W3F1-2012-0085, Request for Alternative W3-ISI-020, ASME Code Case N-770-1 Baseline Examination Request

Request for Alternative W3-ISI-020, ASME Code Case N-770-1 Baseline Examination Request

ML12296A241
Person / Time
Site:	Waterford
Issue date:	10/16/2012
From:	Mason M Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2012-0085
Download: ML12296A241 (29)

Text

Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093

ýEntergy Tel 504 739 6673 Fax 504 739 6698 mmason@entergy.com Michael E. Mason Licensing Manager, Acting Waterford 3 W3F1-2012-0085 October 16, 2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Waterford 3 Request for Alternative W3-ISI-020, ASME Code Case N-770-1 Baseline Examination Request for Alternative Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38

Dear Sir or Madam:

Pursuant to 10 CFR 50.55a(a)(3)(ii), Entergy Operations, Inc. (Entergy) hereby requests NRC approval of the attached Inservice Inspection (ISI) Request for Alternative for Waterford Steam Electric Station Unit 3 (WF3). This alternative is for the current third ten-year ISI 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 in the Final Rule 10 CFR 50.55a(g)(6)(ii)(F)(3), dated June 21, 2011.

To support the startup of WF3 following its refueling outage in the Fall of 2012, Entergy requests approval of this alternative by December 1, 2012.

This letter contains no new commitments. If you have any questions or require additional information, please contact the acting Licensing Manager, Michael E.

Mason, at (504) 739-6673.

Sincerely, MEM/RJP

Attachment:

Request for Alternative W3-ISI-020 r\J

W3F1-2012-0085 Page 2 cc: Mr. Elmo E. Collins, Jr. RidsRgn4MailCenter@nrc.gov Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 E. Lamar Blvd.

Arlington, TX 76011-4511 NRC Senior Resident Inspector Marlone.Davis@nrc.gov Waterford Steam Electric Station Unit 3 Dean. Overland@nrc.gov P.O. Box 822 Killona, LA 70066-0751 U. S. Nuclear Regulatory Commission Kaly.Kalyanam@nrc.gov Attn: Mr. N. Kalyanam Mail Stop O-07D1 Washington, DC 20555-0001

I ,

Attachment to W3F1-2012-0085 Request for Alternative W3-ISI-020

Attachment to W3F17-2012-0085 Page 1 of 26 Waterford 3 Request for Alternative In Accordance with 10 CFR50.55a(g)(3)(ii)

Hardship or Unusual Difficulty without Compensating Increase in Level of Quality or Safety

1. ASME Code Component(s) Affected I Applicable Code Edition Components / Numbers: See Table 1, Pressure retaining dissimilar metal piping welds containing Alloy 82/182 Code of Record: AMSE Section XI, 2001 Edition through 2003 Addenda as amended by 10CFR50.55a (2011)

ASME Code Case N-770-1 Code Class: American Society of Mechanical Engineers (ASME) Class 1 Code Case N-770-1: Item B - Unmitigated butt weld at cold leg operating temperature Unit / Inspection Interval: Waterford Steam Electric Station, Unit 3 / Third Ten-Year Interval

2. Applicable Code Requirement

The American Society of Mechanical Engineers (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 1 OCFR50.55a (2011).

A. 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: 10 CFR 50.55a(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 50.55a(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%. 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."

Attachment to W3F1-2012-0085 Page 2 of 26 C. Regulation 10 CFR 50.55a(g)(6)(ii)(F)(4) states that the axial examination coverage requirements of Code Case N-770-1, -2500(c) may not be considered to be satisfied unless essentially 100% coverage is achieved.

The welds covered by this proposed alternative are classified as Inspection item B (described below) for which visual and essentially 100% volumetric examination, as amended by 10 CFR 50.55a(g)(6)(ii)(F)(4), are required.

ASME Cd*esCa*.WRsess N-77r-1 as Amended by eOCFR5a.55p(g)M*anO. l o

'Clbss 11PWIR Pressure Retaining Dissimilar Metal: Piping, and Ves~sel Nozzle Butt Welds. Containing Alloy 82/1 82 --

Patxamine" lnsp ExetAn Frqec -of Examination item Bare metal visual examination once per interval Unmitigated butt weld at Essentially 100% volumetric examination for axial and Coldtegperating

(-24circumferential flaws in accordance with the applicable temperature (-2410) B requirements of ASME Section XI, Appendix VIII, every

• 525°F (274°C) and second inspection period not to exceed 7 years. Baseline

< 580°F (304"C) examinations shall be completed by the end of the next refueling outage after January 20, 2012.

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 welds without cast materials. ASME Section XI, Appendix VIII, states that the supplement for the examination of cast stainless steel is "in the course of preparation."

4. Reason for Request

Entergy is requesting permission to utilize the ultrasonic examinations performed in accordance with MRP-1 39 during outages conducted prior to the issuance of the revised rule (in June of 2011) to satisfy the baseline examination requirements of 10CFR50.55a(g)(6)(ii)(F)(3). However, the welds listed within this request did not satisfy the required ASME Code Case N-770-1, as amended by 10CFR50.55a(g)(6)(ii)(F)(3),

examination volume coverage due to their configuration. The scanning limitations prohibited essentially 100% ultrasonic examination coverage of the required examination volume.

