W3F1-2009-0026, Request for Relief from ASME Section XI Volumetric Examination Requirements - Second 10-Year Interval

Request for Relief from ASME Section XI Volumetric Examination Requirements - Second 10-Year Interval

ML091540088
Person / Time
Site:	Waterford
Issue date:	06/01/2009
From:	Murillo R Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2009-0026
Download: ML091540088 (40)

Text

Entergy Operations, Inc.

17265 River Road vEntergy Killona, LA 70057-3093 Tel 504-739-6715 Fax 504-739-6698 rmurill@entergy.com Robert J. Murillo Licensing Manager Waterford 3 W3F1-2009-0026 June 1, 2009 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Requests for Relief from ASME Section Xl Volumetric Examination Requirements - Second 10-Year Interval Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38

REFERENCE:

1. Entergy Letter to the NRC, "Inservice Inspection (ISI) Relief Request ISI-001, Revision 7, Limited Examination of Welds/Components" dated January 27, 1998 (W3F1-98-0003)

2. Entergy Letter to the NRC, "Additional Information Regarding Inservice Inspection (ISI) Relief Request ISI-001, Revision 7" dated March 22, 1999 (W3F1-99-0042)

Dear Sir or Madam:

Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from the requirements of the American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel (B&PV) Code,Section XI pertaining to volumetric examinations at Waterford Steam Electric Station, Unit 3 (Waterford 3). In several locations, the required coverage cannot be obtained due to interference or geometry. The individual relief requests by examination category are provided in the attachments. These reliefs are for the second 10-year interval.

Entergy has previously submitted relief requests for limited volumetric examinations for Waterford 3 pressure-retaining welds (References 1 and 2).

This !submittal contains no new commitments.

-ýNc-7

W3F1-2009-0026 Page 2 Please contact Robert J. Murillo, Manager, Licensing at (504) 739-6715 should you have any questions concerning this submittal.

Sincerely,-----.

RJM/RJ ssf Attachments:

1. Request for Relief WF3-ISI-007

2. Request for Relief WF3-ISI-008

3. Request for Relief WF3-ISI-009

4. Request for Relief WF3-ISI-010

5. Request for Relief WF3-ISI-01 1

6. Request for Relief WF3-ISI-012

7. Request for Relief WF3-ISI-013

8. Request for Relief WF3-ISI-014

W3F1-2009-0026 Page 3 cc: Mr. Elmo E. Collins, Jr.

Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 U. S. Nuclear Regulatory Commission Attn: Mr. N. Kalyanam Mail Stop O-07D1 Washington, DC 20555-0001 Wise, Carter, Child & Caraway ATTN: J. Smith P.O. Box 651 Jackson, MS 39205 Louisiana Department of Environmental Quality Office of Environmental Compliance Surveillance Division P. 0. Box 4312 Baton Rouge, LA 70821-4312 American Nuclear Insurers Attn: Library 95 Glastonbury Blvd.

Suite 300 Glastonbury, CT 06033-4443

Attachment I to W3F1 -2009-0026 Request for Relief WF3-ISI-007 to W3F1-2009-0026 Page 1 of 3 REQUEST FOR RELIEF WF3-ISI-007 Components/Numbers: See Table 1 Code Classes: ASME Code Class 1

References:

ASME Section XI 1992 Edition, Table IWB-2500-1 ASME Section XI 1980 Edition with the Winter of 1981 Addenda for ultrasonic examinations ASME Section XI 1992 Edition with 1993 Addenda ASME Section Xl 1995 Edition with 1995 & 1996 Addenda Examination Category: B-A,

,Description: Pressure Retaining Welds in Reactor Vessel Item Number(s): B13.12, B1.22, 81.30, B1.40 Unit/Inspection Interval Waterford 3 Nuclear Station (WF3), Second (2nd)10-year Applicability: interval

1. , Code Requirement(s)

ASME Section XI, Table IWB-2500-1, Examination Category B-A, Pressure Retaining Welds in Reactor Vessel - Inspection Program B:

1) Item B1.22 - Requires a volumetric examination of Meridional Welds in Reactor Vessel Heads.

2) Item B1.40 - Requires a volumetric examination of Reactor Vessel Head to Flange Welds During the 2 nd 10-year ISI interval at WF3, 10CFR50.55a(g)(6)(ii)(C) mandated an implementation schedule for all licensees'to begin use of Appendix VIII of the 1995 Edition, with 1996 Addenda of ASME Section XI. As a result, all examinations listed in this relief request were performed prior to this implementation schedule, and were performed in accordance with, Article 4 of the 1980 Edition, through the Winter 1981 Addenda of Section V. The methodology used to determine Code coverage for each of the components listed in this relief request, therefore, depends on which set of requirements were in effect during the examination. Where earlier Code rules were in effect, Entergy credited Code coverage for examinations using the techniques and examination angles required at that time. After the implementation of Appendix VIII, examinations were performed using the techniques and examination angles qualified through PDI for consideration of Code coverage, in accordance with qualified PDI to k W3FI-2009-0026 Page 2 of 3 procedures.

