2CAN022202, Requests for Relief from American Society of Mechanical Engineers Section XI Volumetric Examination Requirements - Fourth 10-Year Interval, Second and Third Periods
| ML22055B120 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 02/24/2022 |
| From: | Couture P Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 2CAN022202 | |
| Download: ML22055B120 (88) | |
Text
Entergy Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5138 Phil Couture Sr. Manager, Fleet Regulatory Assurance 10 CFR 50.55a 2CAN022202 February 24, 2022 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Requests for Relief from American Society of Mechanical EngineersSection XI Volumetric Examination Requirements -
Fourth 10-Year Interval, Second and Third Periods Arkansas Nuclear One, Unit 2 NRC Docket No. 50-368 Renewed Facility Operating License No. NPF-6 REFERENCES 1 Entergy Operations, Inc. (Entergy) letter to the U. S. Nuclear Regulatory Commission (NRC), "Request EN-ISI-16-1 : Use of Later Edition/Addenda of ASME Section XI Code for lSI Related Activities,"
(CNRO-2016-00023), (ML16337A368), dated December 1, 2016.
2 NRC letter to Entergy, "Arkansas Nuclear One, Unit 2 and Indian Point Nuclear Generating Station, Unit No. 3 - Relief Request EN-ISl-16-1 Regarding Use of Later Edition and Addenda of the ASME Code (CAC NOS. MF8905 AND MF8906)," (ML17174B144), dated July 12, 2017.
Pursuant to 10 CFR 50.55a(z)(2), Entergy Operations, Inc. (Entergy) requests relief from the requirements of American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code,Section XI pertaining to the limited surface and volumetric examinations at Arkansas Nuclear One, Unit 2 (ANO-2). In several locations, the required coverage cannot be obtained due to interference or geometry. Individual relief requests are provided in the attachments, divided by examination category.
10 CFR 50.55a(g)(5)(iii) requires that the basis for the determination of impracticality be submitted to the NRC for review and approval within 12 months after the expiration of the 120-month inspection interval. These reliefs are for the fourth ANO-2 10-year Inservice Inspection (ISI) interval, second and third periods. The interval started on March 26, 2010, and ended on August 1, 2020. The second period started on March 26, 2013, and ended March 25, 2017. The third period started March 26, 2017 and ended August 1, 2020. The interval was extended to end March 25, 2021.
2CAN022202 Page 2 of 2 It should be noted that the 2001 Edition / 2003 Addenda of Section XI of the ASME Code was the Code of Record when the fourth interval commenced. ANO-2 requested (Reference 1) and was approved (Reference 2) to use the 2007 Edition / 2008 Addenda of Section XI of the ASME Code for ISI activities for the remainder of the fourth ANO-2 ISI interval. ISI examinations performed in the 26th and 27th refueling outages, Fall of 2018 and Spring of 2020, were performed to the requirements of the 2007 Edition / 2008 Addenda of Section XI.
All examinations performed prior to that used the 2001 Edition / 2003 Addenda.
There are no new regulatory commitments made in this submittal.
If you have any questions or require additional information, please contact Riley Keele at 479-858-7826.
Respectfully, Philip Digitally signed by Philip Couture Couture Date: 2022.02.24 15:56:07 -06'00' Phil Couture PC/rwc Attachments:
- 1. Request for Relief - ANO2-ISI-023
- 2. Request for Relief - ANO2-ISI-024
- 3. Request for Relief - ANO2-ISI-025
- 4. Request for Relief - ANO2-ISI-026
- 5. Request for Relief - ANO2-ISI-027
- 6. Request for Relief - ANO2-ISI-028 cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - Arkansas Nuclear One NRC Project Manager - Arkansas Nuclear One
Attachment 1 2CAN022202 Request for Relief ANO2-ISI-023 2CAN022202 Page 1 of 24 REQUEST FOR RELIEF ANO2-ISI-023 Components / See Table 1 Numbers:
Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1
References:
ASME Section XI 2001 Edition with 2003 Addenda, Table IWB-2500-1 ASME Code Case N-460 Examination Category: B-D Item Number(s) B3.110, B3.130, B3.140, B3.90
==
Description:==
Full Penetration Welded Nozzles in Vessels Unit / Inspection Arkansas Nuclear One, Unit 2 (ANO-2) / Fourth (4th) 10-Year Interval Applicability: Interval, Second (2nd) and Third (3rd) Inspection Periods I. CODE REQUIREMENTS ASME Section XI, Table IWB-2500-1, Examination Category B-D, Full Penetration Welded Nozzles in Vessels - Inspection Program B:
- 1) Item B3.110 requires a volumetric examination of Pressurizer Nozzle-to-Vessel Weld volume, as depicted in Figures IWB-2500-7(a) through (d), as applicable.
- 2) Item B3.130 requires a volumetric examination of Steam Generators (Primary Side) Nozzle-to-Vessel Weld volume, as depicted in Figures IWB-2500-7(a) through (d), as applicable.
- 3) Item B3.140 requires a volumetric examination of Steam Generators (Primary Side) Nozzle Inside Radius Section volume, as depicted in Figures IWB-2500-7(a) through (d), as applicable.
- 4) Item B3.90 requires a volumetric examination of Reactor Vessel welds as depicted in Figures IWB-2500-7 (a) through (d).
ASME Code Case N-460 allows that a reduction in examination coverage due to interference by another component or part geometry may be accepted provided the reduction in coverage is less 10% (overall coverage is greater than 90%).
2CAN022202 Page 2 of 24 II. RELIEF REQUEST Pursuant to 10 CFR 50.55a(g)(6)(iii), Entergy Operations, Inc. (Entergy) requests relief from achieving the Code-required coverage when performing volumetric examinations of the components identified in Table 1.
III. BASIS FOR RELIEF During ultrasonic examination of the nozzle-to-vessel welds and inner radii listed in Table 1 below, 100% coverage of the required examination volume could not be obtained.
Examinations were performed utilizing 0, 45 and 60 beam angles in the axial and circumferential directions in accordance with Entergy approved procedures specific to ferritic vessels greater than 2 inches in thickness.
Due to the geometric configuration of the components and the close proximity of other structures which limited scan paths, the use of approved beam angles in the axial and circumferential direction were not able to achieve greater than 90% code required volume.
See Table 1 for additional information.
Radiography is not practical on these types of nozzle-to-vessel weld configurations, which prevent placement of the film and exposure source. To effectively perform any significant additional Code allowable ultrasonic examinations, modification and/or replacement of the component would be required. The examinations performed on the subject items in addition to the examination of other vessel welds contained in the Inservice Inspection program would detect generic degradation, if it existed, therefore, demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS No alternative testing is proposed at this time. Entergy has examined these welds to the extent practical and will continue to perform pressure testing on the subject components as required by the Code.
V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law, will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
2CAN022202 Page 3 of 24 Entergy believes that it is impractical to obtain greater examination coverage on these welds. To effectively obtain significant additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject welds, in addition to the examination of similar welds contained in the program, would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. Entergy requests the proposed relief be authorized pursuant to 10 CFR 50.55a(g)(6)(i).
Attachment 1 2CAN022202 Page 4 of 24 Table 1 Limited B-D Examinations Component Description Additional Information Estimated %
Coverage of Item Comp. Exam Method Surface Exam Item Description Code Examination Summary Scan Plan Search Units Number ID and Limitations Examination Results Required Volume B3.110 05-009 Pressurizer 67.51 This is a single sided examination. See the attached Manual UT Wave modalities None No (PZR) Surge Examination of the required volume information Scan path are longitudinal required. indications Nozzle-to-Head as depicted in Figure IWB-2500-7 (Figure 1 and 1a) limitation due to and shear. were Circumferential was limited due to the component derived from the configuration Insonification observed Weld configuration. Both the nozzle and ultrasonic testing of the angles included or head are carbon steel with stainless (UT) examination component. 0°, 45°, and 60°. recorded.
steel cladding on the inside surface. performed in 2R23 Acceptable and report 2-ISI- Search unit UT-14-017 on file frequencies at ANO. were 2.25 MHz.
