2CAN011603, Arkansas, Unit 2 - Requests for Relief from American Society of Mechanical Engineers (ASME) Section XI Volumetric Examination Requirements - Fourth 10-Year Interval, First Period

Arkansas, Unit 2 - Requests for Relief from American Society of Mechanical Engineers (ASME)Section XI Volumetric Examination Requirements - Fourth 10-Year Interval, First Period

ML16015A276
Person / Time
Site:	Arkansas Nuclear
Issue date:	01/14/2016
From:	Pyle S Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2CAN011603
Download: ML16015A276 (19)

Text

2CAN011603 January 14, 2016 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 Examination Requirements -

Fourth 10-Year Interval, First Period 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 ASME, Boiler and Pressure Vessel Code,Section XI pertaining to volumetric 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.

10 CFR 50.55a(g)(5)(iv) requires that the basis for the determination of impracticality be submitted to the NRC for review and approval within 12 months after the expiration of the 120-month inspection interval. These reliefs are for the fourth ANO-2 10-year Inservice Inspection interval, first period. The interval and first period started on March 26, 2010. The first period ended March 25, 2013.

There are no new regulatory commitments made in this submittal.

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4704 Stephenie L. Pyle Manager, Regulatory Assurance Arkansas Nuclear One

2CAN011603 Page 2 of 2 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-018

2.

Request for Relief - ANO2-ISI-019 cc:

Mr. Marc L. Dapas 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: Ms. Andrea E. George MS O-8B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852

to 2CAN011603 Request for Relief ANO2-ISI-018 to 2CAN011603 Page 1 of 9 REQUEST FOR RELIEF ANO2-ISI-018 Components / Numbers:

Pressurizer Nozzle Welds 010,05-011, 05-012, and 05-013 Code Classes:

American Society of Mechanical Engineers (ASME) Code Class 1

References:

ASME Section XI 2001 Edition with 2003 Addenda, Table IWB-2500-1 ASME Code Case N-460 Examination Category:

B-D Item Number(s)

B3.110

==

Description:==

Full Penetration Welded Nozzles in Vessels - Inspection Program B Unit / Inspection Interval Applicability:

Arkansas Nuclear One, Unit 2 (ANO-2) / Fourth (4th) 10-Year Interval, First (1st) Inspection Period I.

CODE REQUIREMENTS ASME Section XI, Table IWB-2500-1, Examination Category B-D, Full Penetration Welded Nozzles in Vessels - Inspection Program B:

Item B3.110 requires a volumetric examination of Pressurizer Nozzle-to-Vessel Weld volume, as depicted in Figures IWB-2500-7(a) through (d), as applicable.

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.

III.

BASIS FOR RELIEF During ultrasonic examination of the non-Appendix VIII non-mitigated Pressurizer-to-Vessel welds listed in Table 1, greater than 90% coverage of the required examination volume, as required by Code Case N-460, could not be obtained due to component configuration.

Examinations were performed utilizing 0, 45 and 60 beam angles in the axial and circumferential directions in accordance with Entergy approved procedures specific to ferritic vessels greater than 2 inches in thickness. See Table 1 for additional information.

to 2CAN011603 Page 2 of 9 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 2CAN011603 Page 3 of 9 Table 1 Limited B-D Examinations Component Description Additional Information Item Number Comp.

ID Item Description Estimated %

Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Exam Exam Results B3.110 05-010 Pressurizer (PZR) Spray Nozzle-to-Head Circumferential Weld 65 This is a dual sided exam.

Examination of the required volume as depicted in Fig. IWB-2500-7(a) was limited due to the component configuration. Both the nozzle and head are carbon steel with stainless steel cladding on the inside surface.

See the attached sketch (Figure 1) derived from ultrasonic testing (UT) examination report 2-ISI-UT 016 on file at ANO.

Manual UT Scan path limitation due to the configuration of the component.

(See Figures 1 &

5).

Wave modalities are longitudinal and shear.

Insonification angles included 0°, 45°, and 60°.

None required No indications were observed or recorded.

Acceptable B3.110 05-011 PZR Safety Valve Nozzle-to-Head Circumferential Weld 82 This is a dual sided exam.

Examination of the required volume as depicted in Fig. IWB-2500-7(b) was limited due to the component configuration. Both the nozzle and head are carbon steel with stainless steel cladding on the inside surface.

