far side-.53 sq. inches (100%)

• 50% Coverage achieved using 60° Shear Examination (US-O% + DS-1000% + cW-50% + CCW-50%)/4=50%

Examination Volume Dimensions: Length 21.8" x Width 2.0" x Height .253" Weld Thickness= .76 Weld Length= 218 Weld Width= 1.5

................ Coverage sum mary- Weld # 5I -504-1-S.W-77................................

.......

Required Scans- each has a weighing factor of 100% for complete coverage_

60 O96_______0 100% 100%

60RL 100% (best effort) -

Co de Cove rage Total 50%

Best Effort Coverage (Max 25%) Total 25%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination period

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated pro edure for single sided coverage. .......................... ...... ....

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 27 of 28 Flow Required examination volume- .57 sq. inches Far side required examination volume- .35 sq. inches Volume examined on far side-.07 sq. inches (20%)

50% Coverage achieved using 60° Shear Examination (US-100% + DS-O% + CW-50% + CCW-50%)/4=50%

Examination Volume Dimensions: Length 21"__ x Width 1.0 x Height ,27" Weld Thickness= ,81 Weld Length= 21" Weld Width= 1.20" Coverage Summary- Weld # SlL-504-F W-15

.................... Reqluired Sans-each- has-a weighing factor-of l00%fOr compl~etecoverage ...

An-gle .... Upstram-Axial

..... Upsrem- n:rc. Downstream Axial Downstream Crc.-

60 100%  ! 100% ________ 0%

70 __ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _

6oRL _________________ 20% (best effort) ________

Code Coverage Total 50%

Best Effort Coverage (Max 25%) Total i 20%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination period

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII

_ d~em on~st~rated* *procedur e for single _sided cov~erage ..................................... ..................

Serial No.15-313 Docket No. 50-423 Attachment 4, Page 28 of 28 1.0" 1.0" 1.20" 1.10" 45s 60RL 60s Transiton Piece / Valve Flow Required Examination Volume .5329 sq. inches Far Side Required Examination Volume .2591 sq. inches Volume examined on far side .1283 sq. inches (50%)

Examination Volume Dimensions: 3487 Length 34.87" Widthith 1._£ xWed 70" x Height .33__"

Weld Thickness= 1.0 Weld Length= 1.20" (US-100%+DS-0%+CW-50%+CCWS0%)/4=50%

Coverage Summary- Weld # SIL-8-FW-3 Required ,Scans- each has a weighing factor of 100% for complete coverage Angle Upstream-Axial IUpstream- Circ., Downstream Axial Downstream Circ.

45/60 100% 100% _______

60 RL 50%(Best Effort) ________

Code Coverage Total 50%

1oo+1oo+o+5o~Z5o/4-so Best Effort coverage (Max 25%) Total 12.5%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Serial No.15-313 Docket No. 50-423 ATTACHMENT 5 RELIEF REQUEST IR-3-23 EXAMINATION CATEGORY C-F-2 PRESSURE RETAINING WELDS IN CARBON OR LOW ALLOY STEEL PIPING DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3

Serial No.15-313 Docket No. 50-423 Attachment 5, Page 1 of 8 Relief Requested In Accordance with 10 CFR 50.55a(g)(5)(iii)

Inservice Inspection Impracticality

1. ASME Code Components Affected:

ASME Code Class: Code Class 2 Examination Category: C-F-2, Pressure Retaining Welds in Carbon or Low Alloy Steel Piping.

Item Numbers: C5.51, Circumferential Welds: Piping Welds > 3/8 in. (10mm) Nominal Wall Thickness for Piping >NPS 4 (DN 100)

Component Identification: Listed in Table I Material: Listed in Table I

2. Applicable Code Addition and Addenda ASME Section Xl, 2004 Edition, No Addenda

3. Applicable Code Requirement

ASME Section Xl, 2004 Edition, Examination Category C-F-2 requires 100 percent (%) volumetric examination coverage for circumferential piping welds.

The alternative requirements of ASME Section XI, Code Case N-460, approved for use in Regulatory Guide 1.147, Rev. 17, allows credit for essentially 100%

coverage of the weld provided greater than 90% of the required volume has been examined.

4. Impracticality of Compliance Pursuant to 10 CFR 50.55a(g)(5)(iii), relief is requested from the essentially 100% volumetric examination coverage requirement of the subject welds due to the geometric configuration which limit the volumetric coverage that can be obtained.

The subject welds were examined with a manual ultrasonic technique using pulse echo ultrasonic instruments and search units to achieve the maximum examination coverage practical. Examinations were performed using personnel,

,. Serial No.15-313 Docket No. 50-423 Attachment 5, Page 2 of 8 equipment and procedures qualified in accordance with ASME Section Xl, Appendix VIII as implemented by the Performance Demonstration Initiative (PDI).

No alternative techniques or advanced technologies were considered capable of obtaining complete coverage of the examination volume.

The subject welds include configurations that consist of either pipe to valve or pipe to weldolet that limit the circumferential scans on the upstream side. Due to the tapered surface of the valve or weldolet, within close proximity of the weld, no circumferential scans could be performed on the upstream side of these welds.

The coverage calculations are provided in this attachment.