B3.130 03-005 Steam 86.65 This is a single sided examination. See the attached Manual UT Wave modalities None No Generator (SG) Examination of the required volume information Scan path are longitudinal required. indications A Primary as depicted in Figure IWB-2500-7 (Figure 2 and 2a) limitation due to and shear. were Outlet Nozzle- was limited due to the component derived from UT the configuration Insonification observed to-Extension configuration. Both the nozzle and examination of the angles included or Pipe extension piece are carbon steel performed in 2R23 component. 0°, 35°,45°, 60° recorded.
Circumferential with stainless steel cladding on the and report 2-ISI- and 70°. Acceptable Weld inside surface. UT-14-013 on file at ANO. Search unit frequencies were 2.25 MHz.
B3.130 03-006 SG A Primary 86.65 This is a single sided examination. See the attached Manual UT Wave modalities None No Outlet Nozzle- Examination of the required volume information Scan path are longitudinal required. indications to-Extension as depicted in Figure IWB-2500-7 (Figure 3 and 3a) limitation due to and shear. were Pipe was limited due to the component derived from UT the configuration Insonification observed Circumferential configuration. Both the nozzle and examination of the angles included or Weld extension piece are carbon steel performed in 2R23 component. 0°, 35°, 45°, 60° recorded.
with stainless steel cladding on the and report 2-ISI- and 70°. Acceptable inside surface. UT-14-014 on file at ANO. Search unit frequencies were 2.25 MHz.
Attachment 1 2CAN022202 Page 5 of 24 Estimated %
Coverage of Item Comp. Exam Method Surface Exam Item Description Code Examination Summary Scan Plan Search Units Number ID and Limitations Examination Results Required Volume B3.130 04-005 SG B Primary 88.44 This is a single sided examination. See the attached Manual UT. Wave modalities None No Outlet Nozzle- Examination of the required volume information Scan path are longitudinal required. indications to-Extension as depicted in Figure IWB-2500-7 (Figure 4 and 4a) limitation due to and shear. were Pipe was limited due to the component derived from UT the configuration Insonification observed Circumferential configuration. Both the nozzle and examination of the angles included or Weld extension piece are carbon steel performed in 2R24 component. 0°, 45°, and 60°. recorded.
with stainless steel cladding on the and reports 2-ISI- Acceptable inside surface. UT-15-007 & 010 Search unit on file at ANO. frequencies were 2.25 MHz.
B3.130 04-006 SG B Primary 88.44 This is a single sided examination. See the attached Manual UT. Wave modalities None No Outlet Nozzle- Examination of the required volume information Scan path are longitudinal required. indications to-Extension as depicted in Figure IWB-2500-7 (Figure 5 and 5a) limitation due to and shear. were Pipe was limited due to the component derived from UT the configuration Insonification observed Circumferential configuration. Both the nozzle and examination of the angles included or Weld extension piece are carbon steel performed in 2R24 component. 0°, 45°, and 60°. recorded.
with stainless steel cladding on the and reports 2-ISI- Acceptable inside surface. UT-15-008 & 011 Search unit on file at ANO. frequencies were 2.25 MHz.
B3.130 04-007 Extension 87.21 This is a single sided examination. See the attached Manual UT. Wave modalities None No Pipe-to-SG B Examination of the required volume information Scan path are longitudinal required. indications Primary Inlet as depicted in Figure IWB-2500-7 (Figure 6 and 6a) limitation due to and shear. were Nozzle was limited due to the component derived from UT the configuration Insonification observed Circumferential configuration. Both the nozzle and examination of the angles included or Weld extension piece are carbon steel performed in 2R24 component. 0°, 35°, 45°, and recorded.
with stainless steel cladding on the and report 2-ISI- 60°. Acceptable inside surface. UT-15-018 on file at ANO. Search unit frequencies were 2.25 MHz.
Attachment 1 2CAN022202 Page 6 of 24 Estimated %
Coverage of Item Comp. Exam Method Surface Exam Item Description Code Examination Summary Scan Plan Search Units Number ID and Limitations Examination Results Required Volume B3.140 04- SG B Primary 89.03 This is a single sided examination. See the attached Manual UT Wave modality None No 005IR Outlet Nozzle Examination of the required volume information and required. indications Scan path insonification Inner Radii as depicted in Figure IWB-2500-7 (Figure 7 and 7a) limitation due to were was limited due to the component derived from UT angles included observed the configuration 25 shear at 90 configuration. Both the nozzle and examination of the or head are carbon steel with stainless performed in 2R24 skew angle; 35 recorded.
component. Four shear at +120 steel cladding on the inside surface. and reports 2-ISI- integral Acceptable Scanning was performed from the UT-15-001 and 2- and -120 skew attachments, angles; 55 vessel side only due to component ISI-UT-15-002 on each 4.25 x configuration. file at ANO. shear at +22 3.75 in size, and -22 skew located on the angles and 70 SG lower head, shear at +19 reduced and -19 skew examination. angles.
Search unit frequencies were 2.25 MHz.
B3.140 04- SG B Primary 89.03 This is a single sided examination. See the attached Manual UT. Wave modality None No 006IR Outlet Nozzle Examination of the required volume information Scan path and required. indications Inner Radii as depicted in Figure IWB-2500-7 (Figure 7 and 7a) limitation due to insonification were was limited due to the component derived from UT the configuration angles included observed configuration. Both the nozzle and examination of the 25 shear at 90 or head are carbon steel with stainless performed in 2R24 component. Four skew angle; 35 recorded.
steel cladding on the inside surface. and report 2-ISI- integral shear at +120 Acceptable Scanning was performed from the UT-15-003 and 2- attachments, and -120 skew vessel side only due to component ISI-UT-15-004 on each 4.25 x angles; 55 configuration. file at ANO 3.75 in size, shear at +22 located on the and -22 skew SG lower head, angles and 70 reduced shear at +19 examination. and -19 skew angles.
Attachment 1 2CAN022202 Page 7 of 24 Estimated %
Coverage of Item Comp. Exam Method Surface Exam Item Description Code Examination Summary Scan Plan Search Units Number ID and Limitations Examination Results Required Volume B3.90 01-021 RPV Nozzle to 73.83 This is a single sided examination. See the attached Automated UT. Wave modality None No Shell Weld @ 0° Examination of the required volume information Scan path and required. indications Azimuthal as depicted in Figure IWB-2500-7 (Figure 8, 8a and limitation due to insonification were was limited due to the component 8b) derived from the configuration angles included observed configuration. Both the nozzle and UT examination of the 45° shear and or vessel are carbon steel with performed in 2R26 component. 45° Long. , Bore recorded.
stainless steel cladding on the and report 2-ISI- Scan angles Acceptable inside surface. Scanning was VE-18-032 and included 50°,
performed remotely from the vessel Wesdyne Report 35°, 5°, 40°, 25° internally only due to component WDI-PJF-1320221-configuration and access. FSR-001 on file at ANO.
