2CAN031203, Requests for Relief from American Society of Mechanical Engineers (ASME) Section XI Volumetric and Surface Examination Requirements - Third 10-Year Interval
| ML12086A293 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 03/26/2012 |
| From: | Pyle S Entergy Operations |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| 2CAN031203 | |
| Download: ML12086A293 (71) | |
Text
Entergy Operations, Inc.
1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4704 Stephenie L. Pyle Manager, Licensing Arkansas Nuclear One 2CAN031203 March 26, 2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Requests for Relief from American Society of Mechanical Engineers (ASME)Section XI Volumetric and Surface Examination Requirements -
Third 10-Year Interval Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6
Dear Sir or Madam:
Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from the requirements of the ASME, Boiler and Pressure Vessel Code,Section XI pertaining to volumetric and surface examinations at Arkansas Nuclear One, Unit 2 (ANO-2). In several locations, the required coverage cannot be obtained due to interference or geometry.
Individual relief requests are provided in the attachments, divided by examination category.
These reliefs are for the third 10-year Inservice Inspection (ISI) interval.
There are no new regulatory commitments made in this submittal.
If you have any questions or require additional information, please contact me.
Sincerely, Original signed by Stephenie L. Pyle SLP/rwc Attachments:
- 1. Request for Relief - ANO2-ISI-008
- 2. Request for Relief - ANO2-ISI-009
- 3. Request for Relief - ANO2-ISI-010
- 4. Request for Relief - ANO2-ISI-011
- 5. Request for Relief - ANO2-ISI-012
- 6. Request for Relief - ANO2-ISI-013
- 7. Request for Relief - ANO2-ISI-014
2CAN031203 Page 2 of 2 cc: Mr. Elmo E. Collins Regional Administrator U. S. Nuclear Regulatory Commission, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 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
Attachment 1 to 2CAN031203 Request for Relief ANO2-ISI-008 to 2CAN031203 Page 1 of 11 REQUEST FOR RELIEF ANO2-ISI-008 Components / See Table 1 Numbers:
Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1
References:
ASME Section XI 1995 Edition with 1996 Addenda, for Ultrasonic Testing (UT) Examination ASME Section XI 2001 Edition with 2003 Addenda, Table IWB-2500-1 ASME Code Case N-593 Examination Category: B-D Item Number(s) B3.130; B3.140
==
Description:==
Full Penetration Welded Nozzles in Vessels - Inspection Program B Unit / Inspection Arkansas Nuclear One, Unit 2 (ANO-2) / Third (3rd) 10-Year Interval Interval Applicability:
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 B3.130 requires a volumetric examination of the Steam Generator (SG) Nozzle-to-Vessel Weld volume, as depicted in Figures IWB-2500-7 (a) through (d).
- 2) Item B3.140 requires a volumetric examination of the SG Nozzle-to-Vessel Inner Radii, 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.
III. BASIS FOR RELIEF During ultrasonic examination of the nozzle-to-vessel welds and inner radii listed in Table 1 below, 100% coverage of the required examination volume could not be obtained.
to 2CAN031203 Page 2 of 11 Due to the geometric configuration of the components and the close proximity of other structures which limited scan paths, the use of approved beam angles in the axial and circumferential direction were not able to achieve greater than 90% code required volume. See Table 1 below for additional information.
Radiography is not practical on these types of nozzle-to-vessel weld configurations, which prevent placement of the film and exposure source. To effectively perform any significant additional Code allowable ultrasonic examinations, modification and/or replacement of the component would be required. The examinations performed on the subject items in addition to the examination of other vessel welds contained in the Inservice Inspection Program would detect generic degradation, if it existed, demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS No alternative testing is proposed at this time. Entergy has examined these welds to the extent practical and will continue to perform pressure testing on the subject components as required by the Code.
V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law 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 effectively obtain significant additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject welds, in addition to the examination of similar welds contained in the program, would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. Entergy requests the proposed relief be authorized pursuant to 10 CFR 50.55a(g)(6)(i).
to 2CAN031203 Page 3 of 11 Table 1 Limited B-D Examinations Component Description Additional Information Estimated %
Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume B3.130 04-005 Steam 61.5 Component was scanned from both See the attached Manual UT Wave modalities are None No Generator (SG) sides; however, scanning was limited sketch (Figure 1) A detailed sketch longitudinal and shear. required. indications B Primary from the nozzle side due to the derived from UT (Figure 1) of the Insonification angles were Outlet Nozzle- component configuration. examination report limitation is included 0°, 45°, and recorded.
to-Extension ISI-UT-06-045 on included with the 60°.
Pipe file at ANO. scan plan Circumferential Weld B3.130 04-006 SG B Primary 61.5 Component was scanned from both See the attached Manual UT Wave modalities are None No Outlet Nozzle- sides; however, scanning was limited sketch (Figure 2) A detailed sketch longitudinal and shear. required. indications to-Extension from the nozzle side due to the derived from UT (Figure 2) of the Insonification angles were Pipe component configuration. examination report limitation is included 0°, 45°, and recorded.
Circumferential ISI-UT-06-046 on included with the 60°.
Weld file at ANO. scan plan.
B3.130 04-007 Extension Pipe- 54.69 Component was scanned from both See the attached Manual UT Wave modalities are None No to-SG B sides; however, scanning was limited sketch (Figure 3) A detailed sketch longitudinal and shear. required. indications Primary Inlet from the nozzle side due to the derived from UT (Figure 3) of the Insonification angles were Nozzle component configuration. examination report limitation is included 0°, 45°, and recorded.
Circumferential ISI-UT-06-049 on included with the 60°.
Weld file at ANO. scan plan.
to 2CAN031203 Page 4 of 11 Table 1 (cont)
Limited B-D Examinations Component Description Additional Information Estimated %
Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume B3.140 03- SG A Primary 88 Scanning was performed from the See the attached Manual UT Wave modality and None No 005IR Outlet Nozzle vessel side only due to component sketch (Figure 4) Four integral insonification angles required. indications Inner Radii configuration. derived from UT attachments, included 25 shear at were examination each 4.25 x 90 skew angle; 35 recorded.
reports ISI-UT 3.75 in size, shear at +120 and 059 and ISI-UT located on the -120 skew angles; 55 060 and UT SG lower head, shear at +22 and -22 procedure CEP- reduced skew angles and 70 NDE-0485 on file at examination shear at +81 and -81 ANO. coverage by skew angles.
12%
B3.140 03- SG A Primary 88 Scanning was performed from the See the attached Manual UT Wave modality and None No 006IR Outlet Nozzle vessel side only due to component sketch (Figure 4) Four integral insonification angles required. indications Inner Radii configuration. derived from UT attachments, included 25 shear at were examination each 4.25 x 90 skew angle; 35 recorded.
reports ISI-UT 3.75 in size, shear at +120 and 061 and ISI-UT located on the -120 skew angles; 55 062 and UT SG lower head, shear at +22 and -22 procedure CEP- reduced skew angles and 70 NDE-0485 on file at examination shear at +81 and -81 ANO. coverage by skew angles.
12%
B3.140 03- SG A Primary 90 Scanning was performed from the See the attached Manual UT Wave modality and None No 007IR Inlet Nozzle vessel side only due to component sketch (Figure 4) Four integral insonification angles required. indications Inner Radii configuration. derived from UT attachments, included 25 shear at were examination each 4.25 x 90 skew angle; 35 recorded.
reports ISI-UT 3.75 in size, shear at +120 and 063 and ISI-UT located on the -120 skew angles; 55 064 and UT SG lower head, shear at +22 and -22 procedure CEP- reduced skew angles and 70 NDE-0485 on file at examination shear at +81 and -81 ANO. coverage by skew angles.
