1CAN050902, Arkansas, Unit 1, Requests for Relief from ASME Section XI Volumetric, Surface and Visual Examination Requirements - Third 10-Year Interval
| ML091520610 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 05/29/2009 |
| From: | David Bice Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 1CAN050902 | |
| Download: ML091520610 (24) | |
Text
Entergy Operations, Inc.
1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4710 David B. Bice Acting Manager, Licensing Arkansas Nuclear One 1CAN050902 May 29, 2009 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Requests for Relief from ASME Section XI Volumetric, Surface and Visual Examination Requirements - Third 10-Year Interval Arkansas Nuclear One, Unit 1 Docket No. 50-313 License No. DPR-51
REFERENCE:
- 1. Entergy Letter to the NRC, Requests for Relief from ASME Section XI Volumetric Examination, dated December 2, 2003 (CNRO-2003-00063)
Dear Sir or Madam:
Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from the requirements of the American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel (B&PV) Code,Section XI pertaining to volumetric, surface, and visual examinations at Arkansas Nuclear One, Unit 1 (ANO-1). In several locations, the required coverage cannot be obtained due to interference or geometry. The individual relief requests by examination category are provided in the attachments. These reliefs are for the third 10-year interval.
Entergy has previously submitted relief requests for limited volumetric examinations for ANO-1 pressure-retaining welds (Reference 1).
This submittal contains no new commitment.
1CAN050902 Page 2 of 2 If you have any questions or require additional information, please contact me.
Sincerely, DBB/rwc Attachments:
- 1. Request for Relief ANO1-ISI-015
- 2. Request for Relief ANO1-ISI-016
- 3. Request for Relief ANO1-ISI-017
- 4. Request for Relief ANO1-ISI-018
- 5. Request for Relief ANO1-ISI-019
- 6. Request for Relief ANO1-ISI-020 cc: Mr. Elmo E. Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector Arkansas Nuclear One P. O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Kaly Kalyanam MS O-8B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Bernard R. Bevill Arkansas Department of Health Radiation Control Section 4815 West Markham Street Slot #30 Little Rock, AR 72205
Attachment 1 1CAN050902 Request for Relief ANO1-ISI-015 to 1CAN050902 Page 1 of 3 REQUEST FOR RELIEF ANO1-ISI-015 Components / Numbers: See Table 1 Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1
References:
ASME Section XI 1992 Edition, Table IWB-2500-1 ASME Section XI 1995 Edition with 1996 Addenda Examination Category: B-A Item Number(s) B1.11, B1.21
==
Description:==
Pressure Retaining Welds in Reactor Vessel - Inspection Program B Unit / Inspection Interval Arkansas Nuclear One, Unit 1 (ANO-1) / Third (3rd) 10-Year Applicability: Interval I. CODE REQUIREMENTS ASME Section XI, Table IWB-2500-1, Examination Category B-A, Pressure Retaining Welds in Reactor Vessel - Inspection Program B:
- 1) Item B1.11 requires a volumetric examination of the circumferential shell welds as depicted in Figure IWB-2500-1,
- 2) Item B1.21 requires a volumetric examination of the head welds as depicted in Figure IWB-2500-3.
II. RELIEF REQUEST Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving the Code-required coverage when performing volumetric examinations of the components identified in Table 1 below.
to 1CAN050902 Page 2 of 3 Table 1 Limited B-A Examinations Item # Item ID Description Coverage Reason for Limitation
(%)
B1.11 01-005 Lower Shell to Lower Head 36.38 Lower Head Configuration B1.21 01-006 Bottom Head Weld 59.07 Lower Head Configuration III. BASIS FOR RELIEF During the ANO-1 twenty-first refueling outage (1R21), the reactor pressure vessel welds were examined to comply with the examination requirements of the ASME Section XI Code, which included the requirements of Mandatory Appendix VIII for ultrasonic examinations (Performance Demonstration for Ultrasonic Examination Systems).
The ultrasonic examination procedures were qualified through the performance demonstration initiative (PDI) process conducted at the Electric Power Research Institute (EPRI).