Serial No.15-313 Docket No. 50-423 Attachment 5, Page 3 of 8 TABLE 1- Examination Category C-F-2 Weld with Limited Volumetric Examination Coverage System Ultrasonic Examination Examination Surface Code Configuration Angle and Wave Coverage Examination Weld Number Item # Material Mode Limitation and Results (%) Results DTM-25-FW-1 C5.51 Main Steam 450 Shear Wave Limited examination performed 75% Magnetic particle 6" Weldolet-To- from the pipe side only due to examination taper of the weldolet within close performed Pipe proximity of the weld. There is obtaining 100 SA1 06 GR B, not sufficient distance between percent Schedule 80 the weld and weldolet to perform coverage. No any scanning on the weldolet recordable side of the weld. One indication indications was detected that was evaluated detected.

as acceptable root geometry.

MSS-32-FW-2 C5.51 Main Steam 450 Shear Wave Limited examination performed 75% Magnetic particle from the pipe side only due to examination 8" Pipe-To-Valve taper of the valve within close performed SA1 06 GR B, proximity of the weld. There is obtaining 100 Schedule 100 not sufficient distance between percent the weld and valve to perform coverage. No any scanning on the valve side of recordable the weld. No recordable indications indications were detected, detected.

Serial No.15-313 Docket No. 50-423 Attachment 5, Page 4 of 8 System Ultrasonic Examination Examination Surface Code Configuration Angle and Wave Coverage Examination Weld Number Item # Material Mode Limitation and Results (%) Results MSS-32-FW-3 C5.51 Main Steam 450 Shear Wave Limited examination performed 75% Magnetic particle from the pipe side only due to examination 8" Pipe-To-Valve taper of the valve within close performed SA1 06 GR B, proximity of the weld. There is obtaining 100 Schedule 100 not sufficient distance between percent the weld and valve to perform coverage. No any scanning on the valve side of recordable the weld. No recordable indications indications were detected. detected.

" Serial No.15-313 Docket No. 50-423 Attachment 5, Page 5 of 8

5. Burden Caused by Compliance Compliance with the Code requirements would require extensive modification or replacement of components with a design that would allow examination from both sides of the weld. This option to meet the 100% Code examination requirement for coverage is considered to be impractical based on the cost, additional radiation exposure and impact to plant equipment.

6. Proposed Alternative and Basis for Use The subject welds received a volumetric examination to the maximum extent practical on the accessible portions of the welds using the best available techniques. Additionally, a surface examination was performed with 100%

coverage obtained and a visual (VT-2) examination is performed each inspection period during the system leakage tests as required by Section Xl, Table IWC-2500-1, Category C-H.

Based upon the volumetric examination coverage that was obtained with acceptable results, the surface examination obtaining 100% coverage with acceptable results, and the visual (VT-2) examination performed each period, it is reasonable to conclude that service induced degradation would be detected.

Therefore, these proposed alternatives will provide an acceptable level of quality and safety by providing reasonable assurance of structural integrity of the subject welds.

7. Duration of Proposed Alternative The relief is requested for the third ten-year inspection interval for Millstone Power Station Unit 3, which began on April 23, 2009 and will end April 22, 2019.

Serial No.15-313 Docket No. 50-423 Attachment 5, Page 6 of 8 SFlow

.41" .41" .41" .57" Weld-o-let Pipe Required Examination Volume- .2333 Sq. inches Examination Volume Dimensions: Length 21"._* x Width 1.00.__" x Height .13" Weld Thickness= .54__" Weld Length= 21__" Weld Width: 1.00" (UoverageDSummaryW-WeldCWDTM-25-FW-1 Coverage Summary- Weld # DTM-25-FW-1 Rpauired Stans- .eah has a weiuhinz factor of 100% for comolete coverage Angle I-Upstream-Axial Upstream- Circ. Downstream Axial Downstream Circ.

45 I 100% 0% 100% 100%

___________________Code Coverage Total 75%

IBest Effort Coverage (Max 25%) Total _______

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage

Serial No.15-313 Docket No. 50-423 Attachment 5, Page 7 of 8 Flow

.64" .64" .84" Required Examination volume- .41 sq. inches Examination Volume Dimensions: Length 45" x Width 1.45" x Height .21" Weld Thickcness= 84" Weld Length= 45._ Weld Wldth= .95" (US-100%+DS-100%+CW-50%+CCW-50%)/4=75%

Coverage Summary- Weld # MSS-32-FW-2 Required Scans- each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream- Circ. Downstream Axial Downstream Circ.

45 100% 100% 100% 0%

_____________________Code Coverage Total ] 75%

IBest Effort Coverage (Max 25%) Total] 0%

Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage..........

4.

4 Serial No.15-313 Docket No. 50-423 Attachment 5, Page 8 of 8

• jFlow

.68" .57" .59" .60*'

Required Examination volume- .33 sq. inches Examination Volume Dimensions: Length 25.1" x Width 1.50" x Height .21" Weld Thickness= 68__" WeldLength= 25.1" WeldWidth= 1.00" ____

(US-100%+DS1OO%+CW-50%+CCW-50%)/4=75%

Coverage Summary- Weld # MSS-32-FW-3 TRequired Scans- each has a weighing factor of 100% for complete coverage Angle Upstream-Axial Upstream- Oirc. jDownstream Axial [Downstream Circ.

45 100% 0% I 100% 100%

Code Coverage Total 75%

+

I Best Effort Coverage (Max 25%) Total Notes:

1. Code Coverage refers to the maximum percentage of the required examination volume that is effectively examined with the qualified examination procedure

2. Best Effort Coverage refers to the required examination volume past the centerline that is examined in the axial beam direction with an Appendix VIII demonstrated procedure for single sided coverage