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Request for Alternative ANO2-R&R-005, Proposed Alternative to ASME Code Requirements for Weld Overlay Repairs
	ML070860369
Person / Time
Site:	Arkansas Nuclear
Issue date:	03/21/2007
From:	Burford F; Entergy Operations
To:	; Document Control Desk, NRC/NRR/ADRO
References
	CNRO-2007-00012
	Download: ML070860369 (66)
	v • d • e

Entergy Operations, Inc.

tergyJackson, 1340 Echelon Parkway Mississippi 39213-8298 Tel 601-368-5758 F. G. Burford Acting Director Nuclear Safety & Licensing CNRO-2007-00012 March 21, 2007 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Request for Alternative ANO2-R&R-005 Proposed Alternative to ASME Code Requirements for Weld Overlay Repairs Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6

Dear Sir or Madam:

Pursuant to 10 CFR 50.55a(a)(3)(i), Entergy Operations, Inc. (Entergy) proposes to the NRC staff an alternative to the requirements of ASME Code, Section Xl IWA-4330 for mitigating primary water stress corrosion cracking (PWSCC) on dissimilar metal welds using full structural weld overlays. This request, contained in Enclosure 1 as Request for Alternative ANO2-R&R-005, is based on ASME Code Case N-740 and is applicable to Arkansas Nuclear One, Unit 2 (ANO-2).

This request is based on a similar one submitted by Entergy for Arkansas Nuclear One, Unit 1 (TAC No. MD4019) and one submitted by Southern Nuclear Operating Company for its Farley and Vogtie units (TAC Nos. MD2794, MD2795, MD2796, and MD2797).

Entergy requests approval of ANO2-R&R-005 by March 1, 2008 to support the nineteenth refueling outage at ANO-2 currently scheduled for the spring, 2008. Should you have any questions regarding this request, please contact Guy Davant at (601) 368-5756.

This letter contains commitments identified in Enclosure 2.

Sincerely, FGB/GHD/ghd

Enclosures:

1. Request for Alternative ANO2-R&R-005

2. Licensee-Identified Commitments 740 1f7

CNRO-2007-00012 Page 2 of 2 cc: Mr. W. A. Eaton (ECH)

Mr. J. S. Forbes (ECH)

Mr. T. G. Mitchell (ANO)

Dr. Bruce S. Mallet Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 U.S. Nuclear Regulatory Commission Attn: Ms. F. E. Saba MS 0-8 B1 Washington, DC 20555-0001

ENCLOSURE I CNRO-2007-00012 REQUEST FOR ALTERNATIVE ANO2-R&R-005

ENTERGY OPERATIONS, INC.

ARKANSAS NUCLEAR ONE, UNIT 2 REQUEST FOR ALTERNATIVE ANO2-R&R-005 I. COMPONENTS Component / Number: Hot Leg "A" Drain Line 2CCA-32-2" Surge Line 2BCA-1-12" Shutdown Cooling Line 2CCA-25-14"

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Description:==

"A" Hot Leg-to-Drain Line Nozzle Dissimilar Metal Weld (1)

"A" Hot Leg-to-Surge Line Nozzle Dissimilar Metal Weld (1) and Safe-End Stainless Steel Weld (1)

"B" Hot Leg-to-Shutdown Cooling Line Nozzle Dissimilar Metal Weld (1)

Code Class: 1

References:

1. ASME Code, Section Xl, 1992 Edition with portions of the 1993 Addenda as listed in Reference 5

2. ASME Section Xl, 1995 Edition through 1996 Addenda is used for Appendix VIII, "Performance Demonstration for Ultrasonic Examinations Systems"

3. ASME III, Subsection NB, 1971 Edition through Summer 1971 Addendum (Original Construction Code)

4. ASME Section III, Subsection NB, 1989 Edition

5. CEP-ISI-004, ANO-2 Inservice Inspection Plan

6. EPRI Report 1011898, Justification for the Removal of the 100 Square Inch Temperbead Weld Repair Limitation

7. EPRI Report GC-1 11050, Ambient Temperature Preheatfor Machine G TAW Temperbead Applications

8. EPRI Report 1006696, Crack Growth Rates for EvaluatingPWSCCC of Alloy 82, 182, and 132 Welds (MRP-115)

9. ASME Code Case N-740

10. ASME Code Case N-504-2

11. ASME Code Case N-638-1

12. EPRI Report 1013558, Temper Bead Welding Applications- 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Hold for Ambient Temperature Temper Bead Welding

13. EPRI Report 1010087, PrimarySystem PipingButt Weld Inspection and Evaluation Guidelines (MRP-139)

Unit/Inspection Interval: Arkansas Nuclear One, Unit 2 (ANO-2) / Third (3 rd) 10-Year Interval 1 of 54

II. CODE REQUIREMENTS IWA-4170(b) requires that repairs and installation of replacement items be performed in accordance with the Owner's Design Specification and the original Construction Code of the component or system. Alternatively, IWA-4170(b) allows for use of later Editions/Addenda of the Construction Code or ASME Section II1. IWA-4300 and IWA-4500 provide defect removal and alternative welding methods when the requirements of IWA-4170(b) cannot be met. IWA-4800 requires the performance of preservice examinations based on IWB-2200 for Class 1 components. Table IWB-2500, Category B-J, prescribes inservice inspection requirements for Class 1 piping butt welds. Appendix VIII, Supplement 11 of ASME Section Xl specifies performance demonstration requirements for ultrasonic examination of weld overlays.

Ill. REASON FOR PROPOSED ALTERNATIVE Primary water stress corrosion cracking (PWSCC) of Alloy 600 components and welds exposed to pressurized water reactor (PWR) primary coolant has become a growing concern in the nuclear industry over the past decade. In particular, dissimilar metal welds (DMWs) made with Nickel Alloy 82 and 182 weld metal exposed to elevated operating temperatures, such as hot leg DMWs, are believed to pose a heightened propensity to PWSCC. Due to this concern, Entergy has concluded that the application of preemptive full structural weld overlays to the hot leg DMWs identified above is the most appropriate course of action to ensure Reactor Coolant System (RCS) pressure boundary integrity and improve future inspectability.

NOTE The pressurizer at ANO-2 was replaced during the fall 2006 refueling outage. During the installation of the replacement pressurizer, DMWs requiring Inconel filler metal were welded with Alloy 52 or 52M filler metal. Therefore, none of the DMWs associated with the ANO-2 pressurizer require preemptive full structural weld overlays.

Structural weld overlays have been used for several years on piping of both boiling water reactors (BWRs) and PWRs to arrest the growth of existing flaws while establishing a new structural pressure boundary. While this is the case, no evidence of PWSCC has been found in the subject hot leg DMWs at ANO-2. However, PWSCC is difficult to detect except when the inspection is performed in accordance with the stringent requirements of ASME Section XI, Appendix VIII as implemented by the Performance Demonstration Initiative (PDI) Program. This request for alternative is applicable to three (3) DMWs and one (1) stainless steel weld as described below. It should be noted that two (2) of the three (3) DMWs have been evaluated and do not meet the surface or geometric requirements of Appendix VIII. Therefore, inspection of these DMWs welds cannot be performed to Appendix VIII without modifying the weld geometry or configuration. Regarding the third DMW weld, there are no PDI mock-ups to cover its configuration. As a result, an additional mock-up is required to qualify the PDI procedure for this configuration. The stainless steel weld is being overlaid due to inspection interference that would result after installing a weld overlay onto an adjacent DMW.

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Currently, there are no generically accepted Code-approved criteria for a licensee to preemptively apply a full structural weld overlay to DMWs constructed of Alloy 82/182 weld material. Although ANO-2 performs repair/replacement activities in accordance with the 1992 Edition of ASME Section Xl, this edition of ASME Section Xl does not include requirements for application of a preemptive, full structural weld overlay. For that matter, preemptive full structural weld overlay requirements are not presently included in any Edition/Addenda of ASME Section Xl (including Code Cases) approved by the NRC.

Nozzle-to-safe end weld overlays have been applied as repairs to other plants in accordance with ASME Code Cases N-504-2 and N-638-1, which are "conditionally accepted" for use in Regulatory Guide 1.147. Application of these code cases to nozzle DMWs requires a series of relief requests since Code Case N-504-2 was written specifically for stainless steel pipe-to-pipe welds and Code Case N-638-1 contains some restrictions and requirements that are not applicable to weld overlays. Code Case N-740 has recently been approved by the ASME Code Committee to specifically address weld overlays on DMWs. It also incorporates changes to the latest approved version of Code Case N-638 (i.e., N-638-3). However, Code Case N-740 does not specifically address preemptive weld overlays and has not yet been accepted by the NRC in Regulatory Guide 1.147.

This request for alternative is specific to the three (3) DMWs and one (1) stainless steel similar metal weld described below. These welds are associated with the ANO-2 hot legs.

Hot Leg "A" Nozzle to Drain Line The hot leg "A" drain nozzle, which is carbon steel (P-No. 1), is welded to a stainless steel (P-No. 8) safe-end. The weld joining the nozzle to the safe-end is an 82/182 DMW. See Attachment 1 for additional details.

" Hot Leq "A"to Surge Line The hot leg "A" surge nozzle, which is carbon steel (P-No. 1), is welded to a cast stainless steel (P-No. 8) safe-end, which is, in turn, welded to a (P-No. 8) stainless steel pipe. The weld joining the nozzle to the safe-end is an 82/182 DMW, and the weld joining the safe-end and pipe is a stainless steel similar metal weld. To facilitate inspection of the stainless steel weld after installation of the preemptive structural weld overlay, the weld overlay of the DMW will be extended across the stainless steel weld. See Attachment 1 for additional details.

Hot Leg "B" to Shutdown Cooling (SDC) Line The hot leg "B" nozzle, which is carbon steel (P-No. 1), is welded to a cast stainless steel (P-No. 8) safe-end. The weld joining the nozzle to the safe-end is an 82/182 DMW. See Attachment 1 for additional details.

A preemptive full structural weld overlay is proposed for each of the above DMW locations. The full structural weld overlays will be applied by depositing Alloy 52M (ENiCrFe-7A) weld metal on the outside surface of the DMWs and adjacent base materials.

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IV. PROPOSED ALTERNATIVE Pursuant to 10 CFR 50.55a(a)(3)(i), Entergy Operations, Inc. (Entergy) proposes the following as alternatives to the Code requirements specified in Section II above. The proposed alternatives are applicable to the three (3) DMWs and the one (1) stainless steel weld identified in Section III above.

A. Install preemptive full structural weld overlays in accordance with the proposed alternatives specified in Attachments 2 and 3. These alternatives are based on the methodology of ASME Section Xl Code Case N-740.

" Attachment 2 specifies an alternative applicable to the design, fabrication, examination, pressure testing, and inservice inspection of preemptive full structural weld overlays.

" Attachment 3 specifies an alternative applicable to ambient temperature temperbead welding. The Attachment 3 alternative will be applied to the welds as an alternative to the postweld heat treatment requirements of ASME Section II1.

B. Perform ultrasonic examinations of the proposed preemptive full structural weld overlays in accordance with Appendix VIII, Supplement 11 of the 1995 Edition/1996 Addenda of ASME Section Xl accept as modified by PDI. The proposed PDI alternatives to Appendix VIII, Supplement 11 are specified in Attachment 6.

V. BASIS FOR PROPOSED ALTERNATIVE A. Proposed Alternative for Preemptive Structural Weld Overlays Entergy intends to install preemptive full structural weld overlays to the three (3)

DMWs (Inconel 82/182) identified in Section III, above, in accordance with proposed alternative of Attachment 2. Due to the close proximity of an adjacent stainless steel butt weld to the proposed preemptive weld overlay of the Hot Leg "B" to SDC nozzle DMW, the weld overlay will be extended across the adjacent stainless steel butt weld as described in Section III of this request. A tabular comparison of the proposed alternative of Attachment 2 with Code Case N-504-2 and Appendix Q of ASME Section Xi has been performed and is provided in Attachment 4.

NOTE ASME Code Case N-504-2 has been conditionally approved by the NRC in Regulatory Guide 1.147 with the condition that the provisions of ASME Section Xl, Appendix Q be met when using the Case.

This proposed alternative provides an acceptable methodology for preventing potential failures due to PWSCC based on the use of filler metals that are resistant to PWSCC (e.g., Alloy 52M), procedures that create compressive residual stress profiles in the original weld, and post-overlay preservice and inservice inspection requirements that ensure structural integrity for the life of the plant. The proposed weld overlays will also meet the applicable stress limits from ASME Section IIl.

Crack growth evaluations for PWSCC and fatigue of any conservatively postulated flaws will demonstrate that structural integrity will be maintained.

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Please note that as stated above, preemptive weld overlays will be installed using Alloy 52M filler metal in accordance with Attachment 2. However, Alloy 52M weld metal has demonstrated sensitivity to certain impurities, such as sulfur, when deposited onto austenitic stainless steel base materials. Therefore, should this condition exist, a butter (transitional) layer of authentic stainless steel filler metal will be applied across the austenitic stainless steel base material. The austenitic stainless steel butter layer will not be included in the structural weld overlay thickness as defined in Attachment 2.

1. Weld Overlay Design and Verification The fundamental design basis for full structural weld overlays is to maintain the original design margins with no credit taken for the underlying PWSCC-susceptible weldments. The assumed design basis flaw for the purpose of structural sizing the weld overlays is 3600 and 100% through the original wall thickness of the DMWs. Regarding the crack growth analysis for the preemptive full structural weld overlay, a flaw originating from the inside diameter with a depth of 75% and a circumference of 3600 will be assumed. A 75% through-wall flaw is the largest flaw that could remain undetected. A preservice volumetric examination will be performed after application of the weld overlay using an ASME Section XI, Appendix VIII (as implemented through PDI) examination procedure. This examination will verify that there is no cracking in the upper 25% of the original weld and base material except as described in paragraph V.A.3.c of this request. The preservice examination will also demonstrate that the assumption of a 75% through-wall crack is conservative. However, if any crack-like flaws are identified in the upper 25%

of the original weld or base material by the preservice examination, then the as-found flaw (postulated 75% through-wall flaw plus the portion of the flaw in the upper 25%) will be used in the crack growth analysis.

