PNP 2012-035, Relief Request - Proposed Alternative - Use of Alternate ASME Code Case N-770-1 Baseline Examination
| ML12118A144 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/26/2012 |
| From: | Vitale T Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PNP 2012-035 | |
| Download: ML12118A144 (21) | |
Text
~* Entergy PNP 2012-035 April 26, 2012 U. S. Nuclear Regulatory Commission AnN: Document Control Desk Washington, DC 20555-0001 Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Tel 269 764 2000 Tony J. Vitale Site Vice President
SUBJECT:
Relief Request - Proposed Alternative - Use of Alternate ASME Code Case N-770-1 Baseline Examination Palisades Nuclear Plant Docket 50-255 License No. DPR-20
Dear Sir or Madam:
Pursuant to 10 CFR 50.55a(a)(3)(ii), Entergy Nuclear Operations, Inc. (Entergy) hereby requests NRC approval of the Request for Relief for a Proposed Alternative for the Palisades Nuclear Plant (PNP). This alternative is for the current fourth 10-year lSI interval.
The request is associated with the use of an alternative to the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Code Case N-770-1, as conditioned by 10 CFR 50.55a(g)(6)(ii)(F)(3), dated June 21, 2011.
To support the ongoing PNP refueling outage, Entergy requests approval of this alternative by May 2, 2012.
Summary of Commitments This letter identifies one new commitment, as described in Attachment 2, and no revised commitments.
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PNP 2012-035 Page 2 Attachments:
- 1. Proposed Alternative
- 2. Description of Commitment cc:
Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC
ATTACHMENT 1 PROPOSED ALTERNATIVE ATTACHMENT 1 ENTERGY NUCLEAR OPERATIONS, INC.
PALISADES NUCLEAR PLANT PROPOSED ALTERNATIVE in Accordance with 10 CFR SO.SSa(a)(3)(ii)
Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality and Safety
- 1. ASME Code Component(s) Affected I Applicable Code Edition Components / Numbers:
See Table 1 Code of Record:
Pressure Retaining Dissimilar Metal Piping Butt Welds Containing Alloy 821182 American Society of Mechanical Engineers (ASME)Section XI, 2001 Edition through 2003 Addenda as amended by 10 CFR 50.55a (2011)
ASME Code Case N-770-1 N-770-1 Inspection Item: A-1 and B
==
Description:==
Class 1 PWR pressure retaining Dissimilar Metal Piping and Vessel Nozzle Butt Welds Containing Alloy 821182 Unit/Inspection Interval: Palisades Nuclear Plant/ Fourth 10-Year Interval
2. Applicable Code Requirements
The ASME Boiler and Pressure Vessel Code, Rules for Inservice Inspection of Nuclear Power Plant Components,Section XI, 2001 Edition through 2003 Addenda, as amended by 10 CFR 50.55a (2011).
With the issuance of a revised 10 CFR 50.55a in June 2011, the Nuclear Regulatory Commission (NRC) staff incorporated by reference Code Case N-770-1, "Alternative Examination Requirements and Acceptance Standards for Class 1 PWR Piping and Vessel Nozzle Butt Welds Fabricated with UNS N06082 or UNS W86182 Weld Filler Material With or Without Application of listed Mitigation Activities,Section XI, Division 1." Specific implementing requirements are documented in 10 CFR 50.55a(g)(6)(ii)(F) and are listed below:
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ATTACHMENT 1 PROPOSED ALTERNATIVE A. 10 CFR SO.SSa(g)(6)(ii)(F)(1), effective date August 22, 2011, requires "licensees of existing, operating pressurized water reactors as of July 21,2011, shall implement the requirements of ASME Code Case N-770-1, subject to the conditions specified in paragraphs (g)(6)(ii)(F)(2) through (g)(6)(ii)(F)(10) of this section, by the first refueling outage after August 22,2011."
