CNRO-2005-00013, Request for Alternatives W3-R&R-003, Response to NRC Request for Additional Information

Request for Alternatives W3-R&R-003, Response to NRC Request for Additional Information

ML050740451
Person / Time
Site:	Waterford
Issue date:	03/08/2005
From:	Burford F Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNRO-2005-00013, W3-R&R-003
Download: ML050740451 (18)

Text

Entergy Operations, Inc.

1340 Echelon Parkway EntergyJackson.

Mississippi 39213-8298 Tel 601-368-5758 F. G. Burford Acting Director Nuclear Safety & Licensing CNRO-2005-00013 March 8, 2005 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Request for Alternatives W3-R&R-003 Response to NRC Request for Additional Information Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38

REFERENCES:

1. Entergy letter CNRO-2005-00001 to the NRC dated January 31, 2005

2.

Arizona Public Service letter to the NRC dated June 15, 2004

3.

NRC letter to Arizona Public Service dated November 5, 2004

Dear Sir or Madam:

Entergy Operations, Inc. (Entergy) recently submitted to the NRC via Reference #1 Request for Alternative W3-R&R-003 for use at Waterford Steam Electric Station, Unit 3.

W3-R&R-003 proposed alternatives to the temper bead welding requirements of ASME Section XI IWA-4500 and IWA-4530, which are needed to support the pro-active replacement of pressurizer heater sleeves and instrument nozzles with ones made from a material less susceptible to primary water stress corrosion cracking (PWSCC).

Representatives of the NRC staff and Entergy discussed this proposal in a telephone conversation on March 2, 2005. In that call, Entergy agreed to provide to the staff a matrix that identifies the differences between W3-R&R-003 and a similar request submitted by Arizona Public Service (APS) for use at the Palo Verde Nuclear Generating Station (PVNGS Relief Request 28). [APS submitted PVNGS Relief Request 28 via Reference 2; the NRC staff approved the APS request via Reference #3.] This matrix is provided in the enclosure to this letter. In summary, Entergy identified 3 difference categories involving 21 specific items.

Entergy requests approval of W3-R&R-003 in order to support the pressurizer nozzle replacement activities scheduled to be performed during Waterford 3's upcoming refueling outage RF-13.

CNRO-2005-00013 Page 2 of 2 Should you have any questions regarding this submittal, please contact Guy Davant at (601) 368-5756.

This letter contains no new commitments.

Sincerely, FGB/ghd

Enclosure:

Comparison of Entergy's Request for Alternative W3-R&R-003 to APS' PVNGS Relief Request 28 cc:

Mr. W. A. Eaton (ECH)

Mr. J. E. Venable (W3)

Dr. Bruce S. Mallet Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 U. S. Nuclear Regulatory Commission Attn: Mr. N. Kalyanam MS 0-7D1 Washington, DC 20555-0001 NRC Senior Resident Inspector Waterford 3 P. O. Box 822 Killona, LA 70066-0751

ENCLOSURE CNRO-2005-0001 3 COMPARISON OF ENTERGY'S REQUEST FOR ALTERNATIVE W3-R&R-003 TO APS' PVNGS RELIEF REQUEST 28

Enclosure to CNRO-2005-00013 Page 1 of 15 COMPARISON OF ENTERGY'S REQUEST FOR ALTERNATIVE W3-R&R-003 TO APS' PVNGS RELIEF REQUEST 28 REVIEW

SUMMARY

This review identified 21 specific items that resulted in differences between Entergy's Request for Alternative W3-R&R-003 and Arizona Public Service's (APS) PVNGS Relief Request 28.

These items are categorized as follows:

Editorial Clarification Entergy provided additional information to ensure understanding. Eight (8) items fall into this category.

Difference in Code Requirements The ASME Section Xl Code of Record for Waterford 3 is the 1992 Edition while the Code of Record for Palo Verde is the 1992 Edition, 1992 Addenda. The different Codes of Record result in different requirements for postweld soak temperatures. Specifically, ASME Section Xl, 1992 Edition requires 4500F - 5500F while the 1992 Addenda requires 3000F. Eight (8) items fall into this category.

Difference of Application This category denotes the differences in the applications for which the ambient temperature temper bead welding process will be used at the two plants. These differences are sub-categorized as follows:

> Mid-Wall Repair (Palo Verde) vs. Mid-Wall and Pad Repairs (Waterford 3)

Entergy will use the ambient temperature temper bead process for mid-wall and pad repairs at locations on the pressurizer top head, bottom head, and side shell. APS proposed to use the process for mid-wall repairs on the pressurizer head, only. The technical requirements for the noted applications and locations are the same.

