73
Dominion Nuclear Connecticut, Inc. 5000 Dominion Boulevard, Glen Allen, VA 23060 : Dominion Web Address: www.dom.com October 18, 2012 U.S. Nuclear Regulatory Commission Serial No. 12-636 Attention: Document Control Desk NLOS/MAE RO Washington, DC 20555 Docket No. 50-336 License No. DPR-65 DOMINION NUCLEAR CONNECTICUT, INC. MILLSTONE POWER STATION UNIT 2 RELIEF REQUEST RR-04-13 FOR THE TEMPORARY NON-CODE COMPLIANT CONDITION OF THE CLASS 3 SERVICE WATER SYSTEM 10 INCH EMERGENCY DIESEL GENERATOR SUPPLY PIPING FLANGE Pursuant to 10 CFR 50.55a(a)(3)(ii), Dominion Nuclear Connecticut, Inc. (DNC) requests relief from the Section XI requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code for Millstone Power Station Unit 2 (MPS2). This request is based on the hardship of performing required ASME code repair/replacement activities to a piping flange in the 10-inch service water (SW) supply line to the Facility 2 emergency diesel generator (EDG) heat exchangers. In accordance with 10 CFR 50.55a(g)(1), this safety-related piping must meet the requirements applicable to components which are classified as ASME Code Class 3. A Code repair requires shut down of MPS2 to replace the piping flange. Given the limited risk associated with the condition of the flange, Code repair is considered a hardship without a compensating increase in the level of quality and safety. An alternative of continued operation with compensatory actions is proposed until the flange is replaced at the next refueling outage. Attachment 1 to this letter describes the temporary compensatory actions taken by DNC and the technical basis for the proposed relief request for this 10-inch moderate energy SW flange. Attachment 2 provides a structural integrity evaluation. At the time of discovery of this condition (September 19, 2012) MPS2 was operating at 100% power. Subsequently, on October 6, 2012, MPS2 entered refueling outage 21 and is currently shutdown. The submittal of this alternative request was the subject of a discussion between DNC (William Bartron) and the NRC (James Kim) on September 21, 2012, and again: between DNC (William Bartron) and the NRC (Timothy Lupold) on October 9, 2012. These discussions encompassed the analytical approach used in support of continued plant operation with the identified condition until the plant was shut down for the planned refueling outage, as well as the timely submittal of this alternative request, recognizing the request would likely be submitted after the shutdown of the unit for refueling. A permanent code-compliant replacement for the identified 10-inch SW flange will be completed no later than the end of the refueling outage which started on October 6, 2012.

Inc. Dominion Web Address: October 18, 2012 · leakage occurs. UT examinations of spool SK-2963 determined that ... The examination identified symptoms of localized area corrosion

  • Upload
    others

  • View
    2

  • Download
    0

Embed Size (px)

Citation preview

Dominion Nuclear Connecticut, Inc.5000 Dominion Boulevard, Glen Allen, VA 23060 : DominionWeb Address: www.dom.com October 18, 2012

U.S. Nuclear Regulatory Commission Serial No. 12-636Attention: Document Control Desk NLOS/MAE ROWashington, DC 20555 Docket No. 50-336

License No. DPR-65

DOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 2RELIEF REQUEST RR-04-13 FOR THE TEMPORARY NON-CODE COMPLIANTCONDITION OF THE CLASS 3 SERVICE WATER SYSTEM 10 INCH EMERGENCYDIESEL GENERATOR SUPPLY PIPING FLANGE

Pursuant to 10 CFR 50.55a(a)(3)(ii), Dominion Nuclear Connecticut, Inc. (DNC) requestsrelief from the Section XI requirements of the American Society of Mechanical Engineers(ASME) Boiler and Pressure Vessel Code for Millstone Power Station Unit 2 (MPS2).This request is based on the hardship of performing required ASME coderepair/replacement activities to a piping flange in the 10-inch service water (SW) supplyline to the Facility 2 emergency diesel generator (EDG) heat exchangers. In accordancewith 10 CFR 50.55a(g)(1), this safety-related piping must meet the requirementsapplicable to components which are classified as ASME Code Class 3.

A Code repair requires shut down of MPS2 to replace the piping flange. Given thelimited risk associated with the condition of the flange, Code repair is considered ahardship without a compensating increase in the level of quality and safety. Analternative of continued operation with compensatory actions is proposed until the flangeis replaced at the next refueling outage. Attachment 1 to this letter describes thetemporary compensatory actions taken by DNC and the technical basis for the proposedrelief request for this 10-inch moderate energy SW flange. Attachment 2 provides astructural integrity evaluation.

At the time of discovery of this condition (September 19, 2012) MPS2 was operating at100% power. Subsequently, on October 6, 2012, MPS2 entered refueling outage 21 andis currently shutdown. The submittal of this alternative request was the subject of adiscussion between DNC (William Bartron) and the NRC (James Kim) on September 21,2012, and again: between DNC (William Bartron) and the NRC (Timothy Lupold) onOctober 9, 2012. These discussions encompassed the analytical approach used insupport of continued plant operation with the identified condition until the plant was shutdown for the planned refueling outage, as well as the timely submittal of this alternativerequest, recognizing the request would likely be submitted after the shutdown of the unitfor refueling.

A permanent code-compliant replacement for the identified 10-inch SW flange will becompleted no later than the end of the refueling outage which started on October 6,2012.

Serial No. 12-636Docket No. 50-336

Relief Request RR-04-13Page 2 of 2

If you have any questions regarding this submittal, please contact Wanda Craft at (804)273-4687.

Sincerely,

J. ±rice

Vice President - Nuclear Engineering

Attachments:

1. Relief Request RR-04-13 for the Temporary Non-Code CompliantCondition of the Class 3 Service Water System 10 Inch Emergency DieselGenerator Supply Piping Flange

2. ETE-CME-2012-1024, Rev 2, Structural Integrity Evaluation of DegradedFlange in B Service Water Pipe to EDG Spool SK-2963

Commitments made in this letter:

1. Replace the downstream flange on Spool Piece 2963 (Facility 2 SW supply pipingto the Facility 2 EDG HXs) no later than the end of the next refueling outagescheduled for October 2012.

2. UT examination of the pipe flange will be done on a daily basis to track theprogression of the corrosion damage.

cc: U.S. Nuclear Regulatory CommissionRegion I475 Allendale RoadKing of Prussia, PA 19406-1415

J. S. Kim, Project ManagerU.S. Nuclear Regulatory CommissionOne White Flint North11555 Rockville PikeMail Stop 0-8 C2ARockville, MD 20852-2738

NRC Senior Resident InspectorMillstone Power Station

Serial No. 12-636Relief Request RR-04-13

Docket No. 50-336

ATTACHMENT 1

RELIEF REQUEST RR-04-13 FOR THE TEMPORARY NON-CODE COMPLIANTCONDITION OF THE CLASS 3 SERVICE WATER SYSTEM 10 INCH

EMERGENCY DIESEL GENERATOR SUPPLY PIPING FLANGE

DOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 2

Serial No. 12-636Docket No. 50-336

Relief Request RR-04-13Attachment 1, Page 1 of 7

RELIEF REQUEST RR-04-13

Relief RequestIn Accordance with 10 CFR50.55a(a)(3)(ii)

-- Code Repair Hardship/No Compensating Increase in Safety --

1.0 ASME Code Component(s) Affected

ASME Code Class: Code Class 3

Reference: ASME Section Xl, IWA-4000

Description: Repair/Replacement Activities

Component: Service Water (SW) System 10-inch Light WeightSlip-on Flange (10"JGD-4 spool SK-2963)

Material Coated Carbon Steel

2.0 Applicable Code Edition and Addenda

Millstone Power Station Unit 2 (MPS2) is currently in the fourth 10-yearinservice inspection (ISI) interval, which began on April 1, 2010. AmericanSociety of Mechanical Engineers (ASME) Section Xl, 2004 Edition, NoAddenda (Reference 8.1) applies to the ISI program and is used as theprimary ASME code edition for Section Xl repair/replacement activities. TheSW system piping design code (code of construction) is ANSI B31.1, 1967Edition through the summer of 1973 Addendum (Reference 8.4) and thefitting design code (code of construction) is ANSI B16.5, 1968.

3.0 Applicable Code Requirement

ASME Code Section Xl, 2004 Edition, No Addenda, Article IWA-4000,Repair/Replacement Activities.

4.0 Reason For The Request

On September 19, 2012, Ultrasonic Test (UT) inspections were performedon a slip-on flange located on 10" service water supply line to B EmergencyDiesel Generator (10"-JGD-4 spool SK-2963) to identify damage before,leakage occurs. UT examinations of spool SK-2963 determined thatmaterial has been lost from several localized areas.

Serial No. 12-636Docket No. 50-336

Relief Request RR-04-13Attachment 1, Page 2 of 7

Enclosure 1 to this attachment contains UT inspection results for theobserved flaw area of the flange.

A Code repair would require shutting down to replace the piping flange.Given the limited risk associated with the present condition~of the flange,Code repair is considered a hardship without a compensating increase inthe level of quality and safety. Online repair was considered, however, itwould require entry into abnormal operating procedures (i.e., OP 2326C,Off-Normal Service Water System Operations) including the followingactions and/or conditions to effect a Code repair.

1. Ensure that SW temperature is less than 580F (currently SWtemperature is approximately 660F and normally remains above 58°Fwell into October). One SW train is sufficient to support accident andsafe shutdown loads. Online operation requires two SW trains tosupport the additional loads unless SW temperature is less than 58°F.

2. Align vital switchgear room coolers and chillers to the A train (orestablish compensatory cooling).

3. Disable the B EDG.

4. Align the swing reactor building closed cooling water (RBCCW) heatexchanger (HX) to the A train on the SW side and the B train on theRBCCW side and ensure swing RBCCW HX can provide adequate Btrain cooling with SW flow less than 1500 gpm.

5. Align the swing SW pump mechanically to the A train and electrically tothe B train and start the pump.

6. Align two turbine building component cooling water (TBCCW) HXs tothe A train on the SW side (this may require a reactor down power toprovide sufficient cooling).

Once in this configuration, completion of the work activities for the spoolreplacement within the remaining time of the limiting condition for operationof 72 hours will not be possible. Therefore a transition to Mode 5 (ahardship) would be required to perform this repair. Therefore, this is not afeasible option. Further, there is no compensating increase in plant safetyby performing the repair during the operating cycle.

This temporary degraded condition of the 10-inch light weight slip on flangeis not in compliance with ASME Section Xl, 2004 Edition, IWA-4000, nor

Serial No. 12-636Docket No. 50-336

Relief Request RR-04-13Attachment 1, Page 3 of 7

does it fall within the scope of the accepted analysis methods contained inNRC Generic Letter (GL) 90-05 (Reference 8.2). Additionally, Code CaseN-513-3 (Reference 8.3) is not applicable for use in structural evaluationsbecause the degradation is in a component (10-inch light weight slip-onflange) which is specifically excluded from the scope of the code case.However, the current pipe stress analysis of record has been reviewed andthe pipe stress levels adjacent to the flange (for the non-degraded condition)have been determined to be less than 10% of applicable Code allowables.The current corrosion damage to the flange is characterized through UTevaluations as limited. Because the observed damage is limited, it isconsidered that adequate margin is available to accommodate the corrosionthat is anticipated to occur during the remaining week of operation until thenext refueling outage.

5.0 Proposed Alternative and Basis for Use

5.1 Flaw Characterization - Based on the UT results of the current conditionand experience from other similar lining failures discovered during normalinspection on carbon steel piping components in SW, the flaw ischaracterized to be a localized area corrosion rather than a crack-like flaw.Dominion procedure ER-AA-NDE-UT-701 (included as Enclosure 2 toAttachment 1) contains additional details on the nondestructive examinationprocess used. The inspection process is reviewed by a qualified Level IIIinspector.

The examination identified symptoms of localized area corrosion which isconsistent with prior experience from other lining failures on this system.The flange in question was not designed to permit a complete volumetricexamination once installed. However, the UT examination process used iscapable of identifying localized area corrosion in the flange. There is nohistory of crack-like flaws in this system and it is not considered credible thatsuch a flaw exists in the small area that did not receive a volumetricexamination.

The coating on SW spool SK-2963, where the degradation is occurring onthe outlet flange, is inspected every other refueling cycle to ensure that thepressure boundary of the SW pipe remains intact and that the tube sheetsof safety-related heat exchangers (HXs) do not become clogged by coatingmaterial. This every other refueling outage inspection is based upon theinspection of one train of SW every outage. This inspection scheme hasbeen used for over ten years. Numerous defects have been detected bythese inspections and repaired before a through-wall leak occurred.

Serial No. 12-636Docket No. 50-336

Relief Request RR-04-13Attachment 1, Page 4 of 7

Galvanic Corrosion MechanismThe typical corrosion encountered in this carbon steel lined pipe, used forMPS2 SW, comes from a break or perforation (holiday) in the coating orlining.

The flaws in the coating have been observed most often in or around theinner diameter (ID) corners of the flanged joints. Once the coating isdamaged, seawater penetrates into the coating and eventually migratesthrough to the carbon steel. Once the seawater electrolyte makes contactwith the carbon steel, galvani6 corrosion begins if the affected flange isjoined to another flange of dissimilar metal (as in this case, AL6XN). Thecarbon steel is anodic to the surrounding coated carbon steel and anyuncoated alloy surfaces. This creates an electrical current and metal ionsare released into solution creating a cavity. The cavity grows from the initialpoint outwards in a radial shape in all directions and takes on a concaveappearance.

When the fit-up line between the slip-on flange ID and pipe outer diameter(OD) is exposed, this narrow space is flooded and exposed to seawaterwhich then becomes subject to corrosion. However, the geometry of thisgap is not favorable for the mass exchange (movement of negativelycharged chloride and free oxygen atoms in and positively charged metalions out) required for rapid corrosion. The free oxygen within the gap isquickly depleted and the rate of corrosion diminishes to a substantially loweramount compared to that in the active cavity. Thus, significant corrosion ofthe flange hub or attachment weld beyond the active cavity is not expected.