The specific analyses and verifications to be performed are summarized below.

Nozzle-specific stress analyses will be performed to establish a residual stress profile in each nozzle. Severe internal diameter weld repairs will be assumed in these analyses that effectively bound any actual weld repairs that may have occurred in the nozzles. The analyses will then simulate application of the weld overlays to determine the final residual stress profiles. Post-weld overlay residual stresses at normal operating conditions will be shown to result in beneficial compressive stresses on the inside surface of the components, assuring that further crack initiation due to PWSCC is highly unlikely.

Fracture mechanics analyses will also be performed to predict crack growth for postulated flaws. Crack growth due to PWSCC and fatigue will be analyzed for the original DMW. The crack growth analyses will consider all design loads and transients, plus the post-weld overlay and through-wall residual stress distributions. It will demonstrate that the postulated cracks will not grow beyond the design basis for the weld overlays.

The analyses will demonstrate that applying the weld overlays does not impact the conclusions of the existing nozzle stress reports. The ASME Code,Section III stress and fatigue criteria will be met for regions of the overlays remote from assumed cracks.

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Shrinkage will be measured during the overlay application. Shrinkage stresses at other locations in the piping systems arising from the weld overlays will be demonstrated not to have an adverse effect on the systems. Clearances of affected supports and restraints will be checked after the overlay repair, and will be reset within the design ranges as required.

The total added weight on the piping systems due to the overlays will be evaluated for potential impact on piping system stresses and dynamic characteristics.

The as-built dimensions of the weld overlays will be measured and evaluated to demonstrate that they meet or exceed the minimum design dimensions of the overlays.

2. Suitability of Proposed Ambient Temperature Temperbead Technique An ambient temperature temperbead welding technique will be used when welding on the ferritic base materials of the nozzles in lieu of the post-weld heat treatment requirements of ASME Section II1. Research by the Electric Power Research Institute (EPRI) and other organizations on the use of an ambient temperature temperbead process using the machine gas tungsten arc welding (GTAW) process is documented in EPRI Report GC-1 11050 (Ref. 7).

According to the EPRI report, repair welds performed with an ambient temperature temperbead procedure utilizing the machine GTAW welding process exhibit mechanical properties equivalent to or better than those of the surrounding base material. Laboratory testing, analysis, successful procedure qualifications, and successful repairs have all demonstrated the effectiveness of this process.

a. Suitability of Ambient Temperature Temperbead Welding The effects of the ambient temperature temperbead welding process of Attachment 3 on mechanical properties of welds, hydrogen cracking, and cold restraint cracking are addressed in the following paragraphs:

Mechanical Properties The principal reasons to preheat a component prior to repair welding is to minimize the potential for cold cracking. The two cold cracking mechanisms are hydrogen cracking and restraint cracking. Both of these mechanisms occur at ambient temperature. Preheating slows down the cooling rate resulting in a ductile, less brittle microstructure thereby lowering susceptibility to cold cracking. Preheat also increases the diffusion rate of monatomic hydrogen that may have been trapped in the weld during solidification.

As an alternative to preheat, the ambient temperature temperbead welding process utilizes the tempering action of the welding procedure to produce tough and ductile microstructures. Because precision bead placement and heat input control are utilized in the machine GTAW process, effective tempering of weld heat affected zones (HAZ) is possible without applying preheat. According to Section 2-1 of EPRI Report GC-1 11050, "the temperbead process is carefully designed and controlled such that successive weld beads 6 of 54

supply the appropriate quantity of heat to the untempered HAZ such that the desired degree of carbide precipitation (tempering) is achieved. The resulting microstructure is very tough and ductile."

The IWA-4530 temperbead process also includes a post-weld soak requirement. Performed at 450°F - 550°F for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (P-No. 1 base materials), this post-weld soak assists diffusion of any remaining hydrogen from the repair weld. As such, the post-weld soak is a hydrogen bake-out and not a post-weld heat treatment as defined by the ASME Code. At 450OF - 550 0 F, the post-weld soak does not stress relieve, temper, or alter the mechanical properties of the weldment in any manner.

The alternative in Attachment 3 establishes detailed welding procedure qualification requirements for base materials, filler metals, restraint, impact properties, and other procedure variables. The qualification requirements contained in Attachment 3 provide assurance that the mechanical properties of repair welds will be equivalent to or superior to those of the surrounding base material.

Hydroqen Crackingq Hydrogen cracking is a form of cold cracking. It is produced by the action of internal tensile stresses acting on low toughness HAZs. The internal stresses are produced from localized build-ups of monatomic hydrogen. Monatomic hydrogen forms when moisture or hydrocarbons interact with the welding arc and molten weld pool.

The monatomic hydrogen can be entrapped during weld solidification and tends to migrate to transformation boundaries or other microstructure defect locations. As concentrations build, the monatomic hydrogen will recombine to form molecular hydrogen, thus generating localized internal stresses at these internal defect locations. If these stresses exceed the fracture toughness of the material, hydrogen-induced cracking will occur. This form of cracking requires the presence of hydrogen and low toughness materials. It is manifested by intergranular cracking of susceptible materials and normally occurs within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of welding.

IWA-4500 establishes elevated preheat and post-weld soak requirements. The elevated preheat temperature of 300°F increases the diffusion rate of hydrogen from the weld. The post-weld soak at 450°F was also established to bake-out or facilitate diffusion of any remaining hydrogen from the weldment. However, while hydrogen cracking is a concern for shielded metal arc welding (SMAW), which uses flux covered electrodes, the potential for hydrogen cracking is significantly reduced when using the machine GTAW welding process.

The machine GTAW welding process is inherently free of hydrogen.

Unlike the filler used in the SMAW process, GTAW welding filler metals do not rely on flux coverings, which may be susceptible to moisture absorption from the environment. Conversely, the GTAW process utilizes dry inert shielding gases that cover the molten weld pool from oxidizing atmospheres. Any moisture on the surface of the 7 of 54

component being welded will be vaporized ahead of the welding torch. The vapor is prevented from being mixed with the molten weld pool by the inert shielding gas that blows the vapor away before it can be mixed. Furthermore, modern filler metal manufacturers produce wires having very low residual hydrogen. This is important because filler metals and base materials are the most realistic sources of hydrogen for automatic or machine GTAW temperbead welding.

Therefore, the potential for hydrogen-induced cracking is greatly reduced by using the machine GTAW process.

In the unlikely case that hydrogen cracking occurs, nondestructive examination (NDE) of the weldment will be performed after the weldment has been at ambient temperature for 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , thereby providing assurance that the cracking would be identified.

Cold Restraint Crackinq Cold cracking generally occurs during cooling at temperatures approaching ambient temperature. As stresses build under a high degree of restraint, cracking may occur at defect locations. Brittle microstructures with low ductility are subject to cold restraint cracking.

However, the ambient temperature temperbead process is designed to provide a sufficient heat inventory so as to produce the desired tempering for high toughness. Because the machine GTAW temperbead process provides precision bead placement and control of heat, the toughness and ductility of the HAZ will typically be superior to the base material. Therefore, the resulting structure will be appropriately tempered to exhibit toughness sufficient to resist cold cracking.

b. Exceptions to ASME Code Case N-638-1 Conditions The ambient temperature temperbead technique of Code Case N-638-1 was conditionally approved by the NRC in Regulatory Guide 1.147. The proposed ambient temperature temperbead welding technique of Attachment 3 is identical to Code Case N-638-1 with the following exceptions:

" Code Case N-638-1, paragraph 1.0(a) limits the maximum area of an individual weld to 100 square inches. The proposed alternative limits the surface area to 500 square inches. The technical basis for this change is provided in Attachment 5.

Code Case N-638-1, paragraph 1.0(a) states that "the depth of the weld shall not be greater than one-half of the ferritic base metal thickness". Because the proposed alternative applies to deposition of weld overlays for which there are no weld or base material excavations, this limitation does not apply and is not included in Attachment 3.

When welding is to be performed in a pressurized environment (e.g.,

an enclosed environment that is pressurized to prevent leakage so that welding can be performed), Code Case N-638-1, paragraph 2.1 (b) requires that the pressurized environment be duplicated in the procedure qualification test assembly. Because this condition does 8 of 54

not exist when applying weld overlays in the request, this requirement is not included in Attachment 3.

When welding is performed in the core beltline region of the reactor pressure vessel, Code Case N-638-1, paragraph 2.1 (c) requires that the effects of irradiation on the properties of the materials be considered. Because weld overlays will not be applied to the core beltline region of the reactor pressure vessel, this requirement is not included in Attachment 3.

" Code Case N-638-1, paragraph 2.1 (h) requires the performance of Charpy V-notch testing of the ferritic weld metal of the procedure qualification test coupon. Because austenitic weld metal (i.e., Inconel Alloy 52 "Modified") will be used to fabricate the proposed weld overlays, this requirement does not apply and is not included in Attachment 3.

" Code Case N-638-1, paragraph 2.1 (j) specifies acceptance criteria for Charpy V-notch tests of the HAZ. According to paragraph 2.1(j), the "average values of the three HAZ impact tests shall be equal to or greater than the average values of the three unaffected base metal tests". Although not explicitly stated, the average values referred to in paragraph 2.1 (j) are the average lateral expansion values of the HAZ and base material specimens. Because this is the case, the acceptance criteria for Charpy V-notch testing of the HAZ is also based on average lateral expansion values in the proposed alternative. The technical basis for this change is provided in Attachment 5.

Code Case N-638-1, paragraph 3.0(c) requires the deposition and removal of at least one weld reinforcement layer for "similar materials" (i.e., ferritic materials). This requirement is only applicable when welding is performed using ferritic filler weld metal. When temperbead welding is performed with ferritic filler metal, each ferritic weld layer must be tempered by the heat supplied from a subsequent weld layer. Because the last layer of a weld or weld repair would be untempered without the deposition of one additional weld layer, paragraph 3.0(c) requires the deposition and removal of a reinforcement layer to provide the required tempering. Since only austenitic filler metal (i.e., Alloy 52M) will be used to fabricate the proposed weld overlays, depositing and removing a weld reinforcement layer is not required. Therefore, this requirement is not included into Attachment 3.

Code Case N-638-1, paragraph 3.0 does not specifically address monitoring or verification of welding interpass temperatures. Because this is the case, interpass temperature controls are specified in Attachment 3. The proposed interpass temperature controls are based on field experience with depositing weld overlays. Interpass temperature beyond the third layer has no impact on the metallurgical properties of the low alloy steel HAZ.

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As an alternative to the examination requirements of Section 4.0 of Code Case N-638-1, the weld overlay will be examined in accordance with the examination and inspection requirements of Attachment 2, Section 3.0. The suitability of the proposed examinations is described in Section V.A.3, below.

3. Suitability of Proposed NDE The length, surface finish, and flatness requirements of the weld overlay will be specified in the design to provide for examination volume of the weld overlay as shown in Attachment 2, Figures 1 and 2. Furthermore, the examinations and inspections specified in this proposed alternative will provide adequate assurance of structural integrity for the following reasons:

a. Weld overlays have been used for repair and mitigation of cracking in BWRs since the early 1980s. In Generic Letter 88-01, NRC Position on IntergranularStress Corrosion Cracking (IGSCC) in BWR Austenitic Stainless Steel Piping, the NRC approved the use of Section Xl acceptance standards for determining the acceptability of installed weld overlays.

b. The ultrasonic examinations performed in accordance with the proposed alternative are in accordance with ASME Section Xl, Appendix VIII, Supplement 11 as implemented through the PDI. Except as described in paragraph V.A.3.c below, these examinations are considered more sensitive for detecting fabrication and service-induced flaws than the ASME Section III radiographic or ultrasonic examination methods.

Furthermore, construction-type flaws have been included in the PDI qualification sample sets for evaluating procedures and personnel.

c. "Best effort" preservice and inservice examinations are proposed for the Hot Leg "A" Surge and Hot Leg "B" SDC nozzles, which have cast austenitic stainless steel safe-ends. As stated in paragraph V.A.3.b above, ultrasonic examination procedures for weld overlays are qualified in accordance with ASME Section Xl, Appendix VIII, Supplement 11 as implemented through the PDI. However, these procedures have not been qualified to examine the upper 25% of cast austenitic stainless steel below the weld overlay. This limitation is addressed in Sections 3.0(b) and (c) of Attachment 2. As a result, a "best effort" examination of this region (i.e.,

upper 25% of the cast austenitic stainless steel) has been proposed until procedures with the appropriate detection and/or sizing capability are qualified. Entergy is actively working with the industry to resolve this issue. Once procedures have been qualified with the required detection and/or sizing capability, Entergy will implement these procedures at the next scheduled examination as stipulated in Attachment 2.

The proposed "best effort" preservice and inservice examinations provide reasonable assurance that the structural integrity of the weld overlays will be maintained as further discussed below.

The full structural weld overlays are being preemptively installed over existing 82/182 DMWs due to their susceptibility to PWSCC.

However, PWSCC is not a concern for austenitic stainless steels; there is no industry experience to suggest that PWSCC can occur in 10 of 54

any austenitic stainless steel materials including castings. That said, should a preexisting PWSCC crack begin to propagate, its growth would be dictated by the stress distribution within the 82/182 weld. If the PWSCC crack comes into contact with the cast austenitic' stainless steel, it would blunt and cease to grow as noted in Section 2.5 of EPRI Report 1010087 (MRP-139), which states: "Second, if axial cracks developed in the Alloy 82/182 butt welds, the cracks can continue to propagate into the Alloy 600 base metal rather than arresting as would be the case for welds to low-alloy steel nozzles or stainless steel components." Therefore, there is no concern for growth of a crack by PWSCC into the cast stainless steel.