B3.90 01-024 RPV Nozzle to 73.83 This is a single sided examination. See the attached Automated UT. Wave modality None Two Shell Weld @ Examination of the required volume information Scan path and required. indications 180° Azimuthal as depicted in Figure IWB-2500-7 (Figure 8, 8a, and limitation due to insonification were was limited due to the component 8b) derived from the configuration angles included observed configuration. Both the nozzle and UT examination of the 45° shear and and vessel are carbon steel with performed in 2R26 component. 45° Long. , Bore recorded.
stainless steel cladding on the and report 2-ISI- Scan angles Both were inside surface. Scanning was VE-18-035 and included 50°, evaluated performed remotely from the vessel Wesdyne Report 35°, 5°, 40°, 25° and internally only due to component WDI-PJF-1320221- acceptable configuration and access. FSR-001 on file at per IWB-ANO. 3512-1 2CAN022202 Page 8 of 24 Figure 1 Scan Plan and Coverage for ISI Component 05-009 Not to Scale 2CAN022202 Page 9 of 24 Figure 1a Location sketch and photo for ISI Component 05-009 Not to Scale 05-009 2CAN022202 Page 10 of 24 Figure 2 Scan Plan and Coverage for ISI Component 03-005 Not to Scale 2CAN022202 Page 11 of 24 Figure 2a Location sketch and photo for ISI Component 03-005 Not to Scale 2CAN022202 Page 12 of 24 Figure 3 Scan Plan and Coverage for ISI Component 03-006 Not to Scale 2CAN022202 Page 13 of 24 Figure 3a Location sketch and photo for ISI Component 03-006 Not to Scale 2CAN022202 Page 14 of 24 Figure 4 Scan Plan and Coverage for ISI Component 04-005 Not to Scale 2CAN022202 Page 15 of 24 Figure 4a Location sketch and photo for ISI Component 04-005 Not to Scale 2CAN022202 Page 16 of 24 Figure 5 Scan Plan and Coverage for ISI Component 04-006 Not to Scale 2CAN022202 Page 17 of 24 Figure 5a Location sketch and photo for ISI Component 04-006 Not to Scale 2CAN022202 Page 18 of 24 Figure 6 Scan Plan and Coverage for ISI Component 04-007 Not to Scale 2CAN022202 Page 19 of 24 Figure 6a Location sketch and photo for ISI Component 04-007 Not to Scale
Attachment 1 2CAN022202 Page 20 of 24 Figure 7 Scan Plan and Coverage for ISI Components 04-005IR and 04-006IR Not to Scale 70/19bd 55/22bd 120 120 118 118 116 116 Z 114 Z 114 112 112 110 110 108 108 4 6 8 10 12 14 16 4 6 8 10 12 14 16 R R 25/90bd 35/120bd 120 120 118 118 116 116 Z 114 Z 114 112 112 110 110 108 108 4 6 8 10 12 14 16 4 6 8 10 12 14 16 R R 2CAN022202 Page 21 of 24 Figure 7a Location sketch and photo for ISI Components Not to Scale 2CAN022202 Page 22 of 24 Figure 8 Location Sketch for ISI Components01-021 and 01-024 Not to Scale 2CAN022202 Page 23 of 24 Figure 8a Nozzle Configuration and Exam Volume Sketch for ISI Components01-021 and 01-024 Not to Scale 2CAN022202 Page 24 of 24 Figure 8b Nozzle Exam Coverage Sketch for ISI Components01-021 and 01-024 Not to Scale
Attachment 2 2CAN022202 Request for Relief ANO2-ISI-024 2CAN022202 Page 1 of 11 REQUEST FOR RELIEF ANO2-ISI-024 Components / See Table 1 Numbers:
Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1
References:
ASME Section XI 2001 Edition with 2003 Addenda, Table IWC-2500-1 ASME Code Case N-460 Examination Category: B-O Item Number(s) B14.10
==
Description:==
Pressure Retaining Nozzle Welds in Control Element Drive Mechanism (CEDM) Housing Unit / Inspection Arkansas Nuclear One, Unit 2 (ANO-2) / Fourth (4th) 10-Year Interval Applicability: Interval, Second (3rd) Inspection Period I. CODE REQUIREMENTS ASME Section XI, Table IWB-2500-1, Examination Category B-O, Pressure Retaining Nozzle Welds in Vessels:
- 1) Item B14.10 requires a surface examination or a volumetric examination of the Welds in the Control Rod Housings, as depicted in Figure IWB-2500-18 of 10%
of the peripheral CRD housing welds.
ASME Code Case N-460 allows that a reduction in examination coverage due to interference by another component or part geometry may be accepted provided the reduction in coverage is less 10% (overall coverage is greater than 90%).
II. RELIEF REQUEST Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving the Code-required coverage when performing volumetric examinations of the components identified in Table 1.
III. BASIS FOR RELIEF In 2008, a cooling shroud (Figure 2) was designed and installed around the ANO-2 Reactor Vessel CEDMs (Figure 3). The modification impacted availability to the peripheral CEDM welds because the welds cannot be accessed now without 2CAN022202 Page 2 of 11 repositioning or removing the cooling shroud assembly. The cooling assembly was designed to be lifted a total of 40 inches. In order to gain access to the entire CEDM housing, a significant design modification would have to be performed. The CEDM instrumentation is highly sensitive and the likelihood of damaging the equipment is high.
Dose estimates to remove the cooling assembly, perform examinations and replace the cooling assembly is 6,690 RWP hours and 8.172 rem.
Per ASME Section XI, a 100% surface examination of 10% of the peripheral CEDM housing welds must be examined each inspection interval. This results in four welds on three CEDMs must be examined each interval. ANO-2 chose to inspect the welds on peripheral CEDM 69, 80 and 81 to satisfy the 10% examination population. CEDM 57, 69 and 80 provided the best opportunity to perform code required examinations. Each CEDM contains four pressure boundary welds labeled on Figure 1 below as W, X, Y, and Z. The top Z weld on CEDM 69, 80 and 81 (shown on ISI-202 drawing) was satisfactorily examined during 2R26 (Fall 2018). Attempts were made in 2R26 to examine the W, X, and Y welds but were unsuccessful. Corrective actions were generated to develop an action plan to complete the ASME Section XI required examinations on the ANO-2 CEDM housing welds in 2R27 (Spring 2020).
During the attempted remote surface examination of the ANO-2 CEDM pressure housing welds X and Y, 0% coverage of the required examination area was obtained due to limited access. The failed attempt was entered into the Entergy Corrective Action Program (CAP). It was noted that a remote VT-1 examination was successfully performed per the plan put in place for the previously selected X and Y welds.
Due to the geometric configuration of the components and the close tolerances of the cooling shroud assembly, coverage could not be obtained to meet the code required inspection area. The W and Z welds were examined 100% using a qualified surface examination method (Penetrant Test [PT]). A qualified surface (PT) examination was attempted, but due to the distance from the top of the Reactor Vessel Closure Head (RVCH) structure (Figure 4, 5 and 6) and the tight tolerances of the cooling shroud assembly, 0% coverage could be claimed for the X and Y welds yielding a total of 50% coverage being obtained for Category B-O. See Table 1 below for additional information.
An Eddy Current surface exam could not be performed because of limited access.
Due to the configuration and limited space, a volumetric examination could not be performed from the outside diameter of the CEDM housing at the X and Y weld locations.
A VT-2 examination in accordance with IWB-2500 was performed of the RVCH area to look for evidence of leakage. There were no indications or relevant conditions identified during the performance of the VT-2.
A Visual Examination (VE) in accordance with ASME Code Case N-729 and a VT-2 in accordance with ASME Section XI Table IWB-2500 is performed every refueling outage looking for evidence of leakage from the RVCH including the CEDM housings. No evidence of leakage has been observed.
2CAN022202 Page 3 of 11 IV. PROPOSED ALTERNATIVE EXAMINATIONS No alternative testing is proposed at this time. Entergy has examined the subject items to the extent practical and will continue to perform pressure testing on the subject areas as required by the Code.