Beginning in 2005, sections of the piping have been replaced with superaustenitic stainless steel, AL6XN, designed for seawater service. Dominionhas planned a systematic replacement of the safety-related portion of theSW piping. Spool SK-2963 is scheduled for replacement in the followingrefueling outage (spring 2014).

The coating on the outlet flange was visually inspected by a qualified liningsengineer during 2R20 (spring 2011). Lining engineers receive specifictraining in the inspection of linings to recognize coating defects. The epoxylining on the flange face and ID of the pipe had minor evidence of damagethat was repaired at that time.

Initial evaluation of this degradation assumed a corrosion rate of0.067"/month. In addition, daily UT measurements were taken to determinea growth rate. The nature of these measurements inherently introducessome data scatter, so several days of data were required to confirm thatgrowth rate. On 9/27/12, it was determined that the growth rate of several

Serial No. 12-636Docket No. 50-336

Relief Request RR-04-13Attachment 1, Page 5 of 7

areas of degradation were quite small, but that one area was corroding at arate that could not support continued operability (approximately .005" /day).The service water header was accordingly declared inoperable that evening.Since this rate was indicative of galvanic corrosion and testing indicatedinadequate insulation of the.affected flange, actions were initiated toproperly install insulation kits on that flange by removing one bolt at a timeand replacing it along with an insulating sleeve and washers. By themorning of 9/30/12, the flange had been adequately insulated. Analysesshowed that with the reduced rate of corrosion that could be expected in thisconfiguration, no leakage from this degraded flange would be expected forthe remaining time to the refueling outage plus a 30-day mission time. Themargin to structural integrity and to flow diversion are significantly higherthan the margin to leakage. Daily UT monitoring continues to verify that thecorrosion rate is lower than allowable. It should be noted that the expectedcorrosion rate is less than 20% of the allowable to maintain operability untilthe refueling outage plus 30-day mission time.

5.2 Structural Integrity - Per MPS2 Technical Requirements Manual (TRM)3.4.10, the structural integrity of an ASME component is determined inaccordance with either the original construction code or the ASME SectionXI Code, approved code cases or regulatory-approved methods ofevaluation. No NRC approved methodology could be identified (i.e., GL 90-05) and Code Case N-513-3 is not applicable for use. EngineeringTechnical Evaluation ETE-CME-2012-1024, Revision 2 (Reference 8.6) is astructural integrity assessment of the degraded flange. Pipe stress levelsfor the Code equations for the adjoining pipe are less than 10% of theirassociated allowables. Since the limiting case assumes that a 50%maximum wall loss is experienced (to be confirmed periodically by UT) andthe adjoining pipe element has over 90% margin in the stress equations,structural integrity of the flange joint will be maintained for the loadingconditions (i.e., dead load, thermal and seismic). The flaw is not crack-likeand thus will remain stable under the postulated design loading conditionssince a large structural capability margin exists in the worst case degradedflange. Full structural integrity will be restored during 2R21 with a codecompliant repair.

5.3 Flow Margin - No leakage has been identified from Spool SK2963.Therefore there are no flow margin concerns.

5.4 Spray Concerns - No leakage has been identified from Spool SK2963.Therefore there are no spray concerns.

Serial No. 12-636Docket No. 50-336

Relief Request RR-04-13Attachment 1, Page 6 of 7

5.5 Flooding - No leakage has been identified from Spool SK2963. Thereforethere is no flooding concern.

5.6 Extent of Condition - UT examination of a slip-on flange on the 24" servicewater supply line to the B Reactor Building Closed Cooling Water heatexchanger (24"-JGD-3 spool SK-893) indicated some material loss in thevicinity of bolts 5 & 6 (clockwise from the top of the CS flange). Theaffected spool is planned to be replaced during refueling outage 2R21.Extent of condition examinations (UT and visual) of other areas are beingconducted. Some areas may be left in service for a short time after beingevaluated to ensure acceptable wall thickness for the duration of that inservice period. Areas of degradation will be repaired and the cause of thedegradation (typically coating defects and/or improper galvanic isolation)corrected prior to returning the unit to service from the fall 2012 refuelingoutage. An on-going capital project has replaced much of the carbon steellined/coated carbon steel piping. However, many similar coated carbonsteel flange joints (to the current degraded joint) remain in service. No SWsystem flange leaks are present in the MPS2 SW system. Because thecorrosion rate of carbon steel pipe and fittings can be unacceptably highwhen galvanic corrosion is present, action will be taken during this refuelingoutage to reduce the probability of further galvanic attack. These actionsinclude:

" Identification of the affected components." Identification and selection of strategies including testing, monitoring,

and mitigation activities to minimize the probability of galvanic attack.Additionally, long term corrective actions will be identified.

5.7 Compensatory Monitoring Plan - UT monitoring will be performed dailywhile the degraded spool remains in service until a code compliant repair iscompleted. UT examination of the pipe flange, as was done to identify thedegraded area, will track the progression of the corrosion damage. If thecircumferential extent of corrosion increases to greater than 50% of thecircumference at least partially degraded or if the radial extent of the worstarea of degradation indicates greater than acceptable rate of corrosion, theservice water header will be declared inoperable and appropriate actions inaccordance with Technical Specifications will be taken. Additionally, if thepipe flange experiences a through wall leak, appropriate actions inaccordance with technical specifications will be taken.

Serial No. 12-636Docket No. 50-336

Relief Request RR-04-13Attachment 1, Page 7 of 7

5.8 Conclusion - Although the structural integrity of the degraded flange cannotbe demonstrated in accordance with a regulatory-approved methodology, itis concluded the integrity and functional requirements of the flange will bemaintained. Thus, SW will continue to be capable of providing requiredcooling water flow to meet the required cooling loads including the EDGHXs. There will be no adverse impact on neighboring equipment due toeither spray or flooding. DNC will implement the compensatory monitoringplan above to ensure any growth of the flaw is identified and assessed forits impact on structural integrity.

6.0 Duration of Proposed Alternative

The affected spool piece is scheduled to be repaired in October 2012 during2R21. Therefore, the duration of the proposed alternative is requested untilend of the refueling outage which started in October 2012.

7.0 Precedents

Millstone Power Station, Unit No.2-Issuance of Relief Request RR-04-12Regarding the Temporary Non-Code Compliant Condition of the Class 3Service Water System 10 Inch Emergency Diesel Generator Supply PipingFlange (TAC NO. ME6886), ML113000100.

8.0 References

8.1 ASME Code Section XI, Division 1, 2004 Edition (No Addenda)

8.2 NRC Generic Letter GL 90-05, "Guidelines for Performing Temporary Non-Code Repair of ASME Code Class 1, 2, and 3 Piping," June 15, 1990

8.3 Code Case N-513-3, "Evaluation Criteria for Temporary Acceptance ofFlaws in Moderate Energy Class 2 or 3 Piping," Section Xl, Division 1,January 26, 2009

8.4 American National Standards Institute (ANSI) B31.1, Power Piping Code,1967 Edition through the Summer 1973 Addendum (Note: The MPS2 PipeStress Analysis Criteria Document allows the use of ASME III, 1974 Editionto demonstrate pipe stress acceptability)

8.5 Condition Report CR 488814, UT of coated carbon steel flange adjacent 6%Mo SS indicates damage to carbon steel.

8.6 Engineering Technical Evaluation ETE-CME-2012-1024, Revision 2.

Serial No. 12-636Relief Request RR-04-13

Docket No. 50-336Enclosure 1 of Attachment 1

Enclosure 1(of Attachment 1)

Ultrasonic Test Results

DOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 2

Serial No. 12-636Relief Request RR-04-13

Docket No. 50-336Enclosure 1 of Attachment 1

Exam Data Sheet

Millstone Power Station ULTRASONIC EXAMINATION

STRAIGHT BEAM MEASUREMENTSPlant Millstone Unit 2 Page ILof .22System & Zone No. "B" Train Service Water/ 3326 Exam Data Sheet No N/A

Component ID SK-2963 AWONumber 531025J6395

Component Description Inlet Flaunge on Spool SK-2963 Drawing No. 25203-201941 Sh.2263

Examination Purpose Eneineering Information Line No. 10"-JGD-4

Instrument & Settin

Manufacturer Olympus

Model No. 38 DL Plus

Serial No. 100030807

Range 3.0"

Velocity .2326

Delay N/A

oZet Value 26570

Cal Tolerance 1 ±.002"

Search Unit Data

Manufacturer Panametrics

Type No. D791-RM

Serial No. 109450

- requency 5.0 MHz

Size 0.2"

Intermediate N/A N/A N/A N/A N/AFinal 14:15 .2 50" 1.00" .250" 3.00"

Couplant Data

B.ln Utage 11

Batch No. 11225 GSAP Batch Mgmt. No. NT/A

Temperature Data

Cal. Block Temp. N/A

Component Temp. N/A

Thernometer No N/A

See Attachment for Detailed Examination Results

Examiner (pin & sign)

Reviewer (sign) t S

ANVANII If Required (Sign)

.Level II Date 09/19/2012

Level • Date

Date N/AN/A

Level of Use RA -7

Reference ER-AA-NDE-UT-701

Serial No. 12-636Relief Request RR-04-13

Docket No. 50-336Enclosure 1 of Attachment 1

Millstone Unit 2Service Water System "B" Train

Component ID: SL-2963 (Inlet flange on spoof SK-2963)

WO #: 53102516395Position UT Point 1 UT Point 2 UT Point 3 UT Point 4

1 0.405 N/A 0.816 2.520

2 0.388 N/A 0.822 2.520

3 0.380 N/A 0.816 2.520

4 0.389 N/A 0.823 2.500

5 0.399 N/A 0.810 2,100

6 0.405 N/A 0.808 2.530

7 0.411 N/A 0.803 2.530

8 0.414 N/A 0.809 2.180

9 0.409 N/A 0.812 1.900

10 0.415 N/A 0.826 1.910

11 0.410 'N/A 0.822 2.530

12 0.387 N/A 0.824 1.900

Comments: n ;ý; I I Lý A I I : ;rtoslu on at ell ow etral oUVI. A pl lJ~Ll ll lull inl LlUOltWle QI tLLIuII witln 10w.

Notp: UT readine.~ nht~ined on n~intpd ~uirfsce whirh rniild rp~ijIt in rliffir,,Itx, inNote: UT readings obtained on Dainted surface which could result in difficul- inobtaining UT data at some locations. No UT readings at point 2. Rough weld

surface does not provide for consistent UT point repeatability.

-7

S.

Li 10

.3If

:2. I I

Serial No. 12-636Relief Request RR-04-13

Docket No. 50-336Enclosure 1 of Attachment 1

16.00 (REF)

K10.88 (RIFI

2.59

2.00 ,

E .900 •

1.25

m- _ _ -12.00 (REF)

0.227

Serial No. 12-636Relief Request RR-04-13

Docket No. 50-336Enclosure 2 of Attachment 1

Enclosure 2(of Attachment 1)

Dominion Procedure MP-PROC-000-ER-AA-NDE-UT-701, "NondestructiveExamination Procedure"

Nuclear Fleet

DNondestructive ExaminationProcedure

Title: Ultrasonic Thickness Measurement Procedure

Procedure Number Revision Number NPQR Number

ER-AA-NDE-UT-701 5 ER-AA-NDE-UT-701 -NPQR,

Revision 0Approval signatures on file with approval documentation for this procedure revision.

R. T. StackIndependent Level III Review

K, J. HackerCorporate Level III Approval

J.W. NiemergANII

02/26/2011Date

02/2612011Date

02/26/2011Date

Level of Use: Reference

DOMINION ER-AA-NDE-UT-701Revision 5

Page: 2 of 11

Record of Revision

Rev. Page# Paragraph # Summary of Revision0 All All New issue as Dominion Nuclear Fleet Procedure.1 4 2.3 Added "couplant"

4 5.1.1 Added the option for using other gauges/scopes with Level IIIapproval.

5 5.2.4 Deleted requirements for using dual element transducers formeasuring through coatings.

6 6.2.2 Deleted requirements for using the multi-echo technique.6 7.1 Deleted reference to multi-echo technique.6 7.2 Deleted limitation of single-echo technique for non-coated

surfaces.6 7.3 Deleted (multi-echo requirements)6 7.3.1 Deleted (multi-echo requirements)7 8.5 Deleted (multi-echo requirements)8 9.8 Added new paragraph for guidance for evaluating thickness

results for coated surfaces.2 4 5.1 Added new paragraph for equipment to comply with ER-AA-

NDE-130 requirements.5 5.6.1 Provide allowance for using the component being examined

as the reference standard for calibration.6 8.4 Clarified the guidance for selecting the calibration points for

calibration.10 10.2 Added new paragraph for data records to be processed in

accordance with ER-AA-NDE-1 40 requirements.3 4 3.1 Updated reference to the 2004 Edition.4 4 1.1 Updated the type of UT equipment displays to include A-scan

and direct thickness readout.4 2.1 Reduced the minimum thickness range from 0.050" to 0.025".

Allowed the examination of components outside the specifiedrange provided demonstrated through the calibration processand Level III approval.

4 4.1 Clarified the Level 11-L qualifications by adding straight beamqualification.

5 5.2.1 Identified the ultrasonic instrument requirements based ondisplay.

5 5.3.1 Increased the upper range of search unit frequency from 10MHz to 20 MHz to address thinner limits of the procedure.

5 5.3.4 Included the use of delay lines for high temperature orimproved near surface resolution is required.

6 5.7.1 Changed to require the use of temperature measurementsonly for high temperature components.

8 8.7 Changed to require the use of temperature measurementsonly for high temperature components.

9 9.7 Included additional guidance for addressing areas oflaminations with lower frequency search units.

DOMINION ER-AA-NDE-UT-701Revision 5

Page: 3 of 11

Rev. I Paae # ParaaraDh # Summarv of Revision5 6 5.3.2 Modified the search unit size to "should" and added criteria for

resolution capabilities when using smaller search units.