Regarding crack growth by fatigue, a crack could potentially grow by this mechanism into the cast stainless steel depending on its location in the weld. However, this condition is conservatively bounded by the crack growth evaluation described in paragraph V.1 .A of this request.

This evaluation postulates a flaw initiated in the weld from the inside diameter with a depth of 75% and circumference of 3600. This is the largest possible weld flaw that could remain undetected by the preservice and inservice examinations of Attachment 2. Because this flaw is analyzed for fatigue, the potential growth of a weld crack by fatigue into the cast stainless steel is also addressed.

d. Per Section 3.0(a)(3) of Attachment 2, any planar flaws found during either the acceptance or preservice examination are required to meet the requirements of Table IWB-3514-2. This approach was previously determined to be acceptable in the NRC Safety Evaluation Report (SER) dated July 21, 2004 for Three Mile Island, Unit 1. However, within the same SER, the NRC had issues regarding the application of Table IWB-3514-3 to laminar flaws in a weld overlay. The SER stated, "Applying Table IWB-3514-3 to a weld overlay exposes several inherent oversights.

For instance, the acceptance of a laminar flaw size is independent of the weld overlay size, and the acceptance criteria are silent on the inaccessible volume beneath the lamination which may hide other flaws beneath the lamination." These issues are addressed, as follows:

Per Section 3.0(a)(3)(i) of Attachment 2, Table IWB-3514-3 has been restricted so that the total laminar flaw shall not exceed 10% of the weld surface area and no linear dimension of the laminar flaw shall exceed 3 inches.

" Per Section 3.0(a)(3)(ii) of Attachment 2, the reduction in coverage due to laminar flaws shall be less than 10%. The dimensions of the un-inspectable volume are based on the coverage obtained by angle beam examinations of the weld overlay.

Per Section 3.0(a)(3)(iii) of Attachment 2, any un-inspectable volume in the weld overlay shall be assumed to contain the largest radial planar flaw that could exist within that volume. This assumed flaw shall meet the inservice examination standards of Table IWB-3514-2.

Alternately, the assumed flaw shall be evaluated and meet the requirements of IWB-3640. Both axial and circumferential planar flaws shall be assumed.

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e. Weld overlays for repair of cracks in piping are not addressed by ASME Section III. Section III utilizes NDE procedures and techniques with flaw detection capabilities that are well within the practical limits of workmanship standards for welds. These standards are most applicable to volumetric examinations conducted by radiographic examination.

Radiography (RT) of weld overlays is not appropriate because of the potential for radioactive material in the Reactor Coolant System and water in piping and components.Section III acceptance standards are written for a range of fabrication flaws including lack of fusion, incomplete penetration, cracking, slag inclusions, porosity, and concavity. However, experience and fracture mechanics have demonstrated that many of the flaws that are rejected using Section III acceptance standards do not have a significant effect on the structural integrity of the component.

Furthermore, utilizing ASME Section III acceptance standards on weld overlays would be inconsistent with years of NRC precedence and is without justification given the evidence of past NRC approvals and operating experience.

f. Regarding hydrogen cracking concerns, NDE required by paragraphs 3.0(a)(2) and 3.0(a)(3) of Attachment 2 is more than capable of detecting hydrogen cracking in ferritic materials. First of all, if hydrogen cracking were to occur, it would occur in the HAZ of the ferritic base material either below or immediately adjacent to the weld overlay. Therefore, it is unnecessary to examine the entire 1.5T band defined in paragraph 1.0(e) of Attachment 3. Hydrogen cracking is not a concern in austenitic materials. If it occurs in the ferritic base material below the weld overlay, it will be detected by the ultrasonic examination which will interrogate the entire weld overlay including the interface and HAZ beneath the weld

,overlay. If it occurs in the ferritic base material immediately adjacent to the weld overlay, it will be detected by the liquid penetrant examination which is performed at least 1/2 inch on each side of the weld overlay.

Finally, when ambient temperature temperbead welding is performed over ferritic materials, the liquid penetrant and ultrasonic examinations will not be performed until at least 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after completing of the third layer of the weld overlay. Technical justification for initiating the 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months hold after completing the third layer is provided in paragraph V.A.3.g.

g. Based on Code Case N-740, the 48-hour hold for performing NDE starts after the weld overlay cools to ambient temperature when performing ambient temperature temperbead welding. This 48-hour hold is specified to allow sufficient time for hydrogen cracking to occur (if it is to occur) in the HAZ of ferritic materials prior to performing final NDE. However, based on extensive research and industry experience, the Energy Power Research Institute (EPRI) has provided a technical basis for starting the 48-hour hold after completing the third temperbead weld layer rather than waiting for the weld overlay to cool to ambient temperature. (Weld layers beyond the third layer are not designed to provide tempering to the ferritic HAZ when performing ambient temperature temperbead welding.) EPRI has documented their technical basis in technical report 1013558, Temper Bead Welding Applications - 48 Hour Hold Requirements for Ambient Temperature Temper Bead Welding (Ref. 12). Although the technical data provided by EPRI in their report is based on testing performed on SA-508, Class 2 low alloy steels and other P-Number 3, Group 3 materials, the conclusions are bounding and applicable to P-Number 1 12 of 54

materials such as SA-1 05, Grade 2 which have a lower carbon equivalent and lower hardenability. This point is important because the ANO-2 hot leg nozzles are manufactured from SA-1 05, Grade 2 carbon steel. After evaluating the issues relevant to hydrogen cracking such as microstructure of susceptible materials, availability of hydrogen, applied stresses, temperature, and diffusivity and solubility of hydrogen in steels, EPRI concluded the following on page 5-2 of the report: "There appears to be no technical basis for waiting 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after cooling to ambient temperature before beginning the NDE of the completed weld. There should be no hydrogen present, and even if it were present, the temper bead welded component should be very tolerant of the moisture." Page 5-2 of the report also notes that over 20 weld overlays and 100 repairs have been performed using temper bead techniques on low alloy steel components over the last 20 years. During this time, there has never been an indication of hydrogen cracking by the nondestructive examination performed after the 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months hold or by subsequent inservice inspection.

In addition, the ASME Section Xl Committee approved Revision 4 to Code Case N-638 (i.e., N-638-4) in October 2006 to allow the 48-hour hold to begin after completing the third weld layer when using austenitic filler metals. Paragraph 4(a)(2) of the code case states in part: "When austenitic materials are used, the weld shall be nondestructively examined after the three tempering layers (i.e., layers 1, 2, and 3) have been in place for at least 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ." The ASME Section XI technical basis for this change is documented in the White Paper in ASME C&S Connect for Code Case N-638-4. The ASME White Paper points out that introducing hydrogen to the ferritic HAZ is limited to the first weld layer since this is the only weld layer that makes contact with the ferritic base material. While the potential for introducing hydrogen to the ferritic HAZ is negligible during subsequent weld layers, these layers provide a heat source that accelerates the dissipation of hydrogen from the ferritic HAZ in non-water backed applications. Furthermore, the solubility of hydrogen in austenitic materials such as Alloy 52M is much higher than that of ferritic materials while the diffusivity of hydrogen in austenitic materials is lower than that of ferritic materials. As a result, hydrogen in the ferritic HAZ tends to difuse into the austenitic weld metal which has a much higher solubility for hydrogen. This diffusion process is enhanced by heat supplied in subsequent weld layers. Like the EPRI report, the ASME White Paper concludes that there is sufficient delay time to facilitate detecting potential hydrogen cracking when NDE is performed 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after completing the third weld layer.

h. The successive examination requirements of Attachment 2, paragraph 3.0(c) ensure that cracks identified by inservice inspections are appropriately monitored. According to paragraph 3.0(c) of Attachment 2, the weld overlay "shall be reexamined during the first or second refueling outage following discovery of the growth or new cracking." If additional crack growth or a new crack is discovered during a successive examination, then the successive examination of the weld overlay would be re-performed within the next two refueling outages. However, ifthe successive examination of the weld overlay reveals no additional indication of crack growth or new cracking, the weld overlay shall be placed into a population to be examined on a sample basis. Twenty-five 13 of 54

percent (25%) of this population shall be examined once every ten (10) years. This successive examination schedule is identical to that specified in paragraph Q-4300 of ASME Section Xl, Appendix Q which has been imposed as a condition to using Code Case N-504-2 by the NRC in Regulatory Guide 1.147.

i. The examination and inspection requirements in Attachment 2, Section 3.0 are equivalent to or more conservative than the examination and inspection requirements of Appendix Q of ASME Section Xl as demonstrated in the comparison provided in Attachment 4 of this request.

4. NRC Submittals

a. Entergy will submit the following information to the NRC within fourteen (14) days from completing the final ultrasonic examinations of the completed weld overlays:

Weld overlay examination results including a listing of indications detected 1

Disposition of indications using the standards of ASME Section Xl, IWB-3514-2 and/or IWB-3514-3 2

criteria and, if possible, the type and nature of the indications

" A discussion of any repairs to the weld overlay material and/or base metal and the reason for the repairs.

b. Entergy will also submit to the NRC a stress analysis summary demonstrating that the hot leg piping nozzles will perform their intended design functions after the weld overlay installation. The stress analysis report will include results showing that the requirements of NB-3200 and NB-3600 of the ASME Code,Section III are satisfied. The stress analysis will also include results showing that the requirements of IWB-3000 of the ASME Code, Section Xl, are satisfied. The results will show that the postulated crack including its growth in the nozzles will not adversely affect the integrity of the overlaid welds. This information will be submitted to the NRC prior to entry into Mode 4 start-up from ANO-2's nineteenth refueling outage (2R19).

B. Proposed Alternative to ASME Section XI Appendix VIII, Supplement 11 Appendix VIII, Supplement 11 of the 1995 Edition, 1996 Addenda of ASME Section Xl specifies requirements for performance demonstration of ultrasonic examination procedures, equipment, and personnel used to detect and size flaws in full structural overlays of wrought austenitic piping welds. Entergy modifies the Appendix VIII, Supplement 11 qualification requirements by the proposed 1 The recording criteria of the ultrasonic examination procedure to be used for examining the ANO-2 hot leg overlays requires that all indications, regardless of amplitude, be investigated to the extent necessary to provide accurate characterization, identity, and location. Additionally, the procedure requires that all indications, regardless of amplitude, that cannot be clearly attributed to the geometry of the overlay configuration be considered flaw indications.

2 The ultrasonic examination procedure requires that all suspected flaw indications are to be plotted on a cross-sectional drawing of the weld and that the plots should accurately identify the specific origin of the reflector.

14 of 54

alternatives in the Performance Demonstration Initiative (PDI) Program as indicated in Attachment 6 of this request because the industry cannot meet the requirements of Appendix VIII, Supplement 11. Therefore, the PDI initiatives to ASME Section Xl Appendix VIII, Supplement 11 as described in Attachment 6 will be used for qualification of ultrasonic examinations used to detect and size flaws in the preemptive full structural weld overlays of this request.

VI. CONCLUSION 10 CFR 50.55a(a)(3)(i) states:

"Proposed alternatives to the requirements of (c), (d), (e), (f), (g), and (h) of this section or portions thereof may be used when authorized by the Director of the Office of Nuclear Reactor Regulation. The applicant shall demonstrate that:

(i) The proposed alternatives would provide an acceptable level of quality and safety, or (ii) Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety."

Entergy believes that the proposed alternatives of this request provide an acceptable level of quality and safety. The preemptive weld overlays will be installed using Nickel Alloy 52M filler metal that is resistant to PWSCC. While this is the case, the overlays will also create compressive residual stresses along the inside diameter of the original weld, which prevents the initiation of new PWSCC. Finally, preservice and inservice inspection of the weld overlay will be performed to ensure structural integrity is maintained. Therefore, Entergy requests that the NRC staff authorize the proposed alternative in accordance with 10 CFR 50.55a(a)(3)(i).

VII. ATTACHMENTS Attachment 1: Dissimilar Metal Weld Details and Figures Attachment 2: Proposed Alternative for Preemptive Full Structural Weld Overlays Attachment 3: Proposed Ambient Temperature Temperbead Technique Attachment 4: Comparison of ASME Code Case N-504-2 and Appendix Q of ASME Section Xl with the Proposed Alternative of Attachment 2 for Preemptive Full Structural Weld Overlays Attachment 5: Technical Basis for Alternatives to ASME Code Case N-638-1, Ambient Temperature Temperbead Welding Attachment 6: Comparison of ASME Section Xl Appendix VIII, Supplement 11 to Performance Demonstration Initiative (PDI) 15 of 54

REQUEST FOR ALTERNATIVE ANO2-R&R-005 ATTACHMENT I DISSIMILAR METAL WELD DETAILS AND FIGURES 16 of 54 to ANO2-R&R-005 DISSIMILAR METAL WELD DETAILS Hot Leg "A" to A-105, Gr. 21 DMW 82/182 SA-182, TP-316 35-002 SA-182, TP316 2" NPS 1 Drain Line w/SST Clad ID 35-001 (Elbow)

Hot Leg "A"to A-105, Gr. 2' DMW 82/182 SA-351, GR. CF8M 16-003(4) SA-351, GR. CF8M 12" NPS 2 Surge Line w/SST Clad ID i6-001(4 ) (Elbow)

Hot Leg "B" to A-105, Gr. 21 DMW 82/182 SA-351, GR. CF8M 25-002 SA-312, TP316 14" NPS 1 SDC Line w/SST Clad ID 25-001 (Pipe)

Notes:

1. Nozzle material is carbon steel.

2. These ISI welds are DMWs and require preemptive structural weld overlays. Each DMW includes butter and weld.

3. These IS[ welds are stainless welds joining stainless steel base materials. Therefore, they are not Inconel dissimilar metal welds.