Examination of weld 01-005 was limited due to the core support lugs and flow diverters on the bottom head. Very limited perpendicular and parallel coverage was achievable due to geometrical interference of the lugs and diverters. 45 Shear, 45 Longitudinal, Single and 45 Longitudinal Dual scans were performed on all possible scan areas.
Examination of the required weld volume of weld 01-006 was limited due to twelve (12) flow diverters located on the bottom head of the vessel. 45 Shear, 45 Longitudinal, Single and 45 Longitudinal Dual scans were performed on all possible scan areas.
Radiography is not practical because of the geometry of the components, which prevents proper placement of the film and exposure source. To perform the Code-required examination would require modifying and/or replacing the flow diverters. The examinations performed on the subject items, in addition to the examination of the other reactor vessel welds, would detect generic degradation, if it existed, demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS Entergy has examined these welds to the extent practical with approved ASME Section XI, Appendix VIII, PDI demonstrated ultrasonic examination techniques.
to 1CAN050902 Page 3 of 3 V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Entergy has examined the subject welds to the extent possible with approved ASME Section XI, Appendix VIII, PDI demonstrated techniques. The examinations performed on the subject welds, in addition to the examination of similar welds contained in the program, would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. Entergy requests the proposed alternative be authorized pursuant to 10 CFR 50.55a(g)(6)(i).
Attachment 2 1CAN050902 Request for Relief ANO1-ISI-016 to 1CAN050902 Page 1 of 3 REQUEST FOR RELIEF ANO1-ISI-016 Components / Numbers: See Table 1 Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1
References:
ASME Section XI 1992 Edition, Table IWB-2500-1 ASME Section XI 1980 Edition, with Winter 1981 Addenda for ultrasonic examinations Examination Category: B-D Item Number(s) B3.110
==
Description:==
Full Penetration Welded Nozzles in Vessels - Inspection Program B Unit / Inspection Interval Arkansas Nuclear One, Unit 1 (ANO-1) / Third (3rd) 10-Year Applicability: Interval I. CODE REQUIREMENTS ASME Section XI, Table IWB-2500-1, Examination Category B-D, Full Penetration Welded Nozzles in Vessels - Inspection Program B:
- 1) Item B3.110 requires a volumetric examination of Pressurizer Nozzle-to-Vessel Weld volume, as depicted in Figures IWB-2500-7(a) through (d).
II. RELIEF REQUEST Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving the Code-required coverage when performing volumetric examinations of the components identified in Table 1 below.
to 1CAN050902 Page 2 of 3 Table 1 Limited B-D Examinations Item # Item ID Description Coverage Reason for Limitation
(%)
B3.110 05-014 Pressurizer Relief Nozzle- 28.7 Nozzle-to-Vessel to-Head Weld Configuration B3.110 05-015 Pressurizer Relief Nozzle - 28.7 Nozzle-to-Vessel to-Head Weld Configuration B3.110 05-021 Pressurizer Surge Nozzle- 32 Nozzle-to-Vessel to Head Weld Configuration III. BASIS FOR RELIEF During ultrasonic examination of the Pressurizer and Steam Generator nozzle-to-vessel welds listed in Table 1 above, 100% coverage of the required examination volume could not be obtained.
Due to the geometric configuration of welds05-014 and 05-015, which are located in the intersection (crotch area) of the pressurizer head and relief nozzles, the use of 45, 60, 70, and 0 beam angles in the 45 axial direction and 60 in the circumferential direction were not able to achieve greater than 90% Code required volume.
Due to the outside diameter geometric configuration of weld 05-021, which is located in the crotch area between the pressurizer vessel head and the nozzle, the multi-angle Code required coverage is very limited. Scanning was performed from both the head and nozzle bore, where accessible, with 45, 60, and 70 shear transducers. No circumferential scan coverage was achievable, due to the weld location.
