Text

Inservice Inspection (Lsi) Relief Requests GG-ISI-005 Through 012 American Society of Mechanical EngineersSection XI Second 10-Year Inspection Interval Closeout
	ML091490755
Person / Time
Site:	Grand Gulf
Issue date:	05/29/2009
From:	Perino C; Entergy Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GNRO-2009/00018
	Download: ML091490755 (28)
	v • d • e

GNRO-2009/0001 8 M

May y 29, 2009 Nuclear Regulatory U.S. Nuclear Commissio Regulatory Commission ration : Document Attention: Control D Document Control Desk W

Washington, D.C. 20555-0001 20555-0001

Subject:

Inservice Inspection (lSI) Relief Requests GG-ISI-005 through u 012 American Society of of Mechanical Mechanical Engineers Secti XI Second 10-Year Engineers Section Inspection IntervalI Closeout Close Grand Gulf Nuclear Station, n, Unit 1 Docket No. 50-416 License No. NPF-29

Dear Sir or Madam:

Pursua to 10CFR50.55a(g)(5)(iii), Grand Gulf Nuclear Station (GGNS) requests relief from Pursuant erica Society of Mechanical Engineers (ASME) code American ode requirements.

requirements . The relief requests The relief are associated with lSI activities performed and identified during i the GGNS ASME Section XI second 10-Year Inservice Inspection Interval. The relief requests are based on limitations that preclude full code examination coverage for ASME code welds and components. Full code examination of the welds and components is limited because of design configurations.

The relief requests are provided as an Enclosure.

GGNS requests that NRC provide approval in accordance with 10 CFR 50.55a(g)(6)(i).

GGNS has no specific milestones or schedule for requesting NRC review and approval of thee enclosed relief requests. The enclosed relief requests are being submitted solely for the closure of Grand Gulf Second 10-Year ar Inservice Inservice Inspection Inspection Interval that wa Interval that was completed on October 22,2008 008 for for risk infor risk informed examinations andd MayMay 3131, 2008 200 for all other examinations examinations.GGNS . GGNS, Third Thi 10-year inspection nspection interval started on interval started June 11, 2008.

on June 2008. This This letter letter

, ntains no commitmen contains no commitments.

hould you Should you have have any questions regarding any questions regarding this this submittal, submittal, please please contact contact Ernest Ernest Rufus, Ruf supervisor Engineering Supervisor Programs at Engineering Programs at 601-437-6582.

60 CL P/MJL

Enclosure:

elief Requests Relief Requests GG-ISI-005 GG-ISI-005 through throng GG-ISI-012

GNRO-2009/00018 Page 2 of 2 c NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 U . S . Nuclear Regulatory Commission ATTN : Mr . Elmo E. Collins (wla)

Regional Administrator, Region IV 612 East Lamar Drive, Suite 400 Arlington, TX 76011-4005 U.S. Nuclear Nuclear Regulatory Regulatory Commission Commission ATTN ATTN:: Mr. Carl Lyon, NRR/ADRO/DORL Carl F . Lyon, (w/

NRR/ADRO/DORL (w/2)

ATTN:'N : A ADDRESSEE SEE ONLY ourier Delivery ATTN: Courier Delivery Only Only Ma Mail Stop OWFN/8 B1 11 11555 i Rockville Pike Rockv Rockville, MDM 20852-2378

S ENCLOSURE to

-20 09/00018 GNRO-2009/00018 RELIEF REQUESTS GG-ISI 0005 5 ININGWE CAT. B-A, PRESSURE RETAINING DS IIN REACTOR VESSEL WELDS GG-ISI 006 006 CAT. B-D, FULL PENE TION WELDED NOZZLES IN VESSELS f

GG-ISI 0 7 007 SIMILAR METAL CAT. B-F, PRESSURE RETAINING DISSIMILAR M WELDS IN VESSEL NOZZLES GG-ISI 008 CAT. B-G-1, PRESSURERE RETAINING BOLTING GREATER RETAINING BOLTING CREATE THAN 2 INCHES IN DIAMETE DIAMETER GG-ISI 009 CAT. B-J, PRESSURE PRESSURE RETAINING WELDS IN RETAINING WELDS IN PI PIPING GG-ISI 010 CAT.

CAT. B-K.

B-K, IINTEGRAL TEGRAL ATTACHMENTS ATTACHMENTS FORFOR CLASS 1 VESSELS, CLASS 1 PIPI VESSELS, PIPING, PUMPS, AND D VALVES VALVES GG-ISI 011 CAT. C-F-2, PRESSURE RETAINING RETAINING WELDS WELDS IIN CARBON OR LOW ALLOY STEEL STEEL PIPING PIPING GG-ISI 012 CAT. F-A, SUPPORT OTHER THAN PIPING SUPPORTS

GNRO-2009/00018 -- t:nC:losure GNRO-2009/00018 Enclosure Page Page 1I RELIEF REQUEST REQUEST GGNS-ISI-005 GGNS-ISI-005 C mponents/N umbers :

Components/Numbers: See Table C de Classes Code Classes:: ASME Code Class I References

References:

ASME Section XI 1992 Edition, Table IVVB-2500-ASME Section XI 1977 Edition with the Summer of 11979 Addenda for Ultrasonic Examinations ASME ASME Section X1 1995 1995 Edition with 1996 Addenda with 1996 ,\. ,..."."n'......... (for Ultrasonic Ultrasonic examinations examinations performed performed after after November November 22, 2002)

NRC Letter NRC Letter dated dated December December 1 12, 1996, Evaluation of 1996, Evaluation of Entergy Operations Entergy Operations Inc. Request for Authorization to Update Inservice Inspection to Inc. Request for Authorization to Update Inservice Inspection to the th 92 &

Portions Portions ofof the the 93 ASME 80iler 93 ASME Boiler & Pressure Vessel

& Pressure Vessel Code Code Sectio Section XI NRI 96-00244)

(GNRI96-00244)

NRC Letter dated January 5,2006, Use of Later Editions i and'Addenda of ASME 80iler & Pressure Vessel Code Section XI for Ultrasonic Examinations (CNRI 2006-00002)

Examination Category: 8-A

==

Description:==

Pressure Retaining Welds in Reactor Vessel Item Number(s): 81.12,81.22,81.30,81.40 U it //Inspection Unit Interval Inspection Interval Grand Gulf Grand Gulf Nuclear Station {GGNS},

Nuclear Station (GGNS), SecondSecond (2 {2"}10-year nd

)1 O-year intervalinterval June June b lity :

Applicability: 1997 - May 2008 I. Code Requirement(s)

ASME E Section Section XI, Table IW8-2500-1, Examination Examination Category Category B-A,8-A, Pressure Retaining Welds in Reactor Pressure Retaining Ve Vessel - Inspection ra Program 8:

1. Item 81 .12 - Requires a volumetric examination 81.12 examination of Reactor Vessel of Reactor Vessel Longitudinal Longitudinal Shell Shell Weld Welds.

2

2. Item 81.22 - Requires a volumetric examination of MeridionalI Welds Well in Reactor Vessel Heads.

3. Ite Requires a Item 81.30 - Requires a volumetric examination of volumetric examination o Reactor Vessel Shell Shell to to FlangeFlange Welds Welds.

4. Item 81.40 .4 -- Requires Re etric examination a volumetric examination ofof Reactor Reactor Vessel Vessel Head Head to to Flange Flange Welds We During the the 2"' 10-year ISI 2nd 10-year lSI interval interval at GGNS, 10CFR50.55a(g)(6)(ii)(C) at GGNS, 10CFR50.55a(g)(6)(ii)(C) mandatedmandated an an implementatio implementation schedule schedule for for all all licensees licensees to to begin begin use of Appendix use of Appendix VIII VIII of of the 1995 Edition, the 1995 Edition, with with 1996 1996 Addenda Addenda of of ASME ASME Section Section X1 XI.. As a result, As a some examinations result, some examinations listed listed in in this relief request this relief request were were performed performed priprior to this this implementation schedule,schedule, and and were were performed performed in accordance with, in accordance Article 4 with, Article 4 of of the 1977 Edition, the 1977 Edition through the Summer 1979 Addenda of Section through the Summer 1979 Addenda of Section V.

ethodology used The methodology used toto determine determine Code coverage for Code coverage for each each of of the the components componen listed in this relief nest, therefore, request, depends on therefore, depends on which which set of requirements set of requirements werewere in effect during in effect during the examination . Wh the examination. Where earlier Code rules w ntergy credited were in effect, Entergy credited Code Code coverage coverage for for examination examinations using the

GNRO-2009/00018 -- Enclosure GNRO-2009/00018 Enclosure Page 22 techniques and examination angles required at that time . After the implementation of Appendix VIII, examinations were performed using the techniques and examination angles qualified through PDI (performance demonstrated initiative) for consideration of Code coverage, in accordance with qualified PDI procedures .

Requested Relief Due to the geometric configuration and location, certain code examination volumes, as depicted in ASME Section XI, cannot be examined to the extent of obtaining full code coverage. Pursuant to 10CFR50 .55a(g)(5)(iii), Entergy Operations, Inc . (Entergy) requests permission to perform ultrasonic examination within the limitations described in Table 1 of this relief request .

Tablele 1,1, Limits Limited B-A Examinationsaminatio item Item omp .

Comp. Item Item Number ID Des Description 0/0 Coverage rage Reason for Reason for Limitation Limitation Lion coverage Examination coverage is is limited limited in tw locations along in two RPV RPV App. VIII length, due the length, due toto the the close close proximity proximity ofof core core spry spray Longitudinal Longitudinal nozzleses N513 N5B (8.25" away) and (8.25" away) and Control Rod Drive Control Rod Drive (CRD)

~5" away).