10%
to 2CAN031203 Page 5 of 11 Table 1 (cont)
Limited B-D Examinations Component Description Additional Information Estimated %
Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume B3.140 04- SG B Primary 88 Scanning was performed from the See the attached Manual UT Wave modality and None No 005IR Outlet Nozzle vessel side only due to component sketch (Figure 4) Four integral insonification angles required. indications Inner Radii configuration. derived from UT attachments, included 25 shear at were examination each 4.25 x 90 skew angle; 35 recorded.
reports ISI-UT 3.75 in size, shear at +120 and 050 and ISI-UT located on the -120 skew angles; 55 051 and UT SG lower head, shear at +22 and -22 procedure CEP- reduced skew angles and 70 NDE-0485 on file at examination shear at +81 and -81 ANO. coverage by skew angles.
12%
B3.140 04- SG B Primary 88 Scanning was performed from the See the attached Manual UT Wave modality and None No 006IR Outlet Nozzle vessel side only due to component sketch (Figure 4) Four integral insonification angles required. indications Inner Radii configuration. derived from UT attachments, included 25 shear at were examination each 4.25 x 90 skew angle; 35 recorded.
reports ISI-UT 3.75 in size, shear at +120 and 052 and ISI-UT located on the -120 skew angles; 55 053 and UT SG lower head, shear at +22 and -22 procedure CEP- reduced skew angles and 70 NDE-0485 on file at examination shear at +81 and -81 ANO. coverage by skew angles.
12%
B3.140 04- SG B Primary 90 Scanning was performed from the See the attached Manual UT Wave modality and None No 007IR Inlet Nozzle vessel side only due to component sketch (Figure 4) Four integral insonification angles required. indications Inner Radii configuration. derived from UT attachments, included 25 shear at were examination each 4.25 x 90 skew angle; 35 recorded.
reports ISI-UT 3.75 in size, shear at +120 and 054 and ISI-UT located on the -120 skew angles; 55 055 and UT SG lower head, shear at +22 and -22 procedure CEP- reduced skew angles and 70 NDE-0485 on file at examination shear at +81 and -81 ANO. coverage by skew angles.
10%
to 2CAN031203 Page 6 of 11 Table 1 (cont)
Limited B-D Examinations Component Description Additional Information Estimated %
Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume B3.130 03-005 SG A Primary 50 Component was scanned from See the attached Manual UT Wave modalities are None No Outlet Nozzle- extension pipe side only. sketch (Figure 5) A detailed sketch longitudinal and shear. required. Relevant to-Extension derived from UT (Figure 5) of the Insonification angles indications Pipe examination report limitation is included 0°, 45°, 60°, were Circumferential 203ISIUT011 and included with the and 70°. recorded.
Weld 203ISIUT012 on scan plan file at ANO.
B3.130 03-006 SG A Primary 50 Component was scanned from See the attached Manual UT Wave modalities are None No Outlet Nozzle- extension pipe side only. sketch (Figure 6) A detailed sketch longitudinal and shear. required. indications to-Extension derived from UT (Figure 6) of the Insonification angles were Pipe examination report limitation is included 0°, 45°, 60°, recorded.
Circumferential 203ISIUT013 on included with the and 70°.
Weld file at ANO. scan plan.
B3.130 03-007 Extension Pipe 50 Component was scanned from See the attached Manual UT Wave modalities are None No
-to- SG A extension pipe side only. sketch (Figure 7) A detailed sketch longitudinal and shear. required. indications Primary Inlet derived from UT (Figure 7) of the Insonification angles were Nozzle examination report limitation is included 0°, 45, 60°, recorded.
Circumferential 203ISIUT015 on included with the and 70°.
Weld file at ANO. scan plan.
to 2CAN031203 Page 7 of 11 Figure 1 Scan Plan and Coverage for ISI Component 04-005 Not to Scale 60° 45° 45° Ext.
60° Piece Nozzle Figure 2 Scan Plan and Coverage for ISI Component 04-006 Not to Scale 60° Ext.
45° 45° Piece 60° Nozzle to 2CAN031203 Page 8 of 11 Figure 3 Scan Plan and Coverage for ISI Component 04-007 Not to Scale 45° 60° 45° 60° Nozzle Ext.
Piece to 2CAN031203 Page 9 of 11 Figure 4 Scan Plan and Coverage for ISI Components 03-005IR; 03-006IR; 03-007IR; 04-005IR; 04-006IR AND 04-007IR Not to Scale 70/19bd 55/22bd 120 120 118 118 116 116 Z 114 Z 114 112 112 110 110 108 108 4 6 8 10 12 14 16 18 4 6 8 10 12 14 16 18 R R 25/90bd 35/120bd 120 120 118 118 116 116 Z 114 Z 114 112 112 110 110 108 108 4 6 8 10 12 14 16 18 4 6 8 10 12 14 16 18 R R to 2CAN031203 Page 10 of 11 Figure 5 Scan Plan and Coverage for ISI Component 03-005 Not to Scale 60° 45° 45° Ext.
60° Piece Nozzle Figure 6 Scan Plan and Coverage for ISI Component 03-006 Not to Scale 60° Ext.
45° 45° Piece 60° Nozzle to 2CAN031203 Page 11 of 11 Figure 7 Scan Plan and Coverage for ISI Component 03-007 Not to Scale 45° 60° 45° 60° Nozzle Ext.
Piece
Attachment 2 to 2CAN031203 Request for Relief ANO2-ISI-009 to 2CAN031203 Page 1 of 2 REQUEST FOR RELIEF ANO2-ISI-009 Components / See Table 1 Numbers:
Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1
References:
ASME Section XI 1992 Edition, Table IWB-2500-1 Examination Category: B-H Item Number(s) B8.30
==
Description:==
Integral Attachments for Vessels Unit / Inspection Arkansas Nuclear One, Unit 2 (ANO-2) / Third (3rd) 10-Year Interval Interval Applicability:
I. CODE REQUIREMENTS ASME Section XI, Table IWB-2500-1, Examination Category B-H, Integral Attachments for Vessels, Item B8.30 requires a surface examination, as applicable, of integrally welded attachments.
II. RELIEF REQUEST Due to the geometric configuration of the integrally welded attachment and associated welded insulation bracket, the code examination area, as depicted in ASME Section XI, cannot be examined to the extent of obtaining full code coverage. Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests permission to perform surface examination within the limitations described in Table 1 of this relief request.
Table 1 Limited B-H Examination Item # Item ID Description Coverage Reason for Limitation
(%)
B8.30 04-008 Integrally Welded 62 Structural interference at Attachment - Key the lower weld of Key Bracket Bracket due to welded insulation support.
B8.30 04-009 Integrally Welded 62 Structural interference at Attachment - Key the lower weld of Key Bracket Bracket due to welded insulation support.
to 2CAN031203 Page 2 of 2 III. BASIS FOR RELIEF During surface examination of the vessel integral attachment weld, 100% coverage of the required examination area could not be obtained.
The configuration of the subject component is a metal key bracket with dimensions approximately twenty-two inches by eight inches welded on four sides. The bracket is integrally welded to the steam generate shell. The angle iron insulation support below the bracket is welded in place and restricts access to the lower portion of the weld.
Code examination of this type of integral attachment weld requires a surface examination technique, such as a Liquid Dye Penetrate 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 welded insulation support, access to the lower weld and surrounding base material for examination purposes is limited.
In order to perform additional or alternative Code examinations, modification and/or replacement of the insulation support would be required. The examination performed on the available surface area of the subject item would detect generic degradation, if it existed, demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS No alternative testing is proposed at this time. 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 these areas. To obtain additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject areas, in addition to the examination of similar welds contained in the program would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. Therefore, Entergy requests the proposed relief be authorized pursuant to 10 CFR 50.55a(g)(6)(i).