B. Regulation 10 CFR SO.SSa(g)(6)(ii)(F)(3) states that baseline examinations for welds in Code Case N-770-1, Table 1, Inspection Items A-1, A-2, and B, shall be completed by the end of the next refueling outage after January 20,2012.
Previous examinations of these welds can be credited for baseline examinations if they were performed within the re-inspection period for the weld item in ASME Code Case N-770-1, Table 1 using Section XI, Appendix VIII requirements and met the Code required examination volume of essentially 100 percent. Other previous examinations that do not meet these requirements can be used to meet the baseline examination requirement, provided NRC approval of alternative inspection requirements in accordance with paragraphs (a)(3)(i) or (a)(3)(ii) of this section is granted prior to the end of the next refueling outage after January 20, 2012.
C. Regulation 10 CFR SO.SSa(g)(6)(ii)(F)(4) states that the axial examination coverage requirements of Code Case N-770-1, -2S00(c) may not be considered to be satisfied unless essentially 100 percent coverage is achieved.
The welds covered by this proposed alternative are classified as Inspection items A-1 and B (described below) for which visual and essentially 100 percent volumetric examination, as amended by 10 CFR SO.SSa(g)(6)(ii)(F)(4), are required.
ASME Code Case N-77G-1 as Amended by 10 CFR SO.SSa(g)(6)(Ii)(F)(4)
CLASS 1 PWR Pressure Retaining Dissimilar Metal Piping and Vessel Nozzle Butt Welds Containing Alloy 821182 Parts Examined Insp Extent and Frequency of Examination Item Bare metal visual examination each refueling outage Unmitigated butt weld Essentially 100% volumetric examination for axial and at Hot Leg operating temperature (-2410) >
A-1 circumferential flaws in accordance with the applicable requirements of ASME Section XI, Appendix VIII, every second 625°F (329°C) refueling outage. Baseline examinations shall be completed by the end of the next refueling outage after January 20, 2012.
Bare metal visual examination once per interval Unmitigated butt weld Essentially 100% volumetric examination for axial and at Cold Leg operating circumferential flaws in accordance with the applicable temperature (-2410).?!
B requirements of ASME Section XI, Appendix VIII, every second 525°F (274°C) and <
580°F (304°C) inspection period not to exceed 7 years. Baseline examinations shall be completed by the end of the next refueling outage after January 20, 2012.
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ATTACHMENT 1 PROPOSED ALTERNATIVE As defined by ASME Code Case N-460, essentially 100% means greater than 90% of the examination volume of each weld where reduction in coverage is due to interference by another component or part geometry.
ASME Section XI, Appendix VIII, Supplement 10, "Qualification Requirements for Dissimilar Metal Piping Welds," is applicable to dissimilar metal (DM) welds without cast materials.
3. Reason for Request
The welds listed in Table 1 of this request did not satisfy the exam coverage required by ASME Code Case N-770-1, as conditioned by 10 CFR SO.SSa(g)(6)(ii)(F)(4).
The relevant conditions for this request for alternative are ASME Section XI Code Case N-770-1, and 10 CFR SO.SSa(g)(6)(ii)(F) items (3) and (4), which address performing the required baseline examination and attaining the required examination coverage.
10 CFR SO.SSa(g)(6)(ii)(F)(3) requires that all Inspection Items A-I, A-2, and B receive a baseline examination by the end of the first refueling outage after January 20, 2012.
10 CFR SO.SSa(g)(6)(ii)(F)(4) provides the following exception to ASME Code Case N-770-1,
the axial examination coverage requirements of -2S00(c) may not be considered to be satisfied unless essentially 100 percent coverage is achieved."
Whereas MRP-139 (Reference 4) and ASME Code Case N-770-1 made allowances for limitations in circumferential scanning for axial flaw examination coverage of DM welds, the NRC has stated in 10 CFR SO.SSa(g)(6)(ii)(F)(4) that essentially 100 percent coverage is required. This applies to meeting the baseline requirements for 10 CFR SO.SSa(g)(6)(ii)(F)(3) above, as well as re-examinations.