B1.12 BJ BJ ell Weld Shell 86 % nozzle N6C N6C (6" RPV Meridional Pre- App. VIII Examinations are on the bottom head and are physically Bottom Head limited due to the location of CRD tubes and the Support B1.22 DA DA Weld 44.4% Skirt.

RPV Meridional Pre- App. VIII Examinations are re on the bottom on the bottom head head and are physically and are physically Bottom H Bottom Head limited due to the location tiara of of CRD to CRD tubes and the Support 81 B1.22.22 DB DB Weld 4 44.4% Skirt RPV Meridional Pre- App. VIII VIII dons are Examinations are on on the the bottom bottom head head and are physically and are physicall Bottom Head limited due to the location of CRD tubes and the limited due to the location of CRD tubes and the Supp Support B1.22 DC Weld 17.2 % Ski Skirt RPV Meridional RPV Meridi Pre- App. VIII Examinations Examinations are on tthe bottom head and are physically are on Batty Bottom Head mite due to0 the location of CRD tubes and the Support limited B1.22 DD Weld 17.2 % Skirt Not covered by RPV Shell to App. VI I I App. VIII Weld is only accessible from the shell side and the e flange flange B1.30 AE Flange Weld 75 75% configuration causes restricted access.

Not Not covered covered by b RPV Head to App. VIII VIII Weld is only accessible from the Head side and the B 1 .4 B1.40 AG AG Flange Weld 77.2% flange configuration causes restricted access.

III. Basis for Relief During ultrasonic ultrasonic examination examination of of th the Pressure Retaining Reactor Vessel Welds listed in Table Is 1 of this lief request, relief request, 100%

1000/0 coverage coverage of of the required fired exexamination ion volume volume couldcould not not bebe obtain obtained. d Component Component BJ BJ was was subjects quir menu of subjected to the requirements of Appendix Appendix VIII, Supplement element 4 4 an and 6. The weld configuration and the close proxi configuration and the close proximity of the CRD ozzle and nozzle and core pray nozzle resulted in scan spray nozzle resulted scan limitations, limitations, which which cannot cannot be be overco overcome by y addi adding additional examination motion angles angles.. As As aa result, ththe technique technique and and angles, angles, demonsti demonstrated d through through PDI, POI, we were not of capable capable of of achieving achieving the quired the Code required examination examination volu volume.

ponents DA Components DA through through DD DO were were not not ssubjected bjected to to the the requir requirements rats of of Appendix Appendix V11 VIII as they they wer were mined prior examined prior to to November November 20, 200 20,2000. Thee weld configuratio weld configuration, the location in relation to location in relation to RPV Skirt Skirt aand d

the the CIRD CRD tubestubes resulted resulted in in scan scan limitatio limitations, which hich cannot cannot be be ove overcome by by adding adding additional additional examination examination anglesangles.. AsAs aa result, result, the the use of of 45'S(shear) 45°S(shear), 60 0 S, and OOL(Longitudinal) nal) beam beam angles angles in in ial direction, direction, and and 450S 45°S and and 60 glen iin the circumferential direction, were not not capable capable of 0

the axial 60 S beam angles of

GNRO-2009/00018 *- Enclosure GNRO*2009/00018 Enclosure Page 33 Page achieving the Code required examination volume. The procedure used for these examinations was was written to the requirements of Article 4 of Section V.

Component AE and AG are not covered by Appendix VII I, per Article 1, 1-2110(x), therefore were not subjected to the exam requirements of Appendix VIII . As a result, the use of 45'S, 60'S, and O'L beam angles in the axial direction, and 45'S and 60'S beam angles in the circumferential direction, were not capable of achieving the Code required examination volume due to the component configuration and location of these welds. The procedure used for these examinations was written to the requirements of Article 4 of Section V.

Radiography is LJ ...... I"'tli""'l.I"'tff"' ..........' \ 1 is not practical on on these types of weld configurations, which prevents placement of the film and exposure source. source.

IV. roposed Alternative Proposed Alternative Examinations Examinations No alternative No alternative testing testing is is proposed proposed atat this time time.. Entergy Entergy has has examined examined these these welds welds to to the the extent extent radical and practical and will continue to will continue perform pressure to perform pressure testing testing on on the the subject welds as subject welds as required by the required by the Code.

Code.

V. Conclusion 10CFR50.55a(g)(6)(i) states: tates:

The Commission will evaluate determinations under paragraph (g)(5) of this section that code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

Entergy believes that it is impractical to obtain greater examination coverage on these welds. The examinations performed on the subject welds in addition to the examination of similar welds contained in the program would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. Therefore, we request the proposed relief be authorized pursuant to 10CFR50.55a(g)(6)(i).

These limitations existed during the first 10-year lSI Interval and relief was granted in Relief Request 1-00015, 00015, Rev. Rev. 22 as as submitted submitted via a letter (GNRO 96-00057) to the NRC dated May 21, 1996, ASME Section Section XI XI Relief Relief Requests.

GNRO-2009/00018 -- Enclosure GNRO-2009/00018 Enclosure Page 44 Page RELIEF REQUEST RELIEF REQUEST GGNS-ISI-006 GGNS-ISI-006 C mponents/N umbers : See Table I de Classes:

Code Classes : ASME Code Class 1 I References :

References:

ASME Section XI 1992 Edition, Table IWB-2500-ASME Section XI 1977 Edition with the Summer of 11979 Addenda for Ultrasonic Examinations ASME Sectior 95 Edition with 1996 1996 Addenda Addenda (for Ultrasonic Ultrasonic examinations erformed after after November November 22,2002) 22, 2002)

NRC NRC Letter December December 12, 2006, Evaluation 12, 2006, Evaluation of of Entergy Entergy Operation Operations Inc.

Request Request forfor Authorization Authorization to to Update Update Inservice Inservice Inspection Inspection Program Program to to the the 9 & Portion 92 ortion of of the 9 ASME the 93 ME Boiler Boiler & & Pressure Vessel Code Pressure Vessel Code Section Section XIXI (GNRI 96 0244)

(GNRI-96-00244)

NRC Letter dated January 5,2006, Use of Later Editions and Addenda of ASME Boiler & Pressure Vessel Code Section XI for Ultrasonic Examinations(CNRI- 2006-00002)

Ex mina Examination Category: B-D

Description:

Full P Full Penetration Welded Nozzles in Vessels Ite Item Number: B3.90 Unit /I Inspection Inspection Interval Interval Grand Grand Gulf Gulf Nucl Nuclear Station (GGNS), Second (2 nd )10-year interval June licabili Applicability: 1997 - May 2008 I. Code Requirement(s)

ASME Section XI, Table IWB-2500-1, Examination Category tegory B-D, Full Penetration Welded Nozzles in B-D, Full Vessels - Inspection Program B:

1. Item B3.903.90 -- Requires Requires aa volumetric volumetric examination of Reactor Vessel Nozzle-to-Vessel Welds.

n, During During the the 2 10-year 10-year ISI lSI interval interval at at GGNS, GGNS, 10CFR50 .55a(g)(6)(ii)(C) mandated 10CFR50.55a(g)(6)(ii)(C) mandated an an implementation implementation iedulle for schedule for all all licensees licensees to to begin begin use use of of Appendix Appendix V1 VIIII I of of the the 1995 1995 Edition, Edition, with with 1996 1996 Addenda Addenda of of ASME ASME Section Section X1.XL AsAs aa result, result, some some examinations examinations listed listed in in this this relief relief request request were were performed performed prior prior to to his implementation this implementation schedule, schedule, and and were were performed performed in in accordance accordance with with Article Article 44 of of the the 1977 Edition, 1977 Edition, through through the the Summer Summer 1979 1979 Addenda Addenda of of Section Section V.V.

The methodology methodology used used to to determine determine CodeCode coverage coverage for for each each of of the the components components listed listed in in this this retie relief nest depends request depends on on which which set of of requirements requirements were were in in effect at at the the time time of of the the examination examination.. Whe Where earlier earlier Code Code rules rules were were inin effect, effect, Entergy Entergy credited credited Code Code coverage coverage for examinations using for examinations using the the techniques techniques and examination angles and examination angles required required atat that that time time.. After After the the implementation implementation of of Appen Appendix VIII, examinations were performed using the techniques and examination anon angles angles qualified qualified ththrough POI for

GNRO-2009/00018 - Enclosure GNRO-2009/00018 nclosure Page 5 Page consideration of Code coverage, in accordance with qualified PDI procedures . In addition to utilizing these qualified techniques and procedures, Entergy employed EPRI to perform computer modeling on each of the nozzle configurations to ensure maximum coverage . These differences are reflected in the coverage percentages listed in Table 1, along with a notation of "Pre-App . VI ll" or "App . VI I" for each applicable component, as an indicator of which rules were applied .

Requested Relief Due to the geometric configuration of the nozzle-to-vessel welds listed below, certain code examination volumes, as depicted in ASME Section XI, cannot be examined to the extent of obtaining full code coverage . Pursuant to 10CFR50 .55a(g)(5)(iii), Entergy Operations, Inc . (Entergy) requests permission to perform ultrasonic examination within the limitations described in Table 1 of this relief request.

Table 1, Limited B-D -D Examinations aminati Item Item Comp. Item Item 0/0 mbar Number 10 Description ~ Coverage Description Coverage Reason for Limitation B3 .9 83.90 N01 -KA N018-KA 24" 24" Pre-App. VIII VIII Due to nozzle taper, weld could only be examined from Recirculation Recirculation 0 vessel side. 0°, 45°S and 60 S (axial and circ directions)

Outlet Nozzle Outlet Nozzle 50.0% were used for scanning, where accessible.

to Shell to Shell 83.90 NO N028-KA 12" Pre- App. VIII Due to nozzle taper, weld could only be examined from Recirculation 0 vessel side. 0°, 45°S and 60 S (axial and circ directions)

Inlet Nozzle to 60.0% were used for scanning, where accessible.