V. CONCLUSION 10 CFR50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Entergy believes that it is impractical to obtain greater examination coverage on these areas. To obtain additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject areas, in addition to the examination of similar welds contained in the program would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. Therefore, Entergy requests the proposed relief be authorized pursuant to 10 CFR 50.55a(g)(6)(i).
Attachment 2 2CAN022202 Page 4 of 11 Table 1 Limited B-O Examinations Component Description Additional Information Estimated %
Coverage of Item Item Exam Method Search Exam Comp. ID Code Examination Summary Exam Plan Surface Examination Number Description and Limitations Units Results Required Volume B14.10 CEDM-057 CEDM Motor 50 Examination of the required See the attached Surface Exam, N/A Performed No Housing surface as depicted in information Liquid Penetrant successful ASME XI indications Upper Weld Figure IWB-2500-18 was (Figures 1-6) Limitation due to (PT) examinations were limited due to the component derived from the on Z weld on observed configuration and limited drawing ISI-202 inaccessibility of CEDM 81 in 2R26, or access to two (X, Y) of the on file at ANO and the X and Y on W weld on recorded.
four welds (W, X, Y, Z) photos gathered welds. CEDM 57 in 2R27. Acceptable required to be examined on from 2R26 and Performed remote this CEDM. 2R27. Reference VT-1 exam on X reports and Y welds on 2-ISI-PT-18-006, CEDM 57 due to 2-ISI-PT-20-003, limitation in 2R27.
2-ISI-VT-20-119, 2-ISI-VT-20-122 B14.10 CEDM-069 CEDM 50 Examination of the required See the attached Surface Exam, N/A Performed No Motor surface as depicted in information Liquid Penetrant successful ASME XI indications Housing Figure IWB-2500-18 was (Figures 1-6) Limitation due to (PT) examinations were Upper Weld limited due to the component derived from the on Z weld in 2R26, observed configuration and limited drawing ISI-202 inaccessibility of on W weld in or access to two (X, Y) of the on file at ANO and the X and Y 2R27. Performed recorded.
four welds (W, X, Y, Z) photos gathered welds. remote VT-1 exam Acceptable required to be examined on from 2R26 and on X and Y this CEDM. 2R27. Reference welds due to reports limitation in 2R27.
2-ISI-PT-18-004, 2-ISI-PT-20-005, 2-ISI-VT-20-120, 2-ISI-VT-20-123
Attachment 2 2CAN022202 Page 5 of 11 Estimated Item Item Coverage Exam Method Search Exam Comp. ID Examination Summary Exam Plan Surface Examination Number Description of Code and Limitations Units Results Required Volume B14.10 CEDM-080 CEDM 50 Examination of the required See the attached Surface Exam, N/A Performed No Motor surface as depicted in information Liquid Penetrant successful ASME XI indications Housing Figure IWB-2500-18 was (Figures 1-6) Limitation due to (PT) examinations were Upper Weld limited due to the component derived from the on Z weld in 2R26, observed configuration and limited drawing ISI-202 inaccessibility of on W weld in or access to two (X, Y) of the on file at ANO and the X and Y 2R27. Performed recorded.
four welds (W, X, Y, Z) photos gathered welds. remote VT-1 exam Acceptable required to be examined on from 2R26 and on X and Y this CEDM. 2R27. Reference welds due to reports limitation in 2R27.
2-ISI-PT-18-005, 2-ISI-PT-20-004, 2-ISI-VT-20-121, 2-ISI-VT-20-124 2CAN022202 Page 6 of 11 Figure 1 Location for Component CEDM (Typical)
Not to Scale ASME Section XI (PT) examination performed on Z weld successfully in 2R26 with no limitations and acceptable results.
ASME Section XI (PT) examination on X and Y welds were unsuccessful in 2R26 and 2R27.
Performed a remote visual (VT-1) on both welds with no limitations and acceptable results during 2R27.
ASME Section XI (PT) examination performed on W weld successfully in 2R27 with no limitations and acceptable results.
2CAN022202 Page 7 of 11 Figure 2 Cooling Shroud Assembly Not to Scale 2CAN022202 Page 8 of 11 Figure 3 Cooling Shroud Assembly photo taken during installation in 2008 2CAN022202 Page 9 of 11 Figure 4 Reactor Vessel Closure Head (RVCH) Support Structure photo taken during 2R26 2CAN022202 Page 10 of 11 Figure 5 Top of RVCH Support Structure photo taken during 2R26 (Coil Stacks removed from CEDM 69 and 81) 2CAN022202 Page 11 of 11 Figure 6 Lower access panel removed from RVCH Support Structure photo taken during 2R26 (Cooling Shroud Assembly surrounding Lower CEDM section)
Attachment 3 2CAN022202 Request for Relief ANO2-ISI-025 2CAN022202 Page 1 of 5 REQUEST FOR RELIEF ANO2-ISI-025 Components / See Table 1 Numbers:
Code Classes: American Society of Mechanical Engineers (ASME) Code Class 2
References:
ASME Section XI 2001 Edition with 2003 Addenda, Table IWC-2500-1 ASME Code Case N-460 Examination Category: C-A Item Number(s) C1.10
==
Description:==
Pressure Retaining Nozzle Welds in Vessels Unit / Inspection Arkansas Nuclear One, Unit 2 (ANO-2) / Fourth (4th) 10-Year Interval Applicability: Interval, Third (3rd) Inspection Period I. CODE REQUIREMENTS ASME Section XI, Table IWC-2500-1, Examination Category C-B, Pressure Retaining Nozzle Welds in Vessels - Inspection Program B:
- 1) Item C1.10 requires a volumetric examination of the Shell Circumferential Welds, as depicted in Figure IWC-2500-1.
ASME Code Case N-460 allows that a reduction in examination coverage due to interference by another component or part geometry may be accepted provided the reduction in coverage is less 10% (overall coverage is greater than 90%).
II. RELIEF REQUEST Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving the Code-required coverage when performing volumetric examinations of the components identified in Table 1.
III. BASIS FOR RELIEF During ultrasonic examination of the Letdown Heat Exchanger Flange to Channel Circumferential Weld and the Shutdown Cooling Heat Exchanger Flange to Channel Cylinder and Channel Cylinder to Tubesheet Welds listed in Table 1 below, 100% coverage of the required examination volumes could not be obtained.
2CAN022202 Page 2 of 5 Due to the geometric configuration of the components and the close proximity of other structures which limited scan paths, the use of approved beam angles in the axial and circumferential direction were not able to achieve greater than 90% code required volume.
See Table 1 below for additional information.
Radiography is not practical on these types of nozzle-to-vessel weld configurations, which prevent placement of the film and exposure source. To effectively perform any significant additional Code allowable ultrasonic examinations, modification and/or replacement of the component would be required. The examinations performed on the subject items in addition to the examination of other vessel welds contained in the Inservice Inspection (ISI) program would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS No alternative testing is proposed at this time. Entergy has examined the subject items to the extent practical and will continue to perform pressure testing on the subject areas as required by the Code.
V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Entergy believes that it is impractical to obtain greater examination coverage on these areas. To obtain additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject areas, in addition to the examination of similar welds contained in the program would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. Therefore, Entergy requests the proposed relief be authorized pursuant to 10 CFR 50.55a(g)(6)(i).