See the attached sketch (Figure 2) derived from UT examination report 2-ISI-UT-12-017 on file at ANO.

Manual UT Scan path limitation due to the configuration of the component.

(See Figures 2 &

5).

Wave modalities are longitudinal and shear.

Insonification angles included 0°, 45°, and 60°.

None required Intermittent geometric indications of the nozzle bore were observed and recorded.

Acceptable B3.110 05-012 PZR Safety Nozzle-to-Head Circumferential Weld 77 This is a dual sided exam.

Examination of the required volume as depicted in Fig. IWB-2500-7(b) was limited due to the component configuration. Both the nozzle and head are carbon steel with stainless steel cladding on the inside surface.

See the attached sketch (Figure 3) derived from UT examination report 2-ISI-UT-12-018 on file at ANO.

Manual UT Scan path limitation due to the configuration of the component.

(See Figures 3 &

5).

Wave modalities are longitudinal and shear.

Insonification angles included 0°, 45°, and 60°.

None required Intermittent geometric indications of the nozzle bore were observed and recorded.

Acceptable to 2CAN011603 Page 4 of 9 Table 1 (cont)

Limited B-D Examinations Component Description Additional Information Item Number Comp.

ID Item Description Estimated %

Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Exam Exam Results B3.110 05-013 PZR Safety Nozzle-to-Head Circumferential Weld 82 This is a dual sided exam.

Examination of the required volume as depicted in Fig. IWB-2500-7(b) was limited due to the component configuration. Both the nozzle and head are carbon steel with stainless steel cladding on the inside surface.

See the attached sketch (Figure 4) derived from UT examination report 2-ISI-UT-12-019 on file at ANO.

Manual UT Scan path limitation due to the configuration of the component.

(See Figures 4 &

5).

Wave modalities are longitudinal and shear.

Insonification angles included 0°, 45°, and 60°.

None required Intermittent geometric indications of the nozzle bore were observed and recorded.

Acceptable to 2CAN011603 Page 5 of 9 Figure 1 Scan Plan and Coverage for Component 05-010 Not to Scale 60° & 0° Axial 45° Axial 45°, 60°,

0° Axial 45° & 60° 0° Axial /

Circ TOP HEAD CL 45° & 60° Axial SPRAY NOZZLE NO SCAN COVERAGE 50% SCAN COVERAGE 100% SCAN COVERAGE Diameter - 4 Thickness - 4.1 Circ Scan Coverage in Weld - 50%

Axial Scan Coverage -

45° Base Metal = 82.2%

60° Base Metal = 94.4%

45° Metal = 48.25%

60° Metal = 49.9%

Total - 50% Circ + 82.2% + 48.25% + 94.4% + 49.9% = 324.75/5 = 64.95% or 65%

to 2CAN011603 Page 6 of 9 Figure 2 Scan Plan and Coverage for Component 05-011 Not to Scale 0°,45°,60° Axial CL 0°,45°,60° Circ 45° Axial 60° Axial SAFETY NOZZLE TOP HEAD NO SCAN COVERAGE 50% SCAN COVERAGE 100% SCAN COVERAGE Diameter - 6 Thickness - 4.1 Circ Scan Coverage in Weld - 100%

Axial Scan Coverage -

45° Base Metal = 95%

60° Base Metal = 94%

45° Metal = 70%

60° Metal = 61%

Total - 100% Circ + 95% + 70% + 94% + 61% = 420/5 = 84% x 0.971 = 82%

0.971 factor for limitation due to adjacent nozzle(s) to 2CAN011603 Page 7 of 9 Figure 3 Scan Plan and Coverage for Component 05-012 Not to Scale 0°,45°,60° Axial CL 0°,45°,60° Circ 45° Axial 60° Axial SAFETY NOZZLE TOP HEAD NO SCAN COVERAGE 50% SCAN COVERAGE 100% SCAN COVERAGE Diameter - 6 Thickness - 4.1 Circ Scan Coverage in Weld - 100%