10CFR50.55a(g)(6)(ii)(F)(4) provides the following exception to ASME Code Case N-770-1, "the axial examination coverage requirements of -2500(c) may not be considered to be satisfied unless essentially 100% coverage is achieved."

Attachment to W3F1-2012-0085 Page 3 of 26 Relief is requested from the 10CFR50.55a(g)(6)(ii)(F)(4) exception to ASME Code Case N-770-1 that essentially 100% coverage be achieved for the baseline and future required volumetric examinations.

Hardship In accordance with 10CFR50.55a(a)(3)(ii), relief is requested for the components listed in Table 1, on the basis that the required examination coverage of essentially 100% is unattainable due to limitations imposed by design and geometry.

The design of the Cold Leg nozzles of the components listed in Table 1 contains a cast stainless steel safe-end. The presence of cast stainless steel material within the exam volume contributes to the inability to meet the ASME Code Case N-770-1 exam volume of essentially 100%. Additionally the circumferential scan volume was affected by the geometry of the nozzle configuration. This resulted in limitations to the exam coverage of the non-cast stainless steel materials within the ASME Code exam volume. The examination coverage of the material susceptible to PWSCC (alloy 600) was fully examined within the examination volume of the MRP-139 exam.

5. Proposed Alternative and Basis for Use Proposed Alternative

1) Periodic system pressure tests in accordance with ASME Section XI Category B-P, Table IWB-2500-1.

2) Ultrasonic examinations conducted to the maximum extent possible per ASME Code Case N-770-1 frequencies.

3) During outages, system engineers walkdown Class 1 systems inside containment. This walkdown is performed to look for system anomalies that could affect plant performance.

[Note: these examinations have identified no evidence of leakage for the subject components in the past.]

4) Bare metal visual examinations of the Inspection Item B welds in accordance with ASME Code Case N-722-1. [Note: these examinations have identified no evidence of leakage for the subject components in the past.]

The combination of these examinations provides confidence that an acceptable level of quality and safety has been maintained.

Basis for Use Entergy's Waterford Steam Electric Station Unit 3 plant design (Combustion Engineering) contains a thirty (30) inch I.D. inlet and a thirty (30) inch I.D. outlet weld connected to each of the four (4) reactor coolant pumps (RCPs). Each weld joins mill-clad SA-516, Grade 70 carbon steel pipe with SA-240-304L stainless steel cladding to a SA-351, Grade CF8M stainless steel safe end. There is also a twelve (12) inch O.D. Safety Injection (SI) nozzle weld connected to each reactor coolant pump discharge spool piece. These welds on the

Attachment to W3F1 -2012-0085 Page 4 of 26 safety injection nozzles join mill-clad SA-516, Grade 70 carbon steel pipe with SA-240-304L stainless steel cladding to a SA-351, Grade CF8M stainless steel safe end. During the past several years, examinations have been performed on the eight reactor coolant pump inlet/outlet dissimilar metal welds utilizing manual non-encoded phased array Ultrasonic (UT) techniques from the OD. In all cases, the examinations were performed from the carbon steel side of the weld. In the case of the 30" RCP nozzles, no indications were identified. For the 12" SI nozzles, there were two (08-009 and 10-008) of the four welds that had acceptable recordable indications.

The equipment, procedure, and personnel utilized for the performance of the examinations were qualified in accordance with the requirements of ASME Section XI, Appendix VIII, Supplement 10, as implemented through the Performance Demonstration Initiative (PDI) program. Structural Integrity Associates (SIA) was the Performance Demonstration Initiative (PDI) qualified contractor that performed the inspection. SIA procedure SI-UT-1 30, Revision 3, Addendum 0, "Procedure for the Phased Array Ultrasonic Examination of Dissimilar Metal Welds," was used to perform the examinations. Per PDQS 632, this procedure was PDI qualified for ASME Code Section XI, Supplement 10 single-sided axial coverage. Because the examination of the RCP inlet/outlet configuration and 12" SI nozzles are included in the PDI sample set, a site specific mock-up was not applicable for these weld examinations.

All of the welds covered by this Request for Alternative are found in cold, leg temperature (Tcold) regions of the system. This means there is a lower probability of crack initiation, and a slower crack growth rate. These welds are also very highly flaw tolerant, as demonstrated in the MRP-109 report (ref. 6). No service-induced flaws have been found in these large diameter pipes, even though most of the plants of interest have been in service for over 25 years (ref. 9).

Prior to the issuance of the revised final rule 10CFR50.55a, (effective date August 22, 2011), that includes the requirement to implement the requirements of ASME Code Case N-770-1 as amended, the Materials Reliability Program issued "Primary System Piping Butt Weld Inspection and Evaluation Guidelines (MRP-139)." This document was classified as "mandatory" per the implementation protocol of the Nuclear Energy Institute (NEI) 03-08 initiative. MRP-1 39 provided a strategy to manage degradation of butt welds in primary system piping that are 4" NPS or greater and exposed to temperatures greater than or equal to cold leg temperature. The guideline was structured to categorize weld inspections to acknowledge mitigation, temperature, safety significance of flaw orientation, and inspection capabilities. The guideline defined examination locations on the piping, examination requirements for various weld categories, and extent of examination for each location.