Vessel 83.90 N02C-KA 12" Pre- App. VIII Due to nozzle taper, weld could only be examined from 0

Recirculation vessel side. 0°, 45°S and 60 S (axial and circ directions)

Inlet Nozzle to 60.0% were used for scanning, where accessible.

Vessel 83.90 N02D-KA 12" Pre- App. VIII Due to nozzle taper, weld could only be examined from 0

Recirculation vessel side. 0°, 45°S and 60 S (axial and circ directions)

Inlet Nozzle to 60.0% were used for scanning, where accessible.

Vessel 83.90 N02E-KA 12" Pre- App. VIII VIII Due to nozzle taper, weld could only only be be examined from 60'S S (axial (axial an 0

Recirculation vessel side. 0°, 45°S and 60 and circ directions)

Inlet Nozzle to 60.00/0 were used for scanning, where here accessible accessible..

Vessel 83.90 02 N02F-KA 12" Pre- App. VIII Due to nozzle taper, weld could only be examined from 0

Recirculation vessel side. 0°, 45°S and 60 S (axial and circ directions)

Inlet Nozzle to 60.0% were used for scanning, where accessible.

Vessel 83.90 N02G-KA 1 12" Pre- App. VIII Due to nozzle le taper, taper, weld weld could could only only be mined fr be examined from circulatio vessel vessel side.

side. 0',

0°, 45'S 45°S and and 60'S 60 S (axial and ccirc directions 0

Recirculation (axial and directions)

IInlet let Nozzle Nozzle to 60.0%

60.0% were used for scanning, where where aaccessible.

essel Vessel 83.90 N02H-KA N02H-KA 12" Pre- App App.. VIII VIII ue to Due to nozzle nozzle taper, taper, weld weld could could only only be be exami examineded from from elation Recirculation vessel vessel side side.. 0',

0° 45'S 45°S and and 60'S 60 S (axial 0

(axial and and circ directions)

Inlet Inlet Nozzle Nozzle to to 60.0%% were used for were used for scanning, scanning, where where accessible accessible.

Vessel Vessel 53 .9 83.90 N02J-KA N02J-KA 12" 12" Pre- App. VIII VIII Due Due tto nozzle taper, weldweld could could only only be be examined examined fr from Recirculation Recirculation vessel vessel side.

side. 0°, 45°S and d 60'S 0

(axial and 60 S (axial and circ circ directions) directions)

Inlet Inlet Nozzle Nozzle to to 60 .0%

60.0% re used were used for for sscanning, where where accessible accessible..

essel Vessel 83 .9 83.90 N03A-KA N03A-KA 1 24" 24" Main Main e- App. V111 Pre- VIII Due Due to to nozzle nozzle tape taper, weld weld could could only only be be examined examined from from team Nozzle Steam Nozzle vessel vessel side.

side. 0',

0°, 45 nd 60'S 45°S and 60 S (axial 0

(axial and and circ circ directions) to Vess to Vessel 60.0% were were used used for for scan scanning, where accessible.

accessible.

GNRO-2009/00018 GNRO-2009/00018 - Enclosure closure Page 6 6 Table mited B-D Examinations Item item Number escription Coverage Reason for Limitation B3 .90 N03B-KA 24" Main P App. V111 Due to nozzle taper, weld could only be examined from Steam Nozzle vessel side . 0', 45'S and 60cS (axial and circ directions) to Vessel 60.0 were used for scanning, where accessible .

B3 .90 N04A-K 14" Feedwater Pre- App. V1 I I Due to nozzle taper, weld could only be examined from Nozzle to vessel side . 0', 45'S and 60'S (axial and circ directions Vessel 58.0% were used for scanning, where accessible .,

B3 .90 83.90 N04B-K N048-KA 14" Feedwater Pre- App. V111 Due Due to nozzle nozzle taper, weld could only be examined from Nozzle to vessel vessel sideside.. 0', 45'S 45°S and and 60'S 60 S (axial and 0

and circ circ directions) rt.rt:.~""1'.,"'\nC" Vessel 58.0% were were used used forfor scanning, scannin where where accessible accessible..

B3 .90 83.90 N04C-KA N04C-KA 14" Feedwater Pre- App. Vill VIII Due Due toto nozzle nozzle taper, weld weld couldcould only be examined from be examined from Nozzle to vessel side.

vessel side . 0',

0° 45'S 45°S and and 60'S 60 S (axial and 0

and circ circ directions) rt.rt:.~""1'.,"'\nC" Vessel 58.0% were used were used forfor scanning, scannin where where accessible accessible..

B3 .

83.90 KA N04D-KA 14" Feedwate Feedwater -App. V111 VIII Due Due to nozzle taper, weld to nozzle weld couldcould onlyonly be examined from be examined from Nozzle Nozzle toto 58.0% vessel side vessel side.. 0',

0°, 45'S 45°S and and 60 60'SS (axial 0

(axial and and circ circ directions) directions) essel Vessel were were used used for scannin;canning, where where accessibi accessible.

B3.90 83.90 05A-KA N05A-KA Core Core Spray Spray Pre- App. viii VIII Due to Due to nozz nozzle e taper, taper, weld weld couldcould onlyonly be examin from be examined Nozzle to vesselI side side. 0°, 45°S and and 60 60'S 0

S {axial and circ directions (axial andcirc directions)

Vessel 8 .0% were usedsed for scannin ng, where accessib

,where accessible.

83.90 N06A-KA 12" RHR/LPCI 12" RHRlLPCI Pre- App. VIII VIII Due to Due nozzle taper, to nozzle taper, weld weld couldcould onlyonly be examined from Inlet Nozzle Inlet 0 vessel side. 0°, 45°S and 60 S (axial and circ directions) were used for scannin nni g,,where where aaccessible.

83.90 N068-KA 12" RHR/LPCI Pre- App. VIII VIII Due to nozzle taper, weld weld couldcould only be ex only be examined from Inlet Nozzle vessel side. 0°, 45°S and 0 and 60 S (axial and circ I directions) 58.0 % were used for scannin nning ,where accessible. sible.

133.9 83.90 N06C-KA 12" RHR/LPC1 RHR/LPCI Pre- App. Vill VIII Due to nozzle taper, weld eld could could only be examined only be examined from from Inlet Nozzle Inlet Nozzle vessel side. 0°, 45°S and nd 60'S, (axial 60 0 S (axial and and circ circ directions directions) 58.0% were used for scannin ,where accessible. sibl 83.90 N07-KA 15.5" RCIC Pre- App. VIII Due to nozzle taper, weld could only be examined mined from from Top Head vesselI side side.. 0'.

0°, 45'S 45°S and and 60'S 60 S (axial 0

and circ (axial and circ dire directions)

Spray Inlet 62.0% were used for scanning, where accessible. bl Nozzle 83.90 N08-KA 15.5" RCIC Pre- App. VIII Due to nozzle taper, weld could only be examined from 0

Top Head vessel side. 0°, 45°S and 60 S (axial and circ directions)

Spray Inlet 62 .0 62.0% were used for scanning where accessible.

1 Nozzle 83.90 N09A-KA Due to nozzle taper, weld could only be examined from Instrument 12" Instrument Pre- App. VIII 0

vessel side. 0°, 45°S and 60 S (axial and circ directions)

Nozzle to to were used for scanning, where accessible.

Shell 83.90 N01A-KA N01A-KA 24" App. VIII Scann Scanning limited due to close proximity of nozzle culatio Recirculation ransiti transition. 0 60 RL (Refracted Longitudinal) used (axial and Nozzle Outlet Nozzle circ directi circ directions) per procedure. In addition additio 45°S (+90°/-90° Shell to Shell Skew) w) from from Glen81end and 50 S+/- (60° to 80° Skew}

0 Skew) fro from ssel used vessel used for examination per for examination per EPRI EPRI Modelin Mod .

83.90 N02A-KA 12" App App.. VIII VIII Scanning limited Scanning limited due due to to close proximity of close proximity nozzI of nozzle Recirculati(

Recirculation transition . 60 transition. 60'RL0 used (axial RL used (axial and and circ circ directions) directions) per per Nozzle to Inlet Nozzle t procedure. In procedure. In addition addition 35°S 35'S (+90°/-90°

(+90'/-90' Skew)

Skew) fromfrom 81end Bien Vessel Vessel and 5050'S+/-

0 S+/- (52' to to 76° 76' Skew)

Skew) from from vessel vessel used used for amination per examination EPRI Modelin er EPRI Modeling ..

83.90 N02K-KA N02K-KA 12" 12" App . VIII canning limited Scanning limited due due to to close proximity of close proximity of nozzle nozzle Recirculation Recirculation transition transition.. 60 60'RL0 used (axial and RL used and circ circ directions) directions) per per Inlet Nozzle Inlet Nozzle tot procedure. In addition 35°S In addition 35'S (+90°/-90°

(+90'/-90' Skew)

Skew) fromfrom 81end Bien 0%

Vessel Vessel and 50 and 50'S+/-

0 S+/- (52' to to 76° 76' Skew)

Skew) from from vessel vessel used used for for examination per examination EPRI Modelin er EPRI Modeling ..

NRO-2009/00018 -- Enclosure GNRO-2009/00018 Enclosure Page 7 Page 7 able 1, Limited B-D Examinations Item C Item '~ °/

Number Description Coverage Reason for Limitation B3 .90 N02M-KA 12" App . V111 Scanning limited due to close proximity of nozzle Recirculation transition . 60'RL used (axial and circ directions) per Inlet Nozzle to procedure . In addition 35 o S (+90'/-90' Skew) from Blend 70 .0%

Vessel and 50'S+/- (52' to 76' Skew) from vessel used for examination per EPRI Modeling .