Axial Scan Coverage -

45° Base Metal = 95%

60° Base Metal = 94%

45° Metal = 70%

60° Metal = 61%

Total - 100% Circ + 95% + 70% + 94% + 61% = 420/5 = 84% x 0.92 = 77%

0.92 factor for limitation due to adjacent nozzle(s) to 2CAN011603 Page 8 of 9 Figure 4 Scan Plan and Coverage for Component 05-013 Not to Scale 0°,45°,60° Axial CL 0°,45°,60° Circ 45° Axial 60° Axial SAFETY NOZZLE TOP HEAD NO SCAN COVERAGE 50% SCAN COVERAGE 100% SCAN COVERAGE Diameter - 6 Thickness - 4.1 Circ Scan Coverage in Weld - 100%

Axial Scan Coverage -

45° Base Metal = 95%

60° Base Metal = 94%

45° Metal = 70%

60° Metal = 61%

Total - 100% Circ + 95% + 70% + 94% + 61% = 420/5 = 84% x 0.979 = 82%

0.979 factor for limitation due to adjacent nozzle(s) to 2CAN011603 Page 9 of 9 Figure 5 Sketch for Pressurizer Top Head Not to Scale 18.36

.10 18.28 19.21

.44 SAFETY VALVE NOZZLE B

SAFETY VALVE NOZZLE B VENT NOZZLE SPRAY NOZZLE 22°30 TYP 11.44 90° 270° SEE DETAIL E (G-1)

SAFETY VALVE NOZZLE C UPENDING LUG 34.50 34.50 A

A (B-7) 45° SEE DETAIL E (G-1)

UPENDING LUG B

UPPER LEVEL NOZZLE PRESSURE TAP NOZZLE TOP HEAD SCALE 1.5=12 180° MANWAY 15° 15° UPPER LEVEL NOZZLE PRESSURE TAP NOZZLE B

(D-4) 45° 2X UPENDING LUGS 15° 5.50 (63.44)

(.22) CLAD MANWAY SPRAY NOZZLE SEE DETAIL C (B-3)

TANGENT LINE 49.19 (2) STOCK 40° SECTION A-A (E-6)

SCALE 1.5=12 SR 48.44 +.06

-.00 BASE METAL 3.875 +.125

-.000

to 2CAN011603 Request for Relief ANO2-ISI-019 to 2CAN011603 Page 1 of 6 REQUEST FOR RELIEF ANO2-ISI-019 Components /

Numbers:

See Table 1 Code Classes:

American Society of Mechanical Engineers (ASME) Code Class 2

References:

ASME Section XI 2001 Edition with 2003 Addenda, Table IWC-2500-1 ASME Code Case N-460 Examination Category: C-A Item Number(s)

C1.10 and C1.30

==

Description:==

Pressure Retaining Welds in Pressure Vessels - Inspection Program B Unit / Inspection Interval Applicability:

Arkansas Nuclear One, Unit 2 (ANO-2) / Fourth (4th) 10-Year Interval, First (1st) Inspection Period 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.

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.

III.

BASIS FOR RELIEF During ultrasonic examination of the non-Appendix VIII non-mitigated Shutdown Cooling Heat Exchanger Flange to Channel Cylinder and Channel Cylinder-to-Tubesheet Welds listed in Table 1, greater than 90% coverage of the required examination volume, as required by Code Case N-460, could not be obtained.

to 2CAN011603 Page 2 of 6 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 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, therefore 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, 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 2CAN011603 Page 3 of 6 Table 1 Limited C-A Examinations Component Description Additional Information Item Number Comp.

ID Item Description Estimated %

Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Exam Exam Results C1.10 49-001 Shutdown Cooling Heat Exchanger Flange to Channel Cylinder Circumferential Weld 76 This was a dual-sided examination although scanning was limited due to the configuration and close proximity of the channel head flange and fasteners.

Additionally, scan paths from the shell side were limited due to the inlet and outlet piping configurations attached to the shell. See Figure 3 for sketch.

See the attached sketch (Figure 1) derived from ultrasonic testing (UT) examination report 2-ISI-UT 030 on file at ANO.

Manual UT A detailed sketch (Figure 3) of the limitation is included.

Wave modality used included shear.

Insonification angles included 45° shear (S) and 70°S.

Surface exam was not required One indication identified as a plate segregate located outside the code examination volume ~50° from the shell inside diameter was recorded.

Evaluated as acceptable by the Entergy Level III.