4. To facilitate inservice inspection of ISI weld 16-003, the preemptive structural weld overlay for the DMW (16-001) of the Hot Leg "A"to Surge Line will be extended across ISl weld 16-003. See Figure 2.

17 of 54

ANO-2 HOT LEG DRAIN AND SDC NOZZLE WELD OVERLAYS I

I 2" Drain Nozzle, SA-105, Gr 2 F14" SDC Nozzle, SA-105, Gr2 k

Safe End FIGURE 1 18 of 54

ANO-2 SURGE NOZZLE WELD OVERLAY FIGURE 2 19 of 54

REQUEST FOR ALTERNATIVE ANO2-R&R-005 ATTACHMENT 2 PROPOSED ALTERNATIVE FOR PREEMPTIVE FULL STRUCTURAL WELD OVERLAYS 20 of 54 to ANO2-R&R-005 PROPOSED ALTERNATIVE FOR PREEMPTIVE FULL STRUCTURAL WELD OVERLAYS 1.0 GENERAL REQUIREMENTS (a) Weld overlays may be applied to the 82/182 dissimilar metal welds joining carbon steel (P-No. 1) to stainless steel (P-No. 8) and similar metal welds joining stainless steel (P-No. 8) to stainless steel (P-No. 8).

(b) Weld overlay filler metal shall be austenitic Nickel Alloy 52M (ERNiCrFe-7A) filler metal having a chromium content of at least 28%. The weld overlay is applied 360° around the circumference of the item, and shall be deposited using a Welding Procedure Specification (WPS) for groove welding, qualified in accordance with the Construction Code and Owner's Requirements, and identified in the Repair/Replacement Plan. As an alternative to the post-weld heat treatment requirements of the Construction Code and Owner's requirements, the provisions for "Ambient Temperature Temperbead Welding" may be used on the ferritic nozzle as described in Attachment 3.

(c) Prior to deposition of the weld overlay, the surface to be repaired shall be examined by the liquid penetrant method. Indications larger than 1/16 inch (1.5 mm) shall be removed, reduced in size, or corrected in accordance with the following requirements.

(1) One or more layers of weld metal shall be applied to seal unacceptable indications in the area to be repaired with or without excavation. The thickness of these layers shall not be used in meeting weld reinforcement design thickness requirements. Peening the unacceptable indication prior to welding is permitted.

(2) If correcting indications identified in 1.0(c) is required, the area where the weld overlay is to be deposited, including any local repairs or initial weld overlay layer, shall be examined by the liquid penetrant method. The area shall contain no indications greater than 1/16 in. (1.5 mm) prior to applying the structural layers of the weld overlay.

(d) Weld overlay deposits shall meet the following requirements:

The austenitic nickel alloy weld overlay shall consist of at least two weld layers deposited with a filler material such as identified in 1.0(b) above. The first layer of weld metal deposited may not be credited toward the required thickness.

Alternatively, a diluted layer may be credited toward the required thickness, provided the portion of the layer over the austenitic base material, austenitic weld, and the associated dilution zone from an adjacent ferritic base material contains at least 24% chromium. The chromium content of the deposited weld metal may be determined by chemical analysis of the production weld or from a representative coupon taken from a mockup prepared in accordance with the WPS for the production weld.

(e) A new weld overlay shall not be installed on top of an existing weld overlay that has been in service.

21 of 54 to ANO2-R&R-005 2.0 CRACK GROWTH CONSIDERATIONS AND DESIGN (a) Crack Growth Because the full structural weld overlays are being installed preemptively, a flaw with a depth of 75% and a circumference of 3600 will be assumed. The size of the assumed flaws shall be projected to the end of the design life of the overlay.

Crack growth, including both stress corrosion and fatigue crack growth, shall be evaluated in the materials in accordance with IWB-3640. If the flaw is at or near the boundary of two different materials, evaluation of flaw growth in both materials will be performed.

(b) Structural Desiqn The design of the weld overlay shall be analyzed and shown to satisfy the following, using the assumptions and flaw characterization restrictions in 2.0(a):

(1) The axial length and end slope of the weld overlay shall cover the weld and the heat affected zones (HAZs) on each side of the weld, and shall provide for load redistribution from the item into the weld overlay and back into the item without violating applicable stress limits of NB-3200. Any laminar flaws in the weld overlay shall be evaluated in the analysis to ensure that load redistribution complies with the above. These requirements will usually be satisfied if the weld overlay full thickness length extends axially beyond the projected flaw by at least 0.75*4Rt, where "R" is the outer radius of the item and "t" is the nominal wall thickness of the item.

(2) Unless specifically analyzed in accordance with 2.0(b)(1) above, the end transition slope of the overlay shall not exceed 450. A slope of not more than 1:3 is recommended.

(3) Because the full structural weld overlays are being installed preemptively, flaws shall be assumed to be 100% through the original wall thickness for the entire circumference.

(4) The overlay design thickness of items meeting 2.0(b)(3) above shall be based on the measured diameter using only the weld overlay thickness conforming to the deposit analysis requirements of 1.0(d) above. The combined wall thickness at the weld overlay, any planar flaws in the weld overlay, the flaw size assumptions of 2.0(b)(3) above, and the effects of any discontinuity (e.g., another weld overlay or reinforcement for a branch connection) within a distance of 2.5/Rt from the toes of the weld overlay, shall be evaluated and shall meet the requirements of IWB-3640.

Note: Although planar flaws are considered in the IWB-3640 evaluation of the combined wall thickness in paragraph 2.0(b)(4), these planar flaws must meet the acceptance standards of IWB-3500 as required by Attachment 2, paragraphs 3.0(a) and (b) of ANO2-R&R-005.

22 of 54 to ANO2-R&R-005 (5) The effects of any changes in applied loads, as a result of weld shrinkage from the entire overlay,, on other items in the piping system (e.g., support loads and clearances, nozzle loads, changes in system flexibility and weight due to the weld overlay) shall be evaluated. Existing flaws previously accepted by analytical evaluation shall be evaluated in accordance with IWB-3640.

3.0 EXAMINATION AND INSPECTION In lieu of all other examination requirements, the examination requirements proposed herein shall be met. Nondestructive examination (NDE) methods shall be in accordance with IWA-2200, except as specified herein. NDE personnel shall be qualified in accordance with IWA-2300. Ultrasonic examination procedures and personnel shall be qualified in accordance with Appendix VIII,Section XI.

(a) Acceptance Examination (1) The weld overlay shall have a surface finish of 250 micro-inches (6.3 micrometers) RMS or better and a flatness that is sufficient to allow for adequate examination in accordance with procedures qualified per Appendix VIII. The weld overlay shall be examined to verify acceptable configuration.

(2) The weld overlay and the adjacent base material for at least 1/2 inch (13 mm) from each side of the weld shall be examined using the liquid penetrant method. The weld overlay shall satisfy the surface examination acceptance criteria for welds of the Construction Code or ASME Section III, NB-5300.

The adjacent base metal shall satisfy the surface examination acceptance criteria for base material of the Construction Code or ASME Section III, NB-2500. If ambient temperature temperbead welding is used, liquid penetrant examination shall be conducted at least 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after completing the third layer of the weld overlay.

(3) The examination volume A-B-C-D in Figure 1 (below) shall be ultrasonically examined to assure adequate fusion (i.e., adequate bond) with the base metal and to detect welding flaws, such as inter-bead lack of fusion, inclusions, or cracks. The interface C-D shown between the overlay and the weld includes the bond and the HAZ from the overlay. If ambient temperature temperbead welding is used, the ultrasonic examination shall be conducted at least 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after completing the third layer of the weld overlay. Planar flaws shall meet the preservice examination standards of Table IWB-3514-2. In applying the acceptance standards, wall thickness "tw" shall be the thickness of the weld overlay. Laminar flaws shall meet the following:

(i) Laminar flaws shall meet the acceptance standards of Table IWB-3514-3 with the additional limitation that the total laminar flaw shall not exceed 10% of the weld surface area and that no linear dimension of the laminar flaw area exceeds 3.0 inches (76 mm).

23 of 54 to ANO2-R&R-005 (ii) The reduction in coverage of the examination volume in Figure 1 due to laminar flaws shall be less than 10%. The dimensions of the un-inspectable volume are dependent on the coverage achieved with the angle beam examination of the overlay.

(iii) Any un-inspectable volume in the weld overlay shall be assumed to contain the largest radial planar flaw that could exist within that volume.

This assumed flaw shall meet the inservice examination standards of Table IWB-3514-2. Alternately, the assumed flaw shall be evaluated and shall meet the requirements of IWB-3640. Both axial and circumferential planar flaws shall be assumed.

(4) If a weld overlay does not meet the acceptance 9tandards specified in 3.0(a)(2) and (3)above, the weld overlay shall be corrected by a repair/replacement activity in accordance with IWA-4000.

(5) After completing welding activities, affected restraints, supports, and snubbers shall be VT-3 visually examined to verify that design tolerances are met.

(b) Preservice Inspection NOTE The examination volume A-B-C-D of Figure 2 for each weld overlay will be examined using ultrasonic examination procedures and personnel qualified in accordance with ASME Section Xl, Appendix VIII (as implemented through PDI).

However, as of the submittal date of this request, PDI-qualified procedures to examine the upper 25% of the cast austenitic stainless steel are not available.

Therefore, unless PDI procedures are qualified in time to support the preservice examinations required by this attachment, Entergy will perform a "best effort"'

preservice examination of the cast stainless steel region.

(1) The examination volume A-B-C-D in Figure 2 (below) shall be ultrasonically examined. The angle beam shall be directed perpendicular and parallel to the piping axis, with scanning performed in four directions to locate and size any cracks that might have propagated into the upper 25% of the weld, base material, or into the weld overlay. If ambient temperature temperbead welding is used, the ultrasonic examination shall be conducted at least 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after completing the third layer of the weld overlay.

(2) The preservice examination acceptance standards of Table IWB-3514-2 shall be met for the weld overlay. In applying the acceptance standards, wall thickness, tw, shall be the thickness of the weld overlay. Cracks in the outer 25% of the base metal shall meet the design analysis requirements of 2.0 above.

24 of 54 to AN02-R&R-005 (c) Inservice Inspection NOTE The examination volume A-B-C-D of Figure 2 for each weld overlay will be examined using ultrasonic examination procedures and personnel qualified in accordance with ASME Section Xl, Appendix VIII (as implemented through PDI).

However, as of the submittal date of this request, PDI-qualified procedures to examine the upper 25% of the cast austenitic stainless steel are not available.

Therefore, until such procedures are qualified, Entergy will perform "best effort" inservice inspections of this region. Once qualified, Entergy will implement these PDI procedures at the next scheduled inservice inspection as required by paragraph 3.0(c) of this attachment.

(1) The weld overlay examination volume A-B-C-D in Figure 2 shall be added to the inspection plan and shall be ultrasonically examined during the first or second refueling outage following application.

(2) The weld overlay examination volume in Figure 2 shall be ultrasonically examined to determine if any new or existing cracks have propagated into the upper 25% of the weld or base material or into the overlay. The angle beam shall be directed perpendicular and parallel to the piping axis, with scanning performed in four directions.

(3) The acceptance standards for the ultrasonic examination of the weld overlay are specified in Table IWB-3514-2. However, if the weld overlay fails to meet the acceptance standards of Table IWB-3514-2, it can be accepted based on an analytical evaluation meeting the requirements and acceptance criteria of IWB-3600. However, flaws identified as primary water stress corrosion cracking (PWSCC) cannot be accepted by an IWB-3600 analytical evaluation. Cracks in the outer 25% of the base metal shall meet the design analysis requirements of 2.0 above.

(4) Weld overlay examination volumes that show no indication of crack growth or new cracking shall be placed into a population to be examined on a sample basis. Twenty-five percent (25%) of this population shall be examined once every ten years.

(5) If inservice examinations reveal crack growth, or new cracking, meeting the acceptance standards, the weld overlay examination volume shall be reexamined during the first or second refueling outage following discovery of the growth or new cracking. Weld overlay examination volumes that show no additional indication of crack growth or new cracking shall be placed into a population to be examined on a sample basis. Twenty-five percent (25%) of this population shall be examined once every ten years.

(6) For weld overlay examination volumes that fail to meet the acceptance criteria as described in 3.0(c)(3) above, the weld overlay shall be removed, including the original defective weld, and the item shall be corrected by a repair/replacement activity in accordance with IWA-4000.

25 of 54 to ANO2-R&R-005 (d) Additional Examinations If inservice examinations reveal an unacceptable indication, crack growth into the weld overlay design thickness, or axial crack growth beyond the specified examination volume, additional weld overlay examination volumes, equal to the number scheduled for the current inspection period, shall be examined prior to return to service. If additional unacceptable indications are found in the second sample, 50% of the total population of weld overlay examination volumes shall be examined prior to operation. If additional unacceptable indications are found, the entire remaining population of weld overlay examination volumes shall be examined prior to return to service.

4.0 PRESSURE TESTING A system leakage test shall be performed in accordance with IWA-5000.

5.0 DOCUMENTATION Use of this alternative shall be .documented on Form NIS-2. Alternatively, it may be documented on Form NIS-2A as described in Code Case N-532-1 or any other revision of this case based on appropriate NRC approval.

26 of 54 to ANO2-R&R-005 A B D

t i \

......... EExamination Volume A-B-C-D FIGURE 1 ACCEPTANCE EXAMINATION VOLUME 27 of 54 to ANO2-R&R-005 1/2 inch (13 mm) 1/2 inch (13 mm) (see note) i As-Found Flaw Examination Volume A-B-C-D NOTE For axial or circumferential flaws, the axial extent of the examination volume shall extend at least 1/2 inch (13 mm) beyond the as-found flaw and at least 1/2 inch (13 mm) beyond the toes of the original weld, including weld end butter, where applied.