Attachment 3 2CAN022202 Page 3 of 5 Table 1 Limited C-A Examinations Component Description Additional Information Estimated %
Coverage of Item Comp. Item Exam Method Surface Exam Code Examination Summary Scan Plan Search Units Number ID Description and Limitations Examination Results Required Volume C1.10 49-001 Channel Flange 50 This is a single sided examination. See the attached Manual UT. Wave modalities None No to Channel Examination of the required volume information are longitudinal required. indications Scan path Shell Weld as depicted in Figure IWC-2500-1 (Figures 1 and 1a) limitation due and shear. were was limited due to the component derived from UT to the Insonification observed or configuration and proximity of the examination configuration of angles included recorded.
channel head flange. Both the performed in the component. 45°, 60°, 60L°, Acceptable flange and channel shell are 2R27 and report and 70°.
stainless steel. 2-ISI-UT-20-002 on file at ANO. Search unit frequencies were 2.0 MHz for 60°L and 2.25 MHz for all shear angles.
2CAN022202 Page 4 of 5 Figure 1 Scan Plan and Coverage for ISI Component 49-001 Not to Scale 2CAN022202 Page 5 of 5 Figure 1a Location sketch and photo for ISI Component 49-001 Not to Scale Photo taken prior to installation in 2R25
Attachment 4 2CAN022202 Request for Relief ANO2-ISI-026
Attachment 4 2CAN022202 Page 1 of 8 REQUEST FOR RELIEF ANO2-ISI-026 Components / See Table 1 Numbers:
Code Classes: American Society of Mechanical Engineers (ASME) Code Class 2
References:
ASME Section XI 2001 Edition with 2003 Addenda, Table IWC-2500-1 ASME Code Case N-460 Examination Category: C-B Item Number(s) C2.21
==
Description:==
Pressure Retaining Nozzle Welds in Vessels Unit / Inspection Arkansas Nuclear One, Unit 2 (ANO-2) / Fourth (4th) 10-Year Interval Applicability: Interval, Second (2nd) and Third (3rd) Inspection Period I. CODE REQUIREMENTS ASME Section XI, Table IWC-2500-1, Examination Category C-B, Pressure Retaining Nozzle Welds in Vessels - Inspection Program B:
- 1) Item C2.21 requires a surface and a volumetric examination of the Nozzle-to-Shell (or Head) Weld, as depicted in Figure IWC-2500-4 (a) or (b).
ASME Code Case N-460 allows that a reduction in examination coverage due to interference by another component or part geometry may be accepted provided the reduction in coverage is less 10% (overall coverage is greater than 90%).
II. RELIEF REQUEST Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving the Code-required coverage when performing volumetric examinations of the components identified in Table 1.
III. BASIS FOR RELIEF During ultrasonic examination of the Feedwater Nozzle-to-Shell Weld listed in Table 1 below, 100% coverage of the required examination volumes could not be obtained due to the proximity of one of the steam generator insulation brackets which is located around the circumference of the vessel and directly below the Feedwater nozzles. Scan paths from below the nozzle were impeded.
Attachment 4 2CAN022202 Page 2 of 8 There are several insulation bracket rings located around the circumference of the steam generator. These brackets facilitate supporting the many insulation panels surrounding the circumference of the steam generator. Removal of the subject bracket requires removal of all insulation panels directly supported by that ring as well as removal or engineered rigging of all insulation rings and panels above the removed ring. The insulation rings are not bolted directly to the steam generator shell; therefore, each lower elevation ring helps support the above rings and insulation panels.
Radiography is not practical on these types of nozzle-to-vessel weld configurations, which prevent placement of the film and exposure source. To effectively perform any significant additional Code allowable ultrasonic examinations, modification and/or removal are replacement of the insulation ring would be required. The examinations performed on the subject items in addition to the examination of other vessel welds contained in the Inservice Inspection program would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS No alternative testing is proposed at this time. Entergy has examined the subject items to the extent practical and will continue to perform pressure testing on the subject areas as required by the Code.
V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Entergy believes that it is impractical to obtain greater examination coverage on these areas. To obtain additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject areas, in addition to the examination of similar welds contained in the program would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. Therefore, Entergy requests the proposed relief be authorized pursuant to 10 CFR 50.55a(g)(6)(i).
Attachment 4 2CAN022202 Page 3 of 8 Table 1 Limited C-B Examinations Component Description Additional Information Estimated %
Coverage of Item Comp. Item Exam Method Surface Exam Code Examination Summary Scan Plan Search Units Number ID Description and Limitations Examination Results Required Volume C2.21 04-002 Steam 69.57 This is a single sided examination See the attached Manual UT. Wave modalities A Surface No Generator B but scanned to the extent practical information are longitudinal examination indications Scan path was Feedwater from Nozzle side of weld to (Figures 1 and 1a) limitation due and shear. were Nozzle to Shell maximize coverage. Examination of derived from UT performed observed or to the Insonification and Weld the required volume as depicted in examination configuration of angles included recorded.
Figure IWC-2500-4 was limited due performed in documented the component 0°, 45°, and 60°. on 2-ISI-MT- Acceptable to the shell to nozzle blend area and 2R24 and report and proximity the proximity of an insulation 2-ISI-UT-15-017 on Search unit 15-002 on file of insulation frequencies were at ANO.
bracket ring below the nozzle. Both file at ANO. bracket ring.
the nozzle and vessel shell are 2.25 MHz. 100% of the carbon steel. required surface was examined C2.21 48-013 2E35A 50 This is a single sided examination. See the attached Manual UT. Wave modalities A Surface No Shutdown Examination of the required volume information are longitudinal examination indications Scan path was Cooling Heat as depicted in Figure IWC-2500-4 (Figures 2 and 2a) limitation due and shear. were Exchanger was limited due to the component derived from UT performed observed or to the Insonification and Channel Inlet configuration. Both the nozzle and examination configuration of angles included recorded.
Nozzle Channel are stainless steel. performed in documented the component. 0°, 45°, 60°, 60°L, on 2-ISI-PT- Acceptable 2R27 and report and 70°.
2-ISI-UT-20-004 on 20-013 on file file at ANO. Search unit at ANO.
frequencies were 100% of the 2.0 MHz for 60°L required and 2.25 MHz for surface was all shear angles. examined
Attachment 4 2CAN022202 Page 4 of 8 Estimated %
Coverage of Item Comp. Item Exam Method Surface Code Examination Summary Scan Plan Search Units Number ID Description and Limitations Examination Required Volume C2.21 48-014 2E35A 50 This is a single sided examination. See the attached Manual UT. Wave modalities A Surface No Shutdown Examination of the required volume information are longitudinal examination indications Scan path was Cooling Heat as depicted in Figure IWC-2500-4 (Figures 2 and 2a) limitation due and shear. were Exchanger was limited due to the component derived from UT performed observed or to the Insonification and Channel Outlet configuration. Both the nozzle and examination configuration of angles included recorded.
Nozzle Channel are stainless steel. performed in documented the component. 0°, 45°, 60°, 60°L, on 2-ISI-PT- Acceptable 2R27 and report and 70°.
2-ISI-UT-20-005 on 20-006 on file file at ANO. Search unit at ANO.
frequencies were 100% of the 2.0 MHz for 60°L required and 2.25 MHz for surface was all shear angles. examined 2CAN022202 Page 5 of 8 Figure 1 Scan Plan and Coverage for ISI Component 04-002 Not to Scale 45° NOZZLE 60° 45° CL 60° SHELL 50%
100%
Insulation Bracket Obstruction Not to Scale Top Dead Center 04-002 Weld 41 Dia.,
FW Nozzle 128.8 Circumference @ CL of weld 87.5% 87.5%
60° 60° 45° 45° Limited at BDC:
INSULATION BRACKET 45° - approx. 26.4 = 0% cov.