I1. Relief Requested Due to the.geometric configuration and location, certain code examination volumes, as depicted in ASME Section Xl, cannot be examined'to the extent of obtaining full code coverage. Pursuant to 10CFR50.55a(g)(6)(i), Entergy Operations, Inc.

(Entergy) requests permission to perform ultrasonic examination within the limitations described in Table 1 of this relief request.

Table 1, Limited B-A Examinations Item Item  % Reason for Number Comp. ID Description Coveraqe Limitation Exam coverage limited by shroud, shroud support, and flange configuration. Scanned with 00, 450s, and 60 0 s, where accessible. Six inch wide lifting lugs every 300 around the circumference of the head. Shroud located 8" from the toe of the weld on the head side. Flange located 5 RPV Head to inches from the toe on the opposite B1.40 02-001 Flange Weld 64% side.

RPV Head Peel Segment to Scanning obstructed for 18.1" of a Peel 22.1" weld length, due to shroud. 450 Segment at and 600 shear, and 00 L used for B1.22 02-002 900 18% scanning, where accessible.

RPV Head Peel Segment to Scanning obstructed for 18.1" of a Peel 22.1" weld length, due to shroud. 450 Segment at and 600 shear, and 00 L used for B1.22 02-003 00 18% scanning, where accessible.

III. Basis for Relief During ultrasonic examination of the Pressure Retaining Reactor Vessel Welds listed in Table 1 of this relief request, 100% coverage of the required examination volume could not be obtained.

Radiography is not practical on these types of weld configurations, which prevents

Attachment 1 to W3F1-2009-0026 Page 3 of 3

'placement of the film and exposure source.

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 welds as required by.the Code.

V. Conclusion 10CFR50.55a(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. 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. Therefore, we request the proposed alternative be authorized pursuant to 10CFR50.55a(g)(6)(i).

to W3F1 -2009-0026 Request for Relief WF3-ISI-008 to W3F1-2009-0026 Page 1 of 4 REQUEST FOR RELIEF WF3-ISI-008 Components/Numbers: See Table 1 Code Classes: ASME Code Class 1

References:

ASME Section XI 1992 Edition, Table IWB-2500-1 ASME Section Xl 1980 Edition with the Winter of 1981 Addenda for ultrasonic examinations ASME Section Xl 1992 Edition with 1993 Addenda ASME Section XI 1995 Editi6n with 1995 & 1996 Addenda Examination Category: B-D

Description:

Full Penetration Welded Nozzles in Vessels Item Number(s): B3.10,B3.20, and B3.30 Unit / Inspection Interval Waterford 3 Nuclear Station (WF3), Second (2nd)10-year interval Applicability:

Code Requirement(s)

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

1) Item B3.10 - Requires a volumetric examination of Reactor Vessel Nozzle-to-Vessel Welds.

2) Item B3.20 - Requires a volumetric examination of Reactor Vessel Nozzle Inside Radius Section.

3) Item B3.30 - Requires a volumetric examination of Pressurizer Vessel Nozzle-to-Vessel Welds.

During the 2 nd 10-year ISI interval at WF3, 10CFR50.55a(g)(6)(ii)(C) mandated an implementation schedule for all licensees to begin use of Appendix VIII of the 1995 Edition, with 1996 Addenda of ASME Section Xl. As a result, some examinations listed in this relief request were performed prior to this implementation schedule, and were performed in accordance with Article 4 of the 1980 Edition, through the Winter 1981 Addenda of Section V. The methodology used to determine Code coverage for each of the components listed in this relief request depends on which set of requirements were in effect at the time of the examination. Where earlier Code rules were in effect, Entergy credited Code coverage for examinations using the techniques and examination angles required at that time. After the implementation of Appendix VIII, examinations were performed using the techniques and examination angles qualified through PDI for consideration of Code coverage, in accordance with qualified PDI procedures.

to W3F1-2009-0026 Page 2 of 4 II. Relief Requested Due to the geometric configuration of the nozzle-to-vessel welds listed below, certain code examination volumes, as depicted in ASME Section XI, cannot be examined to the extent of obtaining full code coverage. Pursuant to 10CFR50.55a(g)(6)(i), Entergy Operations, Inc.

(Entergy) requests permission to perform ultrasonic examination within the limitations described in Table 1 of this relief request. /

Table 1, Limited B-D Examinations Item Item  %

Number Comp. ID Description Coveraqe Reason for Limitation-Single side examination (for majority of weld volume), due to weld location adjacent to the 42" Hot Leg nozzle transition. Scanning performed with 00, Nozzle to 45's and 600s where accessible (including two B3.130 03-010 SG#1 86.5% directions for accessible portion of weld volume.