FIGURE 2 PRESERVICE AND INSERVICE EXAMINATION VOLUME 28 of 54

REQUEST FOR ALTERNATIVE ANO2-R&R-005 ATTACHMENT 3 PROPOSED AMBIENT TEMPERATURE TEMPERBEAD TECHNIQUE 29 of 54 to ANO2-R&R-005 PROPOSED AMBIENT TEMPERATURE TEMPERBEAD TECHNIQUE 1.0 GENERAL REQUIREMENTS (a) This appendix applies to dissimilar austenitic filler metal welds joining P-No. 8 material to P-No. 1 material.

(b) The maximum area of an individual weld overlay based on the finished surface over the ferritic base material shall be 500 square inches.

(c) Repair/replacement activities on a dissimilar-metal weld in accordance with this attachment are limited to those along the fusion line of a nonferritic weld to ferritic base material on which 1/8 inch, or less of nonferritic weld deposit exists above the original fusion line.

(d) If a defect penetrates into the ferritic base material, repair of the base material, using a nonferritic weld filler material, may be performed in accordance with this attachment, provided the depth of repair in the base material does not exceed 3/8 inch.

(e) Prior to welding the area to be welded and a band around the area of at least 1-1/2 times the component thickness or 5 inches, whichever is less, shall be at least 50°F (100C).

(f) Welding materials shall meet the Owner's Requirements and the Construction Code and Cases specified in the Repair/Replacement Plan. Welding materials shall be controlled so that they are identified as acceptable until consumed.

(g) Peening may be used, except on the initial and final layers.

2.0 WELDING QUALIFICATIONS Welding procedures and welding operators shall be qualified in accordance with ASME Section IX and the requirements of Sections 2.1 and 2.2 below.

2.1 Procedure Qualification (a) The base materials for the welding procedure qualification shall be of the same P-Number and Group Number, as the materials to be welded. The materials shall be post-weld heat treated to at least the time and temperature that was applied to the materials being welded.

(b) The root width and included angle of the cavity in the test assembly shall be no greater than the minimum specified for the repair.

(c) The maximum interpass temperature for the first three layers of the test assembly shall be 150OF (66 0 C).

30 of 54 to ANO2-R&R-005 (d) The test assembly cavity depth shall be at least 1 inch (25 mm). The test assembly thickness shall be at least twice the test assembly cavity depth.

The test assembly shall be large enough to permit removing the required test specimens. The test assembly dimensions surrounding the cavity shall be at least the test assembly thickness and at least 6 inches (150 mm). The qualification test plate shall be prepared in accordance with Figure 1-1.

(e) Ferritic base material for the procedure qualification test shall meet the impact test requirements of the Construction Code and Owner's Requirements. If such requirements are not in the Construction Code and Owner's Requirements, the impact properties shall be determined by Charpy V-notch impact tests of the procedure qualification base material at or below the lowest service temperature bf the item to be repaired. The location and orientation of the test specimens shall be similar to those required in (f) below, but shall be in the base metal.

(f) Charpy V-notch tests of the ferritic heat-affected zone (HAZ) shall be performed at the same temperature as the base metal test of (e) above.

Number, location, and orientation of test specimens shall be as follows:

(1) The specimens shall be removed from a location as near as practical to a depth of one-half the thickness of the deposited weld metal. The coupons for HAZ impact specimens shall be taken transverse to the axis of the weld and etched to define the HAZ. The notch of the Charpy V-notch specimen shall be cut approximately normal to the material surface in such a manner as to include as much HAZ as possible in the resulting fracture. Where the material thickness permits, the axis of a specimen shall be inclined to allow the root of the notch to be aligned parallel to the fusion line.

(2) If the test material is in the form of a plate or a forging, the axis of the weld shall be oriented parallel to the principal direction of rolling or forging.

(3) The Charpy V-notch test shall be performed in accordance with SA-370.

Specimens shall be in accordance with SA-370, Fig. 11, Type A. The test shall consist of a set of three full-size 10 mm X 10 mm specimens.

The lateral expansion, percent shear, absorbed energy, test temperature, orientation and location of all test specimens shall be reported in the Procedure Qualification Record.

(g) The average lateral expansion value of the three HAZ Charpy V-notch specimens shall be equal to or greater than the average lateral expansion value of the three unaffected base metal specimens.

2.2 Performance Qualification Welding operators shall be qualified in accordance with ASME Section IX.

31 of 54 to ANO2-R&R-005 3.0 WELDING PROCEDURE REQUIREMENTS The welding procedure shall include the following requirements.

(a) The weld metal shall be deposited by the automatic or machine gas tungsten arc welding (GTAW) process.

(b) Dissimilar metal welds shall be made using F-No. 43 weld metal (QW-432) for P-No. 8 to P-No. 1 weld joints.

(c) The area to be welded shall be buttered with a deposit of at least three layers to achieve at least 1/8 inch (3mm) overlay thickness with the heat input for each layer controlled to within +/-10% of that used in the procedure qualification test. Particular care shall be taken in the placement of the weld layers of the austenitic overlay filler material at the toe of the overlay to ensure that the HAZ and ferritic base metal are tempered. Subsequent layers shall be deposited with a heat input not exceeding that used for layers beyond the third layer in the procedure qualification.

(d) The maximum interpass temperature for field applications shall be 350°F (1800C) for all weld layers regardless of the interpass temperature used during qualification.

(e) The preheat and interpass temperatures will be measured using a contact pyrometer. In the first three layers, the interpass temperature will be measured every three to five passes. After the first three layers, interpass temperature measurements will be taken every six to ten passes for the subsequent layers.

Contact pyrometers will be calibrated in accordance with approved calibration and control program documents.

(f) Particular care shall be given to ensure that the weld region is free of all potential sources of hydrogen. The surfaces to be welded, filler metal, and shielding gas shall be suitably controlled.

32 of 54 to ANO2-R&R-005 Trarwyowt BMWSit Fto~aftd Bwtlon Tensile Sd vId Ifollva 111011 Troallwtw Sw. S.d___________

WaWL VWuTlit.

NOTE Base metal Charpy impact specimens are not shown.

FIGURE 1-1 QUALIFICATION TEST PLATE 33 of 54

REQUEST FOR ALTERNATIVE ANO2-R&R-005 ATTACHMENT 4 COMPARISON OF ASME CODE CASE N-504-2 AND APPENDIX Q OF ASME SECTION XI WITH THE PROPOSED ALTERNATIVE OF ATTACHMENT 2 FOR PREEMPTIVE FULL STRUCTURAL WELD OVERLAYS 34 of 54 to ANO2-R&R-005 COMPARISON OF ASME CODE CASE N-504-2 AND APPENDIX Q OF ASME SECTION XI WITH THE PROPOSED ALTERNATIVE OF ATTACHMENT 2 FOR PREEMPTIVE FULL STRUCTURAL WELD OVERLAYS Code Case N-504-2 and Appendix Q of ASME Section XI Proposed Alternative, of Attachment 2 Code Case N-504-2 provides requirements for reducing a defect to a The proposed alternative of Attachment 2 provides requirements for flaw of acceptable size by deposition of weld reinforcement (weld installing a preemptive full structural weld overlay by depositing weld overlay) on the outside surface of the pipe using austenitic stainless reinforcement (weld overlay) on the outside surface of the item using Nickel steel filler metal as an alternative to defect removal. Code Case Alloy 52M filler metal. Attachment 2 is applicable to DMWs associated with N-504-2 is applicable to austenitic stainless steel piping only. ferritic and austenitic stainless steel materials. It is also applicable to According to Regulatory Guide 1.147, the provisions of Non- similar metal welds in austenitic stainless steels. The proposed alternative mandatory Appendix Q of ASME Section Xl must also be met when of Attachment 2 is based on Code Case N-740.

using this Case. Therefore, the Code Case N-504-2 requirements presented below have been supplemented by Appendix Q of ASME Section Xl.

General Requirements 1.0 General Requirements Code Case N-504-2 and Appendix Q are only applicable to P-No. 8 As specified in paragraph 1.0(a) of Attachment 2, the proposed alternative austenitic stainless steels. is applicable to dissimilar metal 82/182 welds joining P-No. 1 to P-No. 8 materials. It is also applicable to austenitic stainless steel welds joining P-No. 8 materials.

Basis: Code Case N-504-2 and Appendix Q are applicable to austenitic weld overlays of P-No. 8 austenitic stainless steel materials. Based on Code Case N-740, the proposed alternative of Attachment 2 was specifically written to address the application of weld overlays over dissimilar metal welds and austenitic stainless steel welds.

According to paragraph (b) of Code Case N-504-2 as supplemented The weld filler metal and procedure requirements of Attachment 2, by Appendix Q, weld overlay filler metal shall be low carbon (0.035% paragraph 1.0(b) are equivalent to Code Case N-504-2 and Appendix Q max) austenitic stainless steel applied 360 degrees around the except as noted below:

circumference of the pipe, and shall be deposited using a Welding Procedure Specification for groove welding, qualified in accordance

Weld overlay filler metal shall be austenitic Nickel Alloy 52M with the Construction Code and Owners Requirements and (ERNiCrFe-7A) filler metal which has a chromium content of at least identified in the Repair/Replacement Plan. 28%.

35 of 54 to ANO2-R&R-005 Code Case N-504-2 and Appendix Q of ASME Section X1 Proposed Alternative of Attachment 2

+

As an alternative to post-weld heat treatment, the provisions for ambient temperature temperbead welding may be used on the ferritic nozzle as described in Attachment 3.

Basis: The weld overlay will be deposited with ERNiCrFe-7 (Alloy 52M) filler metal. It has been included into ASME Section IX as F-No. 43 filler metals. Containing 28.0 - 31.5% chromium (roughly twice the chromium content of 82/182 filler metal), this filler metal has excellent resistance to PWSCC. This point has been dearly documented in EPRI Technical Report MRP-115, Section 2.2. Regarding the WPS, paragraph 1.0(b) of Attachment 2 provides clarification that the WPS used for depositing weld overlays must be qualified as a groove welding procedure to ensure that mechanical properties of the WPS are appropriately established. Where welding is performed on ferritic nozzles, an ambient temperature temperbead WPS will be used. Suitability of an ambient temperature temperbead WPS is addressed in Section V.A.2 of this Request According to paragraph (e) of Code Case N-504-2 as supplemented The weld overlay Attachment 2 is deposited using Nickel Alloy 52M filler by Appendix Q, the weld reinforcement shall consist of at least two metal instead of austenitic stainless steel filler metals. Therefore, the basis weld layers having as-deposited delta ferrite content of at least 7.5 for crediting the first layer towards the required design thickness will be FN. The first layer of weld metal with delta ferrite content of at least based on the chromium content of the nickel alloy filler metal. According to 7.5 FN shall constitute the first layer of the weld reinforcement that paragraph 1.0(d) of Attachment 2, the first layer of Nickel Alloy 52M may be credited toward the required thickness. Alternatively, first deposited weld metal may be credited toward the required thickness layers of at least 5 FN provided the carbon content is determined by provided the portion of the layer over the austenitic base material, chemical analysis to be less than 0.02%. austenitic weld, and the associated dilution zone from an adjacent ferritic base material contains at least 24% chromium. The chromium content of the deposited weld metal may be determined by chemical analysis of the production weld or from a representative coupon taken from a mockup prepared in accordance with the WPS for the production weld.

Basis: The weld overlay will be deposited with ERNiCrFe-7 (Alloy 52M) filler metal. Credit for the first weld layer may not be taken toward the required thickness unless it has been shown to contain at least 24%

chromium. This is a sufficient amount of chromium to prevent PWSCC.

Section 2.2 of EPRI Technical Report MRP-1 15 states the following: "The only well explored effect of the compositional differences among the weld alloys on PWSCC is the influence of chromium. Buisine, et al. evaluated 36 of 54

Attachment 4 to ANO2-R&R-005 Code Case N-504-2 and Appendix Q of ASME Section Xl Proposed Alternative of Attachment 2 the PWSCC resistance of nickel-based weld metals with various chromium contents ranging from about 15% to 30% chromium. Testing was performed in doped steam and primary water. Alloy 182, with about 14.5%

chromium, was the most susceptible. Alloy 82 with 18-20% chromium took three or four times longer to crack. For chromium contents between 21 and 22%, no stress corrosion crack initiation was observed..."

Design and Crack Growth Considerations 2.0 Design and Crack Growth Considerations The design and flaw characterization provisions of Code Case N- The design and flaw evaluation provisions in the proposed alternative of 504-2, paragraphs (f) and (g) as supplemented by Appendix Q are Attachment 2, Section 2.0 are the same as Code Case N-504-2 as summarized below: supplemented in Appendix Q with the exceptions below. Note that the (i) Flaw characterization and evaluation are based on the as-found design and flaw evaluation provisions of Attachment 2 are based on i)flaw. charevacteation andtheevaltiong flare based ont s-fd postulated flaws instead of as-found flaws since the structural weld flaw. Flaw evaluation of the existing flaws is based on IWB- overlays are being installed preemptively.

3640 for the design life.

" Multiple circumferential flaws shall be treated as one flaw of For crack growth evaluations, a flaw with a depth of 75% and a M

length circumferentofl qultile t shallsb traedinasvione flaws o circumference of 3600 will be assumed. The size of the assumed flaws shall be projected to the end of the design life of the overlay. Crack

" Circumferential flaws are postulated as 100% through-wall growth, including both stress corrosion and fatigue crack growth, shall for the entire circumference with one exception. When the be evaluated in the materials in accordance with IWB-3640. If the flaw combined length of circumferential flaws does not exceed is at or near the boundary of two different materials, evaluation of flaw 10% of the circumference, the flaws are only assumed to be growth in both materials is required.