DOMINION ER-AA-NDE-UT-701Revision 5

Page: 4 of 11

Table of Contents

1.0 Purpose ........................................................................................................................... 52.0 Scope .............................................................................................................................. 53.0 Reference Documents ................................................................................................ 54.0 Personnel Qualifications ............................................................................................. 55.0 Equipment and Material Requirements .................................. 56.0 Examination Requirements ........................................................................................ 77.0 Thickness Measurement Technique ............................................................................ 78 .0 C a lib ra tio n ....................................................................................................................... 79.0 Exam ination ..................................................................................................................... 910.0 Data Recording ........................................................................................................... 10

DOMINION ER-AA-NDE-UT-701Revision 5

Page: 5 of 11

1.0 Purpose

1.1 The purpose of this procedure is to provide a process for the calibration andapplication of straight beam ultrasonic techniques for performing thicknessmeasurements utilizing equipment with A-scan display or direct thickness readoutwith A-scan displays.

2.0 Scope

2.1 This procedure is applicable to the manual, pulse echo, straight-beam, longitudinalwave, contact ultrasonic technique for performing thickness measurements offerritic or austenitic tubing, piping, vessels, and components in the nominalthickness range of 0.025 to 20.00 inches. Thickness measurements may be takenoutside of the specified nominal thickness ranges provided the equipmentcapabilities is demonstrated through the calibration process and Level Ill approvalis documented on the examination record.

2.2 Examinations may be conducted from the inside (ID) or outside (OD) surfaces.

2.3 The temperature of the component being examined should not exceed themanufacturer's maximum temperature for the search unit or couplant being used.

3.0 Reference Documents

3.1 ASME Boiler & Pressure Vessel Code, Section V, 1989 Edition through the 2004Edition, Article 23, SE-797, Standard Practice for Measuring Thickness by ManualUltrasonic Pulse-echo Contact Method.

4.0 Personnel Qualifications

4.1 The examiner shall be certified to Level II-L (limited to straight beam or thicknessmeasurements), Level II, or Level Ill in the ultrasonic method in accordance withDominion's written certification practice. The examiner shall be responsible for andshall accept the results of the examination.

4.2 An assistant qualified to at least a Level I in the ultrasonic method in accordancewith Dominion's written certification practice may assist the examiner. The Level Ishall work under the direct supervision of the examiner and shall not evaluate oraccept the examination results.

5.0 Equipment and Material Requirements

5.1 All equipment and materials used to implement this procedure shall comply with therequirements of ER-AA-NDE-130, "Storage and Control of Calibrated NDEEquipment, Calibration Standards, and Consumable NDE Materials".

DOMINION ER-AA-NDE-UT-701Revision 5

Page: 6 of 11

5.2 Ultrasonic Instruments

5.2.1 Approved pulse echo ultrasonic instruments shall provide either a directA-scan display or a combination of an A-scan display with directthickness readout. An acceptable calibration in accordance with thisprocedure demonstrates acceptable ultrasonic instrument selection foruse.

5.3 Search Units

5.3.1 Search units with a nominal central frequency in the range of 5.0 to20.0 MHz should be selected for performing thickness measurements.For thicknesses 0.050" and less the search unit frequency shall be 10.0MHz or higher. Other frequencies between 1.0 and 5.0 MHz may beused when their properties (i.e., sensitivity, penetration, resolution, etc.)provide superior results.

5.3.2 The search unit active element size should be between 0.10" and 1.00"square inches, however smaller search units may be used provided theresolution capabilities of 5.3.5 are maintained.

5.3.3 The search unit elements shall be round.

5.3.4 Either single or dual element search units may be used. Delay linesmay be used for high temperature components or when improved nearsurface resolution is required.

5.3.5 Proper search unit selection (size, shape, configuration, frequency) willbe indicated by the systems ability to properly display and resolve thecalibration standard's reflections throughout the range of the expectedthickness measurements for the component to be examined.

5.4 Cabling

5.4.1 The interconnecting cable between the search unit and the ultrasonicinstrument shall be RG-58 or RG-174 type coaxial cable (or equivalent)with lengths not to exceed 20 feet.

5.5 Couplant

5.5.1 A suitable liquid couplant medium shall be applied to the examinationsurface for the examination. The couplant shall be approved for use atthe site prior to use. The same couplant used for calibration shall beused to perform the examination.

DOMINION ER-AA-NDE-UT-701Revision 5

Page: 7 of 11

5.6 Reference Blocks

5.6.1 Reference blocks used for screen distance calibration and verificationshall be of the same material as the component material beingexamined (e.g. carbon steel or stainless steel). As an alternative, thecomponent being examined may be used for calibration. The referenceblock or component used for calibration must be of known thickness toallow for accurate calibration.

5.7 Thermometer

5.7.1 When required (high temperature components >- 125' F), a calibratedsurface thermometer shall be used to document the surfacetemperature of the reference block and component prior to theexamination.

6.0 Examination Requirements

6.1 Examination Area

6.1.1 The extent of the area to be examined and the criteria, by which theultrasonic measurements and part acceptability will be evaluated, shallbe determined by the parties requesting that the examination beperformed.

6.2 Surface Condition Requirements

6.2.1 The examination surface shall be free of irregularities, loose material, orloose coatings which interfere with the ultrasonic wave transmission.Areas where ultrasonic contact is inadequate shall be documented aslimitations.

7.0 Thickness Measurement Technique

7.1 Thickness measurements shall be taken using the single echo measurementtechnique.

7.2 The single echo technique measures the total thickness of the part using a singlebackwall reflection. This measurement includes any coating which may be presenton the surface, leading to an error in the actual base material thickness.

8.0 Calibration

8.1 Calibration shall include the complete UT system. Any change in search units,couplant, cables, instruments, or any other part of the system shall be cause forcalibration verification.

DOMINION ER-AA-NDE-UT-701Revision 5

Page: 8 of 11

8.2 The calibration shall be performed with a reference block meeting the requirementsof section 5.6.

8.3 System setup and calibration (zero, velocity, gain, time base, etc.) shall beperformed in accordance with the operating manual for the ultrasonic instrumentbeing used for the examination based upon the selected parameters of theexamination (i.e,, measurement technique, material, thickness ranges, search units,etc.).

8.4 The calibration shall utilize two points of known thickness. The calibration pointsmay be single backwall reflections or backwall multiples of known thicknesses.When available, the calibration points should be equal to or greater than thenominal thickness being examined and a thickness less than the nominal thicknessbeing examined.

8.5 Upon completion of the system setup and calibration, couple the search unit toeach of the thickness steps of the reference block used for calibration and verifythat the readings are within ±0.002 inches of the as-built thickness dimension.

8.6 Calibration Verification

8.6.1 System calibration shall be checked using the appropriate referenceblock. Thickness reading of the calibration points shall be recordedduring the initial calibration and shall be verified at the followingintervals:.

8.6.1.1 At the start and finish of each examination;

8.6.1.2 With any change in examination personnel;

8.6.1.3 Whenever the instrument has been turned off and thenturned on;

8.6.114 When there is a change in search unit, cable, or couplant;

8.6.1.5 At intervals not to exceed four hours;

8.6.1.6 Whenever the validity of the calibration is in doubt.

8.6.2 If any calibration thickness point changes by more than 0.005 inches,the following shall be performed:

8.6.2.1 Void all examinations referring to the calibration in questionand performed after the last valid calibration check;

8.6.2.2 Conduct a new calibration;

DOMINION ER-AA-NDE-UT-701Revision 5

Page: 9 of 11

8.6.2.3 Reexamine all areas for which the examinations have beenvoided,

8.7 For thickness measurements on high temperature components (2> 125° F) theexamination surface shall be within 250 F of the reference block used forcalibration. The thermometer identification and surface temperatures shall bedocumented on the data sheets.

9.0 Examination

9.1 The examination shall be performed using a 100 percent scan, partial scan, or spotcheck scanning technique. The type of scan required for each component shall bedefined by the parties requesting that the examination be performed. The types ofscans are defined as follows:

9.1.1 100 Percent Scan - This examination will encompass the completecomponent. )t is a detection, as well as a measuring technique, andshould be utilized to detect the thickest and thinnest areas or whenencountering inclusions, laminations, or rapidly changing thickness (i.e.,erosion/corrosion).

9.1.2 Partial Scan - This examination covers only a percentage of thecomponent being examined. The percentage should be based on therequirements of the examination. This technique should not be utilized iffinding the thickest or thinnest area of the component is required.

9.1.3 Spot Check - This examination is a point-to-point -technique whichmeasures the thickness of the component at predetermined gridlocations. It should not be utilized to detect the thickest or thinnest areaof the component being examined.

9.2 Thickness readings should be taken using similar couplant thickness and searchunit pressure as used for the calibration.

9.3 For dual element search units ensure that the acoustic barrier between the searchunit elements is aligned perpendicular to the axis of the pipe to eliminate the effectsof the curvature on the UT measurements.

9.4 Thickness readings shall be recorded as required (manually or datalogger/recorder).

9.5 The thickness readings taken during an examination should be reviewed at theconclusion of the examination to ensure that no unusual readings exist and that theexamination is complete. If there are any erroneous or missing readings, thoseareas should be reexamined to ensure accurate examination results,

DOMINION ER-AA-NDE-UT-701Revision 5

Page: 10 of 11

9.6 Where available, the digital readout should be utilized as the primary source forthickness readings. The A-Scan display should be monitored to ensure thatthickness readings taken are "true" readings and not the result of couplantreadings, inclusions, laminations, etc.

9.7 If inclusions or laminations are encountered, the area should be scanned andmarked to properly bound the region. The depth(s) of the inclusion(s) orlamination(s) should also be recorded and documented, as necessary. Whenareas of laminations are identified, the area of lamination should be examined witha lower frequency search unit to reduce the limited area examined. Lowerfrequency search units will often penetrate thin/tight laminations due to theincreased penetrating power of the longer wave length.

9.8 For components examined through coatings, the coating thickness will cause aslight increase in the recorded thickness from the actual thickness of thecomponent. Although this increase is small, coating with reported thicknesses nearthe minimum wall thickness (minimum wall +0.015") should be evaluated todetermine if the coating should be removed and the actual thickness verified.

9.9 Upon completion of the examination the excess couplant shall be removed.

Supplies and equipment shall also be removed from the examination area.

10.0 Data Recording

10.1 Calibration and examination data shall be recorded on data sheets and -as aminimum shall include the following:

10.1.1 Calibration sheet identification.

10.1.2 Names and certification levels of examination personnel.

10.1.3 Examination procedure number and revision.

10.1.4 Reference block identification.

10.1.5 Ultrasonic instrument serial number, manufacturer, and modelidentification.

10.1.6 Ultrasonic instrument settings.

10.1.7 Search unit manufacturer, model, and manufacturer's serial number.

10.1.8 Search unit nominal frequency, size, shape, and number of elements.

10.1.9 Special search units, wedges, shoe type, or saddle's identification,delay line, if used.

10.1.10 Search unit cable type, length, and number of intermediate connectors.

DOMINION ER-AA-NDE-UT-701Revision 5

Page: 11 of 11

10.1.11 Times and dates of initial calibration and subsequent calibration checksincluding the thickness measurements of the calibration points.

10.1.12 Signal response amplitudes and sweep positions obtained from the

calibration reflectors.

10.1.13 Couplant type and batch number.

10.1.14 Identification and location of the component scanned.

10.1.15 Surface from which the examination is conducted.

10.1.16 When applicable, the temperature of the reference block andcomponent along with the thermometer manufacturer, model, and serialnumber.

10.1.17 The type of scan completed, i.e. 100 percent scan, partial scan, or spotcheck. For partial scans, record the approximate percentage of eachsection examined.

10.1.18 Examination results (thickness readings) including limitations of thearea scanned. When using data loggers/recorders the data printoutmay be attached to document the thickness measurements.

10.1.19 A drawing or photograph of the component should be included with theexamination records when possible.

10.2 All data records shall be reviewed and processed in accordance with ER-AA-NDE-140, "Processing of Dominion NDE Data".

Serial No. 12-636Relief Request RR-04-13

Docket No. 50-336Attachment 2

ATTACHMENT 2

ETE-CME-2012-1024, Revision 2,Structural Integrity Evaluation of Degraded Flange in B Service Water Pipe to

EDG Spool SK-2963

DOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 2

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 1 of 46

XDnominion-

Engineering Technical Evaluation

Cover Sheet

CMA-T I10 ATAHMN 2, Pae11 f1

1. Stations Doc Type: Sub Type: 2. Document Number 3. Rev # 4. Decomissioning?V MP 0 SU [] NA F] KW F] CO ETE 000 ETE-CME-2012-1024 2 FD Yes [ No

(Note: If both SU and NA, then check CO)

5. Title:Structural Integrity Evaluation of Degraded Flange in "B" Service Water Pipe to EDG Spool SK-29636. ETE Level 7. Unit(s) 8. Quality Classification 9. FSRC Approval Req.?

D] Levell ] Levelll [] Unit1 2 Unit2 [] Unit3 3] ISFS1 IF SR R ] NS D NSQ [ Yes [Z No

110. Preparation, Review, and Approval Signatures (add or delete rows as needed)

Standard Attachments Attachment # of pages Reviewed/No Not Req.

Impact

11. Design Effects and Considerations (DNES-AA-GN-1003) Att#1 1 E li12. Document Impact Summary (DRUL) (DNES-AA-GN-1002) Att#2 1 D13. Considerations and Conditions for Document Updates (check N/A 77 if no document updates are noted on the DRUL)

D] All Document updates noted on the DRUL can be initiated immediately

D Document updates noted on the DRUL are delayed until the following documents/actions are completed:

(e.g., WO, CR etc.) (See DRUL Remarks section)

IOCFR50.59 Attachments Attachment # of pages Not Req.

