2CAN021302, Response to Request for Additional Information on Relief ANO2-ISI-010

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Response to Request for Additional Information on Relief ANO2-ISI-010
ML13037A050
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 02/05/2013
From: Pyle S
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
2CAN021302, TAC ME8272
Download: ML13037A050 (29)


Text

2CAN021302 February 5, 2013 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Response to Request for Additional Information Request for Relief ANO2-ISI-010 Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6

REFERENCES:

1. Entergy letter to NRC, Requests for Relief from American Society of Mechanical Engineers (ASME)Section XI Volumetric and Surface Examination Requirements - Third 10-Year Interval, dated March 26, 2012 (2CAN031203) (ML12086A293)
2. NRC email to Entergy, RAI on Request for Relief No. ANO2-ISI-010, dated September 6, 2012 (TAC No. ME8272) (ML12250A771)

Dear Sir or Madam:

Entergy Operations, Inc. requested NRCs approval of several Requests for Relief for Arkansas Nuclear One, Unit 2 via Reference 1. These requests are associated with the requirements of the ASME, Boiler and Pressure Vessel Code,Section XI pertaining to volumetric and surface examinations. In several locations, the required coverage cannot be obtained due to interference or geometry.

In Reference 2, the NRC determined that additional information was needed to complete the review of Request for Relief ANO2-ISI-010 provided in Reference 1. Attached are the requests for additional information and corresponding responses.

This submittal contains no regulatory commitments.

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4704 Stephenie L. Pyle Manager, Licensing Arkansas Nuclear One

2CAN021302 Page 2 of 2 If you have any questions or require additional information, please contact me.

Sincerely, Original signed by Stephenie L. Pyle SLP/rwc

Attachment:

Response to Request for Additional Information - Relief Request -

ANO2-ISI-010 cc:

Mr. Elmo E. Collins Regional Administrator U. S. Nuclear Regulatory Commission, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 NRC Senior Resident Inspector Arkansas Nuclear One P. O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Kaly Kalyanam MS O-8B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852

Attachment to 2CAN021302 Response to Request for Additional Information Relief Request - ANO2-ISI-010

Attachment to 2CAN021302 Page 1 of 26 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST ANO2-ISI-010 By letter dated March 26, 2012, Entergy Operations, Inc., submitted proposed alternative ANO2-ISI-010 (Reference 1) requesting relief from required volumetric examination coverage of American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code (Code),Section XI, Examination Category B-J welds under the Arkansas Nuclear One, Unit 2 (ANO-2) Risk Informed Inservice Inspection (RI-ISI) Program (Reference 2). In order to complete the review, the staff requests the following additional information:

1. How many Examination Category B-J welds exist at ANO-2 and how many were to be examined under the RI-ISI Program?

The total population of ANO-2 Examination Category B-J welds is 736. A total of 68 ANO-2 Examination Category B-J welds were to be examined under the RI-ISI program during the third 10-year interval.

2. How many Examination Category B-J welds for which adequate coverage was obtained were examined with ASME Code,Section XI, Appendix VIII qualified procedures?

Thirty four (34) Examination Category B-J welds were examined with ASME Code,Section XI, Appendix VIII qualified procedures and completed with the required coverage obtained.

3. Describe the procedure used for calculating the scan coverage.

Scan coverage was calculated by illustrating the cross-sectional profile of the weld with the Code required examination volume being depicted as a rectangle at the lower 1/3t of the component in a scale drawing. The volume of the rectangle was then calculated.

The extent of scanning with the appropriate angle beam transducer(s) was then overlaid on the examination volume in the axial direction scan which interrogates for circumferential flaws. Any limitation to these scans providing 100% coverage on both sides of the weld is documented.

The extent of any scan limitation is measured, and the volume calculated.

The volume of the area scanned is divided by the total volume to determine the estimated percentage of coverage.

Circumferential scans for axial flaws were performed on the adjacent material and the weld crown to the extent possible. These scans were not credited in the coverage calculation.