100% through-wall for the combined length of the flaws. design, flaws shall be assumed to be 100% through the original wall

" For axial flaws 1.5 inches or longer, or for five or more axial thickness for the entire circumference.

flaws of any length, the flaws shall be assumed to be 100% Basis: Preemptive weld overlays are being installed in accordance with through-wall for the axial length of the flaw and entire Attachment 2 to proactively address and mitigate any future PWSCC circumference of the pipe. issues with the subject welds. Because these weld overlays are being (ii) For four or fewer axial flaws less than 1.5 inches in length, the installed preemptively and not as a repair, postulated flaws are being weld overlay thickness need only consist of two or more layers assumed. Regarding the crack growth analysis, a flaw originating from the of weld metal meeting the deposit analysis requirements. inside diameter, with a depth of 75%, and a circumference of 360 degrees will be assumed. A 75% through-wall flaw is the largest flaw that could (iii) The axial length and end slope of the weld overlay shall cover remain undetected. A preservice volumetric examination will be performed the weld and HAZs on each side of the weld, and shall provide after application of the weld overlay using an ASME Section Xl, Appendix for load redistribution from the item into the weld overlay and VIII [as implemented through PDI] examination procedure. This 37 of 54 to ANO2-R&R-005 Code Case N-504-2 and Appendix Q of ASME Section XI Proposed Alternativeof Attachment 2 back into the item without violating applicable stress limits of the examination will verify that there is no cracking in the upper 25% of the Construction Code. Any laminar flaws in the weld overlay shall original weld and base material. The preservice examination will also be evaluated in the analysis to ensure that load redistribution demonstrate that the assumption of a 75% through-wall crack is complies with the above. These requirements are usually met if conservative. However, if any crack-like flaws are identified in the upper the weld overlay extends beyond the projected flaw by at least 25% of the original weld or base material by the preservice examination, 0.75 (Rt) 1 2. then the as-found flaw (postulated 75% through-wall flaw plus the portion of the flaw in the upper 25%) will be used for the crack growth analysis. With (iv) Unless specifically analyzed, the end transition slope of the regard to design, flaws are considered to be 100% through the original overay shall not exceed 450, and a slope of not more than 1:3 weld and no structural credit is taken for the weld. All other requirements is recommended. -are equivalent to Code Case N-504-2 as supplemented by Appendix Q.

(v) The overlay design thickness of items shall be based on the measured diameter, using only the weld overlay thickness conforming to the deposit analysis requirements. The combined wall thickness at the weld overlay, any planar flaws in the weld overlay, and the effects of any discontinuity (e.g.,

another weld overlay or reinforcement for a branch connection) within a distance of 0.75 (Rt)1 /2 from the toes of the weld overlay, shall be evaluated and meet the requirements of IWB-,

IWC-, or IWD-3640.

(vi) The effects of any changes in applied loads, as a result of weld shrinkage or existing flaws previously accepted by analytical evaluation shall be evaluated in accordance with IWB-3640, IWC-3640, or IWD-3640, as applicable.

Examination and Inspection 3.0 Examination and Inspection Code Case N-504-2 does not include requirements for acceptance Attachment 2, Section 3.0 of the proposed alternative specifies examination or inservice examination of weld overlays. Preservice requirements applicable to weld acceptance examinations, preservice examination is addressed. However, Appendix Q, Article Q-4000 examinations, and inservice examinations.

does specify requirements applicable to weld acceptance examinations, preservice examinations, and inservice examinations.

38 of 54 to ANO2-R&R-005 Code Case N-504-2 and Appendix Q of ASME Section Xi Proposed Alternative of Attachment 2 Acceptance Examination 3.0(a) Acceptance Examination Acceptance Examination The acceptance standards in paragraph 3.0(a)(3) of Attachment 2 are identical to those of paragraph Q-41 00(c) except that paragraph 3.0(a)(3)

Q-4100(c) states that the examination volume in Figure Q-4100-1 includes requirements and clarifications that are not included in Appendix shall be ultrasonically examined to assure adequate fusion (i.e.,

Q. First, it specifies that the ultrasonic examination shall be conducted at adequate bond) with the base metal and to detect welding flaws, least 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after completing the third layer of the weld overlay when such as inter-bead lack of fusion, inclusions, or cracks. Planar flaws ambient temperature temperbead welding is used. Secondly, it provides shall meet the preservice examination standards of Table the following clarifications:

IWB-3514-2. Laminar flaws shall meet the following:

" The interface C-D between the weld overlay and the weld includes the bond and the HAZ from the weld overlay.

In applying the acceptance standards, wall thickness "t,"shall be the thickness of the weld overlay.

As of the submittal date of this request, PDI qualified procedures to examine the upper 25% of the cast austenitic stainless steel are not available. Therefore, until procedures are qualified for inspecting cast stainless steels, Entergy will perform a "best effort" preservice inspection of this region.

Basis: Appendix Q is applicable to austenitic stainless steel materials only; therefore, ambient temperature temperbead welding would not be applicable. It is applicable to welding performed in the proposed alternative. When ambient temperature temperbead welding is performed, nondestructive examinations must be performed at least 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after completing the third layer of the weld overlay to allow sufficient time for hydrogen cracking to occur (if it is to occur). Technical justification for starting the 48-hour hold after completing the third layer of the weld overlay is provided in paragraph V.A.3.g of the request. Technical justification for the "best effort" ultrasonic examination is provided in paragraph V.A.3.c of the request The other two changes are simply clarifications that were added to ensure that the examination requirements were appropriately performed.

39 of 54 to ANO2-R&R-005 Code Case N-504-2 and Appendix Q of ASME Section XJ. Proposed Alternative of Attachment 2 Q-4100(c)(1) states that laminar flaws shall meet the acceptance The acceptance standards in paragraph 3.0(a)(3)(i) of Attachment 2 are standards of Table IWB-3514-3. identical to paragraph Q-41 00(c)(1) except that paragraph 3.0(a)(3)(i) includes the additional limitation that the total laminar flaw shall not exceed 10% of the weld surface area and that no linear dimension of the laminar flaw area exceeds 3.0 inches.

Basis: These changes were made to provide additional conservatism to the weld overlay examination and to reduce the size of the un-inspectable volume beneath a laminar flaw. See paragraph V.A.3.d of the request for additional information.

Q-4100(c)(4) allows the performance of radiography in accordance The acceptance standards in paragraph 3.0(a)(3) of Attachment 2 do not with the Construction Code as an alternative to Q-4100(c) (3). include the radiographic alternative of paragraph Q-4100(c)(4).

Basis: The UT examinations performed in accordance with the proposed alternative are in accordance with ASME Section Xl, Appendix VIII, Supplement 11 as implemented through the PDI. These examinations are considered more sensitive for detection of defects, either from fabrication or service-induced, than either ASME Section III radiographic or ultrasonic methods. Furthermore, construction type flaws have been included in the PDI qualification sample sets for evaluating procedures and personnel.

See Section V.A.3 of this request for additional justification.

Preservice Inspection 3.0(b) Preservice Inspection Q-4200(b) states that the preservice examination acceptance The acceptance standards in paragraph 3.0(b)(2) of Attachment 2 are standards of Table IWB-3514-2 shall be met for the weld overlay, identical to paragraph Q-4200(b) except paragraph 3.0(b)(2) includes the Cracks in the outer 25% of the base metal shall meet the design following statement: "In applying the acceptance standards, wall thickness, analysis requirements of Q-3000. t,, shall be the thickness of the weld overlay."

Basis: This provision is actually a clarification that the nominal wall thickness of Table IWB-3514-2 shall be considered the thickness of the weld overlay. It must be remembered that the acceptance standards were originally written for the welds identified in IWB-2500. Because IWB-2500 does not address weld overlays, this clarification was provided to avoid any potential confusion. However, defining the weld overlay thickness as the 40 of 54 to ANO2-R&R-005 Code Case N-504-2 and Appendix Q of ASME Section Xl 'Proposed Alternative of Attachment 2 nominal wall thickness of Table IWB-3514-2 has always been the practice since it literally becomes the new design wall of the piping or component nozzle.

Pressure Testing 4.0 Pressure Testing (h) The completed repair shall be pressure tested in accordance The pressure testing requirements of Section 4.0 of Attachment I are with IWA-5000. A system hydrostatic test is required if the flaw similar to paragraph (h) of Code Case N-504-2 except that only a system penetrated the pressure boundary. A system leakage test may be leakage test per IWA-5000 is required.

performed if pressure boundary is not penetrated.

41 of 54

REQUEST FOR ALTERNATIVE ANO2-R&R-005 ATTACHMENT 5 TECHNICAL BASIS FOR ALTERNATIVES TO ASME CODE CASE N-638-1, AMBIENT TEMPERATURE TEMPERBEAD WELDING 42 of 54 to ANO2-R&R-005 TECHNICAL BASIS FOR PROPOSED ALTERNATIVES TO ASME CODE CASE N-638-1.

AMBIENT TEMPERA TURE TEMPERBEAD WELDING

1. BASIS FOR AREA LIMITATION CHANGE TO 500 SQUARE INCHES IWA-4500 and versions of ASME Code Case N-638 through Revision 2 contained a 100 square-inch limitation on surface area of a temperbead weld over ferritic base metal.

Code Case N-638 Revision 3 changed the surface area limitation to 500 square inches.

The 500 square-inch surface area limitation was incorporated into Code Case N-740 and is included in Attachment 3. It is anticipated that some overlays applied under this alternative will be greater than 100 square inches but less than 500 square inches.

Technical justification for allowing weld overlays on ferritic materials with surface areas up to 500 square inches is provided in the white paper supporting the changes in ASME Code Case N-638-3 and EPRI Report 1011898 (Ref. 6). The ASME white paper notes that the original limit of 100 square inches in Code Case N-638-1 was arbitrary. It cites evaluations of a 12-inch diameter nozzle weld overlay to demonstrate adequate tempering of the weld heat affected zone (HAZ) (Section 2a of the white paper), residual stress evaluations demonstrating acceptable residual stresses in weld overlays ranging from 100 to 500 square inches (Section 2b of the white paper), and service history in which weld repairs exceeding 100 square inches were NRC approved and applied to DMW nozzles in several BWR and PWR (Section 3c of the white paper) applications. Some of the cited repairs are greater than 15 years old, and have been inspected several times with no evidence of any continued degradation.

It is important to note that the above theoretical arguments and empirical data have been verified in practice by extensive field experience with temperbead weld overlays, with ferritic material coverage ranging from less than 10 square inches up to and including 325 square inches. The table below provides a partial list of such applications.

November 2006 SONGS Unit 3 PZR spray nozzle 5.1875 40 Safety/relief nozzles 8 60 PZR surge nozzle 12.75 110 November 2006 Catawba Unit 1 PZR spray nozzle 4 30 Safety/relief nozzles 6 50 PZR surge nozzle 14 120 November 2006 Oconee Unit 1 PZR spray nozzle 4.5 30 Safety/relief nozzles 4.5 30 PZR surge nozzle 10.875 105 HL Surge Nozzle 10.75 70 October 2006 McGuire Unit 2 PZR spray nozzle 4 30 Safety/relief nozzles 6 50 PZR surge nozzle 14 120 43 of 54 to ANO2-R&R-005 April 2006 Davis-Besse Hot leg drain nozzle 4 16 February 2006 SONGS Unit 2 PZR spray nozzle 8 50 Safety/relief nozzles 6 28 November 2005 Kuosheng Unit 2 Recirc. outlet nozzle 22 250 April 2004 Susquehanna Unit 1 Recirc. inlet nozzle 12 100 Recirc. outlet nozzle 28 325 November 2003 TMI Unit 1 Surge line nozzle 11.5 75 October 2003 Pilgrim Core spray nozzle 10 50 CRD return nozzle 5 20 October 2002 Peach Bottom Core spray nozzle 10 50 Recirc. outlet nozzle 28 325 Units 2 & 3 CRD return nozzle 5 20 October 2002 Oyster Creek Recirc. outlet nozzle 26 285 December 1999 Duane Arnold Recirc. inlet nozzle 12 100 June 1999 Perry Feedwater nozzle 12 100 June 1998 Nine Mile Point Unit Feedwater nozzle 12 100 2

March 1996 Brunswick Units 1 & Feedwater nozzle 12 100 2

February 1996 Hatch Unit 1 Recirc. inlet nozzle 12 100 January 1991 River Bend Feedwater nozzle 12 100 March 1986 Vermont Yankee Core spray nozzle 10 50 It can be seen from the information above that the original DMW weld overlay was applied over 20 years ago, and weld overlays with low alloy steel coverage in the 100-square inch range have been in service for 5 to 15 years. Several overlays have been applied with low alloy steel coverage significantly greater than the 100 square inches. These overlays have been examined with PDI qualified techniques, in some cases multiple times, and none have shown any signs of new cracking or growth of existing cracks.

2. Clarification of Charpy V-Notch Acceptance Criteria Paragraph 2.1(j) of Code Case N-638-1 states, "The average of the three HAZ impact tests shall be equal to or greater than the average values of the three unaffected base metal tests." However, the Charpy V-notch test acceptance criteria in Code Case N-638-1 is misleading and inconsistent with the specified acceptance criteria in Section XI 44 of 54 to ANO2-R&R-005 applicable to other Class 1 components, since it implies that all three parameters - lateral expansion, absorbed energy, and percent shear fracture - must be equal to or exceed the base material values.

Code Case N-638-2 corrected paragraph 2.1(j) to state that Charpy V-notch acceptance criteria is based on the average lateralexpansion values rather than the average of all three values. This change clarified the intent of the code case and aligned its Charpy V-notch acceptance criteria with that of Sections III and Xl as demonstrated in the Code references provided below.