Finally, the guideline provided evaluation procedures to determine acceptance of flaws, justification for mitigation actions, and changing examination categories.

MRP-139 delineated acceptable coverage of the required examination volume to be calculated separately for axial and circumferential flaw orientations using the actual weld configuration and the procedure's essential variables, if needed. Coverage calculations could be made by manual plotting or by using computer-aided design (CAD) or other software that models the procedure's beam angles and scan plans.

Attachment to W3F1 -2012-0085 Page 5 of 26

" The inspection was considered complete when, using the qualified procedure and personnel, the coverage for both axial and circumferential flaws was greater than 90% of the required examination volume.

" If >90% coverage for circumferential or axial flaws was not attained, then the following independent actions were required:

- If greater than 90% coverage for circumferential flaws could not be met (using qualified personnel and procedures), then specific actions described within the document were required.

- If greater than 90% coverage for axial flaws could not be met, but greater than 90%

coverage was obtained for circumferential flaws (using qualified personnel and procedures), then the examination for axial flaws would be completed to achieve the maximum coverage possible with limitations noted in the examination report.

The previous UT data reports were reviewed for each weld to determine the amount of examination coverage that was achieved. This review concluded that coverage of the susceptible material in all 12 welds examined for circumferential flaws was very good. As a result, very good coverage of the susceptible material in all 12 welds was examined for circumferential flaws. However, due to the weld taper and the lack of access for examination from the cast CF8M safe-end side of the welds, limited examination volume coverage was noted for axial flaws. Even with these limitations, this examination satisfied the examination volume coverage requirements identified in MRP-139.

Examination coverage was determined utilizing field-obtained contours. Qualification for the UT examination of the cast material is "in the course of preparation." No coverage was claimed in the cast material for MRP-139 or ASME Code Case N-770-1 exam volume in Table 1 based on no qualified Appendix VIII procedure was available for this type of material. However, as shown in the figures, the theoretical beam path extends into the cast material for the examinations performed from the carbon steel side of the weld but this is not included in the coverage due to it not being a qualified method.

For the MRP-139 axial and circumferential flaw examination volume coverage achieved, the calculation includes the carbon steel base material and susceptible material. For the ASME Code Case N-770-1 axial and circumferential flaw examination volume coverage achieved, the calculation includes the volume identified in Figure 1 of the code case (which includes the cast stainless steel). The amount of coverage that could be credited was determined in accordance with the qualified examination procedure.

Table 1 provides the percent of coverage credited for MRP-1 39, and Code Case N-770-1 (as amended by 1 OCFR50.55a(g)(6)(ii)(F)(4)), for the most recent examinations, and references specific figures that illustrate the extent of coverage for each weld. The angles, ultrasonic wave modes (Shear-S or Longitudinal-L) that were employed for the manual non-encoded phased array examinations, and limitations encountered are listed for each weld.

Arrows and lines on the associated weld figures illustrate the phased array search beam direction and extent of the area examined.

r!fIfjI)11.1(,f)01 Attachment to W3F1-2012-0085 Page 6 of 26 The examination volume coverage for MRP-139 included the carbon steel base material and susceptible material. As shown in Table 1, very good coverage of the examination volume for the safety significant circumferential flaw in the carbon steel base material and susceptible material was achieved during the MRP-139 examinations.

Due to the guidance included in the Appendix VIII qualified procedure for single sided access configurations, the MRP-139 axial flaw examination volume coverage did not satisfy the essentially 100% requirement.

As identified in MRP-109 (ref. 6), the axial flaw(s) that could result from a primary water stress corrosion cracking (PWSCC) mechanism in the susceptible alloy 82/182 butt weld are not safety significant. The axial critical flaw length for a RCP inlet and outlet alloy 82/182 butt weld is 38.2" (MRP-1 09 Table 5-2) which exceeds the width of the Waterford Steam Electric Station, Unit 3 RCP inlet and outlet alloy 82/182 butt weld material width of 1.75"-

2.5". Therefore a critical axial flaw in a RCP inlet or outlet alloy 82/182 butt resulting from a PWSCC mechanism is not credible, and improving the exam axial flaw examination volume coverage would not result in an increase in safety.

6. Structural Integrity of these Regions All of the welds covered by this relief are found in lower temperature regions of the system, typically at temperatures near to Tco.d which is approximately 543 0 F. This means there is a lower probability of crack initiation, and a slower crack growth rate [References 7 and 8].

These welds are also very highly flaw tolerant, as demonstrated in MRP-1 09 and MRP-349.

As shown in these references, continued operation without repair can be demonstrated for substantial flaw sizes.

Because of the limited access available for these regions, complete inspection coverage is difficult to obtain, and mitigation is not practical in most cases.