Attachment to 2CAN021302 Page 2 of 26

4. For each of the 30 subject Examination Category B-J welds for which adequate examination coverage could not be obtained:
a. Specify the safety significance classification (High or Medium) of each.

See Table 1.

b. Specify whether it was examined using an ASME Code,Section XI, Appendix VIII qualified procedure.

See Table 1.

c. Specify the diameter and wall thickness, and the materials of construction See Table 1.
d. Provide accurately proportioned drawings clearly showing the area of missed examination coverage for each weld. Describe the reason for the missed coverage.

See Table 1 and figures.

e. Was the weld examined under the RI-ISI program? For those welds that are described by ASME Code,Section XI, Table IWB-2500-1 item numbers (e.g., B9.11, B9.21) identify any potential degradation mechanism the welds may be susceptible to.

See Table 1.

f.

For those welds that have a potential degradation mechanism, explain why the examination coverage achieved is adequate to detect the potential degradation mechanism. Was an adjacent weld examined?

See Table 1.

Of the 30 welds reported with limited examinations, 11 had identified degradation mechanisms. Of the 11 with degradation mechanisms, six had adjacent components examined during the third 10-year interval.

Other Examination Category B-J components that were not selected for examination by volumetric processes but are examined during System Pressure Tests and plant walk-downs have not been found to have degradation issues. The examinations that have been performed, demonstrate effective inservice inspection (ISI) rigor.

Attachment to 2CAN021302 Page 3 of 26

g. For those welds that do not have a potential degradation mechanism, explain why other welds with the same safety significance, for which adequate examination coverage could be achieved, are not being examined.

The component selection process purposely includes welds that have configurations to fittings such as elbows, tees, valves and nozzles. To remove these components in favor of a non-restricted component, e.g., pipe to pipe, would result in an ISI program selection process that would not be conservative or represent the piping system configurations.

h. For those welds where the scan in the axial direction was performed from one side of the weld only, was a best effort attempt made to scan the material on the opposite side of the weld? If not, explain why this was not done and discuss any benefit that a best effort scan may provide.

Review of the data sheets indicates that best effort scanning was performed on both sides of the weld joint where accessible and feasible. Generally, it is not feasible to scan from a valve side or branch connection due to material, surface condition, or part geometry.

REFERENCES

1. Requests for Relief from American Society of Mechanical Engineers (ASME)Section XI Volumetric and Surface Examination Requirements - Third 10-Yewar Interval, Agencywide Documents Access and Management System (ADAMS) Accession No. ML12086A293
2. Safety Evaluation by the Office of Nuclear Reactor Regulation, Proposal to Use ASME Code Case N-578 as an Alternative to ASME Code Section XI, Table IWX-2500, ADAMS Accession Nos. 9901050347 and 9901050353

Attachment to 2CAN021302 Page 4 of 26 Table 1 Limited B-J Examinations Component Description Additional Information Item Number Comp.

ID Item Description Safety Significance (High or Med)

Examined with ASME Sect. XI App VIII procedure Dia.

(in)

Wall Thick.

(in)

Material Reason for missed coverage Examined RI-ISI (Y/N)

Degradation Mechanism Adjacent Weld Examined (Y/N)

B9.11 02-T-082 Reactor Vessel Closure Head (RVCH)

Instrument Nozzle Tube to Flange #82 None Identified Y

2008 2R19 5.565 0.563 Stainless Steel (SS) to SB-167 Nickel-Chromium-Iron (Ni-Cr-Fe)

Missed coverage was due to Instrument Nozzle Tube to Flange/Weld Configuration.

The inside surface was examined. The upper portion of the code volume was missed. 80% exam. See Figure 1 N

N/A N/A B9.11 02-T-083 RVCH Instrument Nozzle Tube to Flange #83 None Identified Y

2008 2R19 5.565 0.563 SS to SB-167 Ni-Cr-Fe Missed coverage was due to Instrument Nozzle Tube to Flange/Weld Configuration.