ASME Section III - NB-4330, Impact Test Requirements

ASME Section Xl - IWA-4620, Temperbead Welding of Similar Materials

ASME Section XI - IWA-4630, Temperbead Welding of DissimilarMaterials The Attachment 3 acceptance criteria for Charpy V-notch testing of the weld HAZ is as specified in Code Case N-638-2. The ASME Section Xl basis for this change is documented in the White Paper in ASME C&S Connect for Code Case N-638-2.

45 of 54

REQUEST FOR ANO2-R&R-005 ATTACHMENT 6 COMPARISON OF ASME SECTION XI, APPENDIX VIII, SUPPLEMENT 11 TO PERFORMANCE DEMONSTRATION INITIATIVE (PDI) 46 of 54 to ANO2-R&R-005 COMPARISON OF ASME SECTION Xl APPENDIX VIII SUPPLEMENT 11 TO PERFORMANCE DEMONSTRATION INITIATIVE (PDI) 1.0 SPECIMEN REQUIREMENTS 1.1 General. The specimen set shall conform to the following No Change requirements.

(b) The specimen set shall consist of at least three specimens (b) The specimen set shall consist of at least three specimens having having different nominal pipe diameters and overlay thicknesses. different nominal pipe diameters and overlay thicknesses. They shall They shall include the minimum and maximum nominal pipe include the minimum and maximum nominal pipe diameters for which the diameters for which the examination procedure is applicable. Pipe examination procedure is applicable. Pipe diameters within a range of 0.9 diameters within a range of 0.9 to 1.5 times a nominal diameter to 1.5 times a nominal diameter shall be considered equivalent. If the shall be considered equivalent. If the procedure is applicable to procedure is applicable to pipe diameters of 24 inches or larger, the pipe diameters of 24 in. or larger, the specimen set must include at specimen set must include at least one specimen 24 inches or larger but least one specimen 24 in. or larger but need not include the need not include the maximum diameter. The specimen set shall include maximum diameter. The specimen set must include at least one specimens with overlays not thicker than 0.1 inch more than the minimum specimen with overlay thickness within -0.1 in. to +0.25 in. of the thickness, nor thinner than 0.25 inch of the maximum nominal overlay maximum nominal overlay thickness for which the procedure is thickness for which the examination procedure is applicable.

applicable. Basis: To avoid confusion, the overlay thickness tolerance contained in the last sentence was reworded.

(d) Flaw Conditions (1) Base metal flaws. All flaws must be cracks in or near the butt (1) Base metal flaws. All flaws must be in or near the butt weld heat-weld heat-affected zone, open to the inside surface, and extending affected zone, open to the inside surface, and extending at least 75%

at least 75% through the base metal wall. Flaws may extend 100% through the base metal wall. Intentional overlay fabrication flaws shall not through the base metal and into the overlay material; in this case, interfere with ultrasonic detection or characterization of the base metal intentional overlay fabrication flaws shall not interfere with flaws. Specimens containing IGSCC shall be used when available. At least ultrasonic detection or characterization of the cracking. Specimens 70% of the flaws in the detection and sizing tests shall be cracks and the containing IGSCC shall be used when available, remainder shall be alternative flaws. Alternative flaw mechanisms, if used, shall provide crack-like reflective characteristics and shall be limited by the following:

47 of 54 to ANO2-R&R-005 Appendix Vill Supplement FuIStructural 11: Qulfcto Overlaid Wrought Austeniticeurmnsfor~

PipingWelds = The P!oposed Alternative PDI to Program:

S upplement 11 Requirements (a) The use of Alternative flaws shall be limited to when the implantation of cracks produces spurious reflectors that are uncharacteristic of actual flaws.

(b) Flaws shall be semi-elliptical with a tip width of less than or equal to 0.002 inch.

Basis: Paragraph 1.1 (d)(1) requires that all base metal flaws be cracks.

Implanting a crack requires excavation of the base material on at least one side of the flaw. While this may be satisfactory for ferritic materials, it does not produce a useable axial flaw in austenitic materials because the sound beam, which normally passes only through base material, must now travel through weld material on at least one side, producing an unrealistic flaw response. To resolve this issue, the PDI program revised this paragraph to allow use of alternative flaw mechanisms under controlled conditions. For example, alternative flaws shall be limited to when implantation of cracks precludes obtaining an effective ultrasonic response, flaws shall be semi-elliptical with a tip width of less than or equal to 0.002 inch, and at least 70% of the flaws in the detection and sizing test shall be cracks and the remainder shall be alternative flaws.

The statement "intentional overlay fabrication flaws shall not interfere with ultrasonic detection or characterization of the base metal flaws" was included into paragraph 1.1(d)(1). Additionally, to avoid confusion, the phrase "and the remainder shall be alternate flaws" was added to the second to last sentence of this paragraph.

48 of 54 to ANO2-R&R-005 (e) Detection Specimens (1) At least 20% but less than 40% of the flaws shall be oriented (1) At least 20% but less than 40% of the base metal flaws shall be within +20 deg. of the pipe axial direction. The remainder shall be oriented within +200 of the pipe axial direction. The remainder shall be oriented circumferentially. Flaws shall not be open to any surface to oriented circumferentially. Flaws shall not be open to any surface to which which the candidate has physical or visual access. The rules of the candidate has physical or visual access.

IWA-3300 shall be used to determine whether closely spaced flaws should be treated as single or multiple flaws. Basis: The requirement for axially oriented overlay fabrication flaws in paragraph 1.1 (e)(1) was excluded from the PDI Program as an improbable scenario. Weld overlays are typically applied using automated Gas Tungsten Arc Welding techniques with the filler metal being applied in a circumferential direction. Because resultant fabrication induced discontinuities would also be expected to have major dimensions oriented in the circumferential direction axial overlay fabrication flaws are unrealistic.

The requirement for using IWA-3300 for proximity flaw evaluation in paragraph 1.1 (e)(1) was excluded, instead, indications will be sized based on their individual merits.

(2) Specimens shall be divided into base and overlay grading units. (2) Specimens shall be divided into base metal and overlay fabrication Each specimen shall contain one or both types of grading units. grading units. Each specimen shall contain one or both types of grading units. Flaws shall not interfere with ultrasonic detection or characterization of other flaws.

(a)(1) A base grading unit shall include at least 3 in. of the length of (a)(1) A base metal grading unit includes the overlay material and the outer the overlaid weld. The base grading unit includes the outer 25% of 25% of the original overlaid weld. The base metal grading unit shall extend the overlaid weld and base metal on both sides. The base grading circumferentially for at least 1 inch and shall start at the weld centerline and unit shall not include the inner 75% of the overlaid weld and base be wide enough in the axial direction to encompass one half of the original metal overlay material, or base metal-to-overlay interface, weld crown and a minimum of 0.50 inch of the adjacent base material.

Basis: The phrase "and base metal on both sides", was inadvertently included in the description of a base metal grading unit. The PDI program intentionally excludes this requirement because some of the qualification samples include flaws on both sides of the weld. This paragraph was also modified to require that a base metal grading unit include at least 1 inch of the length of the overlaid weld, rather than 3 inches.

49 of 54 to ANO2-R&R-005 The Proposed Alternative to Supplement 11 Requirements (a)(2) When base metal cracking penetrates into the overlay (a)(2) When base metal flaws penetrate into the overlay material, the base material, the base grading unit shall include the overlay metal within metal grading unit shall not be used as part of any overlay fabrication 1 in. of the crack location. This portion of the overlay material shall grading unit.

not be used as part of any overlay grading unit.

(a)(3) When a base grading unit is designed to be unflawed, at (a)(3) Sufficient unflawed overlaid weld and base metal shall exist on all least 1 in. of unflawed overlaid weld and base metal shall exist on sides of the grading unit to preclude interfering reflections from adjacent either side of the base grading unit. The segment of weld length flaws.

used in one base grading unit shall not be used in another base Basis: This paragraph was modified to require sufficient unflawed overlaid grading unit. Base grading units need not be uniformly spaced weld and base metal to exist on all sides of the grading unit to preclude around the specimen. interfering reflections from adjacent flaws, rather than the 1 inch requirement.

(b)(1) An overlay grading unit shall include the overlay material and (b)(1) An overlay fabrication grading unit shall include the overlay material the base metal-to-overlay interface of at least 6 square inch. The and the base metal-to-overlay interface for a length of at least 1 inch.

overlay grading unit shall be rectangular, with minimum dimensions Basis: This paragraph was modified to define an overlay fabrication of 2 inches. grading unit as including the overlay material and the base metal-to-overlay interface for a length of at least 1 inch, rather than the 6 square-inch requirement.

(b)(2) An overlay grading unit designed to be unflawed shall be (b)(2) Overlay fabrication grading units designed to be unflawed shall be surrounded by unflawed overlay material and unflawed base metal- separated by unflawed overlay material and unflawed base metal-to-overlay to-overlay interface for at least 1 in. around its entire perimeter. The interface for at least 1 in. at both ends. Sufficient unflawed overlaid weld specific area used in one overlay grading unit shall not be used in and base metal shall exist on both sides of the overlay fabrication grading another overlay grading unit. Overlay grading units need not be unit to preclude interfering reflections from adjacent flaws. The specific spaced uniformly about the specimen. area used in one overlay fabrication grading unit shall not be used in another overlay fabrication grading unit. Overlay fabrication grading units need not be spaced uniformly about the specimen.

Basis: This paragraph states that overlay fabrication grading units designed to be unflawed shall be separated by unflawed overlay material and unflawed base metal-to-overlay interface for at least 1 inch at both ends, rather than around its entire perimeter.

50 of 54 to ANO2-R&R-005

~Appendix VIII Supplement 11: Qualification Requirements for PDI Program:

Full Structural Overiaid Wrought Austenitic Piping Welds The Proposed Alternative to Su'pplement 11 Requirements (b)(3) Detection sets shall be selected from Table VIII-S2-1. The (b)(3) Detection sets shall be selected from Table VIII-S2-1. The minimum minimum detection sample set is five flawed base grading units, ten detection sample set is five flawed base metal grading units, ten unflawed unflawed base grading units, five flawed overlay grading units, and base metal grading units, five flawed overlay fabrication grading units, and ten unflawed overlay grading units. For each type of grading unit, ten unflawed overlay fabrication grading units. For each type of grading the set shall contain at least twice as many unflawed as flawed unit, the set shall contain at least twice as many unflawed as flawed grading grading units. units. For initial procedure qualification, detection sets shall include the equivalent of three personnel qualification sets. To qualify new values of essential variables, at least one personnel qualification set is required.

Basis: This paragraph states that overlay fabrication grading units designed to be unflawed shall be separated by unflawed overlay material and unflawed base metal-to-overlay interface for at least 1 inch at both ends, rather than around its entire perimeter.

(f Sizing Specimen (1) The minimum number of flaws shall be ten. At least 30% of the (1) The minimum number of flaws shall be ten. At least 30% of the flaws flaws shall be overlay fabrication flaws. At least 40% of the flaws shall be overlay fabrication flaws. At least 40% of the flaws shall be open to shall be cracks open to the inside surface. the inside surface. Sizing sets shall contain a distribution of flaw dimensions to assess sizing capabilities. For initial procedure qualification, sizing sets shall include the equivalent of three personnel qualification sets.

To qualify new values of essential variables, at least one personnel qualification set is required.

(3) Base metal cracking used for length sizing demonstrations shall (3) Base metal flaws used for length sizing demonstrations shall be be oriented circumferentially. oriented circumferentially.

(4) Depth sizing specimen sets shall include at least two distinct (4) Depth sizing specimen sets shall include at least two distinct locations locations where cracking in the base metal extends into the overlay where a base metal flaw extends into the overlay material by at least material by at least 0.1 in. in the through-wall direction. 0.1 inch in the through-wall direction.

51 of 54 to ANO2-R&R-005 Appendix VIII Supplement 11: Qualification Requirements for, ' PDI Pro~gram: Rqieet Full Structural Overlaid Wrought Austenitic Pipinig Welds The Proposed Alternative to Supplement II Rqieet 2.0 CONDUCT OF PERFORMANCE DEMONSTRATION The specimen inside surface and identification shall be concealed The specimen inside surface and identification shall be concealed from the from the candidate. All examinations shall be completed prior to candidate. All examinations shall be completed prior to grading the results grading the results and presenting the results to the candidate. and presenting the results to the candidate. Divulgence of particular Divulgence of particular specimen results or candidate viewing of specimen results or candidate viewing of unmasked specimens after the unmasked specimens after the performance demonstration is performance demonstration is prohibited. The overlay fabrication flaw test prohibited. and the base metal flaw test may be performed separately.

Basis: The PDI Program revised paragraph 2.0 allowing the overlay fabrication and base metal flaw tests to be performed separately.

2.1 Detection Test Flawed and unflawed grading units shall be randomly mixed. Flawed and unflawed grading units shall be randomly mixed. Although the Although the boundaries of specific grading units shall not be boundaries of specific grading units shall not be revealed to the candidate, revealed to the candidate, the candidate shall be made aware of the candidate shall be made aware of the type or types of grading units the type or types of grading units (base or overlay) that are present (base metal or overlay fabrication) that are present for each specimen.

for each specimen.

2.2 Length Sizing Test (d) For flaws in base grading units, the candidate shall estimate the (d) For flaws in base metal grading units, the candidate shall estimate the length of that part of the flaw that is in the outer 25% of the base length of that part of the flaw that is in the outer 25% of the base metal wall wall thickness, thickness.

52 of 54 to ANO2-R&R-005 2.3 Depth Sizing Test i

For the depth sizing test, 80% of the flaws shall be sized at a (a) The depth sizing test may be conducted separately or in conjunction specific location on the surface of the specimen identified to the with the detection test.

candidate. For the remaining flaws, the regions of each specimen (b) When the depth sizing test is conducted in conjunction with the containing a flaw to be sized shall be identified to the candidate.

detection test and the detected flaws do not satisfy the requirements of The candidate shall determine the maximum depth of the flaw in 1.1 (f), additional specimens shall be provided to the candidate. The each region.

regions containing a flaw to be sized shall be identified to the candidate.