If contouring becomes necessary, the areas identified by the inspection teams will have to be evaluated by design engineering to determine if such actions do not violate design minimum calculations for the system. Such actions are limited by design minimum wall calculations for the piping. If additional axial coverage were to be obtained, it would require weld build up of the DM weld, additional contouring and a Construction Code required RT examination. This additional contouring to improve axial coverage would be a hardship that would not result in an increase to health and safety of the public.

Industry operating experience has found no flaws in these regions, even though most of the plants of interest have been in service for over 25 years. A statistical treatment of this inspection data leads to a probability of cracking of these welds of between one and seven percent by the end of the 6 0 th year of operation.

No flaws have been found at Waterford Steam Electric Station Unit 3 in the 30" cold leg nozzle welds for which relief is requested and two of the four 12" cold leg nozzle welds (08-009 and 10-008) had acceptable recordable circumferential indications. The acceptable indication at 08-009 was measured to be a/t of 7.6% with an ASME Section XI Table IWB-3514-1 allowable a/t of 10.3%. The acceptable indication at 10-008 was measured to be a/t of 4.6% with an ASME Section XI Table IWB-3514-1 allowable a/t of 10.1%. Even if there

Attachment to W3F1`-2012-0085 Page 7 of 26 were to be flaws in the welds for which an alternative 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 Waterford Steam Electric Station Unit 3, have a leak detection capability of less than or equal to 0.1 gpm (Ref 10). All plants, including Waterford Steam Electric Station Unit 3, 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 (ref. 11), 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 rolling 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].

Attachment to W3F1-2012-0085 Page 8 of 26 These action levels have been incorporated into Waterford Steam Electric Station Unit 3 operating procedures. The enhanced leak detection capability provides an increased level of safety that if a flaw were to grow through wall, although unlikely, that it would be detected prior to it growing to a safety significant size.

Therefore, examination coverage meeting the MRP-1 39 volume, which includes a large percentage of the susceptible material for the safety significant circumferential flaw and a significant percentage of the susceptible material for the non-safety significant axial flaw, combined with the periodic system pressure tests, outage system walk downs and leakage monitoring, provides an acceptable level of quality and safety for identifying degradation from PWSCC prior to a safety significant flaw developing.

7. Duration of Proposed Alternative The duration of the proposed alternative for the welds with limited coverage is for the remainder of Waterford Steam Electric Station Unit 3's third ten-year ISI interval which began on June 1, 2012 and ends on July 1, 2017.

8. 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. ML120530680].

2. Calvert Cliffs Nuclear Power Plant, March 26, 2012 [ADAMS Accession No. ML120860541]

9. References

1. 10CFR50.55a

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. 1015009

5. Nondestructive Evaluation: Procedure for Manual Phased Array Ultrasonic Testing (UT) of Dissimilar Metal Welds (DMW), EPRI Palo Alto, CA: 2008. 1016645

6. Material Reliability Program, Alloy 82/182 Pipe Butt Weld Safety Assessment for US PWR Plant Designs (MRP-1 09): Westinghouse and CE Design Plants, EPRI, Palo Alto, CA: 2005. 1009804.

7. 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].

Attachment to W3F1-2012-0085 Page 9 of 26

8. Materials Reliability Program Crack Growth Rates for Evaluating Primary Water Stress Corrosion Cracking (PWSCC) of Alloy 82,182, and 132 Welds (MRP-115), EPRI, Palo Alto, CA, 2004,1006696 [ML051100204].

9. "Changing the Frequency of Inspections for PWSCC Susceptible Welds at Cold Leg Temperature," in Proceedings of PVP2011 ASME Pressure Vessels and Piping Conference (PVP2011-57829), July 17-21, 2011, Baltimore, Maryland, USA.

10. WCAP-1 6423-NP, Rev. 0, "Pressurized Water Reactor Owners Group Standard Process and Methods for Calculating RCS Leak Rate for Pressurized Water Reactors,"

Westinghouse Electric Co., September 2006.

11. 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.

Attachment to W3F1-2012-0085 Page 10 of 26 Table 1 Pressure retaining dissimilar metal piping welds containing Alloy 82/182 i.)

MRP-1 3*) Volume N-770-1 .

Item Category Coverage Volume Coverage Component Last PDI Axial Circ Axial Circ Angle(s) Fig Component

" 139 : N-770-. Scan

.for,.. .aTlScan

, or "Wave ID _.".Description Exam Date. MRP-: Scan forta Cir./aia for Scfan o" --Total  % Mode 19 for Circ A1 Axial c for Circ."

SFlaws Flaws 30" RCP 1A Inlet 07-002 Elbow(CS) to RF-16 E B 100% 80% 90% 33% 53% 43% 0-80 L 1 Safe-end (Cast 2009 25-75 S SS) I_ _ _ _ _ _ _ _ _ _ __ __ _ _ _ _ _ _ _ _

I__ _

No examination performed from safe end side of weld due to Cast SS material. Circ scan limitation due to MxamnualPA- S tation y the amount of coverage that could be credited in accordance with the qualified examination procedure. No Examination Summary Recordable Indications within examination volume.