14. 1OCFR50.59/72.48 applicability review forms (DNAP-3004 or CM-AA-400) Att#3 E_15. 1OCFR50.59/72.48 screen form (DNAP-3004 or CM-AA-400) __

16. 10CFR50.59/72.48 evaluation form (DNAP-3004 or CM-AA-400) __

Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PMPe Page 2 of 46

~ DominjionrEngineering Technical Evaluation

Cover Sheet

1 - I- - I 0

17. Additional AttachmentsAttachment # of pages Description

Attachment 4 - SK-2963 Flange UT 20Measurementsd

Attachment 5 - Approximated 1Degradation of Flanged

Attachment 9 - Email: Regarding 2Electrical Isolation of Flanged Joint ofSK-2963

Attachment 8 - Anticipated Corrosion 2 Add DescriptionRate Following the Installation of theInsulator Kits on SK-2963

Attachment 6 - Email Regarding 2 Add DescriptionMillstone Unit 2 SW Degdation ReliefRequest

Attachment 10 - Corrtech Data Sheet 2Indicating Electrical Isolation of theFlanged Joint of SK-2963

Attachment 7 - Diagram of Ligament 1Calculation18. DistributionPrimary Recipient(s): (Enter the Name / Dept or Location for EACH Primary Recipient in this block.)

Copy To? Other Recipient / Department or Location Copy To? Other Recipient/Department or LocationF] Preparer [ Dundon, Edward F

W Reviewer [ Fiala, Michael P

D] Supervisor Wagnecz, Laura D

F,/ Site DCE

D] Affected organization

D Program Owners

1.0 Table of Contents

N/A

2.0 Source Document

CR489553 - "Corrosion Rate for spool SK2963 outlet flange exceeds rate assumed in OD000502." dated 09/27/2012 for theUnit 2 service water 10" diameter lightweight flange attached to spool piece SK-2963 in the "B" service water supply.

CR488814 - "UT of Coated Carbon Steel Flange Adjacent 6% Molybdenum Stainless Steel indicates Damage to CarbonSteel," dated 09/20/2012 for the Unit 2 service water 10" lightweight flange attached to spool piece SK-2963 in the "B" servicewater supply.

Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 3 of 46

IEngineering Technical Evaluation

Dominion- Cover Sheet

CMA-T I0 ATTCH-N 2.ae3 f1

3.0 Record of Revision

Revision 0 - Original Revision

Revision 1 - Updated in this revision is the most current UT thickness readings and the corrosion rate of the lined carbonsteel assuming that new stud insulator kits have been installed and tested to show electrical isolation consistent with industrystandards (Assumption 2). Additionally, this revision identifies the maximum allowable corrosion rate based upon the the 30-day mission time and the upcoming Unit 2 Outage (2R21) and the entry into Mode 5.

Revision 2 - Unexpected delay of insulator kit installation resulted in more degradation than considered in Revision 1.Updated in this revision is the most current UT thickness readings after the installation of the stud insulator kits on the carbonsteel flange of pipe spool SK-2963. Operating experience from the failure of the flange on pipe spool SK-2952 from the "A"service water train that failed 1 year ago, has been incorporated.

4.0 Purpose

This revision of the ETE re-evaluates the structural integrity and the minimum required wall thickness for pressureboundary leak integrity of a degraded slip-on flange located on 10" service water supply line to "B" Emergency DieselGenerator (1 0"JGD-4 spool SK-2963). The purpose of this evaluation is to support OD000502 and demonstrate the continuedoperability (inclusive of 30-day post accident mission time per reference 12 and 13) of the MP2 B service water supplyheader. The structural integrity review considers all loading conditions (i.e. deadload, seismic and thermal).

Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 4 of 46

Engineering Technical Evaluation

Dominion- Cover Sheet

CMA-T-0 ATAHMN 2. Pae4 f1

5.0 Design Inputs and Assumptions

Design Inputs

1. Ultrasonic Testing per the AWO 53102516395 - Reference 2 (Attached).

2. Sketch of flange degradation from NDE group (calculated ligament length was verified by engineering) - Attachment 5.

Assumptions

1. It is assumed that UT is adequate for supporting the structural integrity assessment. However it is noted the UT is notcapable of identifying potential through wall flaws due to attack of the grain boundary, which may result in minor orunanticipated leakage. This assumption is covered in this evaluation as any identified pressure boundary flange leakage willmake the flange inoperable and the appropriate TRM or T/S shall be entered. These UT inspections are not considered Codecompliant inspections because of the interferences [due to bolting, flange configuration and flange surface characteristics]involved with taking the measurements. In addition these are not Code required inspections.

As a result of issues related to service water pipe degradation, mockups have been utilized at the station to validate theaccuracy of UTs for the determination of wall thickness. In addition, use of UTs to determine flaw characteristics wasdiscussed with the corporate level III inspector and he concurred that the use of UTs is valid for this application.

2. On 9/27/2012 testing of the dissimilar metal flanges on pipe spool SK-2963 identified an electrical short between theAL-6XN and lined carbon steel flange. Based on station operating experience, the methodology and material used to installthe insulating kit at this flange may not have been adequate to electrically isolate the dissimilar flanges and may haveaccelerated the galvanic corrosion identified in UT data from 9/20/2012 to 9/27/2012 at UT point 4, positions 5, 8, 9, 11 and12. Therefore, the assumed corrosion rate 0.200"/yr is used to determine the ligament length for pressure boundary integrityand the 30-day mission time is based on the installation of the new stud insulator kits which have shown to provide electricalisolation that is consistent with standard industry experience (Attachment 9 & 10).

3. Corrosion on a day-to-day basis is assumed to vary, based on uncertainty. Therefore an absolute value to reach the Unit 2Outage (2R21) is provided to elminate variance in the daily UT data.

Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 5 of 46

Engineering Technical Evaluation

Dominion- Cover Sheet

a ... I

6.0 Methodology

Because no NRC approved methodology is available to evaluate flanges, a methodology is developed here. The objective isto assess the applied piping design loads at the flange (as documented in the stress calculation of record Reference5) compared to a conservative assessment of the extent of remaining flange material (based on bounding the degradationdocumented in UT examination report Reference 2). The pressure boundary leak integrity is based on the minimum wallthickness and documented corrosion rates are calculated to demonstrate that the "B" service water system will remainoperable during a postulated 30-day mission time post accident (Section 14.8.4.3 of Reference 10 and Reference 13).

Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 6 of 46

Engineering Technical Evaluation

DOomninjio Cover Sheet

II I. * .

7.0 Discussion

CR 488814 was generated on 9/20/2012. The CR included the associated UT data (attached to the CR), which documenteda slip-on flange exhibiting degradation. The UT that was performed was not a Code required inspection. The subject flangeis located on the Millstone Unit 2 "B" service water supply train to the "B" emergency diesel generator (10"-JGD-4). Thedegraded light weight flange is lined carbon steel and is at the downstream end of spool piece SK-2963 as shown on drawing25203-20150 Sh. 472 (Ref. 3). The degradation is suspected to be the result of a failed lining and the formation of a galvaniccell.

CR489553 was generated on 9/27/2012. A week following the initial examination period of the carbon steel flange of thedissimilar metal joint on pipe spool SK-2963, this CR determined that based on UT data, the corrosion rate used in revision 0of this ETE was non-conservative. The corrosion rate used (0.067"/month) was based upon corrosion ratespreviously identified in the carbon steel side of the dissimilar metal flange joint in pipe spool SK-2952 on the "A" train(Ref. 9) and based upon industry operating experience. Consistent UT data between 9/20/2012 and 9/28/2012 indicated thatlocally a corrosion rate as high as 0.244"/month was occurring (1.900"-1.835"=0.065", 0.065/8 days = 0.0081", 0.0081"*30days/month = 0.243". Updated corrosion rates (0.200"/year) utilized in this ETE are based upon assumption 2 in Section 5.0and attachment 8.

Flange insulator kit installation for the flange on pipe spool SK-2963 began on 9/28/2012 and ended on 9/30/2012. UTreadings between the 2-day installation indicate that at UT point 4, position 9, a wastage from 1.835" to 1.826" occurredbefore the installation of the insulator kits. Further analysis is performed below to show this change in material thickness.

The flange face nominal thickness is 11/16" and the nominal flange hub thickness is 5/8" (Reference 8). The pipe stresscalculation uses an operating temperature range of 33F to 80F and the conservative pressure of 150 psig per Reference5. The system maximum operating pressure is 80 psig per reference 11. The system design pressure is 100 psig at the flawlocation per reference 11, but 150 psig was conservatively used for the pipe stress analysis qualification calculation.

Structural Integrity Assessment:

Currently there is no NRC approved methodology for ASME Code acceptance of flaws in moderate energy Class 3 flanges.ASME Code Case N-513-2 (Reference 4) provides NRC approved flaw acceptance methodology for Class 2 or 3 piping, butspecifically excludes application to a flanged joint.

Because no NRC approved methodology is available to evaluate flanges, a methodology is developed here. The objective isto assess. the applied piping design loads at the flange (as documented in the stress calculation of record, reference5) compared to a conservative assessment of the extent of remaining flange material (based on bounding the degradationdocumented in UT examination report, reference 2). A minimum allowable thickness is calculated based upon the minimumthickness needed for pressure hoop stress plus an allowance for 30 days of corrosion to demonstrate that the service waterflange will remain operable during a postulated accident and for the 30-day post accident mission time (Section 14.8.4.3 ofReference 10 and Reference 13).

Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 7 of 46

Engineering Technical Evaluation

Dominion Cover Sheet

CMA-T-0 ATAHMN 2 Page

The current piping stress analysis run of record is documented in Addendum B of Reference 5. In the piping analysiscomputer model the subject flange is located at node point 980 (shown in model worksketch sheet 3). The ASME Codeequation pipe stresses for Equation 8 (deadweight/pressure), Equation 9 (Occasional deadweight/pressure + SeismicInertia), Equation 9 Faulted (Occasional deadweight/pressure + Seismic Inertia), Equation 10 (thermal + Seismic anchormotion) and Equation 11 (Deadweight + Pressure + Thermal + Seismic anchor motion) were extracted (stress calculationAttachment B pages 16 and 59) and are shown in Table 1. Also included in Table 1 are the corresponding allowable stressesand percent ratios of the allowables. As shown in the table, the maximum stress percentage at the flange location is 8.25percent of ASME Code allowable in the non-degraded condition. This low stress condition (8.25% of allowable) providesconsiderable margin for material degradation while maintaining structural integrity. The reduced load carrying capability ofthe flange is proportional to the reduction in area. Postulating that half of the flange is fully degraded results in an increaseof 100 percent of the calculated stresses. This increase in stress will increase the percent ratio of applied to allowable stressfrom 10 percent (rounded up) to 20 percent leaving 80 percent margin for all postulated design basis events.

Table 1

Node 980 Stress (psi) Allowable (psi) Percent Ratio ofAllowable Stress after 100% Percent Ratio of

Increase (psi) Allowable

Eq 8 Sustained 1238 15000 8.25 2476 16.51(Deadweight)

Eq 9 Occasional 1436 18000 7.98 2872 15.96(Normal and Upset)

Eq 9 Occasional 1612 35000 4.61 3224 9.21(Faulted)

Eq 10 (Expansion 522 22500 2.32 1044 4.64Stress)

Eq 11 (Deadweight 1760 37500 4.69 3520 9.39+ Expansion Stress)

The UT examination reports are included in Attachment 4. As shown on pages 2 through 18 of Attachment 4, the UTmeasurements were performed at 4 points of the flange (See page 20 of Attachment 4). The drawing on page 19 ofAttachment 4 identifies the 12 positions on the flange. Positions 5, 9, 11 and 12 under UT Point 4 (in Attachment 4, page 18)show considerably lower thickness values (1.823" to 2.082) than the surrounding locations (-2.500"). UT data indicates thatposition 8/9 and 11/12 are each likely one area of degradation. This indicates that there are 3 positions on the flangecircumference that show degradation. With a total of 12 positions under UT Point 4 measured, the degradation still affects5/12ths of the circumference of the flange. To allow for potential growth of the flaws, it can be assumed that 6/12ths or half ofthe flange circumference has been lost to wastage and only half of the flange remains. Based on the extremely low loads(less than 10 percent of the respective allowables) a 50 percent loss of the flange load bearing area and structural load pathwill not challenge the structural integrity of the remaining 50 percent of the flange, as shown above.

Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 8 of 46

Engineering Technical EvaluationDominion- Cover Sheet

CM-AA-ETE-101 ATAHET2 Pg

Minimum Wall Calculation for Pressure Boundary Integrity

In order to maintain pressure retaining capability and minimize the potential for leakage, the following criteria for determiningacceptable pressure retaining capability is used. The minimum wall calculation for pressure boundary integrity is based uponthe maximum operating conditions, which is reasonable to maintain operability. However, the pressure boundary integrity forthe design pressure is calculated below for reference. Equations for the required pressure boundary integrity (leak tightness)are per ASME Section III, NC-3641.1, 1989 Edition (calculated below):

tm = P x Do / [2 x (S + Py)]

Where

P = 80 psi for the maximum operating pressure and 100 psi for the internal design pressure (Reference 11). The thicknessvalue calculated from the equation above uses the maximum operating pressure and is a reasonable value for operability,

Do = 12 in, outside diameter of pipe (in this case flange hub) (Reference 8),

S = 15000 psi at a design temperature 100F, allowable stress for ASTM A181, Grade 1 (Reference 7 and 12),

y = 0.4 a coefficient having a value of 0.4 except when Do/tm < 6 (Reference 12),

This criterion is applicable to the face of the flange and to the hub or pipe portion of the flange. Based upon an a maximumoperating pressure (80 psig) the minimum wall thickness is 0.032". For reference, the maximum wall thickness when usingthe design pressure (100 psig), is 0.040". An average wall thickness of less than 0.032 inches as determinedfrom measurements between any two bolts would not meet the minimum required wall thickness required for pressureboundary integrity (leak tightness).

Ultrasonic Testing of flange SK-2963 at Position 9 of UT Point 4 on 9/30/2012 indicated a minimum measurement of1.823" (See Attachment 4, page 18). Based on nominal flange dimensions, this measurement translates into a remainingligament length of 0.150". Subtracting 0.032" from the ligament length leaves a potential sacrificial thickness of 0.118".Maintaining 0.032" of material ensures the minimum wall thickness for pressure boundary integrity (leak tightness). Basedupon the achievement of electrical isolation per assumption 2 and the rate of degradation provided by the Millstone CorrosionAnalyst (Attachment 8), the annual corrosion rate for the flange is 0.200"/ year (0.017"/month).