B3 .90 N02N-KA 12" App. V111 Scanning limited due to close proximity of nozzle Recirculation transition . 60'RL used (axial and circ directions) per Inlet Nozzle to procedure . In addition 35'S (+90'/-90' Skew) from Blend 70 .0%

Vessel and 50'S+/- (52' to to 76' 76° Skew) fromfrom vessel vessel usedused for for examination examination per er EPRI Modeling .

EPRI Modelin B3.900 N03C-KA N03C-KA 24" Main 24" Main App. VIII ' r *...~nn,ln,., limited Scanning limited due due toto close close proximity of nozzle nrl""\,vln"'Uh, of nozzle Steam Nozzle transition . 60'RL used (axial and circ directions) per 0

Steam Nozzle transition. 60 RL used and circ per to Vessel to Vessel procedure . In addition 45'S (+90'/-90' Skew) from Blend In addition 45°S from Blend 775.00/0

.0%

and 50'S+/- S+/- (59' to to 80° 80' Skew) from vessel vessel usedused for 0

and 50 for examination per examination er EPRI EPRI Modeling Modelin ..

B3 .90 B3.90 I N03D-KA N03D-KA 24" Mai Main App. VIII VIII canning Scanning limited limited due due to to close proximity close proximity of nozz of nozzle Steam Nozzle transition . 60 60'RL used (axial (axial and circ directi 0

Steam Nozzle transition. RL used and circ directions) per to to Vessel Vessel 75.0%

procedure.

procedure. In In addition addition 45'S (+90'/-90' Skew) 45°S (+90°/-90° Ske from Blend and 50'S+/-

and (59' to 50 0 S+/- (59° 80' Skew) to 80° Skew) from from vessel vessel uused for examination er EPRI Modeling Modelin ..

B3.90 N04E N04E-KA 14" Feedwater App. Vill VIII Scanning limited due to close proximity of nozzle 0

Nozzle to transition. 60 RL used (axial and circ directions) per Vessel procedure. In addition 35°S (+90°/-90° Skew) from Blend 72.0% 0 and 50 S+/- (55° to 78° Skew) from vessel used for examination er EPRI Modelin .

B3.90 N05B-KA Core Spray App. VIII Scanning limited due to close proximity of nozzle 0

Nozzle to transition. 60 RL used (axial and circ directions) per Vessel procedure. In addition 35°S (+90°/-90° Skew) from Blend 73.0% 0 and 50 S+/- (55° to 78° Skew) from vessel used for examination per EPRI Modelin .

B3.90 N04F-KA 14" Feedwater App. VIII Scanning limited ited due due to close r)roxi to close proximity of nozzle RL usec ecti 0

Nozzle to transition. 60 RL used (axial and circ directions) per Vessel procedure. In addition addition 35°S (+90°/-90° Skew) from Blend 72.0%

and 50 0 S+/- (55° to 78° Skew) from vessel!11 used used for for examination per EPRI Modelin odelin .

B3.90 N09B-KA 12" Instrument App. VIII Scanning limited due to close proximity roximity of of nozzle irc directions) 0 Nozzle to transition. 60 RL used (axial and circ directions) per 0

Shell procedure. In addition 50 S+/- (13° to 65° Skew) from 77.0%

from vess 0

vessel and 60 S+/- (5° to 21 ° Skew) from vessel used for examination examination per er EPRI EPRI Modelin .

B3 .90 B3.90 O-KA N10-KA CRD Nozzl Nozzle App. Vill VIII arming limited Scanning limited duedue toto close close proximity of nozzle ell to Shell transition . 60'RL transition. 60° used (axial used and ci (axial and circ directions) per procedure procedure.. In addition 35°S In addition 35'S (+50°/-50°

(+50 o/-50' Skew)Skew) from from Bien Blend 0%

and 50'S+/- (27' to 80' Skew)

Skew) from vessel used used for 0

and 50 S+/- (27° to 80° from vessel for xamination, per examination EPRI Modeling er EPRI Modelin .

90 B3.90 N1 N16-KA Instru Instrument App . VIII VIII Scanning Scanning limited limited duedue toto close proximity of close proximity of nozzle nozzle Nozzle to ansition . 60 60'RL used (axial (axial and circ directions) per 0

Nozzle to transition. RL used and circ directions) per Shell Shell procedure procedure.. In In addition addition 35'S (+50'/-50' Skew) 35°S (+50°/-50° Skew) from from Blend Blend 0%

77.0°A>

and 50'S+/- 50 S+/- (25' to 70 o Skew)

Skew) from from vessel vessel used used for for 0

and to 70° examination per examination er EPRI EPRI Modeling Modelin ..

GNRO-2009/00018 -- Enclosure GNRO-2009/00018 Enclosure Page 8 III. Basis for Relief During ultrasonic examination of the Reactor Vessel nozzle-to-vessel welds listed in Table I of this relief request, 100% coverage of the required examination volume could not be obtained .

Components NOI B-KA through N09A-KA were not subjected to the requirements of Appendix VIII as they were examined prior to November 22,, 2002, the implementation date specified for Supplement 7.

he weld configuration and the close proximity of the nozzle taper resulted in geometric scan limitations, which cannot be overcome by adding additional examination angles . As a result, the use of 45'S, 60'S, and O'L beam angles in the axial direction, and 45'S and 60'S beam angles in the circumferential direction, were not capable of achieving the Code required examination volume .

omponents N 1 A-KA through N 1 6-KA were subjected to the requirements of Appendix Vill . The procedure used for these examinations has been demonstrated for the detection of flaws at EPRI i accordance with the requirements of Appendix lull . In accordance with this procedure 60' refracted longitudinal (RL) wave examinations were performed in both the axial (radial) and circumferential scan directions . Additional examinations were performed in accordance with another qualified procedur odeling was performed for each of these nozzle configurations . This scanning was the vessel shell and nozzle blend, where accessible. As a result. the u angle in the axial and circ directions, and the additional beam angles required by the EP odeling, wer t capable of achieving the Code required examination Radiography is not practical on these types of nozzle-to-vessel weld configurations, which prevent placement of the film and exposure source. To perform any additional Code allowable UT examination, modification and/or replacement of the component would be required. The examinations performed on the subject items in addition to the examination of other vessel welds contained in the lSI program would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity.

IV. Proposed Alternative Examinations No alternative testing ting is is pro proposed at this time. Entergy has examined these welds to the extent practicalI and and will will continu continue to perform pressure testing testing on on the subject welds the subject as require welds as required by the Code.

V. Conclusion 10CFR50.55a(g)(6)(i) states:

The Commission will evaluate determinations under paragraph (g)(5) of this section that code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

Entergy Entergy believes believes th mpractical to that it is impractical to obtain obtain greater greater examination coverage on examination coverage on these these weld welds. To obtain additional obtain additional ccoverage would necessitate tate modification modification and/or and/or replacement replacement of of the component. T the component. The examinations examinations performed performed on on the the subje subject welds welds inin addition addition to to the the examination examination of of similar similar welds welds contained contained in in the the program program would would detect detect generic generic de elation, if degradation, if itit existed, existed, therefore therefore demonstrating demonstrating an an acceptable acceptable level level of of integrity integrity.. Therefore, Therefore, we we request he proposed request the proposed relief relief be be aauthorized pursuant to 110CFR50.55a(g)(6)(i).

OCFR50- a (g) (6) (i) .

These limitations limitations exi spection Interval existed during the first Inspection Interval andand relief relief was was granted granted inin Relief Request 1-0001 00015, Rev. 2 as submitted via a I 2 as submitted via a letter NRO 96-00057) to the NRC dated May 21, 1996, (GNRO 96-00057) to the NRC dated May 21, 1996, ASME ASME Sectio Section XI Relief Relief Requests Requests..

GNRO-2009/00018 -- Enclosure GNRO-2009/00018 Enclosure Page 99 REQU RELIEF REQUEST GGNS-1S1-007 GGNS-ISI-007 C mponents/Numbers Components/Numbers: See Table I C de Classes:

Code Classes : ASME Code Class 1 References

References:

ASM Section XI 1992 Edition, Table IWB-2500-1 ASME Section XI 1995 Edition with 1996 Addenda (for Ultrasonic examinations performed after November 22, 2002)

NRC Letter NRC Letter dated June 7, 2008, Relief June 27,2008, Relief Request Request GGNS-ISI-004 GGNS-ISI-004 to to Extending the Inservic, Inspection the Inservice spection Interval Interval (TAC (TAC NO.

NO . MD7477)

IVID7477)

NR12008-00065 (GNRI2008-00065)

Examination Category: B-F

Description:

Dissim Pressure Retaining Dissimilar Metal Welds in Vessel Nozzles Item Number: 85.10 B5.10 Unit /Inspection Interval Grand Gulf Nuclearr Station Station (GGN (GGNS), Second (2 nd ) 1O-year interval June Appi cabill Applicability: 1997 - October 2008 I. Code Requirement(s)

ASME Section n X1, XI, Table IWB-2500-1, Examination Table IWB-2500-1, Category B-F, Examination Category B-F, Pressure Pressure Retaining Retaining Dissimilar Dissimilar fetal Metal ozzle Welds in Vessel Nozzles:

Ite

1. Items B5.10 - Requires 100%

100 % volumetri volumetric examination of of the Class 1 the Class 1 NPS N PS 44 or or Laraer Larger Nozz Nozzle-to-S Safefe End End Butt Welds.