30" RCP 1A 08-614 Outlet Safe-end RF-16 E B 100%- 78% 89% 32% 50% 41% 0-80 L 2 (Cast SS) to 2009 25-75 S Pipe(CS)

No examination performed from safe end side of weld due to Cast SS material. Circ scan limitation due to MxamnualPA- S tation y the amount of coverage that could be credited in accordance with the qualified examination procedure. No Examination Summary Recordable Indications within examination volume.

30" RCP 1B Inlet 09-016 Elbow(CS) to RF-16 E B 100% 83% 91.5% 31.5% 52.5% 42% 0-80 L 3 Safe-end (Cast 2009 25-75 S SS)

No examination performed from safe end side of weld due to Cast SS material. Circ scan limitation due to MxamnualPA- S tation y the amount of coverage that could be credited in accordance with the qualified examination procedure. No Examination Summary Recordable Indications within examination volume.

Attachment to W3F1 -2012-0085 Page 11 of 26 Table 1 Pressure retaining dissimilar metal piping welds containing Alloy 82/182

_.- .. .. 'Itm -MRP-139*"-V6!urne , N-770-1'*' . .

ItemCategory Coverage Volume Coverage circ circ Angle(s) Fig Component Component Last'PDI Axial Cc Axial Cc ane ID Description Exam Date MRP- N-770- Scan Total Scan for .for Total % Mode

-139 1 for Circ Axial  % for Circ Axial FlwsFlaws Flaws _ Flaws FJ~ws- .

30" RCP 1B 10-002 Outlet RF-16 E B 100% 81% 90.5% 33% 53% 43% 0-80L 4 Safe-end (Cast 2009 25-75 S SS) to Pipe (CS)

No examination performed from safe end side of weld due to Cast SS material. Circ scan limitation due to MxamnualPA- S tation y the amount of coverage that could be credited in accordance with the qualified examination procedure. No Examination Summary Recordable Indications within examination volume.

30" RCP 2A Inlet 11-002 Elbow (CS) to RF-16 E B 100% 80% 90% 32% 49% 40.5% 0-80 L 5 Safe-end (Cast 2009 25-75 S SS)

No examination performed from safe end side of weld due to Cast SS material. Circ scan limitation due to MxamnualPA-UTtation Sthe amount of coverage that could be credited in accordance with the qualified examination procedure. No Examination Summary Recordable Indications within examination volume.

30" RCP 2A 12-012 Outlet RF-16 E B 100% 76% 88% 32% 48% 40% 0-80L 6 Safe-end (Cast 2009 25-75 S SS) to Pipe (CS)

Manual PA-UT Limitations / No examination performed from safe end side of weld due to Cast SS material. Circ scan limitation due to the amount of coverage that could be credited in accordance with the qualified examination procedure No Examination Summary Recordable Indications within examination volume.

Attachment to W3F1-2012-0085 Page 12 of 26 Table 1 Pressure retaining dissimilar metal piping welds containing Alloy 82/182 MRP-139AW) Volume N-770-1.*'

ItemCateoryCoverage -Volume Coverage Circ Circ,7 Angle(s) .Fig Component Component 0 Last PDI Axial Scan Axial Scan Wave ID Description Exam Date MRP- N-770- Scan Total Scan for Total % Mode 139 .1 for Circ Axia for  % for Circ Axial-. .i Flaws Flaws 30" RCP 2B Inlet 13-016 Elbow (CS) to RF-16 E B 100% 79% 89.5% 34% 54% 44% 0-80 L 7 Safe-end (Cast 2009 25-75 S SS)

Manual PA-UT Limitations / No examination performed from safe end side of weld due to Cast SS material. Circ scan limitation due to the amount of coverage that could be credited in accordance with the qualified examination procedure. No Examination Summary Recordable Indications within examination volume.

30" RCP 2B 14-002 Outlet RF-16 E B 100% 80% 90% 32.5% 52% 42.25% 0-80L 8 Safe-end (Cast 2009 25-75 S SS) to Pipe (CS)

No examination performed from safe end side of weld due to Cast SS material. Circ scan limitation due to MxamnualPA- S tation y the amount of coverage that could be credited in accordance with the qualified examination procedure. No Examination Summa Recordable Indications within examination volume.

12" RCS 1A CL,08-009 SI Noz RF-16 E B 100% 83% 91.5% 35% 58% 46.5% 0-80 L 9 to Safe-end 2009 25-75 S (Cast SS)

Manual PA-UT Limitations /No examination performed from safe end side of weld due to Cast SS material. Circ scan limitation due to the amount of coverage that could be .credited in accordance with the qualified examination procedure. One Examination Summary Acceptable Recordable Indication within examination volume.