The inside surface was examined. The upper portion of the code volume was missed. 80% exam. See Figure 2 N

N/A N/A B9.11 21-001 Safety Injection Loop 1A Safe End to Nozzle Circumferential (Circ) Weld -

Dissimilar Metal (DM) Weld High N

2000 2R14 12.0 1.125 SA-351 CF-8M CSS to SA-182 CS Missed coverage was due to the Safe End to Nozzle Weld Configuration. 100% of the volume was scanned; however, the nozzle side was only scanned in one direction.

82.5% exam. See Figure 3 Y

None Identified N

R1.11 21-007 Safety Injection Loop 1A Elbow to Valve Circ Weld Med Y

2009 2R20 12.0 1.125 SS SA-403 WP 316 Missed coverage was due to Single Side exam due to the Elbow to Valve Configuration.

Sound was projected into the valve side of the weld.

Coverage volume limited to 50% due to procedure qualification restrictions. See Figure 4 Y

Intergranular Stress Corrosion Cracking (IGSCC)

Thermal Stratification, Cycling, and Striping (TASCS)

N

Attachment to 2CAN021302 Page 5 of 26 Table 1 Limited B-J Examinations Component Description Additional Information Item Number Comp.

ID Item Description Safety Significance (High or Med)

Examined with ASME Sect. XI App VIII procedure Dia.

(in)

Wall Thick.

(in)

Material Reason for missed coverage Examined RI-ISI (Y/N)

Degradation Mechanism Adjacent Weld Examined (Y/N)

B9.11 22-001 Safety Injection Loop 1B Safe End to Nozzle Circ Weld - DM Weld High N

2000 2R14 12.0 1.125 SA-351 CF-8M CSS to SA-182 CS Missed coverage was due to the Safe End to Nozzle Weld Configuration. 100% of the volume was scanned; however, most of the nozzle side was only scanned in one direction. 70% exam. See Figure 5 Y

None Identified N

R1.11 22-004 Safety Injection Loop 1B Valve to Pipe Circ Weld High Y

2005 2R17 12.0 1.125 SS SA-376 TP 316 Missed coverage was due to single side exam due to the Valve to Pipe Configuration.

Sound was projected into the valve side of the weld.

Coverage volume limited to 50% due to procedure qualification restrictions. See Figure 6 Y

None Identified Y

R1.11 22-005 Safety Injection Loop 1B Pipe to Valve Circ Weld Med Y

2005 2R17 12.0 1.125 SS SA-376 TP 316 Missed coverage was due to Single Side exam due to the Pipe to Valve Configuration.

Sound was projected into the valve side of the weld.

Coverage volume limited to 50% due to procedure qualification restrictions. See Figure 7 Y

IGSCC TASCS Y

B9.11 23-001 Safety Injection Loop 2A Safe End to Nozzle Circ Weld - DM Weld High N

2000 2R14 12.0 1.125 SA-351 CF-8M CSS to SA-182 CS Missed Coverage was due to the Safe End to Nozzle Weld Configuration. 100% of the volume was scanned; however, the nozzle side was only scanned in one direction.

70% exam. See Figure 8 Y

None Identified N

Attachment to 2CAN021302 Page 6 of 26 Table 1 Limited B-J Examinations Component Description Additional Information Item Number Comp.

ID Item Description Safety Significance (High or Med)

Examined with ASME Sect. XI App VIII procedure Dia.

(in)

Wall Thick.

(in)

Material Reason for missed coverage Examined RI-ISI (Y/N)

Degradation Mechanism Adjacent Weld Examined (Y/N)

B9.11 23-006 Safety Injection Loop 2A Valve to Pipe Circ Weld High Y

2002 2R15 12.0 1.125 SS SA-376 TP 316 Missed coverage was due to Single Side exam due to the Valve to Pipe Configuration.