Attachment 3 to 2CAN021203 Request for Relief ANO2-ISI-010 to 2CAN031203 Page 1 of 28 REQUEST FOR RELIEF ANO2-ISI-010 Components / See Table 1 Numbers:
Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1
References:
ASME Section XI 1986 Edition, Table IWB-2500-1 ASME Section XI 1992 Edition with 2003 Addenda, Table IWB-2500-1 ASME Section XI 1995 Edition with 1996 Addenda, for Ultrasonic Testing (UT) Examination ASME Section XI 2001 Edition with 2003 Addenda, Table IWB-2500-1 ASME Code Case N-460 Examination Category: B-J Item Number(s) B9.11; B9.21; R1.11 and R1.20
==
Description:==
Pressure Retaining Welds in Piping - Inspection Program B Unit / Inspection Arkansas Nuclear One, Unit 2 (ANO-2) / Third (3rd) 10-Year Interval Interval Applicability:
I. CODE REQUIREMENTS ASME Section XI, Table IWB-2500-1, Examination Category B-J, Pressure Retaining Welds in Piping - Inspection Program B:
- 1) Item B9.11, as allowed by the risk informed (RI) process, requires a volumetric examination of circumferential piping welds Nominal Pipe Size (NPS) 4 or larger, as depicted in Figures IWB-2500-8 and Risk-Informed Inservice Inspection Evaluation Procedure, Electric Power Research Institute (EPRI) Report No. TR-106706, Interim Report, June 1996.
- 2) Item B9.21 requires a volumetric examination of circumferential piping welds less than NPS 4, as depicted in Figures IWB-2500-8 and Risk-Informed Inservice Inspection Evaluation Procedure, EPRI Report No. TR-106706, Interim Report, June 1996.
ASME Code Case N-460 allows a reduction in coverage due to interference or geometry as long as the overall coverage is greater than 90%.
to 2CAN031203 Page 2 of 28 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.
III. BASIS FOR RELIEF During ultrasonic examination of the piping welds listed in Table 1 above, greater than 90% coverage of the required examination volume could not be 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 examinations performed after the 10 CFR 50.55a mandatory implementation date for Appendix VIII of Section XI, and Code coverage percentages reflect what is currently allowed by qualified Appendix VIII techniques.
Appendix VIII qualified Performance Demonstration Initiative (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. 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.
These ultrasonic examinations have been performed over the course of the interval to varying code requirements and procedures. 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, demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS No alternative testing is proposed at this time. Entergy has examined the subject items to the extent practical and will continue to perform pressure testing on the subject areas as required by the Code.
V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is to 2CAN031203 Page 3 of 28 otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Entergy believes that it is impractical to obtain greater examination coverage on these areas. To obtain additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject areas, in addition to the examination of similar welds contained in the program would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. Therefore, Entergy requests the proposed relief be authorized pursuant to 10 CFR 50.55a(g)(6)(i).
to 2CAN031203 Page 4 of 28 Table 1 Limited B-J Examinations Component Description Additional Information Estimated %
Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume B9.11 02-T- Reactor Vessel 80 Component was scanned from both See the attached Manual UT Wave modality is Although not No 082 Closure Head sides; however, scanning of the sketch (Figure 1) shear. required by indications Figure 1 depicts the Risk (RVCH) required code volume was limited from derived from UT the component were Instrument the flange side due to the component examination report Insonification angles Informed (RI) recorded.
configuration. included 45° shear (S) process, a Nozzle Tube-to- configuration. ISI-UT-08-063 on Flange #82 file at ANO. and 70°S. surface examination A 60°S supplemental was exam was also performed performed. and documented on examination report ISI-PT-08-013 on file at ANO.
B9.11 02-T- RVCH 80 Component was scanned from both See the attached Manual UT Wave modality is Although not No 083 Instrument sides; however, scanning of the sketch (Figure 2) shear. required by indications Figure 2 depicts Nozzle Tube-to- required code volume was limited from derived from UT the component the RI were Flange #83 the flange side due to the component examination report Insonification angles process, a recorded.
configuration. included 45°S and configuration. ISI-UT-08-064 on surface file at ANO. 70°S. examination was A 60°S supplemental performed exam was also and performed. documented on examination report ISI-PT-08-014 on file at ANO.
to 2CAN031203 Page 5 of 28 Table 1 (cont)
Limited B-J Examinations Component Description Additional Information Estimated %
Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume B9.11 21-001 Safety Injection 82.5 Component was scanned from both See the attached Manual UT Wave modality was Although not Two Loop 1A Safe sides; however, scanning was limited sketch (Figure 3) longitudinal. required by geometric Figure 3 depicts End-to-Nozzle from the nozzle side due to the derived from UT the component the RI reflectors Circumferential component configuration and weld examination report Insonification angles process, a were configuration included 45°RL and Weld geometry (lift off). 200ISIUT033 on and weld profile. surface recorded.
file at ANO. 60°RL. examination No surface was indications performed were and recorded.
documented on examination report 200ISIPT018 on file at ANO.
R1.11 21-007 Safety Injection 50 Component was scanned from the See the attached Manual UT Wave modality used None No Loop 1A Elbow- elbow side only due to the component sketch (Figure 4) included shear and required. indications Figure 4 depicts to-Valve configuration. derived from UT the component longitudinal. were Circumferential examination report configuration Insonification angles recorded.
Weld ISI-UT-09-004 on and weld profile included 45°S, 60°S file at ANO. at the intrados and 60°RL.
and extrados of the elbow.
to 2CAN031203 Page 6 of 28 Table 1 (cont)
Limited B-J Examinations Component Description Additional Information Estimated %
Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume B9.11 22-001 Safety Injection 70 Component was scanned from both See the attached Manual UT Wave modality was Although not No Loop 1B Safe sides; however scanning was limited sketch (Figure 5) longitudinal. required by indications Figure 5 depicts End to Nozzle from the nozzle side due to the derived from UT the component the RI were Circumferential component configuration and weld examination report configuration Insonification angles process, a recorded.
Weld geometry (lift off). 200ISIUT040 and and weld profile. included 45°RL and surface 200ISIUT041 on 60°RL. examination file at ANO. was performed and documented on examination report 200ISIPT025 on file at ANO.
R1.11 22-004 Safety Injection 50 Component was scanned from the See the attached Manual UT Wave modality used None No Loop 1B Valve- pipe side only due to the component sketch (Figure 6) Figure 6 depicts included shear and required. indications to-Pipe configuration. derived from UT the component longitudinal. were Circumferential examination report configuration Insonification angles recorded.
Weld ISI-UT-05-023 on and weld profile. included 45°S, 60°S An examination, from the pipe side, file at ANO.
was also performed through the weld and 70°RL.
for flaw detection on the valve side of the weld utilizing a 70°RL.
R1.11 22-005 Safety Injection 50 Component was scanned from the See the attached Manual UT Wave modality used None No Loop 1B Pipe- pipe side only due to the component sketch (Figure 7) Figure 7 depicts included shear and required. indications to-Valve configuration. derived from UT the component longitudinal. were Circumferential examination report configuration Insonification angles recorded.
Weld ISI-UT-05-024 on and weld profile. included 45°S, 60°S An examination, from the pipe side, file at ANO.
was also performed through the weld and 70°RL.
for flaw detection on the valve side of the weld utilizing a 70°RL.
to 2CAN031203 Page 7 of 28 Table 1 (cont)
Limited B-J Examinations Component Description Additional Information Estimated %
Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume B9.11 23-001 Safety Injection 70 Component was scanned from both See the attached Manual UT Wave modality was Although not No Loop 2A Safe sides; however scanning was limited sketch (Figure 8) Figure 8 depicts longitudinal. required by indications End-to-Nozzle from the safe end side due to the derived from UT the component Insonification angles the RI were Circumferential component configuration and weld examination report configuration included 45°RL and process, a recorded.
Weld geometry (lift off). 200ISIUT042 and and weld profile. 60°RL. surface 200ISIUT043 on examination file at ANO. was performed and documented on examination report 200ISIPT023 on file at ANO.