Attachment to W3F1-2012-0085 Page 13 of 26 Table 1 Pressure retaining dissimilar metal piping welds containing Alloy 82/182

-Item Categor MRP-139t') Volume N-770-12)..

tmag ___Coverage - Volume Coverage Circ. Circ Angle(s) _Fig Last PDI Axial Scan -Axial Scan / Wave Component Exam Date MRP- N-770- Scan Total Scan for for- TaMe%

'.Total Mode Description 'or 139 1 for Circ fr  % for Circ Flaws al Flaws Axial

• Flaws- Flaws __

12" RCS 1B CL, SI Noz RF-16 E B 100% 81.4% 90.7% 34% 55.5% 44.75% 0-80 L 10 to Safe-end 2009 25-75 S (Cast SS)

Manual PA-UT Limitations / No examinauon performed from safe end side o1 weia due [o Cast S marenal r. irc scan ii1loLuIn due LU the amount of coverage that could be credited in accordance with the qualified examination procedure. One Examination Summary Acceptable Recordable Indication within examination volume.

12" RCS 2A CL,12-009 SI Noz RF-16 E B 100% 80% 90% 34% 55% 44.5% 0-80L 11 to Safe-end 2009 25-75 S (Cast SS)

Manual PA-UT Limitations, No examination performed from safe end side of weld due to Cast SS material. Circ scan limitation due to Examination Summary the amount of coverage that could be credited in accordance with the qualified examination procedure. No Examination Summary__Recordable Indications within examination volume.

12" RCS 2B CL,14-006 SI Noz RF-16 E B 100% 82% 91% 36.5% 60% 48.25% 0-80 L 12 to Safe-end 2009 25-75 S (Cast SS)

No examination performed from safe end side of weld due to Cast SS material. Circ scan limitation due to MxamnualPA- S tation y the amount of coverage that could be credited in accordance with the qualified examination procedure. No Examination Summary Recordable Indications within examination volume.

Note 1 - For the MRP-139 axial and circumferential flaw examination volume coverage achieved, the calculation includes the carbon steel base material and susceptible material.

Note 2 - For the ASME Code Case N-770-1 axial and circumferential flaw examination volume coverage achieved, the calculation includes the volume identified in Figure 1 of the code case.

Attachment to W3F1 -2012-0085 Page 14 of 26 FC- WO_

bNST C C ' -cAA e .125I.-

3

. 0S/L 07 -002.

FctULA:(SUqNVoEu&SQ~jN.)13Z8sjy,.Xjo =7 CS VYIA/SL&MIST):/VE b~ CSAW LQ. EL-B 0\/

S SCALE I1 ASt1EX1VOLUM~E 3.58

'MARP-137 YoL u/1 .237SQ. w.

AIRP I39CtRcScAN VoLut.1Ll/1/TA TI ol M'IS& wA.

,SCAAI: /AX/1 L t2PSTZ:l66/',

\ýCR.STSSY VoLUME h.ZS.1& N.

CiRC cw:7 3 FI&u~r I 172~%EL WATEfKFogfi 3 7oTL A'AE7-(N-77o-I) CoVWKG.L 937%

.. . . . .. .. . . i q HI

Attachment to W3F1-2012-0085 Page 15 of 26 FLow l u PSI t_'NS F CA[1ST SST-SAFE EI~b 2)S~LE Cw L q5 fo1g1vLA: (ScR'WVoL OIlE SQ. IN.) /$2.OSQ. N.Xlt00:/

4XIALSCAAI(bN~ST)

?jYc~cnAIRc7):,.1.ME 1-0,q /,,(0-/0o):0 i.C,

'-IR Sc~dccW):

(I. tt.eo, ASAJEXTVcLUM*2E .&M SCAI: AXIAL DN5/$7: 6q MlRP-139 CRCS5CMVoLU1E L MI 4~N .I q0,5. V AXIAL UPST: 0/% C/iSTSST-VoLu/E I.0.SQ. I ciPIc cw 5o%

CIRC CCW: 50%+/-

230ilv. 9cP IA Ou7LET-T6JAL A& SE X[ (n-770-I) Cov0 tE RFI 7 WATFK~ogtb 3

Attachment to W3F1 -2012-0085 Page 16 of 26 A-L 0w WN.T UPST Cw 3 0511L cc w cI*IR SCA1 CR&T.SSr ELBOW Fo9M":(5CAgVLtig9M1 0/.i3 ; SO, LAIX14 2/ ýS AFENb AYjAL sculM1 nFT)oLuMv AXIAL aAN (D&YsI: MoA~Lb~

CIKC 5cAA' (c w) :1I5sag.I rIKCSCAAI(CCWI): I-7SSQjg. (3.33-.30.22)= 525% 1-(1.22 f:2.")

AS/1E0-" VoL uME 3.33ý SO. IN. SCALE- ,.o SCANV AMIR UPST = 63 '1 ,M8p- 13ý VrLUME 11S&-IN.

AXIAL MvST = 0V/0 M~- j1837cIpc ScA?'1VoLVME LIM17-AT-ION 36 SQ. W,~.

CI RC CWv:=5ý25% , -CPST5SFT VO~LUME i.-22 sQ.iN.