During the 2 nd 10-year lSI interval at GGNS, 10CFR50.55a(g)(6)(ii)(C) mandated an implementation schedule for all licensees to begin use of Appendix VIII of the 1995 Edition, with 1996 Addenda of ASME ESSection XI. After the implementation of Appendix VIII, only 1/2 Vee path examinations have been allowed allowed toto be be uused in austenitic materials, in accordance with qualified POI procedures.

ussion, as to Additional discussion, to the the examination examination coverage coverage determination determination pr process when using Appendix VIII echniqu on single techniques ustenitic welds, single-sided austenitic welds, is is i)rovided provided inin section Section III III of of tthis relief request.

GNRO-2009/00018 - Enclosure GNRO-2009/00018 inclosure Page age 10 10 11.

II. Requested Relief Pursuant to 10CFR50 .55a(g)(5)(iii), Entergy Operations, Inc . (Entergy) requests relief from achieving greater than 90% coverage as allowed by Code Case N-460, when performing volumetric examinations on the following welds .

able 1, LlnlltE~a Limited B-F B-F t:Xcimlnaltlor,s Examinations Item Item Comp. Item Item Number Number 10 Description Oescri Coverage Covera e Reason for Reason for Limitation Limitation 24" 24" Surface concavity limited Axial Surface Axial and and Circ Circ scanning in in two Recirculation Recirculation areas for areas for aa total total of of 34.5" 34 .5" . Scanned Scanned fromfrom Safe Safe End End side side Nozzle-to-Safe Nozzle-to-Safe only . 45'S, 45°L 45'L and and 60 60'RL 0

used for RL used for scanning, where where E5.1 0 B5.10 N01A-KB N01A-KB SS End, SS 75.6%

75.6°J't, accessible .

accessible.

14" 14" Recirculation Recirculation urface concavity limited Surface limited Axial Axial and and Circ Circ scanning scanning forfor ozzle-to-Safe Nozzle-to-Safe 18.25". Scanned 18.25". Scanned from from Safe Safe End side only. 40 End side only. 40'RL, 0

45'S RL, 45°S, B5.10 N02K-KB N02K-KB End, SS End, SS 77 .3%

77.3% 45'RL and 45°RL and 6060'RL 0

used for RL used for scannin scanning, where where accessible.

accessible .

III. Basis for Relief ultrasonic examination Ouring ultrasonic examination of of the the piping piping welds weld listed in Table Table 1 1 of of this this relief relief request, request, 100%

100% coverage coverag quired examination of the required examination volume volume could could notnot be be obtained.

obtained .

Class 1 piping and components are often designed with welded joints such as nozzle-to-pipe, pipe-to-valve and pipe-to-pump which can physically obstruct a large portion of the required examination volume. For the welds listed in Table 1 (above), the examinations were performed after the 10CFR50.55a mandatory implementation date (November 22,2002) for Appendix VIII of Section XI.

The provided code coverage percentages reflect what is currently allowed by qualified Appendix VIII techniques. Appendix VIII qualified (POI) procedures have demonstrated that sound beams may potentially be attenuated and distorted when required to pass through austenitic weld metal. Still, the POI qualified methods employ the best available technology for maximizing examination coverage of these types of welds. For the components listed in this relief request, examination was extended to the far side of the weld to the extent permitted by geometry as qualified through POI.

Entergy has used the best available techniques to examine the subject piping welds. To improve upon these examination coverage percentages, modification and/or replacement of the component would be required. Consistent with the ASME Section XI sampling approach, examination of the subject welds, when combined with examinations that have been performed on other welds within the same Examination Category, is adequate to detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity.

IV. Proposed Proposed Alternative Alternative Examination Examinations No alternative alternative testing testing is is proposed at thisthis time.

time. Entergy Entergy has has examined examined the the subject subject welds welds to to the the ext extent practical and practical and will will continue continue to to pe perform pressure pressure testing testing on the subject on the subject welds welds as as required required by by the the Code Code..

intergy will Entergy will use use pressure pressure test test and and VT-2 VT-2 visual visual examination examination to to compliment compliment the the limited limited examination examination coverage coverage after each each refueling refueling outage.

outage.

GNRO-2009/00018 -- Enclosure GNRO-2009/00018 Enclosure Page 11

v. Conclusion 11 OCFR50 .55 (g)(6)(i) states' The Commission will evaluate determinations under paragraph (g)(5) of this section that code requirements are impractical . The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility .

Entergy believes that it is impractical to obtain greater examination coverage on these areas. areas . To obtain additional coverage would ne(:;es~.slt4ate necessitate modification 1""'\"""1'''

t"V\"",rt.t".,...I""'\t"."",,,,,

and/or r-nnl~l"nrY1nnt' replacement of of the component . The The examinations performed on on the subject areas, areas, in in addition addition to the the examination examination of of similar similar welds welds contained in the program in program would would detect detect generic generic degradation, degradation, ifif itit existed, existed, therefore therefore demonstrating demonstrating anan acceptable acceptable level of level integrity . Therefore, of integrity. Therefore, we we request request the the proposed proposed relief relief be be authorized authorized pursuant pursuant to to 1 OCFR50.55a(g)(6)(i) .

10CFR50.55a(g)(6)(i).

GNRO-2009/00018 -- Enclosure GNRO-2009/00018 Enclosure Page 12 Page 12 ELIEF REQUEST RELIEF REQUEST GGNS-ISI-008 GGNS-ISI-008 mponents/N umbers :

Components/Numbers: See Table de Classes:

Code Classes : ASME Code Class Referet s

References:

ASME Section XI 1992 Edition, Table IWB-2500-ASM ection XI 1977 Edition with the Summer Summer of of 11979 Addenda Addenda forfor Itrasonic examinations NRC Letter December NRC Letter December 112, 2006,2006, Evaluation Evaluation of of Entergy Enterg Operations Inc.

Request Request forfor Authorization Authorization to to Update Update Inservice Inservice Inspection Inspectio Programrograrn to to the 92 && Portion Portion of of the the 9393 ASME ASME Boiler Boiler & & Pressure Pressure Vessel Vessel Code Section Sectio XI (GNRI-96-002 (GNRI-96-00244) min Examination Category: B-G-1

Description:

Pressure Retaining Bolting, Greater Than Than 22 Inches Inches In In Diameter Diameter Item Number: B6.40 (2na) it //Inspection Inspection Interval Grand Gulf Nucl and (2 ) 10-year 10-year interva nd Unit Interval Grand Gulf Nuclear Station (GGNS), Second interval June plicabillity Applicability: 1997 - May 2008 I. Code Requirement(s)

ASME S Section XI,1, Table Table IWB-2500-1, IWB-2500-1, Examinatio Examination Category B-G-1, Pressure Pressure Retaining Retaining Boltin Bolting, Greater Than 2 inches in Diameter: eter:

1. Item B6.40 - Requires a volumetric examin volumetric examination of the Reactor Reactor Vessel, Vessel, Threads Threads in Flange stu in Flange stud hole and one inch inch of of base material around the hole le for a depth equal to the diameter of the for a depth equal to the diameter stud. The examinationsLions are to be performed once per per interval.

i II. Relief Requested Due to the geometric configuration of the threaded area in the upper Reactor Pressure Vessel (RPV) flange, flange, the the code code examination examination volume, volume, as as depicted depicted in in ASME ASME Section XI, cannot be examined to the extent of obtaining obtaining full full code coverage. Pursuant to 10CFR50.55a(g)(6)(i), Entergy Entergy Operati Operations, Inc. (Entergy) requests permission to perform ultrasonic examina requests permission to perform ultrasonic examination within the limitations described in the limitations described in Table Table 11 of of this this reli relief request.

mited B Table 1, Limited B-G-1 Examinations Item Component ne Item 0/0 Num Number ID Description Coverage imitati Reason for Limitation B6.

86.40 FLG LIG 1 Reactor Reactor 86.60/0 canning obstructed Scanning obstructed between between 333 0 and 27 0 due through FLG Vessel Vessel to to the the raised raised seal seal face face configuration configuration.. Scanning Scanning LIG 76 Threads-in Threads-in- performed performed with with OOL, where where accessible accessible.. Se See Flange Flange Figure Figure 11..

GNRO-2009/00018 - Enclosure GNRO-2009/00018 nclosure Page 13 13 111 III.. Basis for Basis for Relief Relief During ultrasonic examination of the threaded area in the upper Reactor Vessel flange, 1100% coverage f the required examination volume could not be obtained .

A 0' Ultrasonic examination of threaded flange is required to be performed on the adjacent I" area around the RPV stud hole . This scan is limited to approximately 85% around the circumference of each stud hole due to the RPV head raised seal surface . This exam is not covered by Appendix V111 .

Radiography is not practical due to the component configuration, which prevents effective placement of the film and exposure source . To perform any additional Code allowable ultrasonic examination, modification and/or replacement of the component would be required . The examination of 86.6% of the required volume of the subject items would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity .

IV. P oposed Alternative Proposed Alternative Examinations Examinations No alternative No alternative testing testing is proposed at is proposed at this this time. Entergy has time. Entergy has examined examined thethe subject items to the extent practical and will practical and continue to will continue to perform perform pressure testing on pressure testing the subject on the areas as subject areas required by as required by the the Code.

Code.

V. Conclusion 10CFR50.55a(g)(6)(i) states:

The Commission will evaluate determinations r under paragraph (g)(5) of this section that code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is autho(ized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

The RPV, including the flange assembly, is subject to a pressure test in accordance with ASME Section I

XI, Table IWB-2500-1.

The The entire code vole entire code volume around the stud to hole is examined except for the area associated with ith the the ssealing surface. This This area area iis examined for a distance of 1/2" from the stud hole where the sealing surface is encountered. d . With ith the RPV PV Head Head inin place place and fastened with and fastened with the the studs studs to to the RPV shell flange, the seal derl surface and underlying material is subjec subjected to compressional loads.