Exam coverage limited by nozzle and weld 30"Cold leg geometry configuration, due to transition of the to SG#1 nozzle adjacent to the weld toe. Scanned with 00, B3.130 03-011 @450 66% 450s and 60Ws, where accessible.

Exam coverage limited by nozzle and weld 30"Cold leg geometry configuration, due to transition of the to SG#1 nozzle adjacent to the weld toe. Scanned with 00, B3.130 03-012 @3150 66% 450s and 60's, where accessible.

Pressurizer Exam coverage limited by nozzle to head Surge configuration, due to transition of the nozzle Nozzle to adjacent to the weld toe. Scanned with 00, 450s B3.1 10 05-009 Head Weld 64% and 60 0 s, where accessible.

Pressurizer Exam coverage limited by nozzle to head Spray Nozzle configuration, due to transition of the nozzle to Head adjacent to the weld toe. Scanned with 00, 450s B3. 110 05-010 Weld 74.8% and 60 0 s, where accessible.

Exam coverage limited due to nozzle to head configuration, due to transition of the nozzle Pressurizer adjacent to .the weld toe. Exam also limited due to Safety head to shell transition area. This obstructed the Nozzle to 450 -axial scan for 13" and the 600 axial scan for B3.1 10 05-011 Head Weld 65.9% 20".

Exam coverage limited due to nozzle to head configuration, due to transition of the nozzle Pressurizer adjacent to the weld toe. Exam also limited due to Safety head to shell transition area. This obstructed the Nozzle to 450 axial scan for 13" and the 600 axial scan for B3.110 05-012 Head Weld 65.9% 20".

Exam coverage limited due to nozzle to head configuration, due to transition of the nozzle Pressurizer adjacent to the weld toe. Exam also limited due to Safety head to shell transition area. This obstructed the Nozzle to 450 axial scan for 13" and the 600 axial scan for B3.110 05-013 Head Weld 65.9% 20".

to W3F1-2009-0026 Page 3 of 4 Table 1 Limited B-D Examinations Item Item  %

Number Comp. ID Description Coverage Reason for Limitation Pressurizer Surge Scanning limited by nozzle to head transition Nozzle Inner configuration. Scanning performed with 60°s and B3.120 05-014 Radius 29.4% 70's, where accessible.

Pressurizer Scanning limited by nozzle to head transition Spray Nozzle configuration. Scanning performed with 60 0 s and B3.120 05-015 Inner Radius 60.4% 70's, where accessible.

Pressurizer Safety Scanning limited by nozzle to head transition Nozzle Inner configuration. Scanning performed with 60°s and, B3.120 05-016 Radius 72% 70 0 s, where accessible.

Pressurizer Safety Scanning limited by nozzle to head transition Nozzle Inner configuration. Scanning performed with 60 0 s and B3.120 05-017 Radius 72% 70 0 s, where accessible.

Pressurizer Safety Scanning limited by nozzle to head transition Nozzle Inner configuration. Scanning performed with 60 0 s and B3.120 05-018 Radius 72% 70°s, where accessible.

Ill. Basis for Relief During ultrasonic examination of the Reactor and Pressurizer Vessel nozzle-to-vessel welds listed in Table 1 of this relief request, 100% coverage of the required examination volume could not be obtained.

Radiography is not practical on these types of nozzle-to-vessel weld configurations, which prevent placement of the film and exposure source. To perform any additional Code allowable UT examination, 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 ISI 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 these welds to the extent practical and will continue to perform pressure testing on the subject welds as required by the Code.

V. Conclusion 10CFR50.55a(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 to W3FI-2009-0026 Page 4 of 4 or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

Entergy believes that it is impractical to obtain greater examination coverage on these welds. To obtain additional coverage would necessitate modification and/or replacement of the component.

The examinations performed on the subject welds in addition to the examination of similar welds contained in the program would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity. Therefore, we request the proposed alternative be authorized pursuant to 10CFR50.55a(g)(6)(i).

Attachment 3 to W3F1 -2009-0026 Request for Relief WF3-ISI-009 I

to W3F1-2009-0026 Page 1 of 3 REQUEST FOR RELIEF WF3-ISI-009 Components/Numbers: See Table 1 Code Classes: ASME Code Class 1

References:

ASME Section XI 1992 Edition, Table IWB-2500-1 ASME Section XI 1995 Edition with 1996 Addenda (for Ultrasonic examinations performed after November 22, 2002)

Examination Category: B-F,

Description:

Pressure Retaining Dissimilar Metal Welds in Vessel Nozzles Item Number(s): B5.40 Unit / Inspection Waterford 3 (WF3), Second (2 nd) 10-year interval Interval Applicability:

Code Requirement(s)

ASME Section XI, Table IWB-2500-1, Examination Category B-F, Pressure Retaining Dissimilar Metal Welds in Vessel Nozzles.