CIRc CCw=5,2,s7,i- FIGURE 3 166 Z0

• 30iV. RC P 18 INLET T()T4ALSI~1E(N6-77?& 1)CCV[9hGL qI2%~ WA19FOWb

Attachment to W3F1-2012-0085 Page 17 of 26 CLOW UPS-Cw 5/L Cc. w CPS T S,5 T 5,-/rEZE~tb ScAN: Ax'rnL LAIST = 6z AX/AL LiPST = 0 % SCALE l&

CjgC c C t 53,%

ClKC ccVV -537ý+/-

1712 7, 7- q (1.0t 1.9q) roAAMZýjNCVI~ q-37, SVOLUME .9qQN

'CfOFSNOdIJPE 1.o0jji27 kORPIULRQ (SAN VoLu1r-SQ.lNI.9S.AI.)~~XIcDo -PIRP-/39 c1~cScIN VawELuimr7-A7oQ *379Q* IN AXiAL5CAN( tS)V6 LIE -. =66 T

-1MZ~.o) -f18P-I3~VLunF1E l9Lsc5 I.W LfUR AXIAL SMAA(UP5TFYNNcaV~bv& T0CPFA9ATjfiL:  ?)0 IN.Rc-p IF)ourzE-p CI&5Wn (C1.0 37): 53%'~

WRqTE K OR D -3 El ýC SCAN (CCW).'I- S75o.IN. ().ýq- 1.0 -.17): S3%

Attachment to W3FI-2012-0085 Page 18 of 26

,,, Low cvv c1psrssr SRF~E Sb SCRA/: AX&7L UPST 6 ',V, AXIAL bNST 0 tl ASAE2YoLF~i 3.98. sai c)Ac cv c vv C~g(viqc%.

SCALE .

~MRP-139 VOLUMYE 2.'1S5Q IN'.

J'1KP-3?C/BCScd1AVVL4E hhJATMcvt. ;S3QSc

IN Fangfl(cn~i~, Amns~.w. x I w

%

~Yi~/ % /IAJ((J ~'f)VoLuA1E; 2 '1~so.~. ~-i~)4~/Y 0 -C/?ST'SST VOL qlýE/~.q3 So. pII.

~X~~AY A6T;M bbJoC s7/4I-:0 FrGuKEU 5 30W. R~CP ýA INLLET nI kc,ý?cAIcw): 19s.g3-5-~3 f /

WATE gFor-L 3

Attachment to W3F1 -2012-0085 Page 19 of 26 FLOW\/

u PSr 3 0S/L CAST* ST SAFE END Cs FoMVLL: (sCAr VoLvmM SQ. IN.) 1;2. 73 SXQýIN. XLmT %

PIPE A>xiAL ScA'i (DHST)VoLumF-: 17s~x(-3-q s-4N (UPST)NoNE DuE 'mrCr,5ATMMML0A L_=%

/X,4L ICirc 5cA K (CW): .32 50. m(2-73-.77-.12) : B7, ICI.c SCAN (ccw): I.32 S.M.(2.73 -.77-.'1.) !3r,

_ ___ _____SCALE .

' R131 VOLUvME I.7q SaW. .-

ScPIv: AXIAL jVSr: 6q% MTP-t3lgcScoT VOLUMEI11iT.4Tw N. Y/S. //V J

SKIL* UPST 01 -CAST 5SF VOL UMvE .ThOIN.1v Cigc CAM LI*7'.

CIRc cvw: q67%+ &i~r TO TA% -.-q 3cm'A. gCP 2A C3UT-LE7-WPTErFf-lo/Z 3

Attachment to W3F1 -2012-0085 Page 20 of 26 4LO UP.ST 55LCw ST SCAN:

AXIAL (JP5T=b' I.9 AXIAL bNST= c%,

cIj(CVcv = // A5q610 6l c c~w=/ 0 t VOLUAIE 3.BS5QIN. S~CALE .

176 %6,q _____(,3 t-2.4Z)

WTL ASA4FTN -776-1)COVWR6E , Io/ CA SiSST VOLU)Mg 1.2 sQ, M R~P-13?CiCSck1/ V(LOME L viATh6Wa .5S5 s(ý. w.

,Og/IULA: (SCA14VOLLM.ESQ.IN.') 3.85s&. i' X16: M AIP-)3q VOLuMUF Q.6 2'5 i,M AXlA L~cAN (UP5sr) VOLuMjE: 2.6&~~6%

2-,;6 JAI GUu -7 yjALS&A(NNST): NONE bu-T-oCASY4TMMAL: 07 ýO RCP23 /INLrE

)C& ACSAfLC-W)::2-0750A. (3.05-. S5-1-23) = ,W/TEK FoKD3 LIKC bos.g

'zcN(C

ýI2) ) .-. 5LV

Attachment to W3F1-2012-0085 Page 21 of 26 FL- 0 vi L UPST bNST cw ccw I pj I L0 S/L CA ST SS T sAFE E/t'

ýFoMULA LScANoL!AMESQI /3.qs%.. X100: /

AXIA1,SArj(D,3T) V6LUME x2 .ISQ11v(3.2y-1t,3) 657t AXALScAN(CUPST):ANON& bvE-ToCASTrA14XtgIL= 0%/

DCkSCAA1((CW): 3 ~I.(. -q-. 3 =.52%c (1-13 1-2z.!