> Code Case N-638 Interpass Temperature Paragraph 2.1(e) of Code Case N-638 limits the maximum interpass temperature to 150OF for procedure qualification. Paragraph 3.0(d), which applies to procedure requirements, specifies that the maximum interpass temperature for field welding applications (i.e., as specified in the welding procedure) shall be 3500F regardless of the interpass temperature utilized during procedure qualification. APS applied the procedure qualification limit of 150OF to the field welding whereas Entergy is consistent with the Code Case by utilizing the 3500F maximum interpass temperature.

Five (5) items fall into this category. [NOTE: Code Case N-638 is being revised by ASME to further clarify these requirements. The draft Section 3.0(d) reads in part, "The maximum interpass temperature for field applications shall be 3500F (1800C) for all weld layers regardless of the interpass temperature used during qualification."]

Enclosure to CNRO-2005-0001 3 Page 2 of 15 Provided in the attached matrix are the specific items from W3-R&R-003 and PVNGS Relief Request 28 (denoted in bold italicized text) as well as the reasons for the differences.

Minor editorial differences, such as word phrasing and descriptive information, are not identified in this review.

Enclosure to CNRO-2005-0001 3 Page 3 of 15 COMPARISON OF ENTERGY'S REQUEST FOR ALTERNATIVE W3-R&R-003 TO APS' PVNGS RELIEF REQUEST 28 (Differences are denoted in bold Italicized text.)

W3-R&R-003 PVNGS Relief Request 28 Reason for the Difference II.

CODE REQUIREMENTS (Page 2 of 24)

III.

Applicable Code Requirements for Welding Alloy 690 Half Sleeve to Pressurizer Mid-wall (Page 4)

IWA-4530 applies to dissimilar materials such as welds that IWA4530 applies to dissimilar materials such as welds Editorial Clarification join P-No. 43 nickel alloy to P-No. 3 low alloy steels.

that join P-No. 43 nickel alloy to P-No. 3 low alloy steels.

According to IWA4530, 'Repairs to welds that join P-No. 8 According to IWA-4530, "Repairs to welds that join P-No.

or P-No. 43 material to P-Nos. 1, 3, 12A, 12B, and 12C 8 or P-No. 43 material to P-Nos. 1, 3, 12A, 12B, and 12C material may be made without the specified postweld heat material may be made without the specified postweld heat treatment provided the requirements of IWA4530 through treatment provided the requirements of IWA-4530 through IWA-4533 are met. Repairs made to this paragraph are IWA4533 are met."

limited to those along the fusion line of a nonferritic weld to ferritic base material where 1/8-inch or less of nonferritic weld deposit exists above the original fusion line after defect removal."

Temper bead repairs are performed in accordance with When the gas tungsten arc welding (GTAW) process is Editorial Clarification IWA-4500 and IWA-4530 whenever the repair cavity is used in accordance with IWA-4500 and IWA4530, temper within 1/8-inch of the ferritic base materials. When the bead welding is performed as follows:

gas tungsten arc welding (GTAW) process is used in accordance with IWA4500 and IWA-4530, temper bead welding is performed as follows:

Enclosure to CNRO-2005-0001 3 Page 4 of 15 W3-R&R-003 l

PVNGS Relief Request 28 Reason for the Difference Upon completion of welding, a postweld soak or Upon completion of welding, a postweld soak or Difference in Code hydrogen bake-out at 4500F - 5500F for a minimum of hydrogen bake-out at 3000F for a minimum of four (4)

Requirements four (4) hours is required hours is required The ASME Section Xl Code of Record for Entergy is the 1992 Edition. This edition requires 4500F - 5500F. APS is committed to follow the 1992 Addenda, which requires 3000F.

III.A Background (Page 3 of 24)

Background Information (Page 1)

This request for alternative is specific to each of the The PVNGS Unit 2 pressurizer heater sleeves were Difference of Application following pressurizer repair welding activities that repaired using a half-sleeve, pad repair... This pad Involve welding using a proposed ambient temperature repair was installed using the process described in As stated in PVNGS Relief temper bead technique:

PVNGS Relief Request 23 approved on July 30, 2003.