C1.30 49-002 Shutdown Cooling Heat Exchanger Channel Cylinder to Tube Sheet Circumferential Weld 82 This was a dual-sided examination although scanning was limited due to the configuration and close proximity of the channel head flange. Additionally, scan paths from the shell side were limited due to the inlet and outlet piping configurations attached to the shell. See Figure 3 for sketch.

See the attached sketch (Figure 2) derived from UT examination report 2-ISI-UT-12-031 on file at ANO.

Manual UT A detailed sketch (Figure 3) of the limitation is included.

Wave modality used included shear.

Insonification angles included 45°S and 70°S.

Surface exam was not required Acceptable plate segregation and clad interface indications identified during the 2nd ISI interval examination were confirmed. No new indications recorded.

to 2CAN011603 Page 4 of 6 Figure 1 Scan Plan and Coverage for Component 49-001 Not to Scale Diameter - 46 Thickness - 1.5 Circ Scan Coverage - CW 88% + CCW 88% = 176/2 = 88%

Axial Scan Coverage - (45° = 67%) + (70° = 62%) = 129/2 = 64.5%

Total - 88% Circ + 64.5% Axial = 152.5/2 = 76.25% or 76%

45° Axial

& Circ CL 45° Axial 45° Circ 45° Axial

& Circ 45° Axial

& Circ, 70° Axial FLANGE SHELL FLOW TWO ANGLE COVERAGE SINGLE ANGLE COVERAGE NO SCAN COVERAGE to 2CAN011603 Page 5 of 6 Figure 2 Scan Plan and Coverage for Component 49-002 Not to Scale TWO ANGLE COVERAGE SINGLE ANGLE COVERAGE NO SCAN COVERAGE Diameter - 46 Thickness - 1.5 Circ Scan Coverage - CW 100% + CCW 100% = 200/2 = 100%

Axial Scan Coverage - (45° = 67%) + (70° = 59%) = 126/2 = 63%

Total - 100% Circ + 63% Axial = 163/2 = 81.5% or 82%

45° Axial

& Circ CL 45° Axial 45° Circ 45° Axial

& Circ 45° Axial

& Circ, 70° Axial FLANGE SHELL FLOW 45° Axial to 2CAN011603 Page 6 of 6 Figure 3 Sketch for Component 49-001 & 49-002 Not to Scale 049-006 049-007 049-003 049-002 049-005 A

A 049-001 049-004 049-008 049-009

2CAN011603 January 14, 2016 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 Examination Requirements -

Fourth 10-Year Interval, First Period 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 ASME, Boiler and Pressure Vessel Code,Section XI pertaining to volumetric 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.

10 CFR 50.55a(g)(5)(iv) requires that the basis for the determination of impracticality be submitted to the NRC for review and approval within 12 months after the expiration of the 120-month inspection interval. These reliefs are for the fourth ANO-2 10-year Inservice Inspection interval, first period. The interval and first period started on March 26, 2010. The first period ended March 25, 2013.

There are no new regulatory commitments made in this submittal.

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4704 Stephenie L. Pyle Manager, Regulatory Assurance Arkansas Nuclear One

2CAN011603 Page 2 of 2 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-018

2.

Request for Relief - ANO2-ISI-019 cc:

Mr. Marc L. Dapas 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: Ms. Andrea E. George MS O-8B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852

to 2CAN011603 Request for Relief ANO2-ISI-018 to 2CAN011603 Page 1 of 9 REQUEST FOR RELIEF ANO2-ISI-018 Components / Numbers:

Pressurizer Nozzle Welds 010,05-011, 05-012, and 05-013 Code Classes:

American Society of Mechanical Engineers (ASME) Code Class 1

References:

ASME Section XI 2001 Edition with 2003 Addenda, Table IWB-2500-1 ASME Code Case N-460 Examination Category:

B-D Item Number(s)

B3.110

==

Description:==

Full Penetration Welded Nozzles in Vessels - Inspection Program B Unit / Inspection Interval Applicability:

Arkansas Nuclear One, Unit 2 (ANO-2) / Fourth (4th) 10-Year Interval, First (1st) Inspection Period I.