1. Items B5.40 - Requires 100% volumetric examination of the Class 1 NPS 4 or Larger Nozzle-to-Safe End Butt Welds.

During the 2 nd 10-year ISI interval at WF3, 10CFR50.55a(g)(6)(ii)(C) mandated an implementation schedule for all licensees to begin use of Appendix VIII of the 1995 Edition, with 1996 Addenda of ASME Section Xl. After the implementation of Appendix VIII, only 1/2 Vee path examinations have been allowed to be used in austenitic materials, in accordance with qualified PDI procedures. Additional discussion, as to the examination coverage determination process when using Appendix VIII techniques on single-sided austenitic welds, is provided in Section III of this relief request.

II. Relief Requested Pursuant to 10CFR50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving greater than 90% coverage as allowed by Code Case N-460, when performing volumetric examinations on the following welds.

Table 1, Limited B-F Examinations Item Item  %

Number Item ID Description Coverage Reason for Limitation PZR Nozzle to 8" x 6" Reducing Scanning limited on reducer side due to OD Safe end taper near the weld toe. 45°s, 45 0 RL and B5.40 26-006 Weld 63% 60°RL used for scanning, where accessible.

Attachment 3 to W3F1-2009-0026 Page 2 of 3 Table 1. Limited B-F Examinations Item Item  %

Number Item ID Description Coveraqe Reason for Limitation Pressurizer Safety Nozzle to 8" x 6" Scan coverage limited on the reducing safe Reducing end side, due to OD configuration. 45°s, Safe end 45 0 RL, and 60°RL used for scanning, where B5.40 26-001 Weld 70% accessible.

Ill. Basis for Relief During ultrasonic examination of the piping welds listed in Table 1 of this relief request, 100%

coverage of the required examination volume could not be obtained.

Class 1 piping and components are often designed with welded joints such as nozzle-to-pipe, pipe-to-valve and pipe-to-pump which can physically obstruct a large portion of the required examination volume. For the welds listed in Table 1 (above), the examinations were performed after November 22, 2002, the 10CFR50.55a mandatory implementation date for Appendix VIII of Section Xl, and code coverage percentages, provided, reflect what is currently allowed by qualified Appendix VIII techniques. Appendix VIII qualified (PDI) procedures have demonstrated that sound beams may potentially be attenuated and distorted when required to pass through austenitic weld metal. Still, the PDI qualified methods employ the best available technology for maximizing examination coverage of these types of welds. For the components listed in this relief request, examination was extended to the far side of the weld to the extent permitted by geometry as qualified through PDI.

Entergy has used the best available techniques to examine the subject piping welds. To improve upon these examination coverage percentages, modification and/or replacement of the component would be required. Consistent with the ASME Section Xl sampling approach, examination of the subject welds, when combined with examinations that have been performed on other welds within the same Examination Category, is adequate to detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity.

IV. Proposed Alternative Examinations No alternative testing is proposed at thisltime. Entergy has examined the subject welds to the extent practical and will continue to perform pressure testing on the subject welds as required .by the Code.

Entergy will use pressure test and VT-2 visual examination to.compliment the limited examination coverage after each refueling outage.

• V.. Conclusion 10CFR50.55a(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 to W3F1-2009-0026 Page 3 of 3 consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

Entergy believes that it is impractical to obtain greater examination coverage on these areas. To obtain additional coverage would necessitate modification and/or replacement of the component.

The examinations performed on the subject areas, in addition to the examination of similar welds contained in the program would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity. Therefore, we request the proposed alternative be authorized pursuant to 10CFR50.55a(g)(6)(i).

-I to W3F1 -2009-0026 Request for Relief WF3-ISI-010 to W3F1-2009-0026 Page 1 of 7 REQUEST FOR RELIEF WF3-ISI-010 Components/Numbers: See Table 1 Code Classes: ASME Code Class 1

References:

ASME Section XI 1992 Edition, Table IWB-2500-1 ASME Section XI 1995 Edition with 1996 Addenda (for ultrasonic examinations performed after May 22, 2000)

Examination Category: B-J

Description:

Pressure Retaining Welds in Piping Item Number(s): B9.11, B9.21,B9.31 Unit /Inspection Waterford 3 (WF3), Second ( 2 nd) 10-year interval Interval Applicability:

Code Requirement(s)

ASME Section Xl, Table IWB-2500-1, Examination Category B-J, Pressure Retaining Welds in Pip ing - Inspection Program B:

1. Item B9.11 - Requires a volumetric examination of Circumferential Welds NPS 4 or Larger.

2. Item B9.21- Requires a volumetric examination of Circumferential Welds less than NPS

.4.