The amount of obtained volumetric coverage that includes the bounded area is adequate to to ensure ensure structural iintegrity of the stud hole regions of the RPV flange.

tergy believes Entergy believes tthat it is impractical to obtain greater g rest examination coverage on these areas. To obtain i

additional coverage would uld necessitate modification tiara and/or and/or replacement replacement of of the the component.

component. The The ex minatians performed examinations performed on on the the subject subject areas would would detect detect generic generic degradation, degradation, if if iit existed, therefore de demonstrating frog an an acceptableable level level of in egrity. Therefore, of integrity. Therefore, we we request the proposed request the proposed alternati alternative be ur authorized pursuant 10CFR50 .55a(c to 10CFR50.55a(g)(6)(i).

Relief Relief was granted for was granted for this e amination during this examination during the the first first interval Interval in Relief Request in Relief Request 1-00019, Rev 1-00019, Rev.. 11 as submitted via a letter (GN submitted via a letter (GNRO 6-00057) to the NRC dated May 21, 1996, 96-00057) to the NRC dated May 21, 1996, ASME ASME Section XI Reli Section XI Relief Requests .

Requests.

GNRO-2009/00018-- Enclosure GNRO-2009100018 Enclosure Page Page 14 14 gure 11 Figure A

Plan View of RPV Flange he full Unable to scan the full 1" 1" of Code required volume

~ Area scanned Code required exam volume 360 0 around stud 1111111111

~~------l('"<*I:I:I:I:I:

.")0.>-------<<" I1111111111

"'~------ClC.11111111111

1:1:1:1:1 RPV ID ---I .... ~_ _----~ 1111111111 1111111111

~------~IIIIIIIIII

~------~IIIIIIIIII 1111111111

~------~ 1111111111

">~ - << I1111111111 A-A

GNRO-2009/00018 GNRO-2009/00018 -- EnclosureEnclosure Page 1515 RELIEF REQUEST RELIEF REQUEST GGNS-ISI-009 GGNS-ISI-009 mponents/Numbers :

Components/Numbers: See Table de Classes Code Classes:: ASME Code Class References :

References:

ASME Section XI 1992 1 Edition, Table IVVB-2500-1 ASME Section XI 11977 :"dition with ummer

,...-...-_.. . 11979 Addenda ASME Section XI 1995 Edition with 1996 Addenda (for ultrasonic ultrasonic examinations performed after May 22, 2000)

NRC Letter dated NRC Letter dated December December 12, Evaluation of 1996, Evaluation 12, 1996, of Entergy Entergy Operations Operations Request for Authorization to Update Inservice Inspection Program Inc. Request for Authorization to Update Inservice Inspection Program to to 1992 &

the 1992 Portion of

& Portion of the 1993 ASME the 1993 ASME BoilerBoiler & Pressure Vessel

& Pressure Vessel CodeCode ection XI (GNRI 96-00244)

Section NRC Letter Letter dated dated Februa February 13, 2007, Request Forr Alte Alternative GG-ISI-003 RE: E Extending the Current Inservice Inspection Interval Inservice Inspection Inte in Accordance with U.S. Nuclear uclear Regulatory Commission Information Regulatory Commission Notice 98-44 (TAC NO. MD3167) 67) (CNR12007-00004}

(CNR12007-00004)

Examination Category:

Examination Cate B-J Des

Description:

Pressure Retaining Welds in Piping Item Number(s): B9.11, B9.31 Interval Unit /Inspection Interval Grand Gulf Nuclear Station (GGNS), Second (2 ) 1O-year Grand Gulf nd ear interval in June bility :

Applicability: 1997 -- October 1997 October 2008 I. Code Requirement(s)

ASME Section X1 XI,. Tab Table IWB-2500-1, Examination Category B-J, B-J, Pressure Pressure Retaining Reta Welds in Piping -

Inspection Program B:

1. Item B9.11 - Requires equires a a volumetric volumetric examination examination of of Circumferential Circumferential welds Welds NPS NPS 44 or Larger

2. Item B9.31 - Requires Requires a a volumetric volumetric examination examination of Branch Pipe of Branch Pipe Connection Connection Welds Welds NPS,NPS 4 or Larger uring the During 10-year ISI the 2"' 10-year lSI interval interval at 1 OCFR50.55a(g)(6)(ii)(C) mandated GGNS, 10CFR50.55a(g)(6)(ii)(C) at GGNS, mandated an an implementation implementation schedule for schedule for all licensees to all licensees begin use to begin use of of Appendix Appendix VIII VIII of the 1995 of the 1995 Edition, with 1996 Addenda with 1996 Addenda of of ASME Section X1 ASME Section XI.. As As a a result, the examinations result, the listed in examinations listed in this this relief request were relief request were performed utilizing performed utilizing procedures procedures written written in in accordance accordance with with the POI Generic the PDI Generic LIT Procedures and UT Procedures and Appendix Appendix VIII VIII.. With With the the implementation of Appendix implementation of Appendix VIII, only only 1/2 1 Vee Vee path path examinations examinations have have been been allowed allowed t to be used in austenitic materials, and angle beams are no longer credited to extend beyond the centerline of austenitic materials, angle beams are no longer credited to extend beyond the centerline of austenitic austenitic welds welds forfor consideration consideration of of Code Code coverage, coverage, in in accordance accordance with qualified PDI with qualified procedures .

POI procedures.

Additional discussion, as Additional discussion, as to examination coverage the examination to the coverage determination determination process process when when using using Appendix Appendix VIII chniques on techniques single-sided austenitic on single-sided austenitic welds, welds, isis provided provided in Section III in Section III ofof this this relief relief reque,,

request.

GNRO-2009/00018 -- Enclosure GNRO-2009/00018 Enclosure Page 16 Page 16 II. Requested Relief Requested Relief Pursuant to 10CFR50 .55a(g)(5)(iii), Entergy Operations, Inc . (Entergy) requests relief from achieving greater than 90% coverage as allowed by Code Case N-460, when performing volumetric examinations on the following welds.

Table 1, Limited Table 1, Limited B-J B-J Examinations Examinations Item ! Comp.

Comp. Item Item %

Number N r 10 Description ~ Coverage Description Covera ge ~ _ Reason for Reason for Limitation Limitation Pre Pre App. VIII VIII Single side side exam exam duedue toto configuration lfijguratio (pipe to to cross) .

B33GO01 Rqq~nnl 24" RCS 24" RCS Pipe to to Scanned from Scanned from pipe side side only . 45'S, 60 60'S 0

and 60 S and 60'RL 0

RL B9.11 89.11 -W34

-W34 Cross, SS Cross, SS 50.0%

1% used for used for scanning, scanning, where accessible .

where accessible.

Pre App. Vill Pre VIII Single Single side side exam exam duedue toto configuration configuration (pipe to to cross) 833G10- 16" RCS Pipe to Scanned Scanned from from pipe side side only.

only . 4SoS, 45'S, 6060'S 0

S and and 60 60'RL 0

RL 89.11 81-A Cross, SS SO.o% used used for scanning, where for scanning, where accessible accessible..

Pre App. VIII Singlengle sideside exam exam duedue toto confi configuration (pipe to cross).

833G10- 16" RCS Pipe to nned from pipe si Scanned from pipe side only. 0 4SoS, 60 S and 60 RL 0 89 .11 89.11 81-8 Cross, SS SO.o% used for used for scanning, scanning, where accessi where accessible.

Single side exam due to configuration uration (elbo (elbow to valve).

Scanned from elbow side only. Used Used 450S 4SoS andand 7070 0 S to scan with per the procedure. 8ecause of the tight fight radius radius App. VIII of the elbow, 8.4" was not scanned due to lift i off resulting ES1G001 6" RCIC Valve in 60% 8i-directional coverage of the required required e exam 89.11 -W40 to Elbow, CS 60.0 60.0% volume utilizing the 70 S. 0 12" RCS App. VIII VIII Single sideside examexam due due tto configuration ion (pip (pipe to sweep-o-833G10- Sweep-o-Iet to ,annE from pipe side let). Scanned side oniv only.. 4SoS 45'S and 60 RL used 0

89.31 89.31 81-H Pipe, SS SO.O% for scanning where for scanning, re accessible accessible.

12" RCS App. VIII Single I side exam due iguration (p to configuration (pipe to sweep-o-833G10-1 Sweep-o-Iet to let) let).. Scanned Scanned from from pipe side only. 4SoS 45'S and and 60 60'RL 0

RL used used 89.31 81-G 81-G Pipe, SS SO.O% for s for scanning, where accessible.

12" RCS App. VIII Single side exam xam due due toto conf configuration (pipe to sweep-o-833G10- 0- Sweep-o-Iet to let). Scanned nned from from pipe pipe siside only. 4SoS and 60 RL used 0 89.31 81-F Pipe, SS SO.o% for scanning, where ere accessible.

acce App. VIII Single side exam due to configuration (pipe to sweep-o-833G001 12" RCS Pipe to let). Scanned from pipe side only. 4SoS and 60 0 RL used B

89.11 -W20 Tee, SS SO.O% for scanning, where accessible.

App. VIII Single side exam due to configuration uration (pipe (pipe toto swee sweep-o-833G001 12" 12" RCS Pipe to let). Scanned from pipe side only. nly. 45'S and 60 4SoS and 60 0 RL used 89.11 -W22 Tee, SS SO.o% for scanning, where accessible.

App. VIII VIII Single side exam due to configuration (pipe to cross).

833G001 12" RCS Valve Scanned from pipe side only. 4SoS and 4soRL used for 89.11 -W33 to Pipe, SS SO.o% scanning, where accessible.