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 ultrasonic examinations, modification and/or replacement of the component would be required. The examinations performed on the subject items in addition to the examination of other vessel welds contained in the Inservice Inspection (ISI) program would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS Entergy has examined these welds to the extent practical and will continue to perform pressure testing on the subject welds on the new replacement vessel head, as required by the Code.
to 1CAN050902 Page 3 of 3 V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Entergy believes that it is impractical to obtain greater examination coverage on these welds. To obtain additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject welds, in addition to the examination of similar welds contained in the program, would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity. Entergy requests the proposed alternative be authorized pursuant to 10 CFR5 0.55a(g)(6)(i).
Attachment 3 1CAN050902 Request for Relief ANO1-ISI-017 to 1CAN050902 Page 1 of 2 REQUEST FOR RELIEF ANO1-ISI-017 Components / Numbers: See Table 1 Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1
References:
ASME Section XI 1992 Edition, Table IWB-2500-1 ASME Section XI 1995 Edition with 1996 Addenda for ultrasonic examinations Examination Category: B-G-1 Item Number(s) B6.40
==
Description:==
Pressure Retaining Bolting, Greater than 2 in. In Diameter Unit / Inspection Interval Arkansas Nuclear One, Unit 1 (ANO-1) / Third (3rd) 10-Year Applicability: Interval I. CODE REQUIREMENTS ASME Section XI, Table IWB-2500-1, Examination Category B-G-1, Pressure Retaining Bolting, Greater Than 2 in. In Diameter, Item B6.40 requires a volumetric examination of the threads in the reactor vessel flange.
II. RELIEF REQUEST Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving the Code-required coverage when performing volumetric examinations of the components identified in Table 1 below.
Table 1 Limited B-G-1 Examinations Item # Item ID Description Coverage Reason for Limitation
(%)
B6.40 01-F-01 Threads in Reactor Vessel 79 Pressure Vessel Head Seal through Flange Surface and Stud Holes 15 01-F-60 and 45 Configurations to 1CAN050902 Page 2 of 2 III. BASIS FOR RELIEF The threads in the reactor vessel flange were examined to comply with the examination requirements of the ASME Section XI Code, which included the requirements of Mandatory Appendix VIII for ultrasonic examinations (Performance Demonstration for Ultrasonic Examination Systems).
The ultrasonic examination procedures were qualified through the performance demonstration initiative (PDI) process conducted at the Electric Power Research Institute (EPRI).
During the ultrasonic examination of the threaded area in the upper Reactor Vessel flange, 100% coverage of the required examination volume could not be obtained.
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 79% of the required volume of the subject items would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS Entergy has examined the subject items to the extent practical and will continue to perform pressure testing on the subject areas as required by the Code.
V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Entergy believes that it is impractical to obtain greater examination coverage on these areas. To obtain additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject areas, in addition to the examination of similar welds contained in the program would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity. Therefore, Entergy requests the proposed alternative be authorized pursuant to 10 CFR 50.55a(g)(6)(i).
Attachment 4 1CAN050902 Request for Relief ANO1-ISI-018 to 1CAN050902 Page 1 of 3 REQUEST FOR RELIEF ANO1-ISI-018 Components / Numbers: See Table 1 Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1
References:
ASME Section XI 1992 Edition, Table IWB-2500-1 ASME Section XI 1995 Edition with 1996 Addenda Code Case N-460 Examination Category: B-J Item Number(s) B9.11, B9.21, B9.32
==
Description:==
Pressure Retaining Welds in Piping Unit / Inspection Interval Arkansas Nuclear One, Unit 1 (ANO-1) / Third (3rd) 10-Year Applicability: Interval I. CODE REQUIREMENTS ASME Section XI, Table IWB-2500-1, Examination Category B-J, Pressure Retaining Welds in Piping, Items B9.11, B9.21, and B9.32, all require 100% volumetric examination of the Class 1 pipe welds identified through the risk-informed process.