3. Item B9.31 - Requires a volumetric examination of Branch Pipe Connection Welds NPS 4 or Larger During the 2 nd 10-year ISI interval at WF3, 10CFR50.55a(g)(6)(ii)(C) mandated an implementation schedule for all licensees to begin use of Appendix VIII of the 1995 Edition, with 1996 Addenda of ASME Section Xl. As a result, the examinations listed in this relief request were performed utilizing procedures written in accordance with the PDI Generic UT Procedures, and Appendix VIII. With the implementation of Appendix VIII, only Y2 Vee path examinations have been allowed to be used in austenitic materials, and angle beams are no longer credited to extend beyond the centerline of austenitic welds for consideration of Code coverage, in accordance with qualified PDI procedures. Additional discussion, as to the examination coverage determination process when using Appendix VIII techniques oh single-sided austenitic welds, is provided in Section III of this relief request.

I1.. Relief Requested Pursuant to 10CFR50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from to W3F1-2009-0026 Page 2 of 7 achieving greater than 90% coverage as allowed by Code Case N-460, when performing volumetric examinations on the following welds.

Table 1, Limited B-J Examinations Item Item  %

Number Comp. ID Description Coveraqe Reason for Limitation 14" Shutdown Cooling Scanning limited on nozzle side of weld due to Nozzle to nozzle transition. 450 and 600 shear, 400, 450 Safe end and 600 RL used for scanning, where -

B9.11 06-006 Weld 86.5% accessible.

Scanning obstructed for 17.8% of weld RCS 30" circumference due to adjacent permanent Elbow to 450 support structure. 45°s and 60's used for B9.11 07-013 Elbow Weld 82.2% scanning, where accessible.

Scan coverage limited on safe end side of' 30" Pipe to weld due to short safe end length and the Safe end, adjacent pump configuration. 450s and 45°RL B9.1 1 08-014 Weld 71% used for scanning, where applicable.

SG Nozzle Ext. Piece to Scanning limited on elbow side of weld due to 30" Elbow elbow OD configuration, limiting the amount of Ext. Piece elbow side coverage. 45's and 60°s used for B9.11 09-002 Weld 87% scanning, where accessible.

Scanning limited on elbow side of weld for 17" of circumference due to adjacent permanent support. Scanning performed across weld from pipe side, but no second direction in 450 Elbow to obstructed area due to ID cladding,'which 30" Elbow precludes bouncing sound. 45Os used for B9.1 1 09-005 Weld 85% scanning, where accessible.

30" Elbow to Scanning limited on safe end side of weld due Safe end to the width and shape of safe end. 450s and Weld (RCP 60 0s, and 450, 600 and 700 RL used for B9.11 09-016 1B Inlet) 52.5% scanning, where accessible.

Scanning limited on safe end side of weld due to the width and shape of safe end. Scanning on Pump side is considered "best effort" due to cast stainless steel material. 1.9% of safe end 30" Safe end side was also obstructed by a 1" diameter to RCP 1B nozzle. 450 RL used for scanning, where B9.11 09-017 Weld 17.5% accessible.

Scanning limited on safe end side of weld due RCP 1 B to to the width and shape of safe end. Scanning 30" Safe end on Nozzle side limited by nozzle transition. 450 B9.11 10-001 Weld 18% RL used for scanning, where accessible.

to W3F1-2009-0026 Page 3 of 7 Table 1, Limited B-J Examinations Item Item  %

Number Comp. ID Description Coveraqe Reason for Limitation Scanning limited on safe end side due to width Safe end to and shape of safe end. Pipe side scanning 30" Pipe Weld limited by adjacent nozzle for 6.75" of 116" of (RCP 1B circumference. 450 and 600 RL used for B9.11 10-002 Outlet) 44.2% scanning, where accessible.

Scanning limited to Nozzle Extension side only, due to Nozzle OD configuration.

Additionally, Nozzle Extension side scanning was limited due to adjacent weld no.13-002, resulting in approximately only 50% coverage SG#2 30" of the required volume from the Nozzle Nozzle to Extension side, in the axial scan direction.

Nozzle Circumferential coverage was unobstructed.

Extension 450 and 600 shear used for scanning, where B9.11 13-001 Weld 62.5% accessible.

Examination limited on reducer side due to taper configuration 0.8" from weld toe.

12" Pipe to Scanning performed with 45's and 70°RL, B9. 11 17-033 Reducer Weld 57% where accessible.

Scanning limited to pipe side only, due to valve 12" Pipe to OD configuration. 45's and 60°RL used for B9.11 19-006 Valve Weld 50% scanning where accessible.

Scanning limited to pipe side only, due to valve Valve end to OD configuration. 45's and 60°RL used for B9.11 19-008 12" Pipe Weld 50% scanning, where accessible.

Single sided examination due to valve 14" Pipe to configuration.45-700s, and 70°RL used for B9.11 21-066 Valve Weld 50% scanning, where accessible.