Request 28, the pad repair previously installed on the Unit 2 Heater Sleeve Mid-Wall Repair The half-sleeve, mid-wall weld repair being proposed pressurizer was performed using for the heater sleeves In Units 1 and 3...

Relief Request 23. Relief Request Heater Sleeve Repair Using an Outside Diameter 28 covers use of ambient Weld Pad temperature temper bead repair for mid-wall repair, only.

OD Weld Pad Repair of Lower Head Instrument Nozzles W3-R&R-003 proposes to use the ambient temperature temper bead OD Weld Pad Repair of Side Shell Instrument weld repair process for both the Nozzle mid-wall repair and the pad repair.

The technical requirements for OD Weld Pad Repair of Previously Repaired Upper both configurations are the same.

Head Instrument Nozzles

Enclosure to CNRO-2005-00013 Page 5 of 15 W3-R&R-003 PVNGS Relief Request 28 J

Reason for the Difference III.B. Proposed Alternative (Pages 4 - 6 of 24)

IV.

Proposed Alternative (Pages 5 - 7)

4.

IWA-4500(e)(2) specifies that thermocouples and

4.

IWA-4500(e)(2) specifies that thermocouples and Editorial Clarification recording instruments shall be used to monitor process recording instruments shall be used to monitor temperatures. Entergy will not employ thermocouples process temperatures. APS will not employ or recording instrumentation since there will be no thermocouples or recording instrumentation since elevated preheat. Because of the large heat sink there will be no elevated preheat. Because of the provided by the pressurizer, the interpass large heat sink interpass temperature is not expected temperature is not expected to approach 3500F. This to approach 3500F.

was verified by mockup testing.

9.

IWA-4532.2(d) specifies that, after at least 3/16-inch of

8.

IWA-4532.2(d) specifies that, after at least 3/16-inch Difference in Code weld metal has been deposited, the weld area shall be of weld metal has been deposited, the weld area shall Requirements maintained at a temperature of 450 F-550 IF for a be maintained at a temperature of 300 I for a minimum of four (4) hours (for P-No. 3 materials). As minimum of four (4) hours (for P-No. 3 materials). As The ASME Section Xl Code of an alternative, Entergy's proposed ambient an alternative, APS' proposed ambient temperature Record for Entergy is the 1992 temperature temper bead technique does not include a temper bead technique does not include a postweld Edition. This edition requires postweld soak soak 4500F - 5500F. APS is committed to follow the 1992 Addenda, which requires 3000F.

Enclosure to CNRO-2005-0001 3 Page 6 of 15 I.,

W3-R&R-003 PVNGS Relief Request 28 Reason for the Difference

10. IWA-4532.2(e) specifies that after depositing at least

9.

IWA-4532.2(e) specifies that after depositing at least Difference in Code 3/16-inch of weld metal and performing a postweld 3/16-inch of weld metal and performing a postweld Requirements soak 450 F - 550IF, the balance of welding may be soak at a minimum temperature of 300 cF, the performed at an interpass temperature of 3500F. As an balance of welding may be performed at an interpass The ASME Section Xl Code of alternative, Entergy proposes that an interpass temperature of 3500F. As an alternative, APS Record for Entergy is the 1992 temperature of 3500F may be used throughout the proposes that an interpass temperature of 3500F may Edition. This edition requires welding process without a postweld soak be used after depositing at least 1/8-inch of weld 4500F - 5500F. APS is committed metal without a postweld soak.

to follow the 1992 Addenda, which requires 3000F.

Difference of Application Paragraph 2.1(e) of Code Case N-638 limits the maximum interpass temperature to 1500F for procedure qualification. Paragraph 3.0(d), which applies to procedure requirements, specifies that the maximum interpass temperature for field welding applications (i.e.,

as specified in the welding procedure) shall be 3500F regardless of the interpass temperature utilized during procedure qualification. Entergy is consistent with the requirements of Paragraph 3.0(d).

14 Enclosure to CNRO-2005-0001 3 Page 7 of 15 W3-R&R-003 PVNGS Relief Request 28 Reason for the Difference

11. IWA-4533 specifies the following examinations shall be

10. IWA-4533 specifies the following examinations shall Editorial Clarification performed after the completed repair weld has been at be performed after the completed repair weld has ambient temperature for at least 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />s: (a) the been at ambient temperature for at least 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />s: (a) Both reflect the same repair weld and preheated band shall be examined by the repair weld and preheated band shall be requirements; however, Entergy the liquid penetrant method; (b) the repaired region examined by the liquid penetrant method; (b) the provides more explicit information.

shall be volumetrically examined by the radiographic repaired region shall be examined by the radiographic This information is repeated in method, and if practical, by the ultrasonic method. As method, and if practical, (c) by the ultrasonic method.