CODE REQUIREMENTS ASME Section XI, Table IWB-2500-1, Examination Category B-D, Full Penetration Welded Nozzles in Vessels - Inspection Program B:

Item B3.110 requires a volumetric examination of Pressurizer Nozzle-to-Vessel Weld volume, as depicted in Figures IWB-2500-7(a) through (d), as applicable.

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.

III.

BASIS FOR RELIEF During ultrasonic examination of the non-Appendix VIII non-mitigated Pressurizer-to-Vessel welds listed in Table 1, greater than 90% coverage of the required examination volume, as required by Code Case N-460, could not be obtained due to component configuration.

Examinations were performed utilizing 0, 45 and 60 beam angles in the axial and circumferential directions in accordance with Entergy approved procedures specific to ferritic vessels greater than 2 inches in thickness. See Table 1 for additional information.

to 2CAN011603 Page 2 of 9 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 2CAN011603 Page 3 of 9 Table 1 Limited B-D Examinations Component Description Additional Information Item Number Comp.

ID Item Description Estimated %

Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Exam Exam Results B3.110 05-010 Pressurizer (PZR) Spray Nozzle-to-Head Circumferential Weld 65 This is a dual sided exam.

Examination of the required volume as depicted in Fig. IWB-2500-7(a) was limited due to the component configuration. Both the nozzle and head are carbon steel with stainless steel cladding on the inside surface.

See the attached sketch (Figure 1) derived from ultrasonic testing (UT) examination report 2-ISI-UT 016 on file at ANO.

Manual UT Scan path limitation due to the configuration of the component.

(See Figures 1 &

5).

Wave modalities are longitudinal and shear.

Insonification angles included 0°, 45°, and 60°.

None required No indications were observed or recorded.

Acceptable B3.110 05-011 PZR Safety Valve Nozzle-to-Head Circumferential Weld 82 This is a dual sided exam.

Examination of the required volume as depicted in Fig. IWB-2500-7(b) was limited due to the component configuration. Both the nozzle and head are carbon steel with stainless steel cladding on the inside surface.

See the attached sketch (Figure 2) derived from UT examination report 2-ISI-UT-12-017 on file at ANO.

Manual UT Scan path limitation due to the configuration of the component.

(See Figures 2 &

5).

Wave modalities are longitudinal and shear.

Insonification angles included 0°, 45°, and 60°.

None required Intermittent geometric indications of the nozzle bore were observed and recorded.

Acceptable B3.110 05-012 PZR Safety Nozzle-to-Head Circumferential Weld 77 This is a dual sided exam.

Examination of the required volume as depicted in Fig. IWB-2500-7(b) was limited due to the component configuration. Both the nozzle and head are carbon steel with stainless steel cladding on the inside surface.

See the attached sketch (Figure 3) derived from UT examination report 2-ISI-UT-12-018 on file at ANO.

Manual UT Scan path limitation due to the configuration of the component.

(See Figures 3 &

5).

Wave modalities are longitudinal and shear.

Insonification angles included 0°, 45°, and 60°.

None required Intermittent geometric indications of the nozzle bore were observed and recorded.

Acceptable to 2CAN011603 Page 4 of 9 Table 1 (cont)

Limited B-D Examinations Component Description Additional Information Item Number Comp.

ID Item Description Estimated %

Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Exam Exam Results B3.110 05-013 PZR Safety Nozzle-to-Head Circumferential Weld 82 This is a dual sided exam.

Examination of the required volume as depicted in Fig. IWB-2500-7(b) was limited due to the component configuration. Both the nozzle and head are carbon steel with stainless steel cladding on the inside surface.

See the attached sketch (Figure 4) derived from UT examination report 2-ISI-UT-12-019 on file at ANO.

Manual UT Scan path limitation due to the configuration of the component.

(See Figures 4 &

5).

Wave modalities are longitudinal and shear.

Insonification angles included 0°, 45°, and 60°.

None required Intermittent geometric indications of the nozzle bore were observed and recorded.