Sound was projected into the valve side of the weld.

Coverage volume limited to 50% due to procedure qualification restrictions. See Figure 9 Y

None Identified Y

B9.11 23-007 Safety Injection Loop 2A Pipe to Valve Circ Weld Med Y

2002 2R15 12.0 1.125 SS SA-376 TP 316 Missed coverage was due to Single Side exam due to the Pipe to Valve Configuration.

Sound was projected into the valve side of the weld.

Coverage volume limited to 50% due to procedure qualification restrictions. See Figure 10 Y

IGSCC TASCS Y

B9.11 24-001 Safety Injection Loop 2B Safe End to Nozzle Circ Weld - DM Weld High N

2000 2R14 12.0 1.125 SA-351 CF-8M CSS to SA-182 CS Missed coverage was due to the Safe End to Nozzle Weld Configuration. 100% of the volume was scanned; however, the nozzle side was only scanned in one direction.

66.5% exam. See Figure 11 Y

None Identified N

R1.11 24-006 Safety Injection Loop 2B Pipe to Valve Circ Weld Med Y

2006 2R18 12.0 1.125 SS SA-376 TP 316 Missed coverage was due to Single Side exam due to the Pipe to Valve Configuration.

Sound was projected into the valve side of the weld.

Coverage volume limited to 50% due to procedure qualification restrictions. See Figure 12 Y

IGSCC TASCS N

Attachment to 2CAN021302 Page 7 of 26 Table 1 Limited B-J Examinations Component Description Additional Information Item Number Comp.

ID Item Description Safety Significance (High or Med)

Examined with ASME Sect. XI App VIII procedure Dia.

(in)

Wall Thick.

(in)

Material Reason for missed coverage Examined RI-ISI (Y/N)

Degradation Mechanism Adjacent Weld Examined (Y/N)

B9.11 25-024 Shutdown Cooling Pipe to Weld-o-let Circ Weld High Y

2002 2R15 3.0 0.438 SA-312 TP 316 SS to SA-182 F316 SS Missed coverage was due to Single Side exam due to the Pipe to Weld-o-let Configuration where coverage was limited in the upper code volume. 68.75%

exam. See Figure 13 Y

TASCS Y

B9.21 27-001 Pressurizer Spray Loop 1B Safe End to Nozzle Circ Weld - DM Weld Med N

2R14 2002 3.0 0.438 SA-182 TP 316 SS to SA-105 CS Missed coverage was due to the Nozzle to Safe End Weld and adjacent Pipe Weld Configuration. The area of limited coverage is in the base material on the Safe End side. 83% exam. See Figure 14 Y

None Identified Y

R1.20 27-002 Pressurizer Spray Piping Loop 1B Elbow to Safe End Circ Weld Med Y

2006 2R18 3.0 0.438 SA-403 WP316 SS to SA-182 TP 316 Missed coverage was due to the intrados of the elbow configuration for approximately 33% of scan on one side. Volume was scanned 100% in one direction. 83% exam. See Figure 15 Y

None Identified Y

R1.20 27-003 Pressurizer Spray Piping Loop 1B Elbow to Pipe Circ Weld Med Y

2006 2R18 3.0 0.438 SS SA-312 TP 316 Missed coverage was due to the intrados of the elbow configuration for approximately 33% of scan on one side. Volume was scanned 100% in one direction. 83% exam. See Figure 16 Y

None Identified Y

Attachment to 2CAN021302 Page 8 of 26 Table 1 Limited B-J Examinations Component Description Additional Information Item Number Comp.

ID Item Description Safety Significance (High or Med)

Examined with ASME Sect. XI App VIII procedure Dia.

(in)

Wall Thick.

(in)

Material Reason for missed coverage Examined RI-ISI (Y/N)

Degradation Mechanism Adjacent Weld Examined (Y/N)

R1.20 27-065 Pressurizer Spray Piping Loop 1B Valve to Pipe Circ Weld Med Y

2005 2R17 3.0 0.438 SS SA-312 TP 316 Missed coverage was due to Single Side exam due to the Valve to Pipe Configuration.