Section IV.B.8 and in Attachment an alternative to the IWA-4533, Entergy proposes to APS will perform the liquid penetrant examination 1, Section 4.0 of W3-R&R-003.

perform the following examinations of the new mid-of the completed repair weld. As an alternative to wall repair weld and OD weld pad:

the radiographic examination of IWA-4533, APS proposes ultrasonic examination of the repair

a. A liquid penetrant examination of the weld.

completed repair weld shall be performed in accordance with NB-5000 of ASME Section III, 1989 Edition. Acceptance criteria shall comply with NB-5350.

b.

The completed repair weld shall be ultrasonically examined in accordance with NB-5000 of ASME Section ill, 1989 Edition.

Acceptance criteria shall comply with NB-5330.

.4 Enclosure to CNRO-2005-0001 3 Page 8 of 15 W3-R&R-003 PVNGS Relief Request 28 Reason for the Difference IV.

BASIS FOR PROPOSED ALTERNATIVE V.

Basis of Alternative for Providing Acceptable (Pages 6 - 9 of 24)

Level of Quality and Safety (Pages 7-10)

The pressurizer upper and lower heads and side shell The pressurizer head was manufactured from P-No. 3, Difference of Application were manufactured from P-No. 3, Group 3 low alloy steel.

Group 3 low alloy steel.

Entergy will use the ambient temperature temper bead process for mid-wall and pad repairs at locations on the pressurizer top head, bottom head, and side shell.

APS proposed to use the process for mid-wall repairs on the pressurizer head, only. The technical requirements for both configurations are the same.

IWA-4500 and IWA-4530 of ASME Section XI establish IWA-4500 and IWA4530 of ASME Section Xl establish Difference in Code requirements for performing temper bead welding of requirements for performing temper bead welding of Requirements

'dissimilar materials". According to IWA4530, either the "dissimilar materials". According to IWA-4530, either the automatic or machine GTAW process or SMAW process automatic or machine GTAW process or SMAW process The ASME Section Xl Code of may be used. When using the machine GTAW process, a may be used. When using the machine GTAW process, a Record for Entergy is the 1992 minimum preheat temperature of 300OF must be minimum preheat temperature of 3000 F must be Edition. This edition requires established and maintained throughout the welding process established and maintained throughout the welding 4500F - 5500F. APS is committed while the interpass temperature is limited to 4500F. Upon process while the interpass temperature is limited to to follow the 1992 Addenda, which completion of welding, a postweld soak is performed at 4500F. Upon completion of welding, a postweld soak is requires 3000F.

450 F - 550 °F for a minimum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

performed at 300 IF (minimum) for a minimum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

I Enclosure to CNRO-2005-0001 3 Page 9 of 15 W3-R&R-003 PVNGS Relief Request 28 Reason for the Difference

1. Mechanical Properties (2d para.)

1. Mechanical Properties (2nd para.)

Difference in Code Requirements The IWA-4530 temper bead process also includes a The IWA-4530 temper bead process also includes a postweld soak requirement. Performed at 450'F-postweld soak requirement. Performed at 300='for 4 The ASME Section Xl Code of 550 IF for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (P-No. 3 base materials), this hours (P-No. 3 base materials), this postweld soak Record for Entergy is the 1992 postweld soak assists diffusion of any remaining assists diffusion of any remaining hydrogen from the Edition. This edition requires hydrogen from the repair weld. As such, the postweld repair weld. As such, the postweld soak is a hydrogen 4500F - 5500F. APS is committed soak is a hydrogen bake-out and not a postweld heat bake-out and not a postweld heat treatment as defined to follow the 1992 Addenda, which treatment as defined by the ASME Code. At 450 IF-by the ASME Code. At 300'F, the postweld soak requires 3000F.

550 If, the postweld soak does not stress relieve, does not stress relieve, temper, or alter the temper, or alter the mechanical properties of the mechanical properties of the weidment in any manner.

weldment in any manner.

2.