B9.11 23-006 Safety Injection 50 Component was scanned from the See the attached Manual UT Wave modality used None One Loop 2A Valve- pipe side only due to the component sketch (Figure 9) Figure 9 depicts included shear and required. geometric to-Pipe configuration. derived from UT the component longitudinal. reflector Circumferential An examination from the pipe side was examination report configuration Insonification angles was Weld also performed through the weld for 202ISIUT032 on and weld profile. included 45°S and recorded.
flaw detection utilizing the 60°RL. file at ANO. 60°RL.
B9.11 23-007 Safety Injection 50 Component was scanned from the See the attached Manual UT Wave modality used None One Loop 2A Pipe- pipe side only due to the component sketch (Figure 10) Figure 10 included shear and required. geometric to-Valve configuration. derived from UT depicts the longitudinal. reflector Circumferential An examination from the pipe side was examination report component Insonification angles was Weld also performed through the weld for 202ISIUT033 on configuration included 45°S and recorded.
flaw detection utilizing the 60°RL. file at ANO. and weld profile. 60°RL.
to 2CAN031203 Page 8 of 28 Table 1 Limited B-J Examinations Component Description Additional Information Estimated %
Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume B9.11 24-001 Safety Injection 66.5 Component was scanned from both See the attached Manual UT Wave modality was Although not No Loop 2B Safe sides; however, scanning was limited sketch (Figure 11) Figure 11 longitudinal. required by indications End-to-Nozzle from the safe end side due to the derived from UT depicts the Insonification angles the RI were Circumferential component configuration and weld examination report component included 45°RL and process, a recorded.
Weld geometry (lift off). 200ISIUT044 and configuration 60°RL. surface 200ISIUT045 on and weld profile. examination file at ANO. was performed and documented on examination report 200ISIPT024 on file at ANO.
R1.11 24-006 Safety Injection 50 Component was scanned from the See the attached Manual UT Wave modalities used None No Loop 2B Pipe- pipe side only due to the component sketch (Figure 12) Figure 12 included shear and required. indications to-Valve configuration. derived from UT depicts the longitudinal. were Circumferential An examination from the pipe side was examination report component Insonification angles recorded.
Weld also performed through the weld for ISI-UT-06-009 on configuration included 45°S, 60°S flaw detection utilizing the 70°RL. file at ANO. and weld profile. and 70°RL.
B9.11 25-024 Shutdown 68.75 Component was scanned from the See the attached Manual UT Wave modality used None No Cooling Pipe- pipe side only due to the component sketch (Figure 13) Figure 13 included shear. required. indications to-Weld-o-let configuration. derived from UT depicts the Insonification angles were Circumferential examination report component included 45°S and recorded.
Weld 202ISIUT005 on configuration 70S°.
file at ANO. and weld profile.
to 2CAN031203 Page 9 of 28 Table 1 Limited B-J Examinations Component Description Additional Information Estimated %
Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume B9.21 27-001 Pressurizer 83 Component was scanned from both See the attached Manual UT Wave modality used Although not One Spray Loop 1B sides; however, scanning was limited sketch (Figure 14) Figure 14 included longitudinal. required by geometric Safe End-to- from the nozzle side due to the derived from UT depicts the Insonification angles the RI reflector Nozzle component configuration and weld examination report component included 32°RL, 45°RL process, a was Circumferential geometry (lift off). 200ISIUT046, configuration and 60°RL. surface recorded.
Weld 200ISIUT047, and and weld profile. examination 200ISIUT048 on was file at ANO. performed and documented on examination report 200ISIPT021 on file at ANO.
R1.20 27-002 Pressurizer 83 Component was scanned from both See the attached Manual UT Wave modality used None No Spray Piping sides; however scanning was limited sketch (Figure 15) Figure 15 included shear. required. indications Loop 1B Safe from the downstream side of the weld derived from UT depicts the Insonification angles were End-to-Elbow at the intrados of the elbow due to the examination report component included 45°S and recorded.
Circumferential component configuration. ISI-UT-06-023 on configuration 70°S.
Weld file at ANO. and weld profile.
R1.20 27-003 Pressurizer 83 Component was scanned from both See the attached Manual UT Wave modality used None No Spray Piping sides; however, scanning was limited sketch (Figure 16) Figure 16 included shear. required. indications Loop 1B Elbow- from the upstream side of the weld at derived from UT depicts the Insonification angles were to-Pipe the intrados of the elbow due to the examination report component included 45°S and recorded.
Circumferential component configuration. ISI-UT-06-024 on configuration 70°S.
Weld file at ANO. and weld profile.
to 2CAN031203 Page 10 of 28 Table 1 Limited B-J Examinations Component Description Additional Information Estimated %
Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume R1.20 27-065 Pressurizer 50 Component was scanned from the See the attached Manual UT Wave modality used None No Spray Piping pipe side only due to the component sketch (Figure 17) Figure 17 included shear and required. indications Loop 1B Valve- configuration. An examination from derived from UT depicts the longitudinal. were to-Pipe the pipe side was also performed examination report component Insonification angles recorded.
Circumferential through the weld for flaw detection ISI-UT-05-036 on configuration included 45°S, 60°S, Weld utilizing the 60°RL. A supplemental file at ANO. and weld profile. 70°S and 60°RL.
examination from the pipe side was also performed with a 45° shear wave transducer.
R1.20 27-066 Pressurizer 73 Component was scanned from both See the attached Manual UT Wave modality used None No Spray Piping sides to the extent practical. An sketch (Figure 18) Figure 18 included shear and required. indications Loop 1B Pipe- examination from the pipe side was derived from UT depicts the longitudinal. were to-Tee also performed through the weld for examination report component Insonification angles recorded.
Circumferential flaw detection utilizing the 60°RL. A ISI-UT-05-037 on configuration included 45°S, 60°S, Weld supplemental examination from the file at ANO. and weld profile. 70°S and 60°RL.
pipe side was also performed with a 45° shear wave transducer.
B9.21 40-005 Charging 59.6 Component was scanned from the See the attached Manual UT Wave modality used None No Piping Loop 1A pipe side only due to the component sketch (Figure 19) Figure 19 included shear. required. indications Valve-to-Pipe configuration. derived from UT depicts the Insonification angles were Circumferential examination report component included 45°S and recorded.
Weld 202ISIUT030 on configuration 70°S.
file at ANO. and weld profile.
B9.21 40-008 Charging 74 Component was scanned from both See the attached Manual UT Wave modality used None No Piping Loop 1A sides; however, scanning was limited sketch (Figure 20) Figure 20 included shear. required indications Pipe-to-Elbow at the elbow intrados due to the derived from UT depicts the Insonification angles were Circumferential component configuration and 360 due examination report component included 45°S and recorded.
Weld to weld crown configuration. 202ISIUT007 on configuration 70°S.
file at ANO. and weld profile.
to 2CAN031203 Page 11 of 28 Table 1 Limited B-J Examinations Component Description Additional Information Estimated %
Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume R1.11 40-025 Charging Piping 85 Component was scanned from both See the attached Manual UT Wave modality used None No Loop 1A Elbow- sides; however, scanning was limited sketch (Figure 21) Figure 21 included shear. required. indications to-Safe End at the intrados of the elbow due to the derived from UT depicts the Insonification angles were Circumferential component configuration. examination report component included 45°S, 60°S recorded.
Weld ISI-UT-09-006 on configuration and 70°S.
file at ANO. and weld profile.
B9.21 41-003 Charging 60 Component was scanned from the See the attached Manual UT Wave modality used None No Piping Loop 2A pipe side only due to the component sketch (Figure 22) Figure 22 included shear. required. indications Valve-to-Pipe configuration. derived from UT depicts the Insonification angles were Circumferential examination report component included 45°S and recorded.
Weld 202ISIUT039 and configuration 70°S.
202ISIUT040 on and weld profile.
file at ANO.