10" of downstream side of the weld, near the intrados of the elbow, was not~accessible due Elbow to 14" to penetration hole. 450 and 600 shear used for B9. 11 22-023 Pipe Weld 88% scanning, where accessible.

4" Pipe to 4" x Scanning limited to 50% circumference on tee 4" x 3" Tee side due to branch connection radius. 45-70°s B9.11 25-009 Weld 75% used~for scanning, where accessible.

4" x 4" x 3" Scanning limited to 50% circumference on tee Tee to 4"- Pipe side due to branch connection radius. 45-70°s B9.11 25-015 Weld 75% used for scanning, where accessible.

4" Pipe to Single sided examination due to valve Valve end configuration. 45-70°s used for scanning, B9.11 25-016 Weld 50% where accessible.

Single sided examination due to valve Valve end to configuration. 45-70°s used for scanning, B9.11 25-018 4" Pipe Weld 50% where accessible.

Scanning limited to 50% circumference on the 4" Pipe to elbow side due to the intrados radius. 45-70°s B9.11 25-019 Elbow weld 75% used for scanning, where accessible. -

to W3F1-2009-0026 Page 4 of 7 Table 1, Limited B-J Examinations Item Item  %

Number ComD ID Description Coveracqe Reason for Limitation Scanning limited to 50% circumference on the Elbow to 4" elbow side due to the intrados radius. 45-70°s B9.11 25-020 Pipe Weld 75% used for scanning, where accessible.

Tee to 4" Branch Scanning limited to 12% on tee side due to the Connection radius of the tee. 45-70°s used for scanning, B9.11 25-022 Weld 62% where accessible.

8" x 6" Reducing Scanning limited on both side of weld due to Safe-end to 6" elbow to reducer OD configuration. 45-70°s B9.11 26-002 Elbow Weld 50% used for scanning, where accessible.

8" x 6" Reducing Scanning limited on both side of weld due to Safe-end to 6" elbow to reducer OD configuration. 45-70°s B9.11 26-007 Elbow Weld 52% used for scanning, where accessible.

2" Drain Examination limited on safe end side of weld Nozzle to due to adjacent safe end to pipe weld. 45's, Safe end 60°RL and 70°RL used for scanning, where B9.21 15-006 Weld 85.5% accessible.

Scanning limited to 50% circumference on the elbow side due to the intrados radius. 45-70 0 s 2" Pipe to and 70°RL used for scanning, where B9.21 27-002 Elbow Weld 75% accessible.

Scanning limited to 50% circumference on the elbow side due to the intrados radius. 45-70°s 2" Pipe to and 70°RL used for scanning, where B9.21 27-004 Elbow Weld 75% accessible.

Scanning limited to 50% circumference on the elbow side due to the intrados radius. 45-70°s Elbow to 2" and 70°RL used for scanning, where B9.21 27-005 Pipe Weld 75% accessible.

Scanning limited to 50% circumference on the elbow side due to the intrados radius. 45-70°s 2" Pipe to and 70°RL used for scanning, where B9.21 27-006 Elbow Weld 75% accessible.

Scanning limited to 50% circumference on the elbow side due to the intrados radius. 45-70°s Elbow to 2" and 70°RL used for scanning, where B9.21 27-007 Pipe Weld 75% accessible.

Scanning limited to 50% circumference on the elbow side due to the intrados radius. 45-70°s

- 2" Pipe to and 70°RL used for scanning, where B9.21 27-008 Elbow Weld 75% accessible.

Scanning limited to 50% circumference on the elbow side due to the intrados radius. 45-70°s Elbow to 2" and 70°RL used for scanning, where B9.21 27-009 Pipe Weld 75% accessible.

to W3F17-2009-0026 Page 5 of 7 N-Table 1, Limited B-J Examinations Item Item  %

Number Comp. ID Description Covera qe Reason for Limitation Scanning limited to 50% circumference on the elbow side due to the intrados radius. 45-70's 2" Pipe to and 70°RL used for scanning, where B9.21 27-010 Elbow Weld 75% accessible.

Scanning limited to 50% circumference on the elbow side due to the intrados radius. 45-70's Elbow to 2" and 70°RL used for scanning, where B9.21 27-011 Pipe Weld 75% accessible.

Scanning limited to 12% on tee side due to the Tee to 2" Pipe radius of the tee. 45-70°s and 70°RL used for B9.21 27-037 Weld 62% scanning, where accessible.

Scanning limited to 50% circumference on the elbow side due to the intrados radius. 45-70°s Elbow to 2" and 70°RL used for scanning, where, B9.21 27-038 Pipe Weld 75% accessible.

Scanning limited to 50% circumference on the 2" Pipe to elbow side due to the intrados radius. 45-70's B9.21 27-054 Elbow Weld 75% used for scanning, where accessible.