Relief is requested from Code Case N-770-1, -2S00, Examination Requirements, as conditioned by 10 CFR SO.SSa(g)(6)(ii)(F)(4) that essentially 100% coverage must be achieved of the inspection volume for the baseline and future required volumetric examinations.
Relief is also requested to defer the baseline volumetric examination of two of the two inch cold leg drain DM butt welds for one cycle past the required deadline specified in 10 CFR SO.SSa(g)(6)(ii)(F)(3) due to physical limitations of the joint geometry such that volumetric examination of these welds would result in minimal or no coverage.
Hardship In accordance with 10 CFR SO.SSa(a)(3)(ii), relief is requested for the components listed in Table 1, on the basis that the required examination coverage of essentially 100 percent is unattainable due to limitations imposed by design and geometry.
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ATTACHMENT 1 PROPOSED ALTERNATIVE PCS-2-DRL-1 A 1-1 and PCS-2-DRL-1 B 1-1 Two NPS 2 cold leg drains could not be examined. The geometry of the drains is such that phased array probes cannot be fitted against the piping, even after weld preparation. Probe length is greater than the flat length on the pipe. The area to be examined is bounded on the upstream side by an intemally and extemally tapered nozzle, and on the downstream side by a socket weld. Figures 1 and 2 illustrate the piping geometry. Conventional ultrasonic (UT) Performance Demonstration Initiative (POI) qualified examination of these welds would result in additional worker exposure, and would not achieve an increase in coverage that would provide a compensating increase in the level of quality and safety. Mitigation would require a repair that has not been designed or planned, but is estimated to take 120 worker-hours. At area dose rates of approximately 750 mrem/hour and 550 mrem/hour, respectively, repair during the present outage would result in 90 and 66 rem exposure, respectively, to implement in the field.
PCS-2-CHL-1A1-17 The geometry of one NPS 2 charging inlet is such that essentially 100% coverage of the required area could not be attained with either phased array or conventional POI examination (Figure 3). Although one phased array probe (circumferentially shooting, looking for axial oriented flaws) would barely fit onto the pipe following weld preparation, there is insufficient area to manipulate the probe. The other required phased array probe (axial shooting, looking for circumferentially oriented flaws) would not fit at all. A manual conventional examination using a qualified POI UT procedure, personnel and probes was employed. One of the required qualified probes needed for detection of axial flaws was not located after an extensive industry search. A probe was located and used for this specific scan of the weld, but the focal depth of the transmitted sound was slightly short of the required focal depth range for the inner 1/3 of the pipe thickness. A scan was performed using this probe, however, no credit was factored into the coverage shown on Table 1 for this weld. The area to be examined is bounded on the upstream side by a socket welded check valve, and on the downstream side by an intemally and extemally tapered nozzle. Mitigation would require a repair that has not been designed or planned, but is estimated to take 120 worker-hours. At an area dose rate of approximately 200 mrem/hour, repair during the present outage would result in a 24 rem exposure to implement in the field.
PCS-2-DRL-2A 1-1 The geometry of one NPS 2 cold leg drain is such that essentially 100% coverage of the required area could not be attained (Figure 4). The area to be examined is bounded on the upstream side by an intemally and extemally tapered nozzle, and on the downstream side by a socket weld. Conventional POI examination would take more time than phased array, resulting in undesirable worker exposure, and would not achieve an increase in coverage that would provide a compensating increase in the level of quality and safety. Mitigation would require a repair that has not been designed or planned, but is estimated to take 120 worker-hours. At an area dose rate of approximately 400 mrem/hour, repair during the present outage would result in a 48 rem exposure to implement in the field.