App. VIII Single side exam due to configuration (valve to pipe).

1833G10 24" Pipe to Scanned from pipe side only. 4SoS, 60 0 S and 4soRL 89 .11 89.11 -A1-8 Cross, SS SO.O% used for scanning, where accessible.

App. VII App. VIII Single Single sideside exam exam due to configuration (pipe to tee).

1833G 1833GOO 24" Pipe to Tee, Scanned Scanned from from pipe pipe sid, side only. 4SoS and 4soRL used for 89 .1 89.11 1W11 1W11 SS .0%

SO.O% scanning, scanning, where where accessible accessible.

App. VIII ingle side Single side exam exam duedue toto configuration configuration (pipe(pipe toto cross) cross)..

G 1833G10 24" Pipe to ~canned from Scanned from pipe pipe side side only only.. 45 0S and 4SoS and 45'RL 4soRL usedused forfor 89 .11 89.11 Al -A

-A1-A Cross, SS SO.o% nning, where accessible .

scanning, where accessible.

Scanning Scanning limited limited to to 66%

66% of of the the circumference circumference on on ththe App. VIII ranch fitting side of the weld (100% on pipe side), due branch fitting side of the weld (100 %

on pipe side), due to to 1833G10 12" RCS branch branch configuration configuration.. 45'S, 45'RL 4soRL and and 60'RL 60 0 RL used used for for 89.31 -A1-F 8ranch, SS 83.0% scanning where where accessible accessible..

GNRO-2009/00018 -- Enclosure GNRO-2009/00018 Enclosure age 17 Page 17 Table 1, Limited B-J Examinations Item Comp .

Comp. Item Number 10 Description Coverage Reason for Limitation Scanning limited to 66% of the circumference on the App . VIII : branch fitting side of the weld (100% on pipe side), due to 1B33G10 12" RCS branch configuration . 45'S, 45'RL and 60'RL used for B9 .31 -Al-G Branch, SS 83 .0% , scanning, where accessible .

Scanning limited to 66% of the circumference on the App. VIII branch fitting side of the weld (100% on pipe side), due to 1B33G10 12" RCS branch configuration. 45'S, 45'RL and 60'RL used for B9 .31 89.31 Branch, SS 83 .0% scanning, where accessible .

scannin III. Basis for Relief D ring ultrasonic During ultrasonic examination examination of of the the piping piping welds welds listed listed in in Table Table 11 ofof this this relief relief request, request, 100%

100% coverage coverag quired examination of the required examination volume could not volume could not be be obtaine obtained.

Class 1 piping and components are often designed with welded joints such as nozzle-to-pipe, pipe-to-valve and pipe-to-pump which can physically obstruct a large portion of the required examination volume. For the welds listed in Table 1 (above), the examinations were performed after the 10CFR50.55a mandatory implementation date (November 22,2002) for Appendix VIII of Section XI.

The provided code coverage percentages reflect what is currently allowed by qualified Appendix VIII techniques. Appendix VIII qualified (POI) procedures have demonstrated that sound beams may potentially be attenuated and distorted when required to pass through austenitic weld metal. Still, the POI qualified methods employ the best available technology for maximizing examination ination coverage coverage of these types of welds. For all the components listed listed in this relief request, examination was extended in this relief request, examination was extended to to the far side of the weld to the extent permitted by geometry, but this his portion o portion of the examination is not included in the reported coverage for welds examined under POI and Appendix VIII rules.

Entergy has used the best available ilable techniques techniques to to examine examine thethe subject piping welds.

subject piping welds. To To improve improve upon upon these examination coverage percentages, modification and/or replacement of the component would uld be required. Consistent with the ASME Section XI sampling approach, examination of the subject welds, when combined with examinations that have been performed on other welds within the same Examination Category, is adequate to detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity.

IV. Proposed Alternative Alternative Examinatio Examinations No No alternative alternative tes ing is testing is proposed proposed at at this this titime. Entergy Entergy has has examined examined the the subject subject welds welds to to the extent the extent Tactical and practical and wiwillI continue continue toto perfoi perform pressure ure testing testing on on the the subject subject welds welds as as required required by by the the Code Code..

Entergy Entergywillwill use use hydrostatic hydrostatic pressure pressure testing testing and and VT-2 VT-2 visual visual examinations examinations to to compliment compliment the the limited limited examination examination coverage coverage after after each each refueling refueling outage.

outage.

GNRO-2009/00018 -- Enclosure GNRO-2009/00018 Enclosure age 18 Page 18 onclusio Conclusion OCFR50 .55 (g)(6)(i) states :

The Commission will evaluate determinations under paragraph (g)(5) of this section that code requirements are impractical . The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility .

Entergy believes that it is impractical to obtain greater examination coverage on these areas. To obtain additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject subject areas, areas, in in addition addition to to the examination of similar welds contained in the in the program program would would detect generic degradation, ifif itit existed, generic existed, therefore demonstrating demonstrating an acceptable an acceptable level of level integrity . Therefore, of integrity. Therefore, we we request request the proposed relief the proposed relief be be authorized authorized pursuant to 10CFR50 .55a(g)(6)(i 10CFR50.55a(g)(6)(i).

nclosure GNRO-2009/00018

Enclosure GNRO*2009/00018 Page 19 19 ELIEF REQUEST REQUE GGNS-ISI-010 GGNS-ISI-010 mponents/Numbers : See Table C de Classes Code Classes:: ASME Code Class 11 References :

References:

ASME Section XI 11992 Edition, Table IVVB-2500-1 Examination Category:

Examination Category :

Description

Description:

Integral Attachments for Class 11 Vessels, Ves, Piping, Pumps, Pumps, andand Valves valves Item Number(s): B10.10, B10.20 nd Unit I Inspection Interval Grand GulfIf Nuclear Station {GGNS),

Nuclear Station Second (2 (GGNS), Second (2")) 19-year interval June 1O-year interval J pliability:

Applicability: 1997 -- May 1997 May 2008 2008 I. Code Requirement(s)

ME Section XI, Table IWB-2500-1, Examination ASME amination Category Category B-K,B-K, Integral Integral Attachments Attachments for Class 1 for Class 1 Vessels, Piping, Pumps, and Valves:

1. Item B10 .10 -- Requires B10.10 Requires a s a surface examination, of Pressure Vessel Integrally Welded gilded menu .

Attachments.

2. 10.2 - Requires a surface examination, of Piping Integrally Welded Attachments.

Item B10.20 Figure IWB-2500-13, 14, and 15 show the surface exam volume to be areas A-B and C-D.

II. Requested Relief Pursuant to 10CFR50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests permission to perform surface examination within the limitations described in Table 1 of this relief request.

Tabll Table 1, Limited B-K KE Examinations Item Comp. X 0/0 Number 10 Item Descriptionon erage Coverage Reason for Limitation B10.10 CG RPV RPV Support Support Skirt Skirt Access Access is is available available only only from outside of the RPV Attachment Attachment Wet Weld Skirt. Onlv the Skirt. Only the A-B, A-B area area was was examined examined B10.20 1B21G11- Attachment Attachment Weld Weld 32.0%

32.0% Box Box support support on on pipe pipe only only allowed allowed access access for for aa very very D1-P limited limited portion portion ofof the the weld weld crown crown and and downstre downstream ipe side pipe side of of the the required required examinati examination surface.

GIN ,0-2009/00018 --Enclosure GNRO-2009/00018 Enclosure age 20 Page 20 Basis for Relief During surface examination of both the RPV Skirt weld and pipe support integral attachment weld, 100% coverage of the required examination area could not be obtained .

The configuration of "CG", the Support Skirt Weld, is such that access is only available from the outside surface of the support leaving half of the exam volume inaccessible ; refer to Figure IWB-2500-1 3, 14, and 15 for exam volume . The later Edition of the ASME Code recognizes this and only requires the examination from the accessible surface .

The configuration of 1 B21 G1 1-D1-P is four steel lugs evenly spaced around the pipe and integrally welded in place . The lugs are located within a box-type pipe support that is structurally anchored to wall, serving to restrain the pipe from horizontal motion . Code examination of this type of integral attachment weld requires a surface examination technique, such as as Liquid Dye Dye Penetrant or Magnetic Particle Particle Testing, Testing, of of the weld crown the weld crown surface surface and 1/2 inch of 1/2 inch of base material material on on either side side ofof the the weld toes .

owever, due However, to the configuration due to configuration of this integral of this integral attachment, attachment, and associated pipe and associated pipe support, access to support, access to the weld the weld and and surrounding surrounding base base material, material, for for examination, examination, is is very very limite limited.

In order to perform any type perform any type ofof additional Code examination, additional Code examination, modification and/or replacement modification and/or replacement of of th the component would component would be quired .

required.

IV. Proposed Alternative Examinations No alternative testing is proposed proposed at at this this time. Entergy has time. Entergy has examined examined the subject item the subject item toto the the extent practical.

V. Conclusion OCF 10CFR50.55a(g)(6)(i) states:

The Commission will evaluate determinations under paragraph (g)(5) of this section that code requirements are impractical. The Commission may grant such relief Iii and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the and will not endanger common defense and security and is otherwise in the public interest interest giving giving due due consideration consid to the burden upon the licensee that could result if the requirements quirements were were imposed imposed on on the facility the facility.

Entergy believes that it is impractical to obtain greater examination coverage on this item. To obtain additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject item, in addition to the examination of similar items contained in the program would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity. Therefore, we request the proposed relief be authorized pursuant to 10CFR50.55a(g)(6)(i).