During the third 10-year Inservice Inspection (ISI) interval at ANO-1, 10 CFR 50.55a(g)(6)(ii)(C) mandated an implementation schedule for all licensees to begin use of Appendix VIII of the 1995 Edition with the 1996 Addenda of ASME Section XI. With the implementation of Appendix VIII, only 1/2 Vee path examinations have been allowed to be used in austenitic materials and angle beams are no longer credited to extend beyond the centerline of austenitic welds for consideration of Code coverage, in accordance with qualified performance demonstrated initiative (PDI) procedures. The examinations listed in Table 1 are all PDI examinations. Additional discussion, as to the examination coverage determination process when using Appendix VIII techniques on single-sided austenitic welds, is provided in Section III of this relief request.
II. RELIEF REQUEST Pursuant to 10CFR50.55a(g)(6)(i), 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.
to 1CAN050902 Page 2 of 3 Table 1 Limited B-J Examinations Item # Item ID Description Coverage Reason for Limitation
(%)
B9.11 09-001 D Reactor Coolant Pump 50 Pipe-to-Pump Configuration (RCP) Pump-to-Pipe Weld B9.21 18-010 Pressurizer Spray Valve- 50 Pipe-to-Valve Configuration to-Pipe Weld B9.21 23-055 High Pressure Injection 41 Valve Configuration (HPI) to B2 loop Elbow-to-Valve Weld B9.32 09-006 Pipe to HPI Nozzle Weld 50 Pipe-to-Valve Configuration III. BASIS FOR RELIEF During ultrasonic examination of the piping welds listed in Table 1 above, 100%
coverage of the required examination volume could not be obtained.
Access was limited to single side on weld 09-001 due to pipe-to-pump configuration for both axial and circumferential scans.
Access was limited to single side on weld 18-010 due to pipe-to-valve configuration for both axial and circumferential scans.
Access was limited to single side on weld 23-055 due to valve configuration on the downstream side of the weld. Additionally, the scan access was limited on the elbow side of the weld, due to the loss of transducer contact in the intrados of the elbow (9%
CRV limitation).
Access on weld 09-006 was limited to single side due to 28 inch clad pipe to 6 inch HPI nozzle weld configuration (no access to the examination volume from the nozzle boss side).
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 10 CFR 50.55a mandatory implementation date for Appendix VIII of Section XI, and Code coverage percentages provided reflect what is currently allowed by qualified Appendix VIII techniques. Appendix VIII qualified (PDI) procedures have demonstrated that sound beams may potentially be attenuated and distorted when required to pass through austenitic weld metal. Still, the PDI qualified methods employ the best available technology for maximizing examination coverage of these types of welds. For all the components listed in this relief request, to 1CAN050902 Page 3 of 3 examination was extended to the far side of the weld to the extent permitted by geometry, but this portion of the examination is not included in the reported coverage for welds examined under PDI and Appendix VIII rules.
Entergy has used the best available and EPRI approved 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 ALTERNATIVE EXAMINATIONS Entergy has examined the subject welds to the extent practical and will continue to perform pressure testing and VT-2 visual examination in accordance with ASME Section XI requirements to compliment the limited examination coverage after each refueling outage.
V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Entergy believes that it is impractical to obtain greater examination coverage on these areas. To obtain additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject areas, in addition to the examination of similar welds contained in the program would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity. Therefore, Entergy requests the proposed alternative be authorized pursuant to 10 CFR 50.55a(g)(6)(i).
Attachment 5 1CAN050902 Request for Relief ANO1-ISI-019 to 1CAN050902 Page 1 of 2 REQUEST FOR RELIEF ANO1-ISI-019 Components / Numbers: See Table 1 Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1
References:
ASME Section XI 1992 Edition, Table IWB-2500-1 Examination Category: B-K-1 Item Number(s) B10.20
==
Description:==
Integral Attachments for Piping, Pumps, and Valves Unit / Inspection Interval Arkansas Nuclear One, Unit 1 (ANO-1) / Third (3rd) 10-Year Applicability: Interval I. CODE REQUIREMENTS ASME Section XI, Table IWB-2500-1, Examination Category B-K, Integral Attachments for Piping, Pumps, and Valves, Item B10.20 requires a volumetric or surface examination, as applicable, of Integrally Welded Attachments.