60° - approx. 32.1 = 0% cov 2CAN022202 Page 6 of 8 Figure 1a Location sketch and photo for ISI Component 04-002 Not to Scale 2CAN022202 Page 7 of 8 Figure 2 Scan Plan and Coverage for ISI Components48-013 and 48-014 Not to Scale 2CAN022202 Page 8 of 8 Figure 2a Location sketch and photo for ISI Components48-013 and 48-014 Not to Scale
Attachment 5 2CAN022202 Request for Relief ANO2-ISI-027 2CAN022202 Page 1 of 5 REQUEST FOR RELIEF ANO2-ISI-027 Components / See Table 1 Numbers:
Code Classes: American Society of Mechanical Engineers (ASME) Code Class 2
References:
ASME Section XI 2001 Edition with 2003 Addenda, Table IWC-2500-1 ASME Code Case N-460 Examination Category: C-C Item Number(s) C3.10
==
Description:==
Integral Attachments for Vessels, Piping, Pumps, and Valves Unit / Inspection Arkansas Nuclear One, Unit 2 (ANO-2) / Fourth (4th) 10-Year Interval Applicability: Interval, Second (2nd) Inspection Period I. CODE REQUIREMENTS ASME Section XI, Table IWC-2500-1, Examination Category C-C, Integral Attachments for Vessels, Piping, Pumps, and Valves:
Item C3.10 requires a surface examination of the Integrally Welded Attachments of Pressure Vessel, as depicted in Figure IWC-2500-5.
ASME Code Case N-460 allows that a reduction in examination coverage due to interference by another component or part geometry may be accepted provided the reduction in coverage is less 10% (overall coverage is greater than 90%).
II. RELIEF REQUEST Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving the Code-required coverage when performing volumetric examinations of the components identified in Table 1.
III. BASIS FOR RELIEF During surface examination of the pipe support integral attachment weld, 100%
coverage of the required examination area could not be obtained.
The configuration of the subject component is four 5/8 x 1 x 1 lugs, placed 4 1/16 apart end to end in pairs at 0° and 180° on the vertical pipe. The lugs are integrally welded to the pipe with full penetration welds. The 2 piece 4 wide hanger strap is positioned and bolted between the end to end lugs, contacting the upper lugs which 2CAN022202 Page 2 of 5 support the vertical pipe. Code examination of this type of integral attachment weld requires a surface examination technique, such as Liquid Dye Penetrant or Magnetic Particle Testing, of the weld crown surface and 1/2 inch of base material on either side of the weld toes. However, due to the configuration of this integral attachment and associated hanger strap, access to the weld ends and surrounding base material for examination purposes is limited.
In order to perform additional or alternative Code examinations, modification and/or replacement of the component would be required. The examination performed on the available surface area of the subject item would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS No alternative testing is proposed at this time. Entergy has examined the subject items to the extent practical and will continue to perform pressure testing on the subject areas as required by the Code.
V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Entergy believes that it is impractical to obtain greater examination coverage on these areas. To obtain additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject areas, in addition to the examination of similar welds contained in the program would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. Therefore, Entergy requests the proposed relief be authorized pursuant to 10 CFR 50.55a(g)(6)(i).
Attachment 5 2CAN022202 Page 3 of 5 Table 1 Limited C-C Examinations Component Description Additional Information Estimated %
Coverage of Item Comp. Item Exam Method Surface Exam Code Examination Summary Scan Plan Search Units Number ID Description and Limitations Examination Results Required Volume C3.10 04-009 Steam 64 Examination of the required surface N/A Surface Exam, N/A See attached Rounded Generator B as depicted in Figure IWC-2500-5 Liquid information indications South Key was limited due to component Penetrant (PT) (Figures 1 (weld Bracket configuration and limited access to Limitation due and 1a) porosity) the lower portion of bracket due to to lower portion derived from were noted permanent insulation support. of the bracket PT that were Vessel and Bracket are Carbon inaccessibility examination acceptable to Steel. Liquid Penetrant surface performed in construction examination chosen due to limited 2R23 and code and access. report 2-ISI- ASME PT-14-002 on Section XI file at ANO. Acceptable 2CAN022202 Page 4 of 5 Figure 1 Coverage for ISI Component 04-009 Not to Scale Weld Key Bracket 2CAN022202 Page 5 of 5 Figure 1a Location sketch and photo for ISI Component 04-009 Not to Scale
Attachment 6 2CAN022202 Request for Relief ANO2-ISI-028 2CAN022202 Page 1 of 27 REQUEST FOR RELIEF ANO2-ISI-028 Components / See Table 1 Numbers:
Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1
References:
ASME Code Case N-716-1 ASME Code Case N-460 Examination Category: R-A Item Number(s) R1.11, R1.16, R1.20
==
Description:==
High Safety Significant Class 1 and 2 Piping Welds Unit / Inspection Arkansas Nuclear One, Unit 2 (ANO-2) / Fourth (4th) 10-Year Interval Applicability: Interval, Second (2nd) and Third (3rd) Inspection Periods I. CODE REQUIREMENTS ASME Section XI, Code Case N-716-1, Examination Category R-A, Risk Informed Piping Welds:
- 1) Item R1.11 requires volumetric examination of elements subject to thermal fatigue as depicted in Figure IWB-2500-8(c) and IWB-2500-9, 10, 11.
- 2) Item R1.16 requires volumetric examination of elements subject to Intergranular or Transgranular Stress Corrosion Cracking as depicted in Figure IWB-2500-8(c) and IWB-2500-9, 10, 11.
- 3) Item R1.20 requires volumetric examination of elements not subject to a Degradation Mechanism as depicted in Figure IWB-2500-8(c) and IWB-2500-9, 10, 11.
ASME Code Case N-460 allows that a reduction in examination coverage due to interference by another component or part geometry may be accepted provided the reduction in coverage is less 10% (overall coverage is greater than 90%).
II. RELIEF REQUEST Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving the Code-required coverage when performing volumetric examinations of the components identified in Table 1.
2CAN022202 Page 2 of 27 III. BASIS FOR RELIEF During ultrasonic examination of these ASME Section XI, Appendix VIII piping welds listed in Table 1, greater than 90% coverage of the required examination volume could not be obtained. Examinations were performed utilizing EPRI qualified Appendix VIII, Supplement 2 procedures specific to wrought austenitic piping welds.
Due to the geometric configuration and material type of the components, effective volumetric examination could only be performed as noted in the Table 1 for each weld. Although insonification was extended to the far side of the welds to the extent practical, this portion of the examination is not included in the reported examination coverage per the Performance Demonstration Initiative (PDI) and ASME Section XI, Appendix VIII rules. The use of 45, 60° and 70 beam angles in the axial and circumferential direction were not able to achieve greater than 90% code required volume as required by Code Case N-460. See Table 1 for specific information.
Entergy has used the best available and EPRI approved techniques to examine the subject piping welds. To effectively perform any significant additional Code allowable ultrasonic examinations, modification and/or replacement of the component would be required. The examinations performed on the subject items in addition to the examination of other piping welds contained in the Inservice Inspection (ISI) program would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity.
As with requests for relief for limited examinations of traditional programs, it is also necessary to complete the interval for a risk-informed program so that all limited examinations can be identified. Once all limited examinations are identified, the cumulative effect of the limited examinations can be determined for each affected system and for the total delta risk.
The following is a summary of the cumulative effect of the limited examinations for each system and total being reported in the relief request.
The eleven welds are contained in three systems. Four welds in the Chemical and Volume Control (CH), five welds in the Reactor Coolant (RCS), and two welds in the Safety Injection (SI).