Hvdrogen Cracking (2'm paragraph)

2. Hydrogen Cracking (2nd paragraph)

Difference in Code IWA-4500 establishes elevated preheat and postweld IWA-4500 establishes elevated preheat and postweld Requirements soak requirements. The elevated preheat temperature soak requirements. The elevated preheat temperature The ASME Section Xl Code of of 300°F increases the diffusion rate of hydrogen from of 300°F increases the diffusion rate of hydrogen from Record for Entergy is the 1992 the weld. The postweld soak at 450'F-550'Fwas the weld. The postweld soak at 300 'Fwas also Edition. This edition requires also established to bake-out or facilitate diffusion of established to bake-out or facilitate diffusion of any 450°F - 550°F. APS is committed any remaining hydrogen from the weldment. However, remaining hydrogen from the weldment. However, to follow the 1992 Addenda, which while hydrogen cracking is a concern for SMAW, which while hydrogen cracking is a concern for SMAW, requires 3000F.

uses flux covered electrodes, the potential for which uses flux covered electrodes, the potential for hydrogen cracking is significantly reduced when using hydrogen cracking is significantly reduced when using the machine GTAW welding.

the machine GTAW welding.

Enclosure to CNRO-2005-0001 3 Page 10 of 15 W3-R&R-003 PVNGS Relief Request 28 Reason for the Difference lV.B Evaluation of Proposed Alternatives to IWA-4500 V.B Evaluation of Proposed Alternatives to ASME and IWA-4530 Section Xl, IWA-4500 and IWA-4530 (Pages 10 - 13 of 24)

(Pages 12 - 15)

1. According to IWA-4500(a), repairs may be performed

1. According to IWA-4500(a), repairs may be performed Difference in Code to dissimilar base materials and welds without the to dissimilar base materials and welds without the Requirements specified postweld heat treatment of ASME Section ill specified postweld heat treatment of ASME Section ill provided the requirements of IWA-4500 and IWA-4530 provided the requirements of IWA-4500 and IWA-4530 The ASME Section Xl Code of are met. The temper bead rules of IWA-4500 and IWA-are met. The temper bead rules of IWA-4500 and Record for Entergy is the 1992 4530 apply to dissimilar materials such as P-No. 43 to IWA-4530 apply to dissimilar materials such as P-No.

Edition. This edition requires P-No. 3 base materials welded with F-No. 43 filler 43 to P-No. 3 base materials welded with F-No. 43 4500F - 5500F. APS is committed metals. When using the GTAW-machine process, the filleremetals. When using the GTAW-machine to follow the 1992 Addenda, which IWA-4500 and IWA4530 temper bead process is process, the IWA-4500 and IWA4530 temper bead requires 3000F.

based fundamentally on an elevated preheat process is based fundamentally on an elevated temperature of 300°F, a maximum interpass preheat temperature of 300°F, a maximum interpass temperature of 450°F, and a postweld soak of 450°F-temperature of 450°F, and a postweld soak of 300'F.

550"F. The proposed alternative of Attachment 1 also The proposed alternative of Attachment 1 also establishes requirements to perform temper bead establishes requirements to perform temper bead welding on dissimilar material welds that join P-No. 43 welding on dissimilar material welds that join P-No. 43 to P-No. 3 base materials using F-No. 43 filler metals.

to P-No. 3 base materials using F-No. 43 filler metals.

However, the temper bead process of Attachment I is However, the temper bead process of Attachment 1 is an ambient temperature technique that only utilizes the an ambient temperature technique that only utilizes GTAW-machine or GTAW-automatic process. The the GTAW-machine or GTAW-automatic process. The suitability of the proposed ambient temperature temper suitability of the proposed ambient temperature bead technique is evaluated in this section. The temper bead technique is evaluated in this section.

results of this evaluation demonstrate that the The results of this evaluation demonstrate that the proposed ambient temperature temper bead technique proposed ambient temperature temper bead technique provides an acceptable level of quality and safety.

provides an acceptable level of quality and safety.