II. RELIEF REQUEST Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving the Code-required coverage when performing volumetric examinations of the components identified in Table 1 below.
Table 1 Limited B-K-1 Examinations Item # Item ID Description Coverage Reason for Limitation
(%)
B10.20 22-099W Pipe Support Integral 38.35 Box Support on Pipe Attachment Weld Configuration III. BASIS FOR RELIEF During surface examination of the pipe support integral attachment weld, 100%
coverage of the required examination area could not be obtained.
to 1CAN050902 Page 2 of 2 The configuration of the subject component is a round piece of steel plate, which has been placed around a pipe and integrally welded in place. The plate is then placed within a box-type pipe support that is structurally anchored to a 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 Liquid Dye Penetrant or Magnetic Particle Testing, of the weld crown surface and 1/2 inch of base material on either side of the weld toes. However, due to the configuration of this integral attachment, and associated pipe support, access to the weld and surrounding base material, for examination, is very limited.
In order to perform any type of additional Code examination, modification and/or replacement of the component would be required. The examination performed on the available surface area of the subject item would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS Entergy has examined the subject item to the extent practical V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Entergy believes that it is impractical to obtain greater examination coverage on 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, Entergy requests the proposed alternative be authorized pursuant to 10 CFR 50.55a(g)(6)(i).
Attachment 6 1CAN050902 Request for Relief ANO1-ISI-020 to 1CAN050902 Page 1 of 3 REQUEST FOR RELIEF ANO1-ISI-020 Components / Numbers: See Table 1 Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1
References:
ASME Section XI 1992 Edition, Table IWB-2500-1 Examination Category: F-A Item Number(s) F1.40
==
Description:==
Supports Other Than Piping Supports (Class 1, 2, 3 and MC)
Unit / Inspection Interval Arkansas Nuclear One, Unit 1 (ANO-1) / Third (3rd) 10-Year Applicability: Interval I. CODE REQUIREMENTS ASME Section XI, Table IWB-2500-1, Examination Category F-A, Supports, Item F1.40 Supports Other Than Piping Supports, requires essentially 100% visual examination of the support.
II. RELIEF REQUEST Due to the geometric configuration and external obstructions, certain Code examination surfaces, as depicted in ASME Section XI, could not be examined to the extent of obtaining full Code coverage. Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from the Code requirement of 100% visual examination of the support for the items listed in Table 1 below.
to 1CAN050902 Page 2 of 3 Table 1 Limited F-A Examinations Item # Item ID Description Coverage Reason for Limitation
(%)
F1.40 01-032 Reactor Vessel (RV) 0 Geometric Configuration and Support Skirt Environment Circumferential Weld F1.40 01-033 RV Support Skirt to 70 Geometric Configuration and Flange Weld Environment F1.40 01-034 RV Support Skirt Flange 70 Geometric Configuration and Bolting Environment III. BASIS FOR RELIEF During visual examination of the RV Support Skirt and associated welds and bolting listed in Table 1 of this relief request, 100% coverage of the required examination surface could not be obtained.
These components are located in an area that is very confining, congested with incore instrumentation piping and general area radiation dose rates that are 500 to 600 millirem per hour (mr/hr). Access to the components is approximately 12 feet above the floor level. Limited access and high dose rates make it impractical to erect safe scaffolding to remove the insulation panels allowing better access to the components.
As a result, a fiberscope was used to perform the examinations to the extent possible.
Of the accessible portions of the components outside the RV skirt, the surface conditions revealed no detrimental conditions, only light rust on some of the bolting.
Examination of the components inside the RV skirt was performed through the small access holes, where again the accessible components revealed no detrimental conditions and light rust on bolting.
IV. PROPOSED ALTERNATIVE EXAMINATIONS Entergy has examined these welds to the extent practical to 1CAN050902 Page 3 of 3 V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Entergy believes that it is impractical to obtain greater examination coverage on these welds. To obtain additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject components would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity. Therefore, Entergy requests the proposed alternative be authorized pursuant to 10 CFR 50.55a(g)(6)(i).