None of the four welds have been selected for in-service examination during the fourth interval as part of the N-716 risk-informed ISI program. While these welds are high safety significant, they were not selected for examination. The four welds examined have no contribution to the delta risk evaluation from not having an in-service examination. The table below provides the delta risk with the four welds credited and with the four welds not credited. The columns under heading Examined include the delta risk with the four welds included. The columns under heading Not Examined include the adjusted delta risk after removing the four welds. As can be seen, there is no change to the result, and this result is below the individual system acceptable limits of 1E-07 for Core Damage Frequency (CDF) and 1E-08 for Large Early Release Frequency (LERF). Therefore, a limited examination of the four CH welds is acceptable.
2CAN022202 Page 3 of 27 Chemical and Volume Control (CH)
CDF Impact LERF Impact w/ POD w/o POD w/ POD w/o POD Source of Delta Risk Examined 4th interval periodic update
-1.01E-09 -4.86E-10 -1.01E-10 -4.86E-11 required by N-716 Not Examined Adjusted delta risk using the
-1.01E-09 -4.86E-10 -1.01E-10 -4.86E-11 periodic update delta risk
- Reactor Coolant (RCS) (Welds43-031, 43-033,28-041, 28-042, and 29-056)
To quantify the effect on delta risk for the five RCS welds, the delta risk is adjusted by not crediting the five RCS welds with limited examination coverage. The table below provides the delta risk with the five RCS welds credited and with the five RCS welds not credited. The columns under heading Examined include the delta risk with the five welds included. The columns under heading Not Examined include the adjusted delta risk after removing the five welds. As can be seen, the change is negligible and well below the individual system acceptable limits of 1E-07 for CDF and 1E-08 for LERF.
Therefore, a limited examination of the five RCS welds is acceptable.
CDF Impact LERF Impact w/ POD w/o POD w/ POD w/o POD Source of Delta Risk Examined 4th interval periodic update
-1.15E-09 -3.60E-10 -1.15E-10 -3.60E-11 required by N-716 Not Examined Adjusted delta risk using the
-1.11E-09 -3.31E-10 -1.11E-10 -3.31E-11 periodic update delta risk
To quantify the effect on delta risk for the two SI welds, the delta risk is adjusted by not crediting the two SI welds with limited examination coverage. The below table provides the delta risk with the two SI welds credited and with the two SI welds not credited. The columns under heading Examined include the delta risk with the two welds included.
The columns under heading Not Examined include the adjusted delta risk after removing the two welds. As can be seen, the change is negligible and well below the individual system acceptable limits of 1E-07 for CDF and 1E-08 for LERF. Therefore, a limited examination of the two SI welds is acceptable.
Safety Injection (SI)
CDF Impact LERF Impact w/ POD w/o POD w/ POD w/o POD Source of Delta Risk Examined 4th interval periodic update 5.56E-09 5.99E-09 5.56E-10 5.99E-10 required by N-716 Not Examined Adjusted delta risk using the 5.57E-09 6.00E-09 5.57E-10 6.00E-10 periodic update delta risk 2CAN022202 Page 4 of 27
- Cumulative Effect to Delta Risk for All Eleven Welds In the initial request for alternative to use a risk informed program for the fourth interval, the delta risk was provided for each system and cumulatively for all systems. The impact of the limited examination on the delta risk for the individual system is addressed above. The cumulative effect on the total delta risk is provided below. The columns under heading Examined are the delta risk with the eleven welds included. The columns under heading Not Examined is the adjusted delta risk after removing the eleven welds. As can be seen, the change is negligible and well below the total increase acceptable limits of 1E-06 for CDF and 1E-07 for LERF. Therefore, a limited examination of the four CH, five RCS, and two SI welds is acceptable.
Total CDF Impact LERF Impact w/ POD w/o POD w/ POD w/o POD Source of Delta Risk Examined 4th interval periodic update 7.11E-09 8.93E-09 7.11E-10 8.93E-10 required by N-716 Not Examined Adjusted delta risk using the 7.17E-09 8.97E-09 7.17E-10 8.97E-10 periodic update delta risk IV. PROPOSED ALTERNATIVE EXAMINATIONS No alternative testing is proposed at this time. Entergy has examined the subject items to the extent practical and will continue to perform pressure testing on the subject areas as required by the Code.
V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Entergy believes that it is impractical to obtain greater examination coverage on these areas. To obtain additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject areas, in addition to the examination of similar welds contained in the program would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. Therefore, Entergy requests the proposed relief be authorized pursuant to 10 CFR 50.55a(g)(6)(i).
Attachment 6 2CAN022202 Page 5 of 27 Table 1 Limited R-A Examinations Component Description Additional Information Estimated Item Comp. Item Coverage Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description of Code and Limitations Examination Results Required Volume R1.11 37-028 Pipe to Valve 63 This is a single sided examination. See the attached Manual UT. Wave modalities None No Circumferential Examination of the required volume information are shear. required indications Scan path Weld as depicted in Figure IWB-2500-8(c) (Figures 1) limitation due Insonification were with Note 1 from ASME Code Case derived from UT to the angles included observed or N-716-1 was limited due to the examination configuration of 45° and 70°. recorded.
component configuration. Both the performed in the component. Acceptable Valve and Pipe are stainless steel. 2R24 and report Search unit 2-ISI-UT-15-023 on frequencies were file at ANO. 2.25 MHz for 70° and 5.0 MHz for 45° angle.
R1.11 43-031 Tee to Pipe 50 This is a single sided examination. See the attached Manual UT. Wave modalities None No Circumferential Examination of the required volume information are shear. required indications Scan path Weld as depicted in Figure IWB-2500-8(c) (Figures 2 and 2a) limitation due Insonification were with Note 1 from ASME Code Case derived from UT to the angles included observed or N-716-1 was limited due to the Tee examination configuration of 45°, 60 and 70°. recorded.
to Pipe component configuration. performed in the component. Acceptable Both the Tee and Pipe are stainless 2R26 and report Search unit steel. 2-ISI-UT-18-036 on frequencies were file at ANO. 2.25 MHz for 70° and 5.0 MHz for 45° and 60° angles.
Attachment 6 2CAN022202 Page 6 of 27 Estimated %
Coverage of Item Comp. Item Exam Method Surface Exam Code Examination Summary Scan Plan Search Units Number ID Description and Limitations Examination Results Required Volume R1.11 43-033 Tee to Pipe 50 This is a single sided examination. See the attached Manual UT. Wave modalities None No Circumferential Examination of the required volume information are shear. required indications Scan path Weld as depicted in Figure IWB-2500-8(c) (Figures 3 and 2a) limitation due Insonification were with Note 1 from ASME Code Case derived from UT to the angles included observed or N-716-1 was limited due to the Tee examination configuration of 45°, 60 and 70°. recorded.
to Pipe component configuration. performed in the component. Acceptable Both the Tee and Pipe are stainless 2R26 and report Search unit steel. 2-ISI-UT-18-035 on frequencies were file at ANO. 2.25 MHz for 70° and 5.0 MHz for 45° and 60° angles.
R1.16 21-007 Elbow to Valve 50 This is a single sided examination. See the attached Manual UT. Wave modalities None No Circumferential Examination of the required volume information are longitudinal required indications Scan path Weld as depicted in Figure IWB-2500-8(c) (Figures 4 and 4a) limitation due and shear. were with Note 1 from ASME Code Case derived from UT to the Insonification observed or N-716-1 was limited due to the examination configuration of angles included recorded.
Elbow to Valve component performed in the component. 45°, 60 and 60°L. Acceptable configuration. Both the Elbow and 2R26 and report Valve are stainless steel. 2-ISI-UT-18-034 on Search unit file at ANO. frequencies were 2.00 MHz for 60°L and 2.25 MHz for 45° and 60° angles.