R fief was Relief granted for was granted for this this examination examination during during the first 10-year the first 10-year lSI ISI Interval Interval in Relief Request in Relief Request 1-00010, I

Rev . 6 as submitted Rev. 6 as submitted via via a a letter letter (GNRC}

(GNRO 96-00057) 96-00057) to to the the NRC NRC dated dated May May 21, 21, 19 1996, ASME Section XI Relief Relief Requests.

GNRO-2009/00018 GNRO*2009/00018 -* Enclosure Enclosure Page Page 21 21 RELIEF RELIEF REQUEREQUEST GGNS-ISI-011 GGNS-ISI-011 mponents/Numbers :

Components/Numbers: See Table Codede Classes Classes:: ASME Code Class 22 References

References:

ASM Section X1 1992 Edition, Table IVVC-2500-1 NRC Letter dated February 13, 2007, Request For Alternative 1+_1'"1',,\_+1\,_ GG-ISI-003003 E: Extending the Current Inservice Inspection Interval in Accordance with InC"I""'lr\/'11""'1""'l Int"nl""'l,r"'Tlr,n lr1iT,....r""r,1 in Accordance

.S . Nuclear U.S. Nuclear Regulatory Regulatory Commission Information Notice Notice 98-44 98-44 (TAC(TAC NO NO..

MD3167) (CNR12007-00004}

MD3167) (CNRI2007-00004)

Examina Examination Category:

Description:

Pressure Retaining ning fields in Carbon Welds in Carbon or Low Alloy or Low Alloy Steel Steel Pipi Piping Item Number: C5.51 Unit /Inspection Interval In Grand Gulf Grand Gulf Nuclear Station (GGNS), Second (2 nd ) 1O-year interval June lic billity :

Applicability: October 2008 1997 - October 2008 I. Code Requirement(s)

ACME ASME S SectionLion XI, Table IBC-250o-1, XI, Table IWC-2500-1, Examina Examination Category C-F-2, Pressure Retaining Welds gilds in in Carbon or Low Alloy Steel Piping:

Alloy Steel

1. Item Item C5.51 - Requires 100% volumetric examination of Piping Welds;::: 3/8 inch Nominal Wall Thickness forr Piping Piping> NPS 4, Circumferential Welds II. Requested Relief Pursuant to Pursuant to 10CFR50.55a(g)(5)(iii), Entergy Operations, Inc. (Entergy) requests relief from achieving e

greater than 900/0 coverage as allowed by Code Case N-460, when performing volumetric examinations on the following on the following welds welds.

Table 1, Table 1, Limited C-F-2 Examinations Limited C-F-2 Examinations Item Item pomp.

Comp. %

0/0 Number Number ID ID Item Descri Item Description tion Coverage Covera e Reason for Reason for Limitation itation 05,51 C5.51 1 E51 G004-1E51G004- 8.0" RCIC, Pipe -

8.0" RCIC, 51 .0%

51.0% Scanning is Scanning is completely obstructed by completely obstructed by aa permanent permanent 16-8-3 16-8-3 Elbow, CS CS I I pipe restraint for ipe restraint for 13.5" 13.5" of of the the totaltotal circumference.

circumference .

GNRO-2009/00018 GNRO*2009/00018 *- EnclosureEnclosure Page 22 22 HL -Basis Basis for for Relief Relief During Ultrasonic examination of the pipe to elbow circumferential weld, 100% coverage of the required examination area could not be obtained .

The configuration of 1 E51 G004-16-8-3 is such that 13.5" (49%) of the 27.5" circumferential weld is located under an adjacent pipe restraint that is permanently anchored to a wall, serving to restrain the pipe from horizontal motion as illustrated in Figure 1 . Code examination of this type of this weld requires a volumetric examination technique, in accordance with Appendix VIII of Section X1 . Thi examination was performed utilizing Appendix VIII (PDI) qualified techniques, procedures, and personnel . 100% of the Code Required Volume was obtained in the accessibI personnel.

Entergy has used Entergy has used the bestbest available techniques to to examine examine thethe subject subject piping welds.

welds. To improveimprove upon upon these these examination coverage percentages, examination coverage percentages, modification modification and/or replacement of and/or replacement of the component or the component or restraint would restraint would be required . Consistent be required. with the Consistent with the ASME ASME Section Section XI XI sampling sampling approach, approach, examination examination of of tthe subject subj.ect weld, weld, when combined with when combined with examinations examinations that that have have been performed on been performed on other other welds welds within within the same Examination Lion Category, Category, isis adequate adequate to to detect detect generic generic degradation, degradation, if if itit existed, existed, theref therefore onstra demonstrating eptable level an acceptable level of integrity .

of integrity.

IV. Proposed Alternative Examinations No alternative alternative testing testing isis proposed proposed at at this this time.

time. Enter Entergy has examined the subject welds to the extent practical and will continue to will continue perform pressure to perform pressure testing on the testing on the subject subject welds welds as required by as required by the Cod the Code.

Entergy will use hydrostatic pressure testing and VT-2 visual examinations to compliment the limited examination coverage after each refueling ling outage.

outage V. Conclusion 10CFR50.55a(g)(6)(i) states:

The Commission willI evaluate luate determinations determinations under paragraph (g)(5) under paragraph (g)(5) of of this this section section that that code code req requirements are impractical.1 . The Commission may The Commission grant such may grant relief and such relief may impose and may impose such alternative uirements as requirements as it it determines is s authorized authorized by by lawlaw and and will not endanger will not endanger lifelife or or property or the common defense aand security and common defense nd is otherwise in the public interest giving due consideratio is otherwise in the public interest giving due consideration to the burden upon the the licensee licensee tthat could result if the requirements were imposed imposed on the on foci the facility.

Entergy belie Entergy believes that it is impractical to obtainobtain greater greater examin examination coverage on this item. item . ToTo obtain obtain additionalI coverage would necessitate modification anon and/or and/or replacement replacement of th component. The of the examinations performed on the subject item, in addition to the examination of similar items contained in the program would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity. Therefore, we request the proposed relief be authorized pursuant to 10CFR50.55a(g)(6)(i).

GNRO-2009100018 -- Enclosure GNRO-2009/00018 Enclosure Page 23 Page 23 Figure 1 Figure t::::.

estraint

t::::.

4

</ * *

* *~

t::::.

\>

t::::.

8" RCIC Line t::::.

13.5" obstructed, area not scanned,

GNRO-2009/00018-Enclosure GNRO-2009/00018-Enclosure Page 24 24 RELIEF REQUEST RELIEF REQUEST GGNS-ISI-01 2 GGNS-ISI-012 mponents/Numbers : See Table 1 de Classes:

Code Classes : ASME Code Class 1 References :

References:

ASME Section XI 11992 Edition Examination Category:

Examination Category :

Description :

Description:

Suppo Other Supports ther Thanhan Piping Supports Support; Item Number: F1.40 Unit I Inspection Interval Grand Gulf Nuclear Grand Gulf Nuclear Station Statio (GGNS), Second (2 nd )10-year interval Applicability: June 1997 - May 2008 2008 I. Code Requirement(s)

ASME Section XI, Table IWF-2500-1, 1 . Examination Examination CateaorvCategory F-A, F-A Supports Supports -- Inspection Inspection Program Progra, B:

1. Item F1.40 - Requires a Visual Exa Examination, VT-3 of supports other other than than Pipi Piping Supports.

II. Requested Relief Du Due toto the the g geometric configuration n and and location, certain code location, certain c examination volumes, as depicted in ASME E Secti Section XI, cannot be be examined examined to to the the extent extent of of obtaining obtaining full code coverage full code coverage.. Pursuant Pursuant to to 10CFR50 10CFR50.55a(g)(5)(iii), Entergy Operations, Inc. (Entergy) (Ent requests permission to perform a Visual perform a Visual examination within the limitations described in Table ble 11 of of tthis relief request.

Tab 1, Limited Table Limited F-A Examinat F-A Examinations Item Comp. Item 0/0 Number ID Description Coverage Reason for Limitation port is accessible from the outside only. Visual Support RPV Support E i Examinations can only be performed on one F1.40 8130003S1 Skirt 50.0% surface III. Basis for Relief During g the the Visual Visual examination examination of of the the support support listed listed in in Table Table 11 of of this this relief relief request, request, 100%

100% cover coverage of the the required required examination examination volume volume could could not not be be ob t ed .

obtained.

oration of The configuration of B13DO03S1, B13D003S1 RPV RPV Support Support Skirt,Skirt, is is such such thatthat access access is is only only available available from outside upport leaving of the support leaving the the inside inside surface surface inaccessible inaccessible for visual examination for visual examination..

IV. osed Alternative Proposed Alternative Examinatio, Examinations No alternative alternative ttesting sting is is proposed proposed at at this this time Entergy has time.. Entergy has examined examined this this weld weld to to the the eaten extent practical.

GNRO-2009/00018-Enclosure GNRO-2009/00018-Enclo5ure gage 25 25

v. Conclusion 11 OCFR50 .55 (g)(6)(i) states' The Commission will evaluate determinations under paragraph (g)(5) of this section that code requirements are impractical . The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility .

Entergy believes that itit is is impractical Irnr'~J t'* _ _

..... 1 to obtain greater examination coverage on this Component. The examinations performed on on the subject component would detect generic degradation, if it existed, therefore demonstrating an an acceptable

"::)1",.... ,.....,1""'\ ..._ ...... 1-level of integrity . Therefore, we request the proposed relief b authorized pursuant authorized pursuant toto 10CFR50.55a(g)(6)(i).

1 OCFR50 .55a(g)(6)(i) .

GNRO-2009/00018, Inservice Inspection (Lsi) Relief Requests GG-ISI-005 Through 012 American Society of Mechanical Engineers Section XI Second 10-Year Inspection Interval Closeout

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