Enclosure to CNRO-2005-0001 3 Page 11 of 15 W3-R&R-003 PVNGS Relief Request 28 Reason for the Difference

2. According to IWA-4500(e)(2), the weld area plus a

2. According to IWA-4500(e)(2), the weld area plus a Difference of Application band around the repair area of at least 1-1/2 times the band around the repair area of at least 1-1/2 times the component thickness or 5 inches, whichever is less, component thickness or 5 inches, whichever is less, Paragraph 2.1 (e) of Code Case shall be preheated and maintained at a minimum shall be preheated and maintained at a minimum N-638 limits the maximum temperature of 300OF for the GTAW process during temperature of 300OF for the GTAW process during interpass temperature to 1500 F for welding while the maximum interpass temperature is welding while the maximum interpass temperature is procedure qualification. Paragraph limited to 4500F. The ambient temperature temper limited to 4500F. The ambient temperature temper 3.0(d), which applies to procedure bead technique of Attachment I also establishes a bead technique of Attachment I also establishes a requirements, specifies that the preheat band of at least 1 1/2times the component preheat band of at least 11 times the component maximum interpass temperature thickness or 5 inches, whichever is less. However, the thickness or 5 inches, whichever is less. However, the for field welding applications (i.e.,

ambient temperature temper bead technique requires a ambient temperature temper bead technique requires as specified in the welding minimum preheat temperature of 500F and a maximum a minimum preheat temperature of 500F, a maximum procedure) shall be 3500F interpass temperature of 3500F. The suitability of an Interpass temperature of 150 'F for the first three regardless of the interpass ambient temperature temper bead technique with layers, and a maximum interpass temperature of temperature utilized during reduced preheat and interpass temperatures is 3500F. The suitability of an ambient temperature procedure qualification. Entergy is addressed in Section IV.A.

temper bead technique with reduced preheat and consistent with the requirements of interpass temperatures is addressed in Section IV.A.

Paragraph 3.0(d).

Enclosure to CNRO-2005-0001 3 Page 12 of 15 W3-R&R-003 PVNGS Relief Request 28 Reason for the Difference

6. According to IWA-4532.2(d), the weld area shall be

6. According to IWA-4532.2(d), the weld area shall be Difference in Code maintained at a temperature of 450IF-550 Ffor a maintained at a temperature of 300cF for a minimum Requirements minimum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (for P-No. 3 materials) after at of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (for P-No. 3 materials) after at least least 3/16-inch of weld metal has been deposited. In 3/16-inch of weld metal has been deposited. In the The ASME Section Xi Code of the proposed alternative of Attachment 1, a postweld proposed alternative of Attachment 1, a postweld soak Record for Entergy is the 1992 soak is not required. The suitability of an ambient is not required. The suitability of an ambient Edition. This edition requires temperature temper bead technique without a postweld temperature temper bead technique without a 4500F - 5500F. APS is committed soak is addressed in Section IV.A.

postweld soak is addressed in Section IV.A.

to follow the 1992 Addenda, which requires 3000F.

Enclosure to CNRO-2005-00013 Page 13 of 15 W3-R&R-003 PVNGS Relief Request 28 Reason for the Difference

7. According to IWA-4532.2(e), after depositing at least

7. According to IWA-4532.2(e), after depositing at least Difference in Code 3/16-inch of weld metal and performing a postweld 3/16-inch of weld metal and performing a postweld Requirements soak at 450 I - 550'F', the balance of welding may be soak at a minimum temperature of 300 IF, the performed at an interpass temperature of 3500F. As an balance of welding may be performed at an interpass The ASME Section Xl Code of alternative, Entergy proposes that an interpass temperature of 3500F. As an alternative, APS Record for Entergy is the 1992 temperature of 3500F may be used throughout the proposes that an interpass temperature of 3500F may Edition. This edition requires welding process without a postweld soak. The be used after depositing at least 1/8-inch of weld 4500F - 5500F. APS is committed proposed ambient temperature temper bead process of metal without a postweld soak. The proposed to follow the 1992 Addenda, which Attachment I is carefully designed and controlled such ambient temperature temper bead process of requires 3000F.

that successive weld beads supply the appropriate is carefully designed and controlled such quantity of heat to the untempered heat affected zone that successive weld beads supply the appropriate Difference of Application such that the desired degree of carbide precipitation quantity of heat to the untempered heat affected zone (tempering) is achieved. The resulting microstructure is such that the desired degree of carbide precipitation Paragraph 2.1 (e) of Code Case very tough and ductile. This point is validated during (tempering) is achieved. The resulting microstructure N-638 limits the maximum weld procedure qualification. Based on Charpy is very tough and ductile. This point is validated interpass temperature to 150OF for V-notch testing of the procedure qualification test during weld procedure qualification. Based on Charpy procedure qualification. Paragraph coupon, impact properties in weld heat affected zone V-notch testing of the procedure qualification test 3.0(d), which applies to procedure will be demonstrated to be equal to or better than those coupon, impact properties in weld heat affected zone requirements, specifies that the of the unaffected base material. The suitability of an will be demonstrated to be equal to or better than maximum interpass temperature ambient temperature temper bead technique without a those of the unaffected base material. The suitability for field welding applications (i.e.,

postweld soak is addressed in Section IV.A.

of an ambient temperature temper bead technique as specified in the welding without a postweld soak is addressed in Section IV.A.

procedure) shall be 350IF regardless of the interpass temperature utilized during procedure qualification. Entergy is consistent with the requirements of Paragraph 3.0(d).