R1.20 37-029 Valve to Pipe 50 This is a single sided examination. See the attached Manual UT. Wave modalities None 360° Circumferential Examination of the required volume information are shear. required Intermittent Scan path Weld as depicted in Figure IWB-2500-8(c) (Figures 5 and 5a) limitation due Insonification geometry with Note 1 from ASME Code Case derived from UT to the angles included indications N-716-1 was limited due to the examination configuration of 45°, 60 and 70°. were component configuration. Both the performed in the component. observed Valve and Pipe are stainless steel. 2R24 and report Search unit with 70° on 2-ISI-UT-15-005 on frequencies were far side of file at ANO. 2.25 MHz for 70° weld and and 5.0 MHz for recorded.
45° and 60° angles. Acceptable
Attachment 6 2CAN022202 Page 7 of 27 Estimated %
Item Coverage of Number Comp. Item Exam Method Surface Exam Code Examination Summary Scan Plan Search Units ID Description and Limitations Examination Results Required Volume R1.20 37-030 Pipe to Valve 50 This is a single sided examination. See the attached Manual UT. Wave modalities None 360° Circumferential Examination of the required volume information are shear. required Intermittent Scan path Weld as depicted in Figure IWB-2500-8(c) (Figures 6 and 6a) limitation due Insonification geometry with Note 1 from ASME Code Case derived from UT to the angles included indications N-716-1 was limited due to the examination configuration of 45°, 60 and 70°. were component configuration. Both the performed in the component. observed Valve and Pipe are stainless steel. 2R24 and report Search unit with 70° on 2-ISI-UT-15-006 on frequencies were far side of file at ANO. 2.25 MHz for 70° weld and and 5.0 MHz for recorded.
45° and 60° angles. Acceptable R1.20 40-001 Valve to Pipe 50 This is a single sided examination. See the attached Manual UT. Wave modalities None No Circumferential Examination of the required volume information are shear. required indications Scan path Weld as depicted in Figure IWB-2500-8(c) (Figures 7 and 7a) limitation due Insonification were with Note 1 from ASME Code Case derived from UT to the angles included observed or N-716-1 was limited due to the examination configuration of 45° and 70°. recorded.
component configuration. Both the performed in the component. Acceptable Valve and Pipe are stainless steel. 2R23 and report Search unit 2-ISI-UT-14-021 on frequencies were file at ANO. 2.25 MHz for 70° and 5.0 MHz for 45° and 70° angles.
R1.20 28-041 Tee to Reducer 84.8 This is a dual sided examination. See the attached Manual UT. Wave modalities None No Circumferential Examination of the required volume information are shear. required indications Scan path Weld as depicted in Figure IWB-2500-8(c) (Figures 8 and 8a) limitation due Insonification were with Note 1 from ASME Code Case derived from UT to the angles included observed or N-716-1 was limited due to the examination configuration of 45°, 60 and 70°. recorded.
component configuration (intrados performed in the component. Acceptable of the tee). Both the Tee and 2R26 and report Search unit Reducer are stainless steel. 2-ISI-UT-18-027 on frequencies were file at ANO. 2.25 MHz for 70° and 5.0 MHz for 45°, 60° and 70° angles.
Attachment 6 2CAN022202 Page 8 of 27 Estimated %
Coverage of Item Comp. Item Exam Method Surface Exam Code Examination Summary Scan Plan Search Units Number ID Description and Limitations Examination Results Required Volume R1.20 28-042 Elbow to Tee 88 This is a dual sided examination. See the attached Manual UT. Wave modalities None No Circumferential Examination of the required volume information are shear. required indications Scan path Weld as depicted in Figure IWB-2500-8(c) (Figures 9 and 8a) limitation due Insonification were with Note 1 from ASME Code Case derived from UT to the angles included observed or N-716-1 was limited due to the examination configuration of 45°, 60 and 70°. recorded.
component configuration (Intrados performed in the component. Acceptable of the tee). Both the Tee and Pipe 2R26 and report Search unit are stainless steel. 2-ISI-UT-18-028 on frequencies were file at ANO. 2.25 MHz for 70° and 5.0 MHz for 45°, 60° and 70° angles.
R1.20 29-056 Pipe to Tee 50 This is a single sided examination. See the attached Manual UT. Wave modalities None No Circumferential Examination of the required volume information are shear. required indications Scan path Weld as depicted in Figure IWB-2500-8(c) (Figures 10 and limitation due Insonification were with Note 1 from ASME Code Case 10a) derived from to the angles included observed or N-716-1 was limited due to the UT examination configuration of 45° and 70°. recorded.
component configuration. Both the performed in the component. Acceptable Tee and Pipe are stainless steel. 2R26 and report Search unit 2-ISI-UT-18-029 on frequencies were file at ANO. 2.25 MHz for 70° and 5.0 MHz for 45° angles.
R1.20 21- Elbow to Safe 50 This is a single sided examination. See the attached Manual UT. Wave modalities None No 001A End Examination of the required volume information are longitudinal required indications Scan path Circumferential as depicted in Figure IWB-2500-8(c) (Figures 11 and limitation due and shear. were Weld with Note 1 from ASME Code Case 11a) derived from to the Insonification observed or N-716-1 was limited due to the SS UT examination configuration of angles included recorded.
Elbow to CASS Safe End performed in the component. 45°, 60° and Acceptable configuration. 2R26 and report 60°L.
2-ISI-UT-18-031 on file at ANO. Search unit frequencies were 2.0 MHz for 60°L and 2.25 MHz for 45° and 60° angles.
2CAN022202 Page 9 of 27 Figure 1 Scan Plan, Coverage and Location Sketch for ISI Component 37-028 Not to Scale 2CAN022202 Page 10 of 27 Figure 2 Scan Plan and Coverage for ISI Component 43-031 Not to Scale 2CAN022202 Page 11 of 27 Figure 2a Location Sketch for ISI Component 43-031 Not to Scale 2CAN022202 Page 12 of 27 Figure 3 Scan Plan and Coverage for ISI Component 43-033 Not to Scale 2CAN022202 Page 13 of 27 Figure 4 Scan Plan and Coverage for ISI Component 21-007 Not to Scale 2CAN022202 Page 14 of 27 Figure 4a Location sketch for ISI Component 21-007 Not to Scale 2CAN022202 Page 15 of 27 Figure 5 Scan Plan and Coverage for ISI Component 37-029 Not to Scale 2CAN022202 Page 16 of 27 Figure 5a Location sketch for ISI Component 37-029 Not to Scale 2CAN022202 Page 17 of 27 Figure 6 Scan Plan and Coverage for ISI Component 37-030 Not to Scale 2CAN022202 Page 18 of 27 Figure 6a Location Sketch for ISI Component 37-030 Not to Scale 2CAN022202 Page 19 of 27 Figure 7 Scan Plan and Coverage for ISI Component 40-001 Not to Scale 2CAN022202 Page 20 of 27 Figure 7a Location sketch for ISI Component 40-001 Not to Scale 2CAN022202 Page 21 of 27 Figure 8 Scan Plan and Coverage for ISI Component 28-041 Not to Scale 2CAN022202 Page 22 of 27 Figure 8a Location sketch for ISI Component 28-041 and 28-042 Not to Scale 2CAN022202 Page 23 of 27 Figure 9 Scan Plan and Coverage for ISI Component 28-042 Not to Scale 2CAN022202 Page 24 of 27 Figure 10 Scan Plan and Coverage for ISI Component 29-056 Not to Scale 2CAN022202 Page 25 of 27 Figure 10a Location sketch for ISI Component 29-056 Not to Scale 2CAN022202 Page 26 of 27 Figure 11 Scan Plan and Coverage for ISI Component 21-001A Not to Scale 2CAN022202 Page 27 of 27 Figure 11a Location sketch for ISI Component 21-001A Not to Scale