B9.21 41- Charging 60 Component was scanned from the See the attached Manual UT Wave modality used None No 003C Piping Loop 2A pipe side only due to the component sketch (Figure 23) Figure 23 included shear. required. indications Tee-to-Pipe configuration. derived from UT depicts the Insonification angles were Circumferential examination report component included 45°S and recorded.
Weld 202ISIUT041 and configuration 70°S.
202ISIUT042 on and weld profile.
file at ANO.
B9.11 43-022 Pressurizer 71.2 Component was scanned from both See the attached Manual UT Wave modality used None No LTOP Tee-to- sides; however, scanning was limited sketch (Figure 24) Figure 24 included shear and required indications Pipe from the Tee side due to the derived from UT depicts the longitudinal. were Circumferential component configuration. examination report component Insonification angles recorded.
Weld 203ISIUT021 and configuration included 45°S, 60°S, 203ISIUT023 on and weld profile. 70°S and 60°RL.
file at ANO.
R1.11 43-023 Pressurizer 81 Component was scanned from both See the attached Manual UT Wave modality used None No LTOP Tee-to- sides; however, scanning was limited sketch (Figure 25) Figure 25 included shear and required indications Pipe from the Tee side due to the derived from UT depicts the longitudinal. were Circumferential component configuration. examination report component Insonification angles recorded.
Weld ISI-UT-05-029 on configuration included 45°S, 60°S, file at ANO. and weld profile. 70°S and 60°RL.
to 2CAN031203 Page 12 of 28 Table 1 Limited B-J Examinations Component Description Additional Information Estimated %
Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume B9.11 43-027 Pressurizer 67.6 Component was scanned from the See the attached Manual UT Wave modality used None No LTOP Pipe-to- pipe side and partially from the tee sketch (Figure 26) Figure 26 included shear. required indications Valve due to the component configuration. derived from UT depicts the Insonification angles were Circumferential examination report component included 45°S and recorded.
Weld 202ISIUT011 on configuration 70°S.
file at ANO. and weld profile.
B9.11 43-033 Pressurizer 72.5 Component was scanned from the See the attached Manual UT Wave modality used None No LTOP Tee-to- pipe side only due to the component sketch (Figure 27) Figure 27 included shear. required indications Pipe configuration. derived from UT depicts the Insonification angles were Circumferential examination report component included 45°S and recorded.
Weld 202ISIUT012 on configuration 70°S.
file at ANO. and weld profile.
R1.20 13-008 RCP 2P-32C 60.1 Component was scanned from the See the attached Manual UT Wave modalities are None No Discharge pipe side only with Appendix VIII sketch (Figure 28) Phased Array longitudinal and shear. required indications Nozzle Safe procedure qualified for single side derived from UT examination. Insonification angles were End-to-Pipe access, which also interrogated the examination report Figure 28 included 0°-80° flat L- recorded.
Circumferential cast stainless steel side of the ISI-VE-09-044 on depicts the wave; 25°-75° axial Weld component. Coverage for the cast file at ANO. component shear wave; and 0°-80° stainless steel side was not included in configuration. circumferential L-wave the code required coverage. The w/ +10° & -10° skew.
circumferential scan was limited due to the cast stainless and the component configuration (weld surface/taper)..
R1.20 15-008 RCP 2P-32D 62.8 Component was scanned from the See the attached Manual UT Wave modalities are None No Discharge pipe side only with Appendix VIII sketch (Figure 29) Phased Array longitudinal and shear. required indications Nozzle Safe procedure qualified for single side derived from UT examination. Insonification angles were End-to-Pipe access, which also interrogated the examination report Figure 29 included 0°-80° flat L- recorded.
Circumferential cast stainless steel side of the ISI-VE-09-046 on depicts the wave; 25°-75° axial Weld component. Coverage for the cast file at ANO. component shear wave; and 0°-80° stainless steel side was not included in configuration. circumferential L-wave the code required coverage. The w/ +10° & -10° skew.
circumferential scan was limited due to the cast stainless steel and the component configuration (weld surface/taper).
to 2CAN031203 Page 13 of 28 Table 1 Limited B-J Examinations Component Description Additional Information Estimated %
Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume R1.11 29-056 Pressurizer 50 Component was scanned from the See the attached Manual UT Wave modality used None No Auxiliary Spray pipe side only due to the component sketch (Figure 30) Figure 30 included shear. required indications Pipe-to-Tee configuration derived from UT depicts the Insonification angles were Circumferential examination report component included 45° S and recorded.
Weld ISI-UT-08-060I on configuration. 70° S.
file at ANO.
to 2CAN031203 Page 14 of 28 Figure 1 Scan Plan and Coverage for ISI Component 02-T-082 Not to Scale FLOW FLANGE 70° 45° CL 45° 70° INSTRUMENT NOZZLE TUBE Figure 2 Scan Plan and Coverage for ISI Component 02-T-083 Not to Scale FLOW FLANGE C 70° 45° L 45°70° INSTRUMENT NOZZLE TUBE Figure 3 Scan Plan and Coverage for ISI Component 21-001 Not to Scale Shear/Long. Shear/Long.
Shear/Long. Shear/Long. 45° 45° 45° 45° S.S. SAFE-END CAST S.S. PIPE CL
Attachment 3 to 2CAN031203 Page 15 of 28 Figure 4 Scan Plan and Coverage for ISI Component 21-007 Not to Scale 63° 64° CL 45° 42° 63° ELBOW TO SAFE END WELD NOZZLE SAFE END Figure 5 Scan Plan and Coverage for ISI Component 22-001 Not to Scale EXTRADOS 45° 60° CL INTRADOS 45° CL ELBOW 60° SIDE VALVE SIDE to 2CAN031203 Page 16 of 28 Figure 6 Scan Plan and Coverage for ISI Component 22-004 Not to Scale 1.15 1.20 1.20 1.2 1.10 SHEAR RL 70° PIPE VALVE (2SI-15A) 60° FLOW CL Figure 7 Scan Plan and Coverage for ISI Component 22-005 Not to Scale 1.20 1.20 1.20 1.15 1.20 FLOW PIPE 70° RL VALVE (2SI-15A) 60° Shear CL Figure 8 Scan Plan and Coverage for ISI Component 23-001 Not to Scale 45° CL 45° 45° 45° 45° Nozzle SAFE END Flow to 2CAN031203 Page 17 of 28 Figure 9 Scan Plan and Coverage for ISI Component 23-006 Not to Scale VALVE FLOW PIPE 60° RL 45° 60° RL 45° CL Figure 10 Scan Plan and Coverage for ISI Component 23-007 Not to Scale FLOW VALVE 2SI-15C CL 60° RL 45° 60° RL 45° to 2CAN031203 Page 18 of 28 Figure 11 Scan Plan and Coverage for ISI Component 24-001 Not to Scale 60° 45° CL 60° 45° 60° 45° 45° Nozzle Safe End Flow Figure 12 Scan Plan and Coverage for ISI Component 24-006 Not to Scale CL Valve 70° RL 60° 45° Pipe FLOW to 2CAN031203 Page 19 of 28 Figure 13 Scan Plan and Coverage for ISI Component 25-024 Not to Scale Flow CL Weld-O-Let FL FL 45° 70° Pipe Figure 14 Scan Plan and Coverage for ISI Component 27-001 Not to Scale Flow 45°.60° 45°.60° 45°.60° 45°.60° CL TOE TOE Nozzle Safe End to 2CAN031203 Page 20 of 28 Figure 15 Scan Plan and Coverage for ISI Component 27-002 Not to Scale Flow 70° CL 45° 70° Elbow 45° Safe End Figure 16 Scan Plan and Coverage for ISI Component 27-003 Not to Scale 45°/70° CL 45°/70° PIPE ELBOW FLOW SCANNED ACROSS WELD Figure 17 Scan Plan and Coverage for ISI Component 27-065 Not to Scale CL 60° RL 45° 70° PIPE VALVE 2CV-4655 Flow to 2CAN031203 Page 21 of 28 Figure 18 Scan Plan and Coverage for ISI Component 27-066 Not to Scale 45° 70° CL 45° 70° 1.125 4.225 TEE Flow PIPE TDC 3 ID CL 60° RL 60° RL 9.675 6.675 Figure 19 Scan Plan and Coverage for ISI Component 40-005 Not to Scale CL Flow Valve 70° 45° Pipe 45° to 2CAN031203 Page 22 of 28 Figure 20 Scan Plan and Coverage for ISI Component 40-008 Not to Scale CL 70 70 70 70 Pipe Elbow Flow Figure 21 Scan Plan and Coverage for ISI Component 40-025 Not to Scale Flow Extradose SAFE-END ELBOW CL 45° 45° 70° 60° 60°70° to 2CAN031203 Page 23 of 28 Figure 22 Scan Plan and Coverage for ISI Component 41-003 Not to Scale CL Valve 70°/45° 45° Pipe Flow Figure 23 Scan Plan and Coverage for ISI Component 41-003C Not to Scale CL 70° 70° TEE PIPE
Attachment 3 to 2CAN031203 Page 24 of 28 Figure 24 Scan Plan and Coverage for ISI Component 43-022 Not to Scale FLOW PIPE TEE 45° 45°-60°-70° 60° CL 70° PROFILE SHOWS OBS. OF TEE AT T.D.C. AND BDC 5/5 OF SCAN OBS. IN BOTH AREAS FOR TOTAL OF 11.00 FLOW 45° COVERAGE IS 65% IN OBS. AREA. PLUS 10% MORE PICKED UP WITH THE 60°. CL 45° 60° OBS. AREA IS 2 DIA.