Maximum Theoretical Corrosion Rate

Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 9 of 46

Engineering Technical Evaluation

Dominion- Cover Sheet

CM-A-TE10 ATAHET2 Pg Sf1

Therefore utilizing the same minimum calculated ligament of 0.150 (1.823" measurement) identified on 9/30/2012, themaximum rate that can be tolerated until mode 5 of outage 2R21 on 10/7/2012 is 1.164"/year (0.150" - 0.032" = 0.118",0.118"/(7 days + 30 days (mission time)) = 0.00319"/day or 365 days*0.00319"/day or 0.022" between now and 2R21). Thiscorrosion rate is based upon the remaining time until 2R21 and the 30 day mission time and is not expected to occur. Sincethe corrosion expands equally in all directions, the UT Point 4 measurement cannot degrade more than 0.022" between nowand 2R21 based upon the maximum allowable corrosion rate. The anticipated maximum corrosion rate is 0.200"/year perassumption 2 and Attachment 8. This is described in the section below.

Wall Thickness Margin Calculation Based on UT Readings

Based on attachment 8 and assumption 2, the anticipated maximum corrosion rate, after the insulator kits are installed, isassumed to be 0.200"/year. Analyzing the results from 9/30/2012 and incorporating the required 37 days to meet both themission time and enter the Unit 2 outage 2R21, the wastage over a 37 day period is calculated to be 0.020" using theanticpated maximum corrosion rate of 0.200"/year (0.200"/yr / 365 day/yr = 0.000548"/day, 0.000548"/day *37 Days =0.020"). The current UT Point 4 measurement extrapolated out to Mode 5 of 2R21 (10/7/2012) plus the 30 day mission time,.based on the anticipated corrosion rate of 0.200"/year, is 1.803" (1.823" - 0.020" = 1.803").

Because of the conservative requirements of this analysis, the calculated minimum wall thickness required for operabilityremain less than what was measured at the failed flaw of the "A" train 1 year ago (1.750"). For the current flaw at UT Point 4,position 9, the anticipated measurement should be 1.801" after 37 days of operation.

Operating Experience

Ultrasonic testing was performed on the pipe spool (SK-2952) flange that was removed from the "A" service water supplytrain approximately 1 year ago. Testing from that flange at UT Point 4 indicated a remaining wall thickness of approximately1.750" around the flaw. Based on the measurement performed on the "A" train flange, UT Point 4 measurements at which theflange is considered inoperable for pipe spool SK-2963, are more conservative (1.801").

8.0 Conclusions

This ETE concludes that the structural integrity and the minimum required wall thickness for pressure boundary leak integrityof a degraded slip-on flange located on 10" service water supply line to "B" Emergency Diesel Generator (1 0"JGD-4 spoolSK-2963) is sufficient to support OD000502 and demonstrate the continued operability (inclusive of 30-day accident perreference 12 and 13) of the MP2 B service water supply header. This structural integrity review considers all loadingconditions (i.e. deadload, seismic and thermal).

Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 10 of 46

k Engineering Technical EvaluationDominion- Cover Sheet.

1 ...I I .

9.0 Precautions or Limitations

The type and frequency of the inspections (including UT) shall be performed lAW the requirements of OD000502.

10.0 Required Actions

1. As of 9/30/2012, UT analysis indicates that degradation exists between 5 of the 12 areas between the bolt holes(positions). The degradation is noted at position 5, 8, 9, 11 and 12. Further identification from these areas of degradation hasnoted that position 8/9 and 11/12 appear to each be one area of degradation under the adjoining bolt hole. Therefore threetotal areas of degradation are seen. Of the five positions, on 9/30/2012 position 8 and 9 at UT point 4 indicate a thickness of1.823" while position 11 and 12 indicate a thickness of 1.914" and 1.932", respectively. Position 5 has minimum thickness of2.082".

Based on the analysis provided, if more than 6 zones are identified with measurements less than 1.900", then the "B" servicewater system shall be declared inoperable and the appropriate TRM or T/S shall be entered. (Implemented by OD000502,Rev 1.)

2. If at any time a ligament less than 0.128" corresponding to a UT Point 4 measurement reading of 1.801" or less isidentified, the service water flange shall be declared inoperable and the appropriate TRM or T/S shall be entered. Theligament value is based on standard flange dimensions, the use of the Pythagorean Theorem and the UT Point 4measurements. The value of 1.801" represent the one week limit of corrosion on the flanged joint. This limit assumes thatuncertainty in the data will vary from day-to-day and is provided as an absolute value to which the flange is consideredoperable (Implemented by OD000502, Rev. 1).

3. If any through wall leakage at the service water flange is identified, it shall be declared inoperable and the appropriate TRMor T/S shall be entered. (Implemented by OD000502, Rev. 1).

4. A relief request shall be submitted to the NRC. See Attachment 6 (Implemented by CR488814).

11.0 Recommendations

N/A

Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 11 of 46

IEngineering Technical Evaluation

Dominion- Cover Sheet

I ..- I

12.0 References

1. CR488814 - "UT of Coated Carbon Steel Flange Adjacent 6% Molybdenum Stainless Steel indicates Damage to CarbonSteel"

2. AWO 53102516395 UT Examination Report - See Attachment 4. Note that there are two sets of data. Those performed on9/20/2012 entered in UT Point 1, 3 and 4 while those performed on 9/21/2012 entered in UT Point 2. These two data sets arecomplimentary.

3. Drawing 25203-20150 SH. 472, Rev 11 "Millstone Nuclear Power Station - Unit 2 "B" Train Service Water Supply to DieselEngine Coolers".

4. ASME Code Case N-513-2 "Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3Piping Section X1, Division 1.

5. Calculation MP58B-00138EM Revision 4, Addendum B "Service Water Supply to Diesel Engine Coolers - Stress Problem118".

6. Drawing 25203-20224 SH. 60, Rev 3 "Millstone Nuclear Power Station - Unit 2 "B" Train Service Water Supply to Diesel

Engine Coolers".

7. Drawing 25203-22200 SH 327141 Rev 4 "Service Water Supply to Diesel Engine Coolers Mark No 327141".

8. Crane Catalog 61, "Welded Fittings, Forged Flanges."

9. Engineering Technical Evaluation ETE-MP-2011-1143, Rev. 0, " Design Criteria for material selection of stainless steel* and nickel based alloys for seawater service applications at Millstone Station (Revision to ETE-MP-2010-1014 rev. 1)."

10. Unit 2 Final Safety Analysis Report, Revision 29.2.

11. Bechtel Piping Spec 7604-MS-1, Piping Class Summary.

12. American National Standard Institute Code for Pressure Piping, ANSI B31.1, 1967 Edition; All applicable addenda up toand including Summer 1973.

Sep 30, 2012 7:40 PM

DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 12 of 46

Engineering Technical Evaluation

Dominion Cover Sheet

I n ..- I

13. Design Change M2-05009, Rev. 1, "Replacement of ECCS Sump Strainer per Generic Letter 2004-02, GSI-191."

13.0 Attachments

Attachment 1 - Design Effects Table (DET)

Attachment 2 - Documents Required to be Updated List (DRUL)

Attachment 3 - Applicability Review

Attachment 4 - SK-2963 Flange UT Measurements

Attachment 5 - Approximated Degradation of Flange

Attachment 6 - Email Regarding Millstone Unit 2 SW Degradation Relief Request

Attachment 7 - Diagram of Ligament Calculation

Attachment 8 - Anticipated Corrosion Rate Following the Installation of Stud Insulator Kit on SK-2963

Attachment 9 - Email: Regarding Electrical Isolation of Flanged Joint of SKr2963

Attachment 10 - Corrtech Data Sheet Indicating Electrical Isolation of the Flanged Joint of SK-2963

Sep 30, 2012 7:40 PM

Attachment #1 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PMPe Page 13 of 46

.J0 D1omi FonDesign Effects Table

DNSA-N10 age 1. of

Instructions:This table will identify impacted programs. If a question is answered yes, the responsible engineer shall address and document inthe discussion section of the Design Change. The responsible engineer shall check "No Impact" or "Impact" as appropriate. Ifnecessary, consult the program owner to assist with the determination. If it is determined that there is an impact, identify programowner, check "Impact" in the applicable section, obtain the consulted individual(s) signature on the engineering product coversheet and document the discussion in the change package. If an impact is determined for any program, then relevant portions ofthis attachment should be attached to the appropriate document. If it is determined that there is "No Impact" in a section where aquestion is answered "Yes", document the basis for this determination in the change package. When all questions are answered"No" in a particular section, do not check "Impact" or "No Impact."

Station: Unit: ETE Document Number:" KPS 10 MPS c CO 0 1 02 2 ETE-CME-2012-1024" NAPS 0 SPS 03 0 ISFSI

Change Document Title: Structural Integrity Evaluation of Degraded Flange in "B" Service Water Pipe to EDG Spool SK-2963

1.1 Fire Protection Equipment or Features El Yes 01 No

1.2 Combustible Loading El Yes 2 No

1.3 Hazards and Ignition Sources E0 Yes 0 No

1.4 Fire Safe-Shutdown Analysis El Yes 10 No

2.0 Environmental Qualification (EQ) El Yes 0 No

3.0 ASME Codes / ISI / IST El Yes 10 No

3.1 Inservice Inspection El Yes 0 No

3.2 Inservice Testing El Yes 0 No

4.0 Regulatory Guide 1.97 - Post Accident Monitoring El Yes 02 No

5.0 Maintenance Rule El Yes 0 No

6.0 Radiological Protection Program (ALARA) El Yes 0 No

7.0 Environmental Impact (Non-Radiological) El Yes 0 No

8.0 Nuclear Material Control El Yes 10 No

9.0 License Renewal Rule Program and Aging El Yes 01 No

Management Activities

10.0 Generic Letter (GL) 89-13 Program 0. Yes 01 No

11.0 Station Blackout (SBO) El Yes 01 No

12.0 Appendix J Program 0 Yes 0 No

13.0 NERC - North American Electric Reliability El Yes 01 NoCouncil

14.0 GSI-191 (Containment Recirculation Sump) El Yes 01 No

Considerations

Attachment #2 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 14 of 46

Documents Required To Be Updated List (DRUL)

SDominion ,E-AG1 002 A H 21 Pg 1

STATION UNIT I ETE Document NumberC KPS 0 MPS 0 NAPS 0 SPS C CO C 1 02 0 3 CISFS1 ETE-CME-2012-1024

Operations Critical Documents Needed N/A

Department I Contact Impacted Document Number and/or Title

Closeout Documents Needed N/A

Department / Contact Impacted Document Number and/or Title

Remarks (Attach additional pages if needed):

Attachment #3 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 15 of 46

50.59 / 72.48 Applicability Review

Applicable Station Applicable Unit(s) ISFSI Parent Document/Revision

r7 North Anna Power Station r- Unit 1 r- Unit 2 r-. ISFSI ETE-CME-2012-1024 Rev. 2

Ir Surry Power Station r.: Unit 1 FI Unit 2 fr ISFSI

F Millstone Power Station I Unit 1 F Unit 2 r- Unit 3 r- ISFSI

IT Kewaunee Power Station IT Unit 1 IT ISFSI

Part I. Brief Description of Activity Being Reviewed (See Attachment 2, Part I)

Structural integrity determination and flow loss evaluation of degraded service water flange on "B" serivce water supply to EDG service waterheader (spool SK-2963)Part II. Activity Previously Reviewed (See Attachment 2, Part II)Is this activity Fully bounded by one or more of the following?

1. Fullt bounded by a IT YES F NO r- Attached (optional) - If YES, identify bounding source documentcompleted 50.59/72.48Screen or Evaluation?

2. fuliyt bounded by a station I- YES 7 NO IT- Attached (optional) - If YES, identify bounding source documentactivity that has alreadyreceived NRC approval?

PART II. CONCLUSION

F Both of the above review questions are answered NO, continue the Applicability Review

f7 One of the above review questions is answered YES, a 50.59/72.48 Screen is NOT required; complete Parts V, VI, VII

Part III. Controlled by Other Regulatory Change Control Process (See Attachment 2, Part III)Check if any of the following documents are identified as part of the proposed activity.NOTE: For example, when a design change is the proposed activity, consequential actions may include changes to one of thesedocuments which have a different change control process and are NQT to be included in this 10 CFR 50.59/72.48 review.

1 Technical Specifications or Operating License

2 Emergency Plan rF

3 Security Plan FT

4 Fire Protection Program and is NOT associated with ISFSI 17

5 Quality Assurance Program Description FT

6 Inservice Test Plan - IST F

7 Inservice Inspection Plan - ISI F

8 ECCS Analysis

9 Environmental Protection Plan r

10 Radiation Protection Program

11 Radiological Environmental Monitoring and Offsite Dose Calculations Manual IT

12 Reactor Vessel Surveillance Withdrawal Schedule FI

PART III. CONCLUSIONF If there are no documents selected, continue the Applicability Review.

r. One or more of the documents listed above are selected, ANM the proposed activity is limited to changing thosedocuments, a 50.59/72.48 Screen is NOT required; complete Parts V, VI, VII.

fT One or more of the documents are selected, however, some portion of the activity involves facility or procedure changes;continue the Applicability Review for that portion.

Part IV.1 General Pre-Screen for Maintenance - Not Applicable to ISFSI (See Attachment 2, Part IVA)1. Is this a maintenance activity limited to restoring an SSC to the normal as designed condition AND r- YES rv NO

does NOT permanently alter the design, performance requirements, operation or control of SSCs?

2. Is the activity limited to installing or testing approved facility changes? F- YES r7 NO

Part IV.1 CONCLUSION[F Both of the above review questions are answered NO, all or some portion of the activity extends beyond maintenance;

continue the Applicability Review for non-maintenance activities.

r- One of the above review questions is answered YES, the activity is subject to review per the Maintenance Rule; a10 CFR 50.59/72.48 Screen is NOT required; complete Parts V, VI, VII.

Attachment #3 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 16 of 46

50.59 / 72.48 Applicability Review5100 miniendi" CMAA40 -Atahet1 .g~f

Part IV.2. General Pre-Screen (See Attachment 2, Part IV.2)Does this activity accomplish any of the following?