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ATTACHMENT 1 PROPOSED ALTERNATIVE PCS-3-PSS-1 B 1-1 and PCS-3-PSS-2A 1-1 The geometry of two NPS 3 spray outlets is such that essentially 100% coverage of the required area could not be attained (Figures 5 and 6). The areas to be examined for these welds are bounded on the upstream side by an internally and externally tapered nozzle, and on the downstream side by a butt welded pipe elbow. Conventional POI examination would take more time than phased array, resulting in undesirable worker exposure, and would not achieve an increase in coverage that would provide a compensating increase in the level of quality and safety. Mitigation would require a repair that has not been designed or planned, but is estimated to take 120 worker-hours. At area dose rates for the two NPS spray outlets of approximately 600 mrem/hour and 195 mrem/hour, respectively, to repair during the present outage would result in a 72 and 23 rem exposure, respectively, to implement in the field.
PCS-4-PRS-1 P1-1 The geometry of one NPS 4 pressurizer nozzle to piping transition piece weld is such that essentially 100% coverage of the required area could not be attained (Figure 7).
Conventional POI examination would take more time than phased array, resulting in undesirable worker exposure, and would not achieve an increase in coverage that would provide a compensating increase in the level of quality and safety. Mitigation would require a repair that has not been designed or planned, but is estimated to take 120 worker-hours.
At an area dose rate of approximately 200 mrem/hour, a repair during the present outage would result in a 24 rem exposure to implement in the field.
4. Proposed Alternative and Basis for Use
Proposed Alternative
- 1) Periodic system pressure tests in accordance with ASME Section XI Examination Category B-P, Table IWB-2500-1.
- 2) Conduct ultrasonic examinations to the maximum extent practical.
- 3) During refueling outages, plant personnel walk down Class 1 systems inside containment. These walk downs are performed to look for system anomalies that could affect plant performance, and are in conformance with the Boric Acid Corrosion Control Program (Reference 13), which ensures careful inspections and treatment of any findings.
- 4) Dye penetrant surface examinations of the Inspection Item B welds. During the 2012 refueling outage, external surface examinations of the welds for which relief is requested identified no evidence of through-wall cracking or leakage for these components.
Options currently being considered to address this condition in the 2013 refueling outage, in a manner that would minimize worker exposure, include:
weld overlay, nozzle removal and weld pad with half nozzle installation, 5 of 18
ATTACHMENT 1 PROPOSED ALTERNATIVE machine removal of existing heat affected zone metal and installation of new PWSCC resistant weld, or alternative inspection approaches.
Entergy will perform appropriate actions to meet ASME Section XI Code Case N-770-1 baseline examinations for those dissimilar metal welds not meeting the examination coverage requirements during the 2012 refueling outage prior to startup from the planned fall 2013 refueling outage. These actions include:
- 1) compliance with N-770-1 requirements, or
- 2) removal of the subject locations from the scope of ASME Section XI Code Case N-770-1, or
- 3) submittal of relief request in accordance with the applicable provisions of 10 CFR SO.SSa.
Basis for Use The UT techniques proposed for each weld were reviewed to determine the amount of examination coverage that could be achieved. Surface conditioning was performed as appropriate to obtain the maximum amount of coverage. However, due to various weld configurations, only limited examination volume coverages were possible for applicable circumferential and axial scans.
Table 1 provides (a) welds that were unable to be volumetrically examined due to geometry and (b) welds examined to Code Case N-770-1 examination requirements with less than essentially 100% coverage. It references specific figures that illustrate the extent of coverage for each weld. The angles and ultrasonic wave modes (Shear-S or Longitudinal-L) that were employed for the examinations and limitations encountered are also listed for each weld.
Subject welds in small bore piping less than 4-inch NPS previously had not been subject to volumetric examination for ASME Class XI, MRP-139, or Code Case N-770-1.
Structural Integrity of these Regions The operating temperature of a component is a primary factor influencing the initiation of Primary Water Stress Corrosion Cracking (PWSCC). Research by the Electric Power Research Institute (EPRI) (Reference 10) indicates that the difference in the operating temperature between hot leg locations and cold leg locations is sufficient to significantly influence the time to initiation of PWSCC, with the susceptibility increasing with temperature.