' W3-R&R-003 states that the postweld soak temperature is 3000F rather than 450IF - 5501F. This is in error. By this letter, Entergy corrects this error as indicated. This correction has no impact on W3-R&R-003 since Entergy is proposing an alternative to IWA-4532.2(e).

Enclosure to CNRO-2005-00013 Page 14 of 15 i

W3-R&R-003 PVNGS Relief Request 28 Reason for the Difference 19 IWA-4533 specifies that (a) the repair weld and preheated band shall be examined by the liquid penetrant method; (b) the repaired region shall be volumetrically examined by the radiographic method, and if practical, by the ultrasonic method.

As an alternative to the IWA-4533, Entergy proposes to perform the following examinations:

a. Liquid penetrant examination shall be performed in accordance with NB-5000 of ASME Section III, 1989 Edition. Acceptance criteria shall comply with NB-5350.

Suitability: When using an ambient temperature temper bead technique, an elevated preheat temperature is not used. As a result, there Is no preheated band. Therefore, the proposed alternative to only examine the new mid-wall repair weld and OD weld pad (including weld heat affected zones) is acceptable.

b. The completed repair weld shall be ultrasonically examined in accordance with NB-5000 of ASME Section III, 1989 Edition.

Acceptance criteria shall comply with NB-5330.

Suitability: Radiographic examination is impractical since the pressurizer vessel Inside diameter Is inaccessible for positioning the gamma source. As an alternative to radiographic examination, an ultrasonic examination of the new mid-wall repair weld and OD weld pad will be performed. Ultrasonic examination of temper bead repair welds is an acceptable option according to ASME Section Xi, IWA-4630 In the 1995 Edition, 1996 Addenda

8. IWA-4533 specifies that the repair weld and preheated band shall be examined by liquid penetrant. Since there is no elevated preheated band, APS will be performing a penetrant examination of the final weld surface and the adjacent heat affected zone only. IWA-4533 also states that the repair weld shall be volumetrically examined by the radiographic method, and if practical, by the ultrasonic method after the completed repair weld has been at ambient temperature for at least 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. As an alternative to the radiographic examination of IWA-4533, APS proposes using the ultrasonic examination method.

Radiographic examination Is Impractical since the pressurizer vessel ID surface Is inaccessible for positioning the gamma source. Ultrasonic examination is another acceptable volumetric NDE method to assure weld quality and the 1996 Addenda of ASME Section Xl (approved by the NRC) provides such an option. The ultrasonic examination will be performed In accordance with NB-5000 and acceptance criteria will be in accordance with NB-5330.

Editorial Clarification Item #9 for W3-R&R-003 repeats and expands the information contained in Item #8 of RR 28.

Item #9 provides the basis for the proposed alternative discussed in Section III.B.1 I of W3-R&R-003.

Enclosure to CNRO-2005-0001 3 Page 15 of 15

.e W3-R&R-003 PVNGS Relief Request 28 Reason for the Difference and later (approved by NRC through the 2001 Edition, 2003 Addenda). Ultrasonic examination of repair welds Is also required in Code Case N-638. The proposed ultrasonic examination will be performed In accordance with ASME Section III, NB-5000 which Includes acceptance criteria that is appropriate for fabrication type flaws.

Attachment I (Pages 21 and 22 of 24)

Attachment I (Page 4) 4.0(a) Prior to welding, a surface examination will be 4.0(a) Prior to welding, a surface examination will be Editorial Clarification performed In accordance with NB-5000 of ASME performed on the area to be welded.

Section il on the area to be welded.

5.0 Use of Request No. W3-R&R-003 shall be 5.0 Use of this request shall be documented on NIS-2.

Editorial Clarification documented on NIS-2. Alternatively, repairs may be documented on Form NIS-2A as described in Code Case N-532 has since been Code Case N-532 If prior approval is obtained approved by the NRC.

from the NRC.

I