1 Does this activity involve any changes to the ISFSI written evaluations required by 10CFR72.212? F_ YES 17 NO

2 Does this activity involve fire protection activities associated with the ISFSI? - YES F NO

3 Does this activity involve maintenance activities on the ISFSI? r YES 7 NO

4 Does this activity alter (temporarily or permanently) the design of an SSC through a modification or f YES P NOaddition to, or removal from the facility as described in the SAR?

5 Does this activity alter (temporarily or permanently) the function, ability to function, or method of r7 YES F NOperforming a function of an SSC as described in the SAR?

6 Does this activity modify how SSCs are operated or controlled as described, outlined, or summarized r YES F NOin the SAR?

7 Does this activity change a numeric value of a design or performance requirement of a SAR F YES F NOdescribed SSC to a value that has NOT been previously reviewed in accordance with10CFR50.59/72.48?

8 Does this activity perform a test or experiment that is NOT described in the SAR? F YES [. NO

9 Does this activity involve a change to a method of evaluation used for evaluating behavior or F YES F NOresponse of the facility or an SSC described in the SAR?

10 Does this activity involve a temporary modification? r YES F NO

PART IV.2 CONCLUSION

1 All Pre-Screen questions are answered NO, a 50.59/72.48 Screen is NOT required; complete Parts V, VI, VII

F One or more Pre-Screen questions are answered YES, perform a 50.59/72.48 Screen per Attachment 3 and completeParts V, VI, VII.

Part V. Safety Analysis Report Interface (See Attachment 2, Part V)

Does this activity require revising the Safety Analysis Report? If YES, initiate a Change Request inaccordance with CM-AA-SAR-101 and include the Change Request number

If YES, additional review required by 50.59/72.48 Screen Preparer/Reviewer if Applicability Review F YES F NO

Preparer and Co-signer (when required) are NOT 59.59/72.48 Screen qualified.Part VI. Comments (use supplemental pages as needed)

(Examples: Identify any 50.59/72.48 Screen or Evaluation, or NRC approved activity that contributes to this review, identifyparts of the activity that are bounded or not bounded by a previously completed review or that are NOT part of anotherchange process, identify the source document supporting a numeric value previously reviewed per 10 CFR 50.59/72.48)

This ETE performs a technical evaluation of a non-code compliant degraded piping component in support of an Operability Determination.Question 4 of Section IV.2 would be answered yes as the flange is not in its original configuration per ASME B16.1/16.5 due to the effects ofcorrosion. However, due to program limitations, Question 4 has been selected as no. The 50.59 review process is being exited as a reliefrequest will be submitted to the NRC for review per attachment 6.

Part VII. Signature

Preparer Name (Print) Preparer Signature DateDigitally Signed by Zachary A Withrow 09/21/2012

09:46:59 PM

Form No. 729534 (Jun 2010)

DRAFT ETE-CME-20 1 2 -1024 Report Generated on 9/30/2012 7:40:57 PM

Page 17 of 46

Exam Data Sheet Attachment 4 - Page I of

Millstone Power Station ULTRASONIC EXAMINATION

STRAIGHT BEAM MEASUREMENTSPlant Millstone Unit 2 Page I of 2

System & Zone No. "B" Train Service Water /3326 Exam Data Sheet No N/A

Component ID SK-29 63 AWO Number 53102516395

Component Des o ool SK-2963 DrawingNo2.2963

Examination Purpose Engineerin Information Line No. l0"-JGD-4

Instrument & Settings Calibration Block(s) Component DataManufacturer Olympus Type Serial No. Material Component T.o, N/AModel No, 38 DL Plus Step Wedge 95-5768 C/S Component Dia. 10" .

Serial No. 100030807 Step Wedge 99-6791 C/S Attachments. yesRange 3,0"Velocity .2326 Calibration Checks Block Thickness Instrument Reading

Delay N/A Type Time Min. Max. Min. Max.Zero Value 26570 Initial 13:50 .250" 1.00" .250" 3,00"Cal Tolerance 1.002" 'Intermediate N/A N/A N/A N/A N/A

Intermediate N/A N/A N/A N/A N/A

Search Unit Data Final 14:15 0 1.00" .250" 3.00"

Manufacturer PanametricsType No. D791-RM Couplant Data Temperature Data

Serial No. 109450 Brand Ultraget I1 Cal. Block Temp. N/AFrequeney 5.0 MHz Batch No. 11225 G Component Temp. N/ASize 0.2" SAP Batch Mgmt. No. N/A Thermometer No. N/A

See Attachment for Detailed Examination Results

Examiner (print & sign) Todd Bohnenkamncr / - Level 1I Date 09/19/20.12

Reviewer (sign) Reuied(Level.) N.Date Date N/A

ANI/ANII If Required (Sign) N/A -Date N/A

20

'el of Use"•ren ]ce

;$& ~ A ER-AA-NDEI-UT-701

Attachmnent #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 18 of 46

Attachment 4 - Page 2 of 20

Page 2 of 2Millstone Unit 2

Service Water System "B" Trin

Component lDit-2963 0( ilange on

WO #: 53102516395

spool SK-2963)

Position UT Point I UT Point 2 UT Point 3 UT Point 4

1 0.405 N/A 0.816 2.520

2 0.388 N/A 0.822 2.520

3 0.380 N/A 0.816 2.520

4 0.389 N/A 0.823 2.500

5 0.399 N/A 0.810 2.100

6 0.405 N/A 0.808 2.530

7 0.411 N/A 0.803 2.530

8 0.414 N/A 0.809 2.180

9 0.409 N/A 0.812 1.900

10 0.415 N/A 0.826 1.910

11 0.410 N/A 0.822 .530

12 0.387 N/A 0.824 1.900

Comments: Position 1 at elbow extradose. All positions run in clockwise direction wit,-,Note: UT readings obtained on painted surface which could result in diffic' Illegible note

indicates thatobtaining UT data at sorne locations. No UT readings at point 2. Rough wel Position 10 and 11surface does not provide for consistent UT p~oin• should be

switched.

-7

1<

P)NY2(htCn

r~)zu O)PEU

tb qOY1.7

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 19 of 46

Attachment 4 - Page 3 of 20

Millstone Unit 2

Service Water System

Component ID: SK-2963

WO #: 53102516395

Page 2 of 2

(Outlet flange on spool SK-2963)

Position UT Point I UT Point 2 UT Point 3 UT Point 4

1 N/A 0.541 N/A N/A

2 N/A 0.535 N/A N/A

3 N/A 0.574 N/A N/A

4 N/A 0.549 N/A N/A

5 N/A 0.549 N/A N/A

6 N/A 0.555 N/A N/A

7 N/A 0.543 N/A N/A

8 N/A 0.539 N/A N/A

9 N/A 0.513 N/A N/A

10 N/A 0.526 N/A N/A

11 N/A 0.518 N/A N/A

12 N/A 0.487 N/A N/A

Comments: Position 1 at elbow extradose. All positions run in clockwise direction withflow. Note: UT readinqs obtained on painted surface which could result indifficulty in obtaining UT data at some locations. Readings at UT point 2obtained on irreaular or uneven surfaces due to weld configuration and maynot provide for consistent repeatability of UT readings.

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 20 of 46

Attachment 4 - Page 4 of 20

Millstone Unit 2 Page 3 of 3

Service Water SystemComponent ID: SK-2963 (Outlet flange on spool SK-2963)WO #: 53102516395

Position UT Point 1 UT Point 2 UT Point 3 UT Point 4

1 N/A N/A N/A N/A

2 N/A N/A N/A N/A

3 N/A N/A N/A N/A

4 N/A N/A N/A N/A

5 0.396 0.549 0.806 2.130

6 NIA N/A N/A NIA

7 N/A N/A N/A N/A

8 0.414 0.539 0.809 2.180

9 0.410 0.512 0.819 1.890

10 0.414 0.526 0.828 :1.950

11 N/A N/A N/A

12 0.382 0.486 0.817 1.970

IComments:

ons.

-C-Di 9 / a-I/ 1 Z,

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PMPage 21 of 46

Attachment 4 - Page 5 of 20

Page 3 of 3Millstone Unit 2Service Water System

Component ID:SK-2963 Outlet flange

WO #: 53102516395Position UT Point 1 UT Point 2 UT Point 3 UT Point 4

1 .395" .536" .815" 2.548"

2 .380" .531" .812" 2.575"

3 .373" .574" .813" 2.565"

4 .388" .546" .819" 2.560"

5 .402" .544" .807" 2.130"

6 .393" .551" .802" 2.574"

7 .411" .538" .804" 2.565"

8 .413" .540" .809" 2.182"

9 .412" .515" .819" 1.865"

10 .416" .524" .830" 2.585"

11 .400" .509" .822" 1.933"

12 .381" .489" .818" 1.975"

Comments: UT data taken daily in SUDoort of OD 000502.

M C 3 9/ a.I/k-2-

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 22 of 46

Attachment 4 - Page 6 of 20

Millstone Unit 2Service Water SystemComponent ID: SK-2963 tkut-fl-bTWO #: 53102516395 /09/24/2012 J

Page 3 of 3

spool SK-2963)

Position UT PointK UT Pnf i 2 UT Point 3 UT Point 4

1 0.399 0.538 0.815 2.531

2 0.388 0.531 0.815 2.550

3 0.378 0.574 0.814 2.564

4 0.388 0.545 0.821 2.560

5 0.399 0.545 0.808 2.137

6 0.398 0.552 0.805 2.569.7 0.412 0.541 0.804 2.559

8 0.413 0.539 0.808 2.181

9 0.410 0.514 0.815 1.869

10 0.415 0.525 0.826 2.580

11 0.405 0.512 0.823 1.938

12 0.384 0.486 0.820 1.972

Comments: Position 1 at elbow extradose. Note: UT readinqs obtained on paintedsurface which could result in difficulty in obtaining UT data at some locations.

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 23 of 46

Attachment 4 - Page 7 of 20

Millstone Unit 2 Page 3 of 3

Service Water System

Component ID: SK-2 n96 0 te i nspool SK-2963)

WO#: 5310251639r5 09/25/2012__Position UT PoiotI _.. oint 2 UT Point 3 UT Point 4

1 0.399 0.541 0.815 2.550

2 0.388 0.531 0.814 2.560

3 0.380 0.570 0.814 2.564

4 0.388 0.545 0.821 2.5605 0.399 0.545 0.810 2.128

6 0.398 0.550 0.805 2.569

7 0.412 0.541 0.806 2.559

8 0.412 0.541 0.808 2.177

9 0.412 0,514 0.816 1.848

10 0.415 0.525 0.826 2.580

11 0.405 0.510 0.823 1.938

12 0.389 0.486 0.819 1.968

Comments: Position 1 at elbow extradose. Note: UT readings obtained on paintedsurface which could result in difficulty in obtaininci UT data at some locations.

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 24 of 46

Attachment 4 - Page 8 of 20

Millstone Unit 2

Service Water SystemComponent ID:SK-2963 Outlet flange

WO 1*: 53102516395

Page 3 of 3

Position UT Point 1 UT Point 2 UT Point 3 UT Point 4

1 .393" .536" .817" 2.555"

2 .378" .531" .814" 2.578"

3 .376" .569" .816" 2.570"

4 .393" .544" .820" 2.574"

5 .402" .543" .805" 2.132"

6 .393" .545" .810" 2.578"

7 .405" .548" .810" 2.568"

8 .415" .540" .811" 2.177"

9 .411" .516" .819" 1.855"

10 .415" .528" .826" 2.580"

11 .402" .513" .822" 1.942"

12 .385" .478". .819" 1.965"

Comments: UT data taken daily in support of OD 000502.

Attachment #-4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 25 of 46

Attachment 4 - Page 9 of 20

Page 3 of 3Millstone Unit 2

Service Water System

Component ID: SK-2.9.3TuitTeTf Ifae on

WO #: 531025163 ,5 09/27/20

spool SK-2963)

Position UT Po'Itt__. -- UT Point 2 UT Point 3 UT Point 4

1 0.399 0.541 0.815 2.550

2 0.388 0.531 0.814 2.555

3 0.379 0.570 0.814 2.564

4 0.388 0.545 0.821 2.560

5 0.399 0.545 0.810 2.120

6 0.398 0.550 0.805 2.569

7 0.412 0.541 0.806 2.559

8 0.412 0.541 0.808 2.177

9 0.412 0.514 0.816 1.840

10 0.415 0.525 0.826 2.580

11 0.405 0.505 0.823 1.932

12 0.389 0.486 0.819 1.962

Comments: Position I at elbow extradose. Note: UT readings obtained on paintedsurface which could result in difficulty in obtaininq UT data at some locations.

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 26 of 46

Attachment 4 - Page 10 of 20

Millstone Unit 2

Service Water System

Component ID: SK-29633 on

WO #: 53102516395 "009/28/2012

Page 3 of 3

spool SK-2963)

Position UT Poi t 1 UT2if• 2 UT Point 3 UT Point 4

1 0.399 -- 0.541 0.815 2.550.

2 0.388 0.531 0.814 2.555

3 0.379 0.570 0.814 2.569

4 0.388 0.545 0.821 2.565

5 0.399 0.545 0.810 2.115

6 0.398 0.550 0.805 2.5697 0.412 0.541 0.806 2.559

8 0.412 0.541 0.808 2.1779 0.412 0.514 0.816 1.83510 0.415 0.525 0.826 2.58011 0.405 0.505 0.823 1.93212 0.389 0.486 0.819 1.962

Comments: Position I at elbow extradose. Note: UT readings obtained on paintedsurface which could result in difficulty in obtaining UT data at some locations.

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 27 of 46

Attachment 4 - Page 11 of 20

Attachment I Exam Data Sheet

Millstone Power Station ULTRASONIC EXAMINALION

STRAIGHT BEAM MEASUREMENTS

Plant Millstone _______Unit 2 Page 1 of 3

System & Zone No. "B" Train Setvice Water Exam Data Sheet No. N/A

Component ID- SK-2963 AWO Number 53102516395

Component Description OutletFlange - Drawing No. 25203-20194 Sh. 2963

Examination Purpose _Dailv Monitorintt Line No. l0"-JGD-4 ------- _-

Instrument & Settings Calibration Block(s) Component Data

Manufacturer KB Type Serial No. Material Cmponent Tnom N/A ]Model No. USN 521. Step Blk. 95-5768 CS Component Dia. 10" i

Serial No. OOCLXR N/A N/A N/A Attachments. N/A JRange 1.0"1

Velocity 2347 Calibration Checks Block Thickness InstrumentReading

Delay -. 203 Type Time Min. Max. Min. Max..