PROFILE SHOWS COVERAGE 60° 45° OBS. 2BCH-16-3/4 IN OBS. AREA FROM 4.2 TO 6.2 SW TEE PIPE 45° 45° 70° 45°-60° CL 45°-60° 70° 70° 60° 60° 70° SCAN COVERAGE ON TEE & PIPE AREA. ABLE TO SCAN 10 TOTAL FROM TEE SIDE. FROM 2.75 CW TO 7.5 CW ALSO FROM 13.25 CW TO 18.5 CW to 2CAN031203 Page 25 of 28 Figure 25 Scan Plan and Coverage for ISI Component 43-023 Not to Scale 45° 70° CL 70° 45° PIPE FLOW TEE 60° RL 60° RL CL TDC 17.6 3.2 6 ID 13.6 7.2 to 2CAN031203 Page 26 of 28 Figure 26 Scan Plan and Coverage for ISI Component 43-027 Not to Scale Flow CL Pipe 45° Valve 70° Figure 27 Scan Plan and Coverage for ISI Component 43-033 Not to Scale 45° CL Flow Tee Pipe 70° 45° to 2CAN031203 Page 27 of 28 Figure 28 Scan Plan and Coverage for ISI Component 13-008 Not to Scale 25° 80° CAST SS SAFE C/S PIPE Figure 29 Scan Plan and Coverage for ISI Component 15-008 Not to Scale 80° 25° C/S PIPE CAST SS SAFE to 2CAN031203 Page 28 of 28 Figure 30 Scan Plan and Coverage for ISI Component 29-056 Not to Scale FLOW CL 70° 70° TEE PIPE
Attachment 4 to 2CAN031203 Request for Relief ANO2-ISI-011 to 2CAN031203 Page 1 of 2 REQUEST FOR RELIEF ANO2-ISI-011 Components / See Table 1 Numbers:
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 Arkansas Nuclear One, Unit 2 (ANO-2) / Third (3rd) 10-Year Interval Interval Applicability:
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 Due to the geometric configuration of the integrally welded attachment and associated pipe support, the code examination area, as depicted in ASME Section XI, cannot be examined to the extent of obtaining full code coverage. Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests permission to perform surface examination within the limitations described in Table 1 of this relief request.
Table 1 Limited B-K-1 Examination Item # Item ID Description Coverage Reason for Limitation
(%)
B10.20 22-071W Integrally Welded 88 Structural interference at Attachment the end of lugs where they Way Vertical contact the support.
Restraint to 2CAN031203 Page 2 of 2 III. BASIS FOR RELIEF During surface examination of the pipe support integral attachment weld, 100%
coverage of the required examination area could not be obtained.
The configuration of the subject component is four 5/8 x 1 x 1 lugs, placed 4 1/16 apart end-to-end in pairs at 0° and 180° on the vertical pipe. The lugs are integrally welded to the pipe with full penetration welds. The two piece four-inch wide hanger strap is positioned and bolted between the end to end lugs, contacting the upper lugs which support the vertical pipe. Code examination of this type of integral attachment weld requires a surface examination technique, such as Liquid Dye Penetrate or Magnetic Particle Testing, of the weld crown surface and 1/2 inch of base material on either side of the weld toes. However, due to the configuration of this integral attachment and associated hanger strap, access to the weld ends and surrounding base material for examination purposes is limited.
In order to perform additional or alternative Code examinations, modification and/or replacement of the component would be required. The examination performed on the available surface area of the subject item would detect generic degradation, if it existed, demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS No alternative testing is proposed at this time. 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 these areas. To obtain additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject areas, in addition to the examination of similar welds contained in the program would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. Therefore, Entergy requests the proposed relief be authorized pursuant to 10 CFR 50.55a(g)(6)(i).
Attachment 5 to 2CAN031203 Request for Relief ANO2-ISI-012 to 2CAN031203 Page 1 of 6 REQUEST FOR RELIEF ANO2-ISI-012 Components / See Table 1 Numbers:
Code Classes: American Society of Mechanical Engineers (ASME) Code Class 2
References:
ASME Section XI 1986 Edition, Table IWC-2500-1 ASME Section XI 1995 Edition with 1996 Addenda for Ultrasonic Examinations Examination Category: C-A Item Number(s) C1.10; C1.30
==
Description:==
Pressure Retaining Welds in Pressure Vessels - Inspection Program B Unit / Inspection Arkansas Nuclear One, Unit 2 (ANO-2) / Third (3rd) 10-Year Interval Interval Applicability:
I. CODE REQUIREMENTS ASME Section XI, Table IWC-2500-1, Examination Category C-A, Pressure Retaining Welds in Pressure Vessels - Inspection Program B:
- 1) Item C1.10 requires a volumetric examination of the Shell Circumferential Weld volume, as depicted in Figure IWC-2500-1.
- 2) Item C1.30 requires a volumetric examination of the Tubesheet-to-Shell Weld, as depicted in Figure IWC-2500-1.
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.
III. BASIS FOR RELIEF During ultrasonic examination of the Letdown Heat Exchanger Flange-to-Channel Circumferential Weld and the Shutdown Cooling Heat Exchanger Flange-to-Channel Cylinder and Channel Cylinder-to-Tubesheet Welds listed in Table 1 below, 100%
coverage of the required examination volumes could not be obtained.
Due to the geometric configuration of the components and the close proximity of other structures which limited scan paths, the use of approved beam angles in the axial and to 2CAN031203 Page 2 of 6 circumferential direction were not able to achieve greater than 90% code required volume. See Table 1 below for additional information.
Radiography is not practical on these types of nozzle-to-vessel weld configurations which prevent placement of the film and exposure source. To effectively perform any significant additional Code allowable ultrasonic examinations, modification and/or replacement of the component would be required. The examinations performed on the subject items in addition to the examination of other vessel welds contained in the Inservice Inspection (ISI) program would detect generic degradation, if it existed, demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS No alternative testing is proposed at this time. Entergy has examined these welds to the extent practical and will continue to perform pressure testing on the subject components as required by the Code.