The research reports PWSCC is least likely to occur in cold leg temperature penetrations.
Other than the pressurizer weld, the welds covered by this relief are found in lower temperature regions of the system, typically at temperatures near to Tcold, which is 6 of 18
ATTACHMENT 1 PROPOSED ALTERNATIVE approximately 537 of. This means there is a lower probability of crack initiation, and a slower crack growth rate [References 11 and 12].
No flaws have been found at Palisades in the welds for which relief is requested. Even If there were to be flaws in the welds for which relief is requested, and these flaws led to leakage, the leak detection methodology presently used by industry is very sensitive. After a number of recent operating events, the industry imposed an NEI 03-08 "needed" requirement, to improve leak detection capability. As a result, virtually all pressurized water reactors (PWRs) in the United States, including Palisades, have a leak detection capability of less than or equal to 0.1 gpm (Reference 8). All plants, including Palisades, also monitor seven day moving averages of reactor coolant system leak rates.
Action response times following a leak detection vary, based on the action level exceeded and range up to containment entry to identify the source of the leak. Utilities take the commitment of shutdowns due to unidentified leakage seriously.
Action levels have been standardized for all PWRs, and are based on deviations from:
The seven day rolling average, Specific values, and The baseline mean.
Leak rate action levels are identified in Pressurized Water Reactor Owners Group (PWROG) report, WCAP-16465, and are stated below:
Each PWR utility is required to implement the following standard action levels for reactor coolant system (RCS) inventory balance in their RCS leakage monitoring program.
A. Action levels on the absolute value of unidentified RCS inventory balance (from surveillance data):
Level 1 - One seven day rOiling average of unidentified RCS inventory balance values greater than 0.1 gpm.
Level 2 - Two consecutive unidentified RCS inventory balance values greater than 0.15 gpm.
Level 3 - One unidentified RCS inventory balance value greater than 0.3 gpm.
Note: Calculation of the absolute RCS inventory balance values must include the rules for the treatment of negative values and miSSing observations.
- 1. Action levels on the deviation from the baseline mean:
Level 1 - Nine consecutive unidentified RCS inventory balance values greater than the baseline mean [~] value.
Level 2 - Two of three consecutive unidentified RCS inventory balance values greater than [~ + 20], where 0 is the baseline standard deviation.
Level 3 - One unidentified RCS inventory balance value greater than [~ +30].
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ATTACHMENT 1 PROPOSED ALTERNATIVE These action levels have been incorporated into Palisades operating procedures.
Therefore, with the periodic system pressure tests, outage system walk downs, and leakage monitoring, and the surface examinations performed during the 2012 refueling outage, an acceptable level of quality and safety is provided for identifying degradation from PWSCC prior to a safety significant flaw developing.
5. Duration of Proposed Alternative
The duration of the proposed alternative for the welds with limited or no coverage is until the next PNP refueling outage, planned for the fall of 2013.
- 6. Precedent This relief request is similar in nature to the following relief requests authorized by the NRC:
- 1. Diablo Canyon Power Plant, February 24, 2012 [ADAMS Accession No. ML120530680J.
- 2. Indian Point Nuclear Generating Unit No.2, February 2,2012 (ML120260090).
- 3. Calvert Cliffs Nuclear Power Plant, March 26, 2012 [ML120860541J.
- 7. References
- 1. 10 CFR 50.55a revision endorsing the 2008 Addenda of Section III and Section XI, Federal Register #76FR36232, July 21, 2011.
- 2. ASME Section XI, "Rules For Inservice Inspection of Nuclear Power Plant Components,"
2001 Edition with Addenda through 2003.
- 3. ASME Section XI, Division 1, Code Case N-460, "Alternative Examination Coverage for Class 1 and Class 2 Welds,Section XI, Division 1."
- 4. Material Reliability Program: Primary System Piping Butt Weld Inspection and Evaluation Guideline (MRP-139), Revision 1, EPRI, Palo Alto, CA, 2008 [ML1009700671].