Zero Value 4.443 Initial 0735 .250" 1.000" .250" 1.000"

Cal Tolerance +/- .002 Intermediate N/A N/A N/A N/A N/A

Intennediate N/A N/A N/A N/A N/A

Search Unit Data Final 0800 .250" 1.000" .250" 1.000"

Manufacturer KBA

Type No. Gamma Couplant Data Temperature Data

Serial No. 01WNDF Brand N/A Cal. B1k. Temp. N/A

Frequency 5 MI-tZ Batch No. 11225 G Component Temp/ N/A

Size .25" SAP Batch Mgmt. No. N/A Thermometer S/N N/A

Sketch/Comments Area - Attach Photo(s) of Relevant Conditions Separately

Calibration sheet for SK-2963 outlet flange.

Calibration for UT points 1, 2 & 3.

See attached for UT examination results.

Examiner (print & sign) Michael Brehlr/ -_Level II Date 09/29/12

Reviewer (sign) L) Level - Date 9/3o/l2

ANIJANII If Required (Sign) N/A Date N/A

Level of Use

Reference

Ma s at pw-VT . 4ZQ;F A

A.,

J4 4~ ~ 11

ER-AA-NDE-UT-701-NPQRRev. 6

Attachment #.4. DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 28 of 46

Attachment 4 - Page 10 of 20

Attachment I Exam Data Sheet

Millstone Power Station ULTRASONIC EXAMINATION

STRAIGHT BEAM MEASUREMENTS

Plant Millstone Unit 2 Page 2 _.__ of 3

System & Zone No. "B" Train Service Water Exam Data Sheet No. N/A

Component ID SK-2963 AWO Number ... 53 102516395

Component Description Outlet Flangq ..e. DrawingNo. 25203-20194 Sh. 2963

Examination Purpose Da4ilyMonitoring Line No. l0"-JGD-4

Instrument & Settings Calibration Block(s) Component Data

Manufacturer KB Type Serial No. Material Component T... N/A

Model No. USN 52L Step Blk. 99-6791 CS ComponentDia. '10',.Serial No. 0OCLXR N/A N/A N/A Attachments. N/A

Range 5.0"

Velocity 2329 Calibration Checks Block Thickness Instrument Reading

Delay -. 375 Type Time Min. Max. Min. Max.

Zero Value 9.873 Initial 0805 1.000" 4.000" 1.000" 4.000"

Cal Tolerance +/- .002 Intermediate N/A N/A N/A N/A N/A

Intermediate N/A N/A N/A N/A N/A

Search Unit Data Final 0820 1.000" 4.000" 1.000" 4.000"

Manufacturer KBA

Type No. MSEB5 Conplant Data Temperature Data

Serial No. 57464-1411 Brand N/A Cal. Blk. Temp. N/A

Frequency 5 MHZ Batch No. 11225 G Component Temp N/A

Size .315" SAP Batch Mgmt. No. N/A Thermometer S/N N/A

Sketch/Comments Area - Attach Photo(s) of Relevant Conditions Separately

Calibration sheet for SK-2963 outlet flange.

Calibration for UT point 4

See attached for UT examination results.

Examiner (print & sign) Michael Brehler/ _ - Level I1 Date 09/29/12

Reviewer (sign) . "-" _ __ __ __Levcl D1_ _ Date _____

ANI/ANII If Required (Sign) N/A Date N/A

Level of Use

Reference

a a ER-AA-NDE-UT-701 -NPQRRev. 6

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 29 of 46

Attachment 4 - Page 13 of 20

Page 3 of 3Millstone Unit 2

Service Water System

Component ID:SK-2963 Outlet flange

WO #: 53102516395

09/29/12Position UT Point 1 UT Point 2 UT Point 3 UT Point 4

1 .393" .526" .818" 2.550"

2 .376" .533" .811" 2.565"

3 .370" .559" .811" 2.567"

4 .387" .544" .818" 2.565"

5 .399" .543" .805" 2.105"

6 .397" .549" .807" 2.570"

7 .411" .540" .805" 2.563"

8 .411" .540" .809" 2.175"

9 .412" .513" .817" 1.835"

10 .412" .524" .826" 2.580"

11 .402" .500" .822" 1.928"

12 .389" .488" .819" 1.962"

Comments: UT data taken daily in support of 0D 000502.

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 30 of 46

Attachment 1 Exam Data Sheet

Attachment 4 - Page 14 of 20

-Order based oncalibration time forreadings from 9/29

AMINATION to 9/30 in the

W MEASTIRE NENTS fol11wing `ages IMillstone Power Station ULTRASONIC EX

STRAIGHT BEA1'

Plant Millstone Unit 2 Page .of j_ /

System & Zone No. "B" Train Service Water Exam Data Sheet No. N/A

Component 1D SK-2963_ AWO Number 531025163957/__

Component Description Outlet Flange Drawing No. 25203-20194 S . 2963 ------

Examination Purpose DailyMnitoring Line No. 10"-JGD-4 _

Instrument & Settings Calibration Block(s) / Component Data

Manufacturer KB Type Serial No. V Material Component Tnom N/A

Model No. USN 52L Step Blk. 99-6791 CS Component Dia. 10",

Serial No. OOCLXR N/A N/A N/A Attachments. N/A

Range 5.0"

Velocity 2329 Calibration Checks Block Thickness Instrument Reading

Delay -. 375 Type ie Min. Max. Min. Max.

Zero Value 9.873 Initial 0930 1.000" 4.000" 1.000" 4.000"

Cal Tolerance +/- .002 Istermediate N/A N/A N/A N/A N/A

Intermediate N/A N/A N/A N/A N/A

Search Unit Data Final 1000 1.000" 4.000" 1.000" 4.000"

Manufacturer KBA

Type No. MSEB5 CouplantData Temperature•Data

Serial No. 57464-1411 Brand N/A Cal. BIk. Temp. N/A

Frequency 5 MHZ Batch No. 11225 G Component Temp N/A

Size .315" SAP Batch Mgmt. No. N/A Thermometer S/N N/A

Sketch/Comments Area -Attach Photo(s) of Relevant Conditions Separately

Calibration sheet for SK-2963 outlet flange. UT point 4 only, at position #5, #9, #11 and #12. These

locations had paint removed.

The following data recorded UT point 4:

Location 5 = 2.083"

Location 9 =1.835"

Location 11=1.915"

Location 12=1.933"

Examiner (print & sign) Michael Brehlor/ Level II Date 09/29/12

Reviewer (sign) RqrLevel SgDate N/Aate N/

IANI/ANII If Required (Sign) N/A Date N/A

Level of Use

ReferenceIQ ER-AA-NDE-UT-701-NPQR

Rev. 6

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 31 of 46

Attachment 4 - Page 15 of 20

Attachment I Exam Data Sheet

Millstone Power Station ULTRASONIC EXAMINATION

STRAIGHT BEAM MEASUREMENTS

Plant Millstone Unit 2 Page 1 of _ 1

System & Zone No. "B" Train Service Water Exam Data Sheet No. N/A

Component ID SK-2963 __ AWO Number 53102516395

Component Description Outlet Flange Drawing No. 25203-20194 Sh, 2963

Examination Purpose Daily Monitoring Line No. l0"-JGD-4 -------

Instrument & Settings Calibration Block(s) Component Data

Manufacturer KB Type Serial No. Material Component T,,, N/A

Model No. USN 52L Step Blk. 99-6791 CS Component Dia. 10"1

Serial No. OOCLXR N/A N/A N/A Attachments. N/A

Range 5.0"

Velocity 2329 Calibration Cheeks Block Thickness Instrument Reading

Delay -. 375 Type Time Min. Max. Min. Max.

Zero Value 9.873 Initial 1845 1.000" 4.000" 1.000" 4.000"

Cal Tolerance +/- .002 Intermediate N/A N/A N/A N/A N/A

Intermediate N/A N/A N/A N/A N/A

Search Unit Data Final 1915 1.000" 4.000" 1.000" 4.000"

Manufacturer KBA

Type No. MSEB5 Couplant Data Temperature Data

Serial No. 57464-1411 Brand N/A Cal. Blk. Temp.I N/A

Frequency 5 MHZ Batch No. 11225 G Component Temp N/A

Size .315" SAP Batch Mgmt. No. N/A Thermometer S/N N/A

Sketch/Comments Area -Attach Photo(s) of Relevant Conditions Separately,

Calibration sheet for SK-2963 outlet flange. UT point 4 only, at position #5, #9, #11 and #12. Theselocations had paint removed.

The following data recorded UT point 4:

Location 5 = 2.084"

Location 9 =1.826"

Location 11=1.913"

Location 12=1.934"

Examiner (print & sign) Michael Brehler/ 2'C4/ • -Level II Date 09/29/12

Reviewer (sign) Level Date

ANI/ANII If Required (Sign) N/A Date N/A

WI. ALevel of Use 6 _, A ET

Reference ' "fi•PP'Rev. 6

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 32 of 46

Attachment 4 - Page 16 of 20

Exam Data Sheet

Millstone Power Station ULTRASONIC EXAMINATION

STRAIGHT BEAM MEASUREMENTSPlant Millstone Unit 2 Page .Lof J_

System & Zone No. "B" Train Service Water / 3326 Exam Data Sheet No N/A

Component ID SK-2963 AWO Number 53102516395

Component Description Sp.q SK-2963 Outlet Flange Drawing No. 25203.20150 S- 471

Examination Purpose Engineering Information Line No. 10"-JGD-4

Instrument & Settings Calibration Block(s) Component Data

Manufacturer Krautkramer Type Serial No. j Material Component T.,.. N/A

Model No. USN 52L Step Wedge 95-5768 C/S Component Dia. 10"

Serial No. 00CLY5 Step Wedge 99-6791 C/S Attachments. yes

Range 5.0"

Velocity .2331 Calibration Checks Block Thickness Instrument Reading.

Delay .250 Type Time Min. Max. Min. Max.

Zero Value 3.910 Initial 00:10 .250" 4.00" .250" 4.00"

Cal Tolerance 1.002" Intermediate N/A N/A N/A N/A N/A

Intermediate N/A N/A N/A N/A N/A

Search Unit Data Final 00:30 .2 50" 4.00" .250" 4.00"

Manufacturer KBA

Type No. MSEB5 Couplant Data Temperature Data

Serial No. 57464-1408 Brand Ultragel II Cal. Block 'emp. N/A

Frequency 5.0 MHz Batch No. 11225 G Component Temp. N/A

Size 8/2 mm SAP Batch Mgmt. No. N/A Thermometer No. N/A

Examination perfoirned at UT Point 4 only at positions 5, 9, 11, & 12.

Data recorded as follows:

Location 5 - 2.084"

Location 9 - 1.823"

Location 11 - 1.914"

Location 12 - 1.934"

Examiner (print & sign) Todd "ohnenkamer Level II Date 09/30/2012

Reviewer (sign) -Level 2 t] Date .

ANIANII If Required (Sign) N/A Date N/A

Level of Use

ReferenceW. ~ ~?~

o-ý FK4 E-R-AA-NDE-UT-70 1

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 33 of 46

Attachment 4 - Page 17 of 20

I Attachment I Exam Data Sheet

Millstone Power Station ULTRASONIC EXAMINATION

STRAIGHT BEAM MEASUREMENTSPlant Millstone Unit 2 Page of

System & Zone No. "B" Train Service Water Exam Data Sheet No. N/A

Component ID SK-2963 AWO Number 53102516.32_5

Component Description Outlet Flange DrawingNo. 25203-20194 Sh. 2963

Examination Purpose Daily Monit'g. Line No. l0"-JGD-4 -_ __ ___

Instrument & Settings Calibration Block(s) Component Data

Manufacturer KB Type Serial No. Material Component Tnom N/A

Model No. USN 52L Step B11k. 99-6791 CS Component Dia. 10"

Serial No. 00CLX]R N/A N/A N/A Attachments. N/A

Range 5.0"1

Velocity 2329 Calibration Checks Block Thickness Instrument Reading

Delay -.375 Type Trime Min. Max. Min. Max.

Zero Value 9.873 Initial 0730 1.000" 4.000" 1.000" 4.000"

Cal Tolerance +/-.002 Intermediate N/A N/A N/A N/A N/A

Intermediate N/A N/A N/A N/A N/A

Search Unit Data Final 0745 1.000" 4.000" 1.000" 4.000"

Manufacturer KBA

Type No. MSEB5 CouplantData Temperature Data

Serial No. 57464-1411 Brand N/A Cal. B1k. Temp. N/A

Frequency 5 MHZ Batch No. 11225 G Component Temp N/A

Size .315" SAP Batch Mgmt. No. N/A. Thermometer S/N N/A

Sketch/Comments Area -Attach Photo(s) of Relevant Conditions Separately

Calibration sheet for SK-2963 outlet flange. UT point 4 only, at position #5, #9, #11 and #12. These

locations had paint removed.

The following data recorded UT point 4:

Location 5 = 2.084"

Location 9 =1.823"

Location 11=1.915"

Location 12=1.933"

Examiner (print & sign) Michael Brehler/ Lvl_ 11~•i~I Date 09/30/12

Reviewer (sign) -- Level Date

ANI/ANII If Required (Sign) N/A Date N/A

Level of Use

Reference

k

ps~\ ~owER-AA-NDE-UT-701-NPQRRev. 6

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 34 of 46

Attachment 4 - Page 18 of 20

I Attachment 1 Exam Data Sheet

Millstone Power Station ULTRASONIC EXAMINATION

STRAIGHT BEAM MEASUREMENTSPlant Millstone Unit . ... Page 1 of 1

System & Zone No. "B" Train Service Water Exam Data Sheet No. N/A

Component ID SK-2963 AWO Number 53102516395

Component Description Outlet Flange Drawing No. 25203-20194 Sh. 2963

Examination Purpose Daily Monitoring Line No. 10"-JGD-4

Instrument &_Settings Calibration Block(s) Component Data

Manufacturer KB Type Serial No. Material Component T... N/A

Model No. USN 52L Step Blk. 99-6791 CS Component Dia. 10"

Serial No. OOCLXR N/A N/A N/A Attachments. N/A

Range 5.0"

Velocity 2329 Calibration Checks Block Thickness Instrument Reading

Delay -. 375 Type Time Min. Max. Min. Max.