V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law 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 effectively obtain significant additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject welds, in addition to the examination of similar welds contained in the program, would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. Entergy requests the proposed relief be authorized pursuant to 10 CFR 50.55a(g)(6)(i).
to 2CAN031203 Page 3 of 6 Table 1 Limited C-A Examinations Component Description Additional Information Estimated %
Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume C1.10 45-001 Letdown Heat 45.7 This was a single-sided exam due to See the attached Manual UT Wave modality None No Exchanger the configuration and close proximity sketch (Figure 1) examination. used included required. indications Flange-to- of the channel head flange. derived from Figure 1 depicts shear. were Channel Additionally, scan paths from the shell ultrasonic test (UT) the component Insonification recorded.
Circumferential side were limited due to the inlet and examination report configuration angles included 45° Weld outlet piping configurations attached to ISI-UT-08-065 on and weld profile. shear (S) and the shell. file at ANO. 70°S.
C1.10 49-001 Shutdown 69.5 This was a single-sided exam due to See the attached Manual UT Wave modality None One Cooling Heat the configuration and close proximity sketch (Figure 2) examination. used included required. indication Exchanger of the channel head flange. derived from UT Figure 2 depicts shear. identified as Flange-to- Additionally, scan paths from the shell examination report the component Insonification a plate Channel side were limited due to the inlet and 204ISIUT001 on configuration angles included segregate Cylinder outlet piping configurations attached to file at ANO. and weld profile. 45°S and 70°S. located Circumferential the shell. outside the Weld code exam volume,
~0.50 from the shell inside diameter, was recorded.
Evaluated as acceptable by the Entergy Level III.
to 2CAN031203 Page 4 of 6 Table 1 Limited C-A Examinations Component Description Additional Information Estimated %
Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume C1.30 49-002 Shutdown 81.8 This was a single-sided exam due to See the attached Manual UT Wave modality None Acceptable Cooling Heat the configuration and close proximity sketch (Figure 3) examination. used included required. plate Exchanger of the channel head flange. derived from UT Figure 3 depicts shear. segregation Channel Additionally, scan paths from the shell examination report the component Insonification and clad Cylinder-to- side were limited due to the inlet and 204ISIUT003 on configuration angles included interface Tubesheet outlet piping configurations attached to file at ANO. and weld profile. 45°S and 70°S. indications Circumferential the shell. identified Weld during the nd 2 ISI Interval examination were confirmed.
No new indications recorded.
to 2CAN031203 Page 5 of 6 Figure 1 Scan Plan and Coverage for ISI Component 45-001 Not to Scale Channel Head 70° 45° 70° CL Toe Toe Flange
- Two Direction Coverage Sketch of Obstructions 3 Linear Obstruction 2 Linear Obstruction 2 Linear Obstruction 45-001 3 Linear Obstruction 45-002 to 2CAN031203 Page 6 of 6 Figure 2 Scan Plan and Coverage for ISI Component 49-001 Not to Scale Bolts FLANGE 45° 45° 45° 70° 70° SHELL Figure 3 Scan Plan and Coverage for ISI Component 49-002 Not to Scale CL FLANGE CHANNEL CYLINDER 45° CL CLAD 70° CLAD
Attachment 6 to 2CAN031203 Request for Relief ANO2-ISI-013 to 2CAN031203 Page 1 of 4 REQUEST FOR RELIEF ANO2-ISI-013 Components / See Table 1 Numbers:
Code Classes: American Society of Mechanical Engineers (ASME) Code Class 2
References:
ASME Section XI 1992 Edition, Table IWC-2500-1 ASME Section XI 1995 Edition with 1996 Addenda for Ultrasonic Examinations Examination Category: C-B Item Number(s) C2.21
==
Description:==
Pressure Retaining Nozzle Welds in Vessels - Inspection Program B Unit / Inspection Arkansas Nuclear One, Unit 2 (ANO-2) / Third (3rd) 10-Year Interval Interval Applicability:
I. CODE REQUIREMENTS ASME Section XI, Table IWC-2500-1, Examination Category C-B, Pressure Retaining Nozzle Welds in Vessels - Inspection Program B:
- 1) Item C2.21 requires a volumetric and surface examination of the Nozzle-to-Shell Weld volume, as depicted in Figure IWC-2500-4 (a) or (b).
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.
III. BASIS FOR RELIEF During ultrasonic examination of the Feedwater Nozzle-to-Shell Weld listed in Table 1 below, 100% coverage of the required examination volumes could not be obtained.
Due to the close proximity of one of the steam generator insulation brackets, located around the circumference of the vessel and directly below the Feedwater nozzles, scan paths from below the nozzle were impeded and 100% examination of the code required volume was not achieved. See Table 1 below for additional information.
There are several insulation bracket rings located around the circumference of the steam generator. These brackets facilitate supporting the many insulation panels surrounding the circumference of the steam generator. Removal of the subject bracket requires to 2CAN031203 Page 2 of 4 removal of all insulation panels directly supported by that ring as well as removal or engineered rigging of all insulation rings and panels above the removed ring. The insulation rings are not bolted directly to the steam generator shell therefore each lower elevation ring helps support the above rings and insulation panels.
Radiography is not practical on these types of nozzle-to-vessel weld configurations, which prevent placement of the film and exposure source. To effectively perform any significant additional Code allowable ultrasonic examinations, modification and/or removal are replacement of the insulation ring would be required. The examinations performed on the subject items in addition to the examination of other vessel welds contained in the Inservice Inspection program would detect generic degradation, if it existed, demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS No alternative testing is proposed at this time. Entergy has examined these welds to the extent practical and will continue to perform pressure testing on the subject components as required by the Code.
V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law 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 effectively obtain significant additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject welds, in addition to the examination of similar welds contained in the program, would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. Entergy requests the proposed relief be authorized pursuant to 10 CFR 50.55a(g)(6)(i).
to 2CAN031203 Page 3 of 4 Table 1 Limited C-B Examinations Component Description Additional Information Estimated %
Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume C2.21 04-002 Steam 71.6 This was a dual sided exam, limited by See the attached Manual UT Wave modality used A surface No Generator B the configuration of the shell-to-nozzle sketch (Figure 1) A detailed sketch included shear. examination indications Feedwater blend area and the close proximity of derived from (Figure 1) of the Insonification angles was were Nozzle-to-Shell an insulation bracket ring below the ultrasonic test (UT) limitation is included 45° shear (S) performed recorded.
Weld nozzle. examination report included with the and 60°S. and ISI-UT-06-067 on scan plan. documented file at ANO. on examination report ISI-MT-06-039.
100% of the required surface was examined.
to 2CAN031203 Page 4 of 4 Figure 1 Scan Plan and Coverage for ISI Component 04-002 Not to Scale 45° NOZZLE 60° CL 60° 45° SHELL Insulation Bracket Obstruction Not to Scale TDC 04-002 100% 100% 100% 100%
60° 45° 45° 60° X X X X INSULATION BRACKET
Attachment 7 to 2CAN031203 Request for Relief ANO2-ISI-014 to 2CAN031203 Page 1 of 9 REQUEST FOR RELIEF ANO2-ISI-014 Components / See Table 1 Numbers:
Code Classes: American Society of Mechanical Engineers (ASME) Code Class 2
References:
ASME Section XI 1992 Edition, Table IWC-2500-1 ASME Section XI 1995 Edition with 1996 Addenda, for Ultrasonic Testing (UT) Examination ASME Code Case N-460 Examination Category: C-F-1 Item Number(s) C5.11; R1.20
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Description:==
Pressure Retaining Welds in Austenitic Stainless Steel or High Alloy Piping - Inspection Program B Unit / Inspection Arkansas Nuclear One, Unit 2 (ANO-2) / Third (3rd) 10-Year Interval Interval Applicability:
I. CODE REQUIREMENTS ASME Section XI, Table IWC-2500-1, Examination Category C-F-1, Pressure Retaining Welds in Austenitic Stainless Steel or High Alloy Piping - Inspection Program B:
- 1) Item C5.11, as allowed by the Risk Informed process, requires a volumetric examination of circumferential piping welds Nominal Pipe Size (NPS) 4 or larger, as depicted in Figure IWC-2500-7 and Risk-Informed Inservice Inspection Evaluation Procedure, Electric Power Research Institute (EPRI) Report No.