ASMEXEVOLU/'4 3. 2 5sQ SCA~LE 10 L NtAff-I3S VOLUME 2.ils&,.1N 5CAA: AXIAL bNS-=rS% AIRMP-1,39UCI Sc'AAI VOLUME LlIMITATIOý,Iv.'?' 2 jI AXIAL UPST: 0% _ CIISTSS5TVOL UM4E .15IN cIc cw :527%

ciSc Ccw:S22%+ Fl&UýE B 3019 RCP 28 OUTLET TOTAL AS'E _(N-770-1)COW-tA6E 92,57 WA TE FoRb 3

Attachment to W3F1 -2012-0085 Page 22 of 26 FL ow 1.0 Rrt'S )A C.L.. 12WM rAFET IN7TrFhTIONV WATERFoRtb 3 ScALE .

-- JL/ASA1MIXIL VOLUMAE I.08s5Q.JN.

Mg~P- I39VOLUJIE .76 SQAN.

ff~-13JCJýC SxCMt VOWu/f I MITA770A' -3 Sri*;

____C PST SST VoLUPIE .32 so I.

EIOhIVLP:(Sca4VoLUpiES~i. N.') /toeiso.u.ivXloo:1"

_1XIALSC 1 P1(RN(ST) VOL wE; .7A So. ThNflB -.32)- 7p7, AXIA L M~ST 700/a AWL 9cANUfST).N6NEi DUETo CfSTMW uOZQý P XIPL UPST 0 CIRC c-cw SB0 /I-T(Lo- .ISAIXL (N-770-1) C~oVERh6E %! S "OX FIGURE 9

Attachment to W3F1-2012-0085 Page 23 of 26 ,-L ow ,

1.0

~CSFC.L. )J2)AW SýFEJ7Y )MECTgIC.A/_

WATEý Fo09 3 SC/ALE '~

C.w Ccov

{HC iRC.

CAlST .S57 (-3 /Volz 0 SAFEF E7Ntb AS/'WXT VOLUME 1.26 sQ. N tP-MR j3Cý VoLLUAE - ýo-N

-MA1P- jBc9CIRC SCiN VoLIUME LIM'A1ir/r,J&c.j,,

1

- CJST SST VoL uMF .YOSQG. yJ FoRIULPflISCflb4\]LUIE SO.W) /14I. .650, . X~O10 =7 9XIRL SCl~p1(bPST) VoLuME: .%c,aY~U6-qO)=6 ANIAL L)PS'T% 0O/,

CIR,C cvv 5.7 V'A LScPh'I(u PSr)NaL buvT6CASýT/ATEU/L': O~

PpIE~L(p770.1) CoVE gR6E T&M L7501 F)GURE 10

Attachment to W3F1-2012-0085 Page 24 of 26 F L o Rcs 2AC.L.. 121t. SflFET-Y INJEC-TION wATUFOt 3 ScALE .0 AZ ccv c- sFs sST 5AFE. EMb MHP-139~V6LuIm .67sQ wN.

~MR P-l3'1 CIRC SC/RA V'oLUAE LItPTATIAI. l3-sv~.m CR1 S~TSSTVbLu/iEI .31SO. /Y FoRAlLR,:CScAN YbLuXE 1;a Iti.) /7? qSO IA] fy)n: 9 AXJAL SCAN' (MNTJVr)LurE: 4lsAmnN. (381-.N)z 68%

A RRW (0PST): 1WE DU To CRST MMfpTRI,JL

?IAX ScPNq: AXIfL DN~ST 687 PXIPL UPST :0%

c5cf~N(ccw :.~H&Q.IM %~2,l- (3): 524 CIRC cw 5S Cl~c C  : 'S57" +

17X6 H' To TAL/4EXIN1'77O~ICOVERfl6 Wj1j.5%

FIGURE 1I

Attachment to W3F1-2012-0085 Page 25 of 26L IBCS 2 8 C.L., I LN. SFE§T IAlJE-C77 0/

WATE-fFop- 3 SCIC 7-ASb1EýZEOLU1'1 1.o~S_-Oqj P4&,[9YoLu1ME .79sQ.ia)

!IKP-139cRCIACcftd VOL LAI FL tirA,T1L/VIS& w~~aiv CPS VSSTOLUM~E ..V75Q. IAI I~AUL,: /Io~

(cANVv~A1~SQ.ia.

c~.IN.XiO:%SCP A/: AWIL bNSTF 737c jqAWVbA4T VbLuIVE: 7 ci. 73AXIA~L UPST- 01fc, bL WAPST:NogLIbVr7OC kTERLM CIRc CW 60c

!( v)1 CicS/ (. 2TI)60/ Cfl~c CCw =67 QAC spv CNCcw): .65SQ. w.(I.oo-.27-.'q) ~60o.% -16~ :q T-07AL ROEl JE(N- 770-1)coVERP&E '/9.25'1' FIGUgE IQ-

Attachment to W3F1 -2012-0085 Page 26 of 26 CLO0W

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I UN3L UPST CS PIPE CAI5 T S,5r7 5/WE4NVt SCALE t.0 C L AD FIGUKE IS TYP)CPl-' CLAD ILLUSTýPTI1OH,%

WATEKFORD 3