Acceptable to 2CAN011603 Page 5 of 9 Figure 1 Scan Plan and Coverage for Component 05-010 Not to Scale 60° & 0° Axial 45° Axial 45°, 60°,

0° Axial 45° & 60° 0° Axial /

Circ TOP HEAD CL 45° & 60° Axial SPRAY NOZZLE NO SCAN COVERAGE 50% SCAN COVERAGE 100% SCAN COVERAGE Diameter - 4 Thickness - 4.1 Circ Scan Coverage in Weld - 50%

Axial Scan Coverage -

45° Base Metal = 82.2%

60° Base Metal = 94.4%

45° Metal = 48.25%

60° Metal = 49.9%

Total - 50% Circ + 82.2% + 48.25% + 94.4% + 49.9% = 324.75/5 = 64.95% or 65%

to 2CAN011603 Page 6 of 9 Figure 2 Scan Plan and Coverage for Component 05-011 Not to Scale 0°,45°,60° Axial CL 0°,45°,60° Circ 45° Axial 60° Axial SAFETY NOZZLE TOP HEAD NO SCAN COVERAGE 50% SCAN COVERAGE 100% SCAN COVERAGE Diameter - 6 Thickness - 4.1 Circ Scan Coverage in Weld - 100%

Axial Scan Coverage -

45° Base Metal = 95%

60° Base Metal = 94%

45° Metal = 70%

60° Metal = 61%

Total - 100% Circ + 95% + 70% + 94% + 61% = 420/5 = 84% x 0.971 = 82%

0.971 factor for limitation due to adjacent nozzle(s) to 2CAN011603 Page 7 of 9 Figure 3 Scan Plan and Coverage for Component 05-012 Not to Scale 0°,45°,60° Axial CL 0°,45°,60° Circ 45° Axial 60° Axial SAFETY NOZZLE TOP HEAD NO SCAN COVERAGE 50% SCAN COVERAGE 100% SCAN COVERAGE Diameter - 6 Thickness - 4.1 Circ Scan Coverage in Weld - 100%

Axial Scan Coverage -

45° Base Metal = 95%

60° Base Metal = 94%

45° Metal = 70%

60° Metal = 61%

Total - 100% Circ + 95% + 70% + 94% + 61% = 420/5 = 84% x 0.92 = 77%

0.92 factor for limitation due to adjacent nozzle(s) to 2CAN011603 Page 8 of 9 Figure 4 Scan Plan and Coverage for Component 05-013 Not to Scale 0°,45°,60° Axial CL 0°,45°,60° Circ 45° Axial 60° Axial SAFETY NOZZLE TOP HEAD NO SCAN COVERAGE 50% SCAN COVERAGE 100% SCAN COVERAGE Diameter - 6 Thickness - 4.1 Circ Scan Coverage in Weld - 100%

Axial Scan Coverage -

45° Base Metal = 95%

60° Base Metal = 94%

45° Metal = 70%

60° Metal = 61%

Total - 100% Circ + 95% + 70% + 94% + 61% = 420/5 = 84% x 0.979 = 82%

0.979 factor for limitation due to adjacent nozzle(s) to 2CAN011603 Page 9 of 9 Figure 5 Sketch for Pressurizer Top Head Not to Scale 18.36

.10 18.28 19.21

.44 SAFETY VALVE NOZZLE B

SAFETY VALVE NOZZLE B VENT NOZZLE SPRAY NOZZLE 22°30 TYP 11.44 90° 270° SEE DETAIL E (G-1)

SAFETY VALVE NOZZLE C UPENDING LUG 34.50 34.50 A

A (B-7) 45° SEE DETAIL E (G-1)

UPENDING LUG B

UPPER LEVEL NOZZLE PRESSURE TAP NOZZLE TOP HEAD SCALE 1.5=12 180° MANWAY 15° 15° UPPER LEVEL NOZZLE PRESSURE TAP NOZZLE B

(D-4) 45° 2X UPENDING LUGS 15° 5.50 (63.44)

(.22) CLAD MANWAY SPRAY NOZZLE SEE DETAIL C (B-3)

TANGENT LINE 49.19 (2) STOCK 40° SECTION A-A (E-6)

SCALE 1.5=12 SR 48.44 +.06

-.00 BASE METAL 3.875 +.125

-.000

to 2CAN011603 Request for Relief ANO2-ISI-019 to 2CAN011603 Page 1 of 6 REQUEST FOR RELIEF ANO2-ISI-019 Components /

Numbers:

See Table 1 Code Classes:

American Society of Mechanical Engineers (ASME) Code Class 2

References:

ASME Section XI 2001 Edition with 2003 Addenda, Table IWC-2500-1 ASME Code Case N-460 Examination Category: C-A Item Number(s)

C1.10 and C1.30

==

Description:==

Pressure Retaining Welds in Pressure Vessels - Inspection Program B Unit / Inspection Interval Applicability:

Arkansas Nuclear One, Unit 2 (ANO-2) / Fourth (4th) 10-Year Interval, First (1st) Inspection Period 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.