- 5. Nondestructive Evaluation: Procedure for Manual Phased Array Ultrasonic Examination of Dissimilar Metal Welds, EPRI-DMW-PA-1, Revision 3,1016645, EPRI Palo Alto, CA, 2008.
- 6. Material Reliability Program, Alloy 821182 Pipe Butt Weld Safety Assessment for US PWR [Pressurized Water Reactor] Plant Designs (MRP-109): Westinghouse and CE
[Combustion EngineeringJ Design Plants, EPRI, Palo Alto, CA, 2005 [ML042434006].
- 7. "Changing the Frequency of Inspections for PWSCC Susceptible Welds at Cold Leg Temperatures", in Proceedings of 2011 ASME Pressure Vessels and Piping Conference, July 17-21,2011, Baltimore, MD.
- 8. WCAP-16465-NP, Rev. 0, "Pressurized Water Reactor Owners Group Standard RCS Leakage Action Levels and Response Guidelines for Pressurized Water Reactors,"
Westinghouse Electric Co., September 2006 [ML070310082].
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ATTACHMENT 1 PROPOSED ALTERNATIVE
- 9. Pressurized Water Reactor (PWR) Owner's Group Letter OG-12-89, "Transmittal of
'Final Relief Request Famework' under Relief Request for Large Diameter Cold Leg Locations with Obstructions (PA-MSC-0934)," March 8, 2012.
- 10. Electric Power Research Institute: PWSCC of Alloy 600 Materials in PWR Primary System Penetrations, EPRI, Palo Alto, CA, 1994, TR-103696 [ML013110446].
- 11. Materials Reliability Program Crack Growth Rates for Evaluating Primary Water Stress Corrosion Cracking (PWSCC) of Thick-Wall Alloy 600 Materials (MRP-55) Revision 1, EPRI, Palo Alto, CA, 2002,1006695 [ML023010510].
- 12. Materials Reliability Program Crack Growth Rates for Evalu~:lting Primary Water Stress Corrosion Cracking (PWSCC) of Alloy 82,182, and 132 Welds (MRP-115), EPRI, Palo Alto, CA, 2004, 1006696 [ML051100204].
- 13. SEP-BAC-PLP-001, "Boric Acid Corrosion Control Program," Revision o.
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ATTACHMENT 1 PROPOSED ALTERNATIVE Table 1: Inspection Coverages
~
Component Descrlptionl Last POI Inspection Item N-770-1 Volume Coverage (%)
10 NPS Exam Date Being MRP-l39 N-770-1 elrc Scan Axial Scan Total Angle/Wave Fig.
Exam Method and Umitationa I Credited for Axial forClrc Mode Flaws Flaws Examination Summary PCS 2" Nozzle to N/A N/A B
0%
0%
0%
N/A 1
Pipe dimension between socket weld ORL-1A1-1 pipe weld to nozzle transition - 1.0" PCS 2" Nozzle to N/A N/A B
0%
0%
0%
N/A 2
Pipe dimension between socket weld ORL-181-1 pipe weld to nozzle transition - 1.25" Manual conventional UT. Geometry PCS 58 & 41 limitation due to limited pipe scanning CHL-1A1-2" Nozzle to N/A N/A B
40.6%
66.6%
53.6%
deg. -S, 3
surface between nozzle and socket 17 pipe weld 43,60 &
weld, and unqualified probe used for 68 deg - L information only. Acceptable, no recordable indications.
PCS 2" Nozzle to PA-UT Manual PA-UT. Geometry limitation ORL-2A1-1 pipe weld N/A N/A B
75%
100%
88%
S&L 4
due to nozzle transition. Acceptable, 10 geometry recorded.
PCS 3" Nozzle to PA-UT Manual PA-UT. Geometry limitation PSS-181-1 elbow weld N/A N/A 8
72.8%
63.6%
68.2%
S&L 5
due to elbow intrados. Acceptable, 10 geometry recorded.