Sound was projected into the valve side of the weld.

Coverage volume limited to 50% due to procedure qualification restrictions. See Figure 17 Y

None Identified Y

R1.20 27-066 Pressurizer Spray Piping Loop 1B Pipe to Tee Circ Weld Med Y

2005 2R17 3.0 0.438 SS SA-312 TP 316 Missed coverage was due to the tee configuration for approximately 55% of scan on one side. 73% exam.

See Figure 18 Y

None Identified Y

B9.21 40-005 Charging Piping Loop 1A Valve to Pipe Circ Weld Med Y

2002 2R15 2.0 0.344 SS SA-312 TP 316 Missed coverage was due to Single Side exam due to the Valve to Pipe Configuration.

Volume was limited on the valve side. 59.6% exam.

See Figure 19 Y

None Identified N

B9.21 40-008 Charging Piping Loop 1A Pipe to Elbow Circ Weld Med Y

2002 2R15 2.0 0.344 SS SA-312 TP 316 to SA-403 WP 316 Missed coverage was due to the intrados of the elbow configuration for approximately 20% on one side and weld crown. 74%

exam. See Figure 20 Y

None Identified Y

R1.11 40-025 Charging Piping Loop 1A Elbow to Safe End Circ Weld High Y

2009 2R20 2.0 0.344 SS/SS SA-403 TP 316 to SA-182 TP 316 Missed coverage was due to the intrados of the elbow configuration for approximately 30% on one side. 85% exam. See Figure 21 Y

Thermal Transient (TT)

N

Attachment to 2CAN021302 Page 9 of 26 Table 1 Limited B-J Examinations Component Description Additional Information Item Number Comp.

ID Item Description Safety Significance (High or Med)

Examined with ASME Sect. XI App VIII procedure Dia.

(in)

Wall Thick.

(in)

Material Reason for missed coverage Examined RI-ISI (Y/N)

Degradation Mechanism Adjacent Weld Examined (Y/N)

B9.21 41-003 Charging Piping Loop 2A Valve to Pipe Circ Weld Med Y

2002 2R15 2.0 0.344 SS SA-312 TP 316 Missed coverage was due to Single Side exam due to the Valve to Pipe Configuration.

Volume was limited on the valve side. 60% exam. See Figure 22 Y

None Identified N

B9.21 41-003C Charging Piping Loop 2A Tee to Pipe Circ Weld Med Y

2002 2R15 2.0 0.344 SS SA-312 TP 316 Missed coverage was due to Single Side exam due to the Tee to Pipe configuration.

Volume was limited on the Tee side. 60% exam. See Figure 23 Y

None Identified N

B9.11 43-022 Pressurizer LTOP Tee to Pipe Circ Weld High Y

2003 2R16 6.0 0.562 SS SA-312 TP 316 Missed coverage was due to the Tee to Pipe configuration and branch connection.

Volume was limited in base material. 71.2% exam. See Figure 24 Y

TASCS Y

R1.11 43-023 Pressurizer LTOP Tee to Pipe Circ Weld High Y

2005 2R17 6.0 0.562 SS SA-312 TP 316 Missed coverage was due to the Tee to Pipe configuration.

Sound was projected into Tee side but scan credit restricted by procedure as single side.

81% exam. See Figure 25 Y

TASCS Y

B9.11 43-027 Pressurizer LTOP Pipe to Valve Circ Weld Med Y

2002 2R15 4.0 0.438 SS SA-312 TP 316 Missed coverage was due to Single Side exam due to the Valve to Pipe Configuration.

Volume was limited on the valve side. 67.6% exam.

See Figure 26 Y

TASCS TT N

Attachment to 2CAN021302 Page 10 of 26 Table 1 Limited B-J Examinations Component Description Additional Information Item Number Comp.