The candidate shall determine the maximum depth of the flaw in each region.

(c) For a separate depth sizing test, the regions of each specimen containing a flaw to be sized shall be identified to the candidate. The candidate shall determine the maximum depth of the flaw in each region.

3.0 ACCEPTANCE CRITERIA 3.1 Detection Acceptance Criteria.

Examination procedures, equipment, and personnel are qualified (a) Examination procedures are qualified for detection when; for detection when the results of the performance demonstration (1) All flaws within the scope of the procedure are detected and the satisfy the acceptance criteria of Table ViII-S2-1 for both detection results of the performance demonstration satisfy the acceptance criteria and false calls. The criteria shall be satisfied separately by the of Table VIII-$2-1 for false calls.

demonstration results for base grading units and for overlay grading units. (2) At least one successful personnel demonstration has been performed meeting the acceptance criteria defined in (3b).

(3) Examination equipment and personnel are qualified for detection when the results of the performance demonstration satisfy the acceptance criteria of Table VIII-S2-1 for both detection and false calls.

(4) The criteria in (2), (3) shall be satisfied separately by the demonstration results for base metal grading units and for overlay fabrication grading units.

53 of 54 to ANO2-R&R-005 Basis: The PDI Program allows procedure qualification to be performed separately from personnel and equipment qualification. Historical data indicate that, if ultrasonic detection or sizing procedures are thoroughly tested, personnel and equipment using those procedures have a higher probability of successfully passing a qualification test In an effort to increase the passing rate, PDI has elected to perform procedure qualifications separately in order to assess and modify essential variables that may affect overall system capabilities. For a procedure to be qualified, the PDI program requires three times as many flaws to be detected (or sized) as shown in Supplement 11 for the entire ultrasonic system. The personnel and equipment are still required to meet Supplement 11.

3.2 Sizing Acceptance Criteria.

+/-

(a) The RMS error of the flaw length measurements, as compared (a) The RMS error of the flaw length measurements, as compared to the to the true flaw lengths, is less than or equal to 0.75 inch. The true flaw lengths, is less than or equal to 0.75 inch. The length of base length of base metal cracking is measured at the 75% through- metal flaws is measured at the 75% through-base-metal position.

base-metal position.

(b) All extensions of base metal cracking into the overlay material This requirement is omitted.

by at least 0.1 inch. are reported as being intrusions into the Basis: The requirement for reporting all extensions of cracking into the overlay material. overlay is omitted from the PDI Program because it is redundant to the RMS calculations performed in paragraph 3.2(c), and its presence adds confusion and ambiguity to depth sizing as required by paragraph 3.2(c).

This also makes the weld overlay program consistent with the Supplement 2 depth sizing criteria.

(c) The RMS error of the flaw depth measurements, as compared (b) The RMS error of the flaw depth measurements, as compared to the to the true flaw depths, is less than or equal to 0.125 inch. true flaw depths, is less than or equal to 0.125 inch.

54 of 54

ENCLOSURE 2 CNRO-2007-00012 LICENSEE-IDENTIFIED COMMITMENTS

Enclosure 2 to CNRO-2007-00012 Page 1 of 2 LICENSEE-IDENTIFIED COMMITMENTS TYPE (Check one) SCHEDULED ONE-TIME CONTINUING COMPLETION COMMITMENT ACTION COMPLIANCE DATE

1. Entergy will submit the following information to " Within fourteen the NRC within fourteen (14) days from (14) days from completing the final ultrasonic examinations of completing the the completed weld overlays: final ultrasonic examinations of

" Weld overlay examination results the completed including a listing of indications detected. weld overlays

Disposition of all indications using the standards of ASME Section XI, IWB-3514-2 and/or IWB-3514-3 criteria and, if possible, the type and nature of the indications

A discussion of any repairs to the weld overlay material and/or base metal and the reason for the repairs.

2. Entergy will submit to the NRC a stress " Prior to entry into analysis summary demonstrating that the hot Mode 4 start-up leg piping nozzles will perform their intended from 2R19 design functions after the weld overlay installation. The stress analysis report will include results showing that the requirements of NB-3200 and NB-3600 of the ASME Code,Section III are satisfied. The stress analysis will also include results showing that the requirements of IWB-3000 of the ASME Code,Section XI, are satisfied. The results will show that the postulated crack including its growth in the nozzles will not adversely affect the integrity of the overlaid welds. This information will be submitted to the NRC prior to entry into Mode 4 start-up from ANO-2's nineteenth refueling outage (2R19).

3. Unless PDI procedures are qualified in time to / Following support the preservice examinations required installation of the by Attachment 2, Entergy will perform a "best weld overlays effort" preservice examination of the cast during 2R19.

stainless steel region.

Enclosure 2 to CNRO-2007-00012 Page 2 of 2 TYPE (Check one) SCHEDULED ONE-TIME CONTINUING COMPLETION COMMITMENT ACTION COMPLIANCE DATE,

4. Until PDI procedures are qualified to examine the upper 25% of the cast stainless steel, Entergy will perform "best effort" inservice inspections of the region shown in Figure 2 of Attachment 2. Once qualified, Entergy will implement these PDI procedures at the next scheduled inservice inspection as required by paragraph 3.0(c) of Attachment 2.

NRC Submittal Review

'Letter #: CNtO-2007-00012 Response Due: N/A Date Issued for Review: 3/20/07

Subject:

Request for Alternative ANO2-R&R-005 - Proposed Alternative to ASME Code Requirements for Weld Overlay Repairs Correspondence Preparer./ Phone #: Guy Davant / 8-433-5756 Section I Letter Concurrence and Agreement to Perform Actions CONCURRENCE

.__________....._(sign,interoffice memo, e-mail, or telecom)

POSITIONI NAME ACTION SIGNATURE Corporate Engineering Concur Programs Supervisor/

Steve Lewis ANO Supervisor, Concur See attached e-mail from R. A.

Engineering Projects Gordon.

William Sims COMMENTS Section II Correspondence Screening Does this letter contain commitments? If "yes," identify the commitments with due dates Yes [

in the submittal and in Section III. No []

Does this letter contain any information or analyses of new safety issues performed at NRC Yes []

request or to satisfy a regulatory requirement? If "yes," reflect requirement to update the No Z UFSAR in Section III Does this letter request NRC approval of a change that may/will require UFSAR, TS Bases, or Yes El other Licensing documents to be updated if approved? If "yes," reflect requirement to No [

update the applicable Licensing document in Section II1.

Does this letter require procedure changes, ifapproved? If "yes," indicate in Section III an Yes E]

action for the responsible department to determine the affected procedures; (The No [

Correspondence Preparer may indicate the specific procedures requiring revision, if known.)

Does this letter contain information certified accurate? If "yes," identify the information and Yes Z document certification in an attachment. (Attachment 9.6 may be used.) No E3

Section III Action Items Required Actions Due Date Responsible Note: Actions needed upon approval should be, captured Dept.

in the appropriateaction tracking system

1. Entergy will submit the following information to the NRC Within fourteen (14) ANO Engineering within fourteen (14) days from completing the final days from Projects ultrasonic examinations of the completed weld overlays: completing the final ultrasonic

" Weld overlay examination results including a listing examinations of the of indications detected completed weld overlays

" Disposition of all indications using the standards of ASME Section XI, IWB-3514-2 and/or IWB-3514-3 criteria and, ifpossible, the type and nature of the indications

" A discussion of any repairs to the weld overlay material and/or base metal and the reason for the repairs.

2. Entergy will submit to the NRC a stress analysis Prior to entry into ANO Engineering summary demonstrating that the hot leg piping nozzles Mode 4 start-up Projects will perform their intended design functions after the weld from 2R19 overlay installation. The stress analysis report will include results showing that the requirements of NB-3200 and NB-3600 of the ASME Code,Section III are satisfied.

The stress analysis will also include results showing that the requirements of IWB-3000 of the ASME Code, Section Xl, are satisfied. The results will show that the postulated crack including its growth in the nozzles will not adversely affect the integrity of the overlaid welds.

This information will be submitted to the NRC prior to entry into Mode 4 start-up from ANO-2's nineteenth refueling outage (2R19).

3. Unless PDI procedures are qualified in time to support Following installation ANO Engineering the preservice examinations required by Attachment 2 of of the weld overlays Projects ANO2-R&R-005, Entergy will perform a "best effort" during 2R19.

preservice examination of the cast stainless steel region.

4. Until PDI procedures are qualified to examine the upper On-going ANO Engineering 25% of the cast stainless steel, Entergy will perform "best Projects effort" inservice inspections of the region shown in Figure 2 of Attachment 2 of ANO2-R&R-005. Once qualified, Entergy will implement these PDI procedures at the next scheduled inservice inspection as required by paragraph 3.0(c) of Attachment 2.

Section IV Final Document Signoff for Submittal Correspondence Preparer Guy Davant// , 1, h* ._

Final Peer Review (optional)

Responsible Department Jerry Burford (See signed letter.)

Head

DAVANT, GUY H From: GORDON, ROBERT A Sent: Wednesday, March 21, 2007 3:02 PM To: DAVANT, GUY H; SIMS, WILLIAM D; JAMES, WILLIAM; BENNETT, STEVE A; THERIAULT, LAWRENCE; EHREN, R KIRK; LEWIS, RAYMOND S; BURFORD, FRANCIS G; WEICKS, JOSEPH G; JAMES, DALE E Cc: BRILEY, MICHAEL W; SWAIN, RONALD VANCE

Subject:

RE: CNRO200700012ghd cleaned up.pdf

Guy, William Sims concurs with this document and this email is intended to document his concurrence by me.

Please let me know if more is needed as well as when this is submitted.

All - Thanks for all the hard work.

Bob Gordon Sr. Project Manager 479-858-4086 (office) 479-964-6349 (pager) rgordon(&entergy.com

---Original

-- Message -----

From: DAVANT, GUY H Sent: Wednesday, March 21, 2007 2:29 PM To: SIMS, WILLIAM D; GORDON, ROBERT A; JAMES, WILLIAM; BENNETT, STEVE A; THERIAULT, LAWRENCE; EHREN, R KIRK; LEWIS, RAYMOND S; BURFORD, FRANCIS G; WEICKS, JOSEPH G; JAMES, DALE E Cc: BRILEY, MICHAEL W; SWAIN, RONALD VANCE

Subject:

CNR0200700012ghd cleaned up.pdf Attached is the final version of relief request ANO2-R&R-005 for weld overlay of the three hot leg DMWs. All comments have been reviewed and addressed as appropriate. It is ready for approval.

Guy

<< File: CNRO200700012ghd cleaned up.pdf >>

1

REV. 0 a EntIerEn NUCLEAR MANAGEMENT (NON)-QUALITY RELATED EN-LI-106 MANU INFORMATION USE Page 1 of I ATTACHMENT 9.5 CERTIFICATION REFERENCE FORM Letter Number: CNRO-2007-0012

Subject:

I Request for Alternative for ANO-2 Weld Overlay ANO-R&R-005 Certifiable Statement(s): (Identify location in submittal (e.g., page3, para2, sent1) OR paste in words of statement.)

Attachment 1 to letter, Objective Evidence or Basis of Peer Review: (Attach pertinent documents and sections or list document number(s) OR give basis for judgment.)

The following references were used to determine the information in Attachment 1:

0 Hot Leg A Drain Nozzle:

Nozzle Material/Size - M-2001-C10-2, Rev. 4, "Nozzle Details" ISI Weld Numbers - ISO 2CCA-32-1, Rev. 12, "RC Drain System" Safe-end Material - M-2001-C10-2, Rev. 4, "Nozzle Details" Connecting Pipe/Fitting Material - ISO 2CCA-32-1, Rev. 12, "RC Drain System"

Hot Lea A Surge Nozzle:

Nozzle Material/Size - M-2001-C10-3, Rev. 6, "Nozzle Details" ISI Weld Numbers - ISO 2BCA-1-1, Rev. N (DRN 06-1816), "Large Bore Isometric Reactor Coolant" Safe-end Material - M-2001-C10-3, Rev. 6, "Nozzle Details" Connecting Pipe/Fitting Material - M-2001-C10-7, Rev. 2, "Pipe Assembly for ANO Piping"

Hot Leaq B Shutdown Cooling Nozzle:

Nozzle Material/Size - M-2001-C10-5, Rev. 6, "Nozzle Details" ISI Weld Numbers - ISO 2CCA-25-1, Rev. 10, "SDC Discharge from RC Loop to 2CV-5086-2" Safe-end Material - M-2001-C10-5, Rev. 6, "Nozzle Details" Connecting Pipe/Fitting Material - ISO 2CCA-25-1, Rev. 10, "SDC Discharge from RC Loop to 2CV-5086-2" Individual certifying the statement(s): (Certification may be documented using electronic mail (e-mail), telecom, "sign off' sheet, or inter-office memorandum. The form of documentation should specifically identify the information being certified.)

NUCLEAR (NON)-QUALITY RELATED EN-LI-106 REV. 0 O fnteW MANAGEMENT MANUAL INFORMATION USE Page 1 of I L. D. Theriault 6-zA <L~=~ Alloy 600 3-21-07 Name Name Department Date Peer Review: (Indicate "N/A" if not used.)

NA Name Department Date

CNRO-2007-00012, Request for Alternative ANO2-R&R-005, Proposed Alternative to ASME Code Requirements for Weld Overlay Repairs

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CNRO-2007-00012, Request for Alternative ANO2-R&R-005, Proposed Alternative to ASME Code Requirements for Weld Overlay Repairs

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