PCS 3" Nozzle to PA-UT Manual PA-UT. Geometry limitation PSS-2A1-1 elbow weld N/A N/A 8
72.8%
63.6%
68.2%
S&L 6
due to elbow intrados. Acceptable, no recordable indications.
Manual PA-UT. Geometry limitation due to short nozzle parallel surfaces PCS 4" Nozzle to N/A N/A A-1 12.5%
82.1%
47.3%
PA-UT 7
and weld transition between nozzle &
PRS-1P1-1 safe-end S&L safe-end replacement. Acceptable CIS base metal inclusion recorded (CR-PLP-2012-03165).
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4.5625" 1.0" 6.1875" ATTACHMENT 1 PROPOSED ALTERNATIVE Figure 1 NPS 2 Cold Leg Drain PCS-2-DRL-1A1-1 Carbon Steel Cold Leg 2.5625" 2.0625" Stainless Steel Pipe 2" Socket Weld Elbow Not to Scale 11 of 18 f
6.625"
ATTACHMENT 1 PROPOSED ALTERNATIVE Figure 2 NPS 2 Cold Leg Drain PCS-2-DRL-181-1 t
Carbon Steel Cold Leg 6.625" 2.5625"
'-------I Full Penetration DM V Weld 4.5625" 2.0625" 1.25" Stainless Steel Pipe 2" Socket Weld Elbow Not to Scale 12 of 18
V~LVE VALVE ATTACHMENT 1 PROPOSED ALTERNATIVE Figure 3 NPS 2 Charging Inlet PCS-2-CHL-1A1-17 Coverage Sheet Pc.s - a. -C.I-\\L - IP-I-11 FL.I>W NO 6Ni£ I\\'\\tit-'L co",,""4&( I\\Chhkb,.)it"
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ATTACHMENT 1 PROPOSED ALTERNATIVE Figure 4 NPS 2 Cold Leg Drain PCS-2-DRL-2A 1-1 Coverage Sheet PAliSADE!]
uJelJ IO pes... ~- o~L - ~ II 1-1
.sCIINN IE IJ
() vel!. we,o 70..t:IaJu e.(}~
/00 % Cooe"(I:J.e.. AX e>{;4t t tP SCANNrN6 Llm.ted CW/CGU) dve -rc. Noh/e Co"f,jurDII~ a/~c. ~,.s 14 of 18
ATTACHMENT 1 PROPOSED ALTERNATIVE Figure 5 NPS 3 Spray Outlet PCS-3-PSS-181-1 Information Sheet
~
15 of 18
ATTACHMENT 1 PROPOSED ALTERNATIVE Figure 6 NPS 3 Spray Outlet PCS-3-PSS-2A 1-1 Information Sheet 16 of 18 Uot?l(
ATTACHMENT 1 PROPOSED ALTERNATIVE 17 of 18
No Z?, Ll,..
l' ATTACHMENT 1 PROPOSED ALTERNATIVE Figure 7 NPS 4 Pressurizer Nozzle PCS-4-PRS-1 P1-1 Coverage Sheet 18 of 18
ATTACHMENT 2 DESCRIPTION OF COMMITMENT This table identifies actions discussed in this letter for which Entergy commits to perform. Any other actions discussed in this submittal are described for information only and are not commitments.
TYPE SCHEDULED (Check one)
COMPLETION COMMITMENT ONE-TIME CONTINUING DATE ACTION COMPLIANCE (If Required)
Entergy will perform appropriate actions to
-/
Prior to startup meet ASME Section XI Code Case N-770-1 from the planned baseline examinations for those dissimilar fall 2013 refueling metal welds not meeting the examination outage.
coverage requirements during the 2012 refueling outage prior to startup from the planned fall 2013 refueling outage. These actions include:
- 1) compliance with N-770-1 requirements, or
- 2) removal of the subject locations from the scope of ASME Section XI Code Case N-770-1, or
- 3) submittal of relief request in accordance with the applicable provisions of 10 CFR SO.SSa.
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