Zero Value 9.873 Initial 0955 1.000" 4.000" 1.000" 4.000"

Cal Tolerance +/- .002 Intermediate N/A N/A N/A N/A N/A

Intermediate N/A N/A N/A N/A N/A

Search Unit Data Final 1010 1.0010" 4.000" 1.000" 4.000"

Manufacturer KBA

Type No. MSEB5 Couplant Data Temperature Data

Serial No. 57464-1411 Brand N/A. Cal. Blk. Temp. N/A

Frequency 5 MHZ Batch No. 11225 G Component Temp N/A

Size .315" SAP Batch Mgmt. No. N/A Thermometer SIN N/A

Sketch/Comments Area - Attach Photo(s) of Relevant Conditions Separately

Calibration sheet for SK-2963 outlet flange. UT point 4 only, at position #5, #9, #11 and #12. Theselocations had paint removed.

The following data recorded UT point 4:

Location 5 = 2.082"

Location 9 =1.823"

Location 11=1.914"

Location 12=1.932"

Examiner (print & sign) Michael Brehler/ . _ Level 11 Date 09/30/12

Reviewer (sign) - Level Date

ANIIANII If Required (Sign) N/A Date N/A

Level of Use

Reference

VSK ER-AA-NDE-UT-701-NPQRRev. 6

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 35 of 46

Attachment 4 Page 19 of 20

UT Positions / Locations

0((-

0 •

3

I?-

Attachment #4 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 36 of 46

Attachment 4 - Page 20 of 20

UT Point Number Location Figure

UT Point 4

UT Point 3 --- I

UT Point 2UT Point 1 --

FlangeBolt Hole

,-Area of Material LossPipe

vI I m U

\

Note: Arrows show UT scan direction.

16.00 (REF)

10.88 (RFF)

I1.25

0.150

12.00 (REF)

Attachment #6 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 38 of 46

From: Deborah H MacDonald (Generation - 4)To: Jane L Marean (Generation - 4); Raymond E Deconto (Generation - 6);

Zachary A Withrow (Generation - 6);Subject: FW: Millstone 2 SW Flange Degradation RRDate: Saturday, September 22, 2012 10:48:19 AM

FYI

Debbie MacDonaldManager Nuclear Design EngineeringMillstone X2293Pager 504-286-2813

From: William D Bartron (Generation - 4)Sent: Friday, September 21, 2012 5:46 PMTo: Kim, JamesCc: Stephen E Scace (Generation - 6); Jeff D Semancik (Generation - 4); MattAdams (Generation - 4); David Sommers (Generation - 6); Scott M Smith(Generation - 4); Bob Sturgill (Generation - 6); Kerry Basehore (Generation - 6);Josephine Ambrosini ([email protected]); J Eric Laine (Generation - 4);Richard MacManus (Generation - 4); Chris Funderburk (Generation - 6); Deborah HMacDonald (Generation - 4); Norm P Sacco (Generation - 4); Wanda D Craft(Generation - 6); Michael F Marino (Generation - 6); George E. Marshall(Generation - 4); Anthony C Conant (Generation - 4); Sonny Stanley (Generation -4); Bill Standley (Generation - 4); Frederick Kral (Generation - 4); Gary J Closius(Generation - 4); Jeffrey P Blonar (Generation - 4); Larry E Salyards (Generation -4); MaryLou L Calderone (Generation - 4); Mohamed A Elmaghrabi (Generation -4); Thomas G Cleary (Generation - 4); William E Brown (Generation - 4)Subject: FW: Millstone 2 SW Flange Degradation RR

Jim,Thank you for getting back to me so quickly.We will be proceeding with the development of an operability determinationwhich will rely, in part, on a structural integrity assessment similar to what wasused for the previous relief request we discussed earlier today.We will follow-up in a timely manner with a relief request for the current condition.Bill

From: Kim, James [mailto:[email protected]]Sent: Friday, September 21, 2012 4:08 PMTo: William D Bartron (Generation - 4)Subject: RE: Millstone 2 SW Flange Degradation RR

Attachment #6 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 39 of 46

Bill,

I was able to get a hold of Tim Lupold (Branch Chief at Piping and NDE Branch) anddiscussed the Millstone 2 condition. He said that if an operability determination utilized a non-code compliant analyses to show that the plant is safe for continued operation, then you canfollow up with a relief request in a timely manner (he defines "timely manner" as 2-3 weeks)for the non-code compliant method.

Thanks,Jim

From: Kim, JamesSent: Friday, September 21, 2012 1:37 PMTo: 'William D Bartron'Subject: Millstone 2 SW Flange Degradation RR

Bill,

Please copy the following people on the email distribution.

TimothyLupoldcnrc.gov

[email protected]~cnrc.gov

Thanks,Jim

Attachment #7 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 40 of 46

Calculation of the ligament between the defect and the outer wall of the flange hub.

2.56" (calculated)

1 0.737 Cale. Ii 1.823" (measu

lnterdose of Pioe ;I...

S/ 0.737" is the radius of the defect based on UT Data Point 4measurement. Therefore using the Pythagoras theorem:

[4 56"Calc from Cati) ]Ligament•/ (0.562 + 0.68752) - 0.737" = 0.150"

Attachment #8 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 41 of 46

From:To:cc:

Subject:Date:Attachments:

Robert Y Schonenberg (Generation - 4)Zachary A Withrow (Generation - 6);Jane L Marean (Generation - 4); Harvey E Beeman (Generation - 4);Deborah H MacDonald (Generation - 4); Scott M Smith (Generation - 4);Document1 [Compatibility Mode]Friday, September 28, 2012 9:15:40 AMDocl.docx

Attached is my input into your ETE. I have attempted to clarify what has beenobserved for corrosion rates with service water piping over that past severalyears. I don't have a reference for why distance from the bi-metal couple makes adifference but the observed behavior speaks for itself.

Achieving proper electrical isolation should change the rate dramatically. If thetesting shows that there is a back current then it will be necessary to isolate thedownstream flange on the AI-6XN elbow (SK2964?). Or accept the fact that therate will not fall that much.

Attachment #8 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 42 of 46

Millstone has had two events where the observed galvanic corrosion rate is relevant to thecurrent condition of service water spool SK2963.

The first of these is the damage and hole that was found on service water spool SK2952 inSeptember 2011. The damage to the outlet flange of SK2952 like that hypothesized on SK2963was through the slip on flange. The observed rate was about .800"/yr. The following sketchillustrates the geometry. It appears the corrosion starts from a point on the flange andprogresses radially with the double ended arrow representing the shortest distance that lead tothe leak. This .800"/yr. rate assumes the corrosion started when the flange pair wasreassembled during 2R19.

The second event occurred in December 2011, where a hole was found in a coated carbonsteel pipe about 2 feet from an improperly isolated carbon steel to AL-6XN flange. This pipewas connected directly to the discharge canal and therefore under a slight vacuum and didn'tleak. Data from the damaged area taken over a month gave a corrosion rate of .5 -.6"/yr. Thisslightly slower corrosion rate demonstrates that the rate is a function of distance from thegalvanic couple interface.

Coating damage and subsequent corrosion damage at the flanges of coated carbon steel pipe(i.e., no galvanic couple) has been observed by the Sea Water Team during virtually everyrecent outage. The corrosion damage has varied in depth from barely noticeable to 1/2" indepth on several larger flanges. The 1½" of corrosion translates to a corrosion rate of .200"/yr.The literature corrosion rate of carbon steel in sea water is only about .010"/yr. Higher corrosionrates at holidays or breaks in coatings is a common phenomena not completely understood.

If it is possible electrically isolate the AL-6XN flange from the carbon steel flange, the corrosionrate of the damaged areas on spool SK2963 should change. With the large electrical potentialfrom the AL-6XN eliminated, the corrosion rate should fall to .200"/yr. (.017"/month) range thathas been observed for carbon steel with a damaged coating.

Attachment #9 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 43 of 46

From: Richard C Bonner (Generation - 4)To: Michael F Marino (Generation - 6); Raymond E Deconto (Generation - 6);

Zachary A Withrow (Generation - 6);Subject: FW: Testing Millstone 2 FlangesDate: Sunday, September 30, 2012 3:31:39 PM

------ Original Message -----From: Scott Paul [mailto:[email protected]]Sent: Sunday, September 30, 2012 2:44 PMTo: Richard C Bonner (Generation - 4); '[email protected]'Cc: John E Plourde (Generation - 4); Donald S Cleary (Generation - 4); DouglasR Tilton (Generation - 4); Russell A Sturgis (Generation - 4); Scott M Smith(Generation - 4); Thomas E Davis (Generation - 4); Eric P Smith (Generation -4); Michael P Fiala (Generation - 4); Joseph A Rigatti (Generation - 4)Subject: Re: Testing Millstone 2 Flanges

Test results obtained today indicate that both insulating flange assemblies areproviding adequate electrical separation of the SK-2963 AL6XN elbow. All boltsof both flanges measured greater thank 1,000,000 ohms to the adjacent pipeflange. voltage across the flanges is 0.532 volts dc and 0.58 M ohms. The 40millamps measure between the carbon steel and AL6XN elbow represenftsapproximately .8 pounds of metal loss per year.

---- Richard C Bonner <[email protected]> wrote:

> Scott,

> As we discussed, can you provide a summary email of your examination /testing of degraded flange SK-2963 today and resulting affect on corrosion rates.It would be beneficial to us if you could provide any bases specifics forconclusion which could include personal experience.

> Thank you

> Rick Bonner> Supervisor Nuclear Engineering> Electrical/I+C Systems> Millstone Station> CONFIDENTIALITY NOTICE: This electronic message contains information> which may be legally confidential and/or privileged and does not in> any case represent a firm ENERGY COMMODITY bid or offer relating> thereto which binds the sender without an additional express written

Attachment #9 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 44 of 46

> confirmation to that effect. The information is intended solely for> the individual or entity named above and access by anyone else is> unauthorized. If you are not the intended recipient, any disclosure,> copying, distribution, or use of the contents of this information is> prohibited and may be unlawful. If you have received this electronic> transmission in error, please reply immediately to the sender that you> have received the message in error, and delete it. Thank you.

Attachment #10 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 45 of 46

Millstone Power FacilityDielectric Insulator Evaluation and Documentation

Work Order Number: W 6) -C 3 / 0 -• 1-~2

Component Number: aj (3-)Date: _ __ page / of . Personnel: To/ c"a_-- /--/Description of Work: ELJL-- va-L-'s / 6' M 6t " • 4 •'•.'-

Test Data _ j' ( -,

Instrument P ., ;o1 .- > f ,

601 Insulation Tester Good indication, needle stays to Defective indication, needle moves

Instrument # /?F ._. right of scale to the left "zero"

Resistance Scale, Multimeter

(Ohms) Oý0OhInstrument # ______

DC Voltage Scale,

Multimeter (VDC) 03qi ) ", '' Volts

Instrument # _____

Evaluation CriteriaCondition 1 Condition 2 Condition 3

601 Insulation Good indication, needle stays Good indication, needle stays to right Defective indication, needle movesTester to right of scale of scale to the left

Multimeter Ohms Measured value greater than Measured value less than 1.0 -Ohm Measured value less than 1.0 -Ohm

200-Ohm

Mfultimeter DC Measured value greater than Measured value less than 0.05-volt Measured value less than 0.05-volt

Volts 0.20-volt

Acknowledgement

YES NO

Condition I Z' 1:

Condition 2 E_

Condition 3 L[I

Insulating Flange GOOD, No backside GroundingInsulating Flange GOOD, With backside groundingInsulating Flange DEFECTIVE

Sketch

V)

1>- -

-*1

Attachment #10 DRAFT ETE-CME-2012-1024 Report Generated on 9/30/2012 7:40:57 PM Page 46 of 46

Millstone Power FacilityDielectric Insulator Evaluation and Documentation

Work Order Number: 4 -) -11_7 / )•- ,5 6 Z&6

Component Number: r"4 p-- [ -e(DI

Date: W3/i-- Page o- Of 2- Personnel: <, --eT

Description of Work: '. 6 • : J•-,p , ,

Test Data 4

Instrument Initials

601 Insulation Tester 4 Good indication, needle stays to ,/ 4 Defective indication, needle movesInstrument # 0v ' right of scale X k'Ito the left "zero" 1k,

Resistance Scale, Multimeter(Ohms) o_______S___?________ OhmsInstrument # m_!(• fT

DC Voltage Scale, j3qf7dMultimeter (VDC) --,_ _ _--_' ___ Volts

Instrument# Al •4V.•ý'L I_

Evaluation Criteria

Condition I Condition 2 Condition 3601 Insulation Good indication, needle stays Good indication, needle stays to right Defective indication, needle movesTester to right of scale of scale to the leftMultimeter Ohms Measured value greater than Measured value less than 1.0 -Ohm Measured value less than 1.0 -Ohm

200-OhmMultimeter DC Measured value greater than Measured value less than 0.05-volt Measured value less than 0.05-voltVolts 0.20-volt

Acknowledgement

YES NO

Condition 1 ' -. t.-,-2 /1//". tI/

Condition 2

Dv,

Condition 3 D _ -__

Insulating Flange GOOD, No backside GroundingInsulating Flange GOOD, With backside groundingInsulating Flange DEFECTIVE

Sketch

I i '" , :

~.. . .i.: .. ,

.. . . .. . . . . .... ... ... .. -... .. . - . . . . . . . ' ". . . . . . : .. .-! . .-/. . ; 7 . .. ". . ... .. . .. . . . . . . . . . . ... . . .i. . .. . . .'