TR-106706, Interim Report, June 1996.
- 2) Item R1.20 requires a volumetric examination of circumferential piping welds as depicted in Figure IWC-2500-7 and Risk-Informed Inservice Inspection Evaluation Procedure, EPRI Report No. TR-106706, Interim Report, June 1996.
ASME Code Case N-460 allows a reduction in coverage due to interference or geometry as long as the overall coverage is greater than 90%.
II. RELIEF REQUEST Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving the Code-required coverage when performing volumetric examinations of the components identified in Table 1 below.
to 2CAN031203 Page 2 of 9 III. BASIS FOR RELIEF During ultrasonic examination of the piping welds listed in Table 1 above, greater than 90% coverage of the required examination volume could not be obtained.
Class 2 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 examinations performed after the 10 CFR 50.55a mandatory implementation date for Appendix VIII of Section XI, and Code coverage percentages reflect what is currently allowed by qualified Appendix VIII techniques.
Appendix VIII qualified Performance Demonstration Initiative (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. 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.
These ultrasonic examinations have been performed over the course of the interval to varying code requirements and procedures. 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, demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS No alternative testing is proposed at this time. Entergy has examined the subject items to the extent practical and will continue to perform pressure testing on the subject areas as required by the Code.
V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Entergy believes that it is impractical to obtain greater examination coverage on these areas. To obtain additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject areas, in addition to the examination of similar welds contained in the program would detect generic degradation, to 2CAN031203 Page 3 of 9 if it existed, demonstrating an acceptable level of integrity. Therefore, Entergy requests the proposed relief be authorized pursuant to 10 CFR 50.55a(g)(6)(i).
to 2CAN031203 Page 4 of 9 Table 1 Limited C-F-1 Examinations Component Description Additional Information Estimated %
Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume C5.11 61-025 Safety Injection 50 Single sided exam from the pipe side See the attached Manual UT Wave modality is shear None Root Header Pipe-to- only due to the component sketch (Figure 1) A detailed sketch and longitudinal. required. geometry Valve configuration and geometry. derived from (Figure 1) of the Insonification angles was Circumferential ultrasonic test (UT) limitation is included 45° Shear (S), recorded Weld examination report included with the 70°S and 60° 360.
203ISIUT019 and scan plan Refracted Longitudinal 203ISIUT020 on (RL).
file at ANO.
C5.11 66-014 Safety Injection 50 Single sided exam from the pipe side See the attached Manual UT Wave modality is shear None No Pipe-to-Flued only due to the component sketch (Figure 2) A detailed sketch and longitudinal. required. indications Head configuration and geometry. derived from UT (Figure 2) of the Insonification angles were Penetration examination report limitation is included 45°S, 70°S recorded.
Circumferential 203ISIUT017 and included with the and 60°RL.
Weld 203ISIUT018 on scan plan.
file at ANO.
R1.20 55- Safety Injection 50 Single sided exam from the pipe side See the attached Manual UT Wave modality is None Root 034A Weld-o-let-to- only due to the component sketch (Figure 3) A detailed sketch shear. required. geometry Pipe configuration and geometry. derived from UT (Figure 3) of the Insonification angles was Circumferential examination report limitation is included 45°S, 60°S recorded Weld 203ISIUT005 and included with the and 70°S. 360°.
203ISIUT006 on scan plan.
file at ANO.
R1.20 55-043 Safety Injection 50 Single sided exam from the pipe side See the attached Manual UT Wave modality is None No Tee-to-Pipe only due to the component sketch (Figure 4) A detailed sketch shear. required. indications Circumferential configuration and geometry. derived from UT (Figure 4) of the Insonification angles were Weld examination report limitation is included 45°S, 60°S recorded.
ISI-UT-06-031 on included with the and 70°S.
file at ANO. scan plan.
to 2CAN031203 Page 5 of 9 Table 1 (cont)
Limited C-F-1 Examinations Component Description Additional Information Estimated %
Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume R1.20 55-057 Safety Injection 46 Single-sided exam from the pipe side See the attached Manual UT Wave modality is None No Pipe-to-Branch only due to the component sketch (Figure 5) A detailed sketch shear. required. indications Connection configuration. A unistrut contacting derived from UT (Figure 5) of the Insonification angles were Circumferential the pipe further limited the upstream examination report limitation is included 45°S and recorded.
Weld scan. ISI-UT-06-030 on included with the 70°S.
file at ANO. scan plan.
R1.20 61-002 Safety Injection 50 Single-sided exam from the pipe side See the attached Manual UT Wave modality is None No Pipe-to-Valve only due to the component sketch (Figure 6) A detailed sketch shear. required. indications Circumferential configuration. derived from UT (Figure 6) of the Insonification angles were Weld examination report limitation is included 45°S and recorded.
ISI-UT-08-001 on included with the 70°S.
file at ANO. scan plan.
R1.20 61-011 Safety Injection 50 Single-sided exam from the pipe side See the attached Manual UT Wave modality is None No Pipe-to-Valve only due to the component sketch (Figure 7) A detailed sketch shear. required. indications Circumferential configuration. derived from UT (Figure 7) of the Insonification angles were Weld examination report limitation is included 45°S and recorded.
ISI-UT-08-027 on included with the 70°S.
file at ANO. scan plan.
R1.20 61-021 Safety Injection 79 Single-sided exam from the pipe side See the attached Manual UT Wave modality is None No Pipe-to-Valve only due to the component sketch (Figure 8) A detailed sketch shear. required. indications Circumferential configuration. derived from UT (Figure 8) of the Insonification angles were Weld examination report limitation is included 45°S and recorded.
200ISIUT014 on included with the 70°S.
file at ANO. scan plan.
R1.20 78-056 Containment 84 Component was scanned from both See the attached Manual UT Wave modality is None No Spray Elbow-to- sides; however scanning was limited sketch (Figure 9) A detailed sketch shear. required. indications Pipe due to lift off at the toes of the weld. derived from UT (Figure 9) of the Insonification angles were Circumferential examination report limitation is included 45°S and recorded.
Weld 200ISIUT024 on included with the 70°S.
file at ANO. scan plan.
to 2CAN031203 Page 6 of 9 Figure 1 Scan Plan and Coverage for ISI Component 61-025 Not to Scale 45° 60° RL 70° 45° 60° RL 70° CL Valve Pipe Flow Figure 2 Scan Plan and Coverage for ISI Component 66-014 Not to Scale 45° 60° RL 70° CL 45° 60° RL 70° Pipe Elbow Flow to 2CAN031203 Page 7 of 9 Figure 3 Scan Plan and Coverage for ISI Component 55-034A Not to Scale FLOW WELD-O-LET PIPE CL 70°-60°-45° 70°-60°-45° Figure 4 Scan Plan and Coverage for ISI Component 55-043 Not to Scale CL 45°/70° 45°/70° TEE PIPE FLOW to 2CAN031203 Page 8 of 9 Figure 5 Scan Plan and Coverage for ISI Component 55-057 Not to Scale CL 45/70 45/70 70° 45° 70° 45° BRANCH FLOW PIPE CONNECTION Figure 6 Scan Plan and Coverage for ISI Component 61-002 Not to Scale FLOW 70° VALVE PIPE to 2CAN031203 Page 9 of 9 Figure 7 Scan Plan and Coverage for ISI Component 61-011 Not to Scale FLOW VALVE PIPE 70° 70° CL Figure 8 Scan Plan and Coverage for ISI Component 61-021 Not to Scale FLOW 70° VALVE PIPE Figure 9 Scan Plan and Coverage for ISI Component 78-056 Not to Scale FLOW CL 70° 70° 70° 70° PIPE ELBOW