Scanning limited to 50% circumference on the Elbow to 2" elbow side due to the intrados radius. 45-70°s B9.21 27-055 Pipe Weld 75% used for scanning, where accessible.

Scanning limited to 50% circumference on the 2" Pipe to elbow side due to the intrados radius: 45-70's B9.21 28-001 Elbow Weld 75% used for scanning, where accessible.

Scanning limited to 50% circumference on the Elbow to 2" elbow side due to the intrados radius. 45-70's B9.21 28-002 Pipe Weld 75% used for scanning, where accessible.

Scanning limited to 50% circumference on the 2" Pipe to elbow side due to the intrados radius. 45-70°s B9.21 28-008 Elbow Weld 75% used for scanning, where accessible.

Scanning limited to 50% circumference on the Elbow to 2" elbow side due to the intrados radius. 45-70's B9.21 28-009 Pipe Weld 75% used for scanning, where accessible.

Scanning limited to 50% circumference on tee side due to branch connection radius.

2" pipe to 2" x Scanning limited to 90% on pipe side due to 2" x 2" Tee an adjacent clamp. 45-70°s used for scanning, B9.21 28-012 Weld 70% where accessible.

2" x 2" x 2" Scanning limited to 50% circumference on tee Tee to 2" Pipe side due to branch connection radius. 45-70°s B9.21 28-013 Weld 75% used for scanning, where accessible.

2" x 2" x 2" Scanning limited to 12% on tee sidedue to the Tee to 2" radius of the tee. Scanning limited to 90% on Branch branch connection side due to an adjacent Connection clamp.45-700s used for scanning, where B9.21 28-016 Weld 51% accessible.

to W3F1-2009-0026 Page 6 of 7 Table 1, Limited B-J Examinations Item Item  %

Number Comp. ID Description Coveragqe Reason for Limitation 2" pipe to 2" x Scanning limited to 50% circumference on tee 2" x 2" Tee - side due to branch connection radius. 45-70°s B9.21 28-074 Weld 75% used for scanning, where accessible.

2" x 2" x 2" Scanning limited to 50% circumference on tee Tee to 2" Pipe side due to branch connection radius. 45-70°s B9.21 28-075 Weld 75% used for scanning, where accessible.

Scanning limited to 12% on tee side due to the Tee to 2" Pipe radius of the tee. 45-70's used for scanning, B9.21 28-076 Weld 62% where accessible.

Scanning limited to 50% circumference on the 2" Pipe to elbow side due to the intrados radius. 45-70°s B9.21 28-077 Elbow Weld 75% used for scanning, where accessible.

Scanning limited to 50% circumference on the Elbow to 2" elbow side due to the intrados radius. 45-70°s B9.21 28-078 Pipe Weld 75% used for scanning, where accessible.

12" Safety Scanning limited to 30" pipe side, due to Injection nozzle*OD configuration. ID clad prevents two Nozzle to 30" directional coverage, via the bounce. 450 B9.31 `08-008 Pipe Weld 50% shear used for scanning, where accessible.

II1. Basis for Relief During ultrasonic examination of the piping welds listed in Table 1 of this relief request,. 100%

coverage of the required examination volume could not be obtained.

Class 1 piping and components are often designed with welded joints such as nozzle-to-pipe, pipe-to-valve and pipe-to-pump which can physically obstruct a large portion of the required examination volume. For many of the welds listed in Table 1 (above), the examinations Were performed after the 10CFR50.55a mandatory implementation date for Appendix VIII of Section XI, and code coverage percentages, provided, reflect what is currently allowed by qualified Appendix VIII techniques. Appendix VIII qualified (PDI) procedures have demonstrated that sound beams may potentially be attenuated and distorted when required to pass through austenitic weld metal.

Still, the PDI qualified methods employ the best available technology for maximizing examination coverage of these types of welds. For all the components listed in this relief request, examination was extended to the far side of the weld to the extent permitted by geometry, but this portion of the examination is not included in the reported coverage for welds examined under PDI and Appendix VIII rules.

Entergy has used the best available techniques to examine the subject piping welds. To improve upon these examination coverage percentages, modification and/or replacement of the component would be required. Consistent with the ASME Section XI sampling approach, examination of the subject welds, when combined with examinations that have been performed on other welds within the same Examination Category, is adequate to detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity.

IV. Proposed Alternative Examinations No alternative testing is proposed at this time. Entergy has examined the subject welds to the to W3F17-2009-0026 Page 7 of 7 extent practical and will continue to perform pressure testing on the subject welds as required by the Code.

V. Conclusion 10CFR50.55a(g)(6)(i) states:

The Commission will evaluate determinations under paragraph (g)(5) of this section that code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

Entergy believes that it is impractical to obtain greater examination coverage on these areas. To obtain additional coverage would necessitate modification and/or replacement of the component.