ID Item Description Safety Significance (High or Med)

Examined with ASME Sect. XI App VIII procedure Dia.

(in)

Wall Thick.

(in)

Material Reason for missed coverage Examined RI-ISI (Y/N)

Degradation Mechanism Adjacent Weld Examined (Y/N)

B9.11 43-033 Pressurizer LTOP Tee to Pipe Circ Weld Med Y

2002 2R15 3.0 0.438 SS SA-312 TP 316 Missed coverage was due to the Tee to Pipe configuration.

Volume was limited on Tee side. 72.5% exam. See Figure 27 Y

TASCS TT N

R1.20 13-008 RCP 2P-32C Discharge Nozzle SE to Pipe Circ Weld

-DM Weld Med Y

2009 2R20 30.0 3.25 CSS/SS to SA-533-67A Missed Coverage was due to Cast Stainless Steel Safe End Side and Weld Crown.

Procedure is restricted from crediting Centrifugal Cast Stainless Steel (CCSS) volume credit. Scanned with Phased Array. 60.1% exam.

See Figure 28 Y

None Identified N

R1.20 15-008 RCP 2P-32D Discharge Nozzle SE to Pipe Circ Weld-DM Weld Med Y

2009 2R10 30.0 3.25 CSS/SS to SA-533-67A Missed Coverage was due to Cast Stainless Steel Safe End Side and Weld Crown.

Procedure restricted from crediting CCSS volume credit. Scanned with Phased Array. 62.8% exam. See Figure 29 Y

None Identified N

R1.11 29-056 Pressurizer Auxiliary Spray Pipe to Tee Circ Weld High Y

2008 2R19 2.0 0.344 SS SA-312 TP 316 Missed coverage was due to the Tee to Pipe configuration.

Sound was projected into Tee side but coverage volume limited to 50% due to procedure qualification restrictions. See Figure 30 Y

TASCS Y

Attachment to 2CAN021302 Page 11 of 26 Figure 1 Scan Plan and Coverage for ISI Component 02-T-082 Not to Scale Figure 2 Scan Plan and Coverage for ISI Component 02-T-083 Not to Scale FLOW FLANGE INSTRUMENT NOZZLE TUBE C L FLOW FLANGE INSTRUMENT NOZZLE TUBE C L Area of limited coverage Area of limited coverage

Attachment to 2CAN021302 Page 12 of 26 Figure 3 Scan Plan and Coverage for ISI Component 21-001 Not to Scale Figure 4 Scan Plan and Coverage for ISI Component 21-007 Not to Scale SAFE END NOZZLE C L ELBOW SIDE C L C L VALVE SIDE INTRADOS EXTRADOS ELBOW TO SAFE END WELD Area of single directional coverage Area of limited coverage Area of limited coverage

Attachment to 2CAN021302 Page 13 of 26 Figure 5 Scan Plan and Coverage for ISI Component 22-001 Not to Scale Figure 6 Scan Plan and Coverage for ISI Component 22-004 Not to Scale PIPE VALVE (2SI-15A)

FLOW C L SAFE END C L Nozzle Flow Area of limited coverage Area of single directional coverage

Attachment to 2CAN021302 Page 14 of 26 Figure 7 Scan Plan and Coverage for ISI Component 22-005 Not to Scale Figure 8 Scan Plan and Coverage for ISI Component 23-001 Not to Scale VALVE (2SI-15A)

FLOW PIPE C L SAFE END C L Nozzle Flow Area of limited coverage Area of single directional coverage

Attachment to 2CAN021302 Page 15 of 26 Figure 9 Scan Plan and Coverage for ISI Component 23-006 Not to Scale Figure 10 Scan Plan and Coverage for ISI Component 23-007 Not to Scale C L PIPE FLOW VALVE C L FLOW VALVE 2SI-15C Area of limited coverage Area of limited coverage