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.

III.

BASIS FOR RELIEF During ultrasonic examination of the non-Appendix VIII non-mitigated Shutdown Cooling Heat Exchanger Flange to Channel Cylinder and Channel Cylinder-to-Tubesheet Welds listed in Table 1, greater than 90% coverage of the required examination volume, as required by Code Case N-460, could not be obtained.

to 2CAN011603 Page 2 of 6 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 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, therefore 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, 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 2CAN011603 Page 3 of 6 Table 1 Limited C-A Examinations Component Description Additional Information Item Number Comp.

ID Item Description Estimated %

Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Exam Exam Results C1.10 49-001 Shutdown Cooling Heat Exchanger Flange to Channel Cylinder Circumferential Weld 76 This was a dual-sided examination although scanning was limited due to the configuration and close proximity of the channel head flange and fasteners.

Additionally, scan paths from the shell side were limited due to the inlet and outlet piping configurations attached to the shell. See Figure 3 for sketch.

See the attached sketch (Figure 1) derived from ultrasonic testing (UT) examination report 2-ISI-UT 030 on file at ANO.

Manual UT A detailed sketch (Figure 3) of the limitation is included.

Wave modality used included shear.

Insonification angles included 45° shear (S) and 70°S.

Surface exam was not required One indication identified as a plate segregate located outside the code examination volume ~50° from the shell inside diameter was recorded.

Evaluated as acceptable by the Entergy Level III.

C1.30 49-002 Shutdown Cooling Heat Exchanger Channel Cylinder to Tube Sheet Circumferential Weld 82 This was a dual-sided examination although scanning was limited due to the configuration and close proximity of the channel head flange. Additionally, scan paths from the shell side were limited due to the inlet and outlet piping configurations attached to the shell. See Figure 3 for sketch.

See the attached sketch (Figure 2) derived from UT examination report 2-ISI-UT-12-031 on file at ANO.

Manual UT A detailed sketch (Figure 3) of the limitation is included.

Wave modality used included shear.

Insonification angles included 45°S and 70°S.

Surface exam was not required Acceptable plate segregation and clad interface indications identified during the 2nd ISI interval examination were confirmed. No new indications recorded.

to 2CAN011603 Page 4 of 6 Figure 1 Scan Plan and Coverage for Component 49-001 Not to Scale Diameter - 46 Thickness - 1.5 Circ Scan Coverage - CW 88% + CCW 88% = 176/2 = 88%

Axial Scan Coverage - (45° = 67%) + (70° = 62%) = 129/2 = 64.5%

Total - 88% Circ + 64.5% Axial = 152.5/2 = 76.25% or 76%

45° Axial

& Circ CL 45° Axial 45° Circ 45° Axial

& Circ 45° Axial

& Circ, 70° Axial FLANGE SHELL FLOW TWO ANGLE COVERAGE SINGLE ANGLE COVERAGE NO SCAN COVERAGE to 2CAN011603 Page 5 of 6 Figure 2 Scan Plan and Coverage for Component 49-002 Not to Scale TWO ANGLE COVERAGE SINGLE ANGLE COVERAGE NO SCAN COVERAGE Diameter - 46 Thickness - 1.5 Circ Scan Coverage - CW 100% + CCW 100% = 200/2 = 100%

Axial Scan Coverage - (45° = 67%) + (70° = 59%) = 126/2 = 63%

Total - 100% Circ + 63% Axial = 163/2 = 81.5% or 82%

45° Axial

& Circ CL 45° Axial 45° Circ 45° Axial

& Circ 45° Axial

& Circ, 70° Axial FLANGE SHELL FLOW 45° Axial to 2CAN011603 Page 6 of 6 Figure 3 Sketch for Component 49-001 & 49-002 Not to Scale 049-006 049-007 049-003 049-002 049-005 A

A 049-001 049-004 049-008 049-009