Attachment to 2CAN021302 Page 16 of 26 Figure 11 Scan Plan and Coverage for ISI Component 24-001 Not to Scale Figure 12 Scan Plan and Coverage for ISI Component 24-006 Not to Scale Safe End C L Flow Nozzle FLOW Pipe Valve C L Area of single directional coverage Area of limited coverage

Attachment to 2CAN021302 Page 17 of 26 Figure 13 Scan Plan and Coverage for ISI Component 25-024 Not to Scale Figure 14 Scan Plan and Coverage for ISI Component 27-001 Not to Scale Flow Pipe Weld-O-Let C L Safe End C L Flow Nozzle TOE TOE Area of limited coverage Area of single directional coverage Area of single directional coverage Area of limited coverage

Attachment to 2CAN021302 Page 18 of 26 Figure 15 Scan Plan and Coverage for ISI Component 27-002 Not to Scale Figure 16 Scan Plan and Coverage for ISI Component 27-003 Not to Scale Flow Safe End Elbow CL PIPE ELBOW FLOW CL SCANNED ACROSS Area of single directional coverage for ~ 33% of one side Area of single directional coverage for ~ 33% of one side

Attachment to 2CAN021302 Page 19 of 26 Figure 17 Scan Plan and Coverage for ISI Component 27-065 Not to Scale Figure 18 Scan Plan and Coverage for ISI Component 27-066 Not to Scale VALVE C L Flow PIPE 2CV-4655 Flow PIPE TEE C

C L Area of limited coverage Area of limited coverage on Tee side for ~ 55% of circumference

Attachment to 2CAN021302 Page 20 of 26 Figure 19 Scan Plan and Coverage for ISI Component 40-005 Not to Scale Figure 20 Scan Plan and Coverage for ISI Component 40-008 Not to Scale Flow Pipe Valve C L Flow C L Pipe Elbow Area of limited coverage Area of limited coverage Area of single directional coverage

Attachment to 2CAN021302 Page 21 of 26 Figure 21 Scan Plan and Coverage for ISI Component 40-025 Not to Scale Figure 22 Scan Plan and Coverage for ISI Component 41-003 Not to Scale Extrados ELBOW C

Flow SAFE-END L

C L Valve Pipe Flow Intrados ELBOW SAFE-END Area of limited coverage for ~ 30% of circumference on one side Area of limited coverage

Attachment to 2CAN021302 Page 22 of 26 Figure 23 Scan Plan and Coverage for ISI Component 41-003C Not to Scale TEE C L PIPE Area of limited coverage

Attachment to 2CAN021302 Page 23 of 26 Figure 24 Scan Plan and Coverage for ISI Component 43-022 Not to Scale PIPE TEE FLOW C L FLOW PIPE TEE C L Area of limited coverage Area of limited coverage Area of single directional coverage for

~35% of circumference

Attachment to 2CAN021302 Page 24 of 26 Figure 25 Scan Plan and Coverage for ISI Component 43-023 Not to Scale Figure 26 Scan Plan and Coverage for ISI Component 43-027 Not to Scale TEE PIPE C L FLOW 70° Valve Pipe C L Flow Area of single directional coverage for

~61% of circumference Area of single directional coverage Area of limited coverage

Attachment to 2CAN021302 Page 25 of 26 Figure 27 Scan Plan and Coverage for ISI Component 43-033 Not to Scale Figure 28 Scan Plan and Coverage for ISI Component 13-008 Not to Scale Tee Pipe C L Flow C/S PIPE CAST SS SAFE Area of single directional coverage Area of limited coverage

Attachment to 2CAN021302 Page 26 of 26 Figure 29 Scan Plan and Coverage for ISI Component 15-008 Not to Scale Figure 30 Scan Plan and Coverage for ISI Component 29-056 Not to Scale C/S PIPE CAST SS SAFE FLOW TEE PIPE C L Area of limited coverage Area of limited coverage