The examinations performed on the subject areas, in addition to the examination of similar welds contained in the program would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity. Therefore, we request the proposed alternative be authorized pursuant to 10CFR50.55a(g)(6)(i).

Attachment 5 to W3F1-2009-0026 Request for Relief WF3-1SI-011 to W3F11-2009-0026 Page 1 of 3 REQUEST FOR RELIEF WF3-ISI-01 1 Components/Numbers: See Table 1 Code Classes: ASME Code Class 2

References:

ASME Section XI 1992 Edition, Table IWC-2500-1 ASME Section XI 1980 Edition with the Winter of 1981 Addenda for ultrasonic examinations ASME Section Xl 1992 Edition with 1993 Addenda ASME Section XI 1995 Edition with 1995 & 1996 Addenda Examination Category: C-A

Description:

Pressure Retaining Welds in Pressure Vessels Item Number(s): C1.10, C1.20 Unit / Inspection Waterford 3 Nuclear Station (WF3), Second ( 2 nd) 10-year interval Interval Applicability:

Code Requirement(s)

ASME Section XI, Table IWC-2500-1, Examination Category C-A, Pressure Retaining Welds in Pressure Vessels.

1. Items C1.10 - Requires 100% volumetric examination of the Class 2 Shell Circumferential Welds.

2. Items C1.20 - Requires 100% volumetric examination of the Class 2 Head Circumferential Welds.

II. Relief Requested Pursuant to 10CFR50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving greater than 90% coverage as allowed by Code Case N-460, when performing volumetric examinations on the following welds.

to W3F1-2009-0026 Page 2 of 3 Table 1, Limited C-A Examinations Item Item  %

Number Item ID Description Coveracqe Reason for Limitation SG Scan obstruction caused by 4" wide insulation Intermediate support ring located 2.3" from toe of weld, 3600 Shell to around circumference. 450 and 60*s used for Conical Shell scanning, where accessible.

C1.10 04-026 Weld 56%

Scanning limited for 11.3% of weld circumference, due to 14 insulation lugs located SG#2 Top 3.5" from weld centerline every 36" around the Head Torus to circumference. 45's and 60's used for Top Head scanning, where accessible.

C1.20 04-029 Dome Weld 89%

Shut Down Heat Exchanger Configuration of top and bottom nozzle saddle Shell to weld and the horizontal shell weld limt this C1.20 54-074 Flange Weld exam.

88%

Shut Down Heat Exchanger Configuration of top and bottom nozzle saddle C1.20 Shell to weld and the horizontal shell weld limt this54-075 Flange Weld exam.

85%

Ill. Basis for Relief During ultrasonic examination of the piping welds listed in Table 1 of this relief request, 100%

coverage of the required examination volume could not be obtained.

Class 1 piping and components are often designed with welded joints such as nozzle-to-pipe, pipe-to-valve and pipe-to-pump which can physically obstruct a large portion of the required examination volume. For the welds listed in Table 1 (above), the examinations were performed after November 22, 2002, the 10CFR50.55a mandatory implementation date for Appendix VIII of Section Xl, and code coverage percentages, provided, reflect what is currently allowed by qualified Appendix VIII techniques. Appendix VIII qualified (PDI) procedures have demonstrated that sound beams may potentially be attenuated and distorted when required to pass through austenitic weld metal. Still, the PDI qualified methods employ the best available technology for maximizing examination coverage of these types of welds. For the components listed in this relief request, examination was extended to the far side of the weld to the extent permitted by geometry as qualified through PDI.

Entergy has used the best available techniques to examine the subject piping welds. To improve upon these examination coverage percentages, modification and/or replacement of the component would be required. Consistent with the ASME Section Xl sampling approach, examination of the subject welds, when combined with examinations that have been performed on other welds within the same Examination Category, is adequate to detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity.

to W3F1-2009-0026 Page 3 of 3 IV. Proposed Alternative Examinations No alternative testing is proposed at this time. Entergy has examined the subject welds to the extent practical and will continue to perform pressure testing on the subject welds as required by the Code.

Entergy will use pressure test and VT-2 visual examination to compliment the limited examination coverage after each refueling outage.

V. Conclusion 10CFR50.55a(g)(6)(i) states:

The Commission will evaluate determinations under paragraph (g)(5) of this section that code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

Entergy believes that it is impractical to obtain greater examination coverage on these areas. To obtain additional coverage would necessitate modification and/or replacement of the component.

The examinations performed on the subject areas, in addition to the examination of similar welds contained in the program would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity. Therefore, we request the proposed alternative be authorized pursuant to 10CFR50.55a(g)(6)(i).

Attachment 6 to W3F1 -2009-0026 Request for Relief WF3-ISI-012 to W3F1-2009-0026 Page 1 of 2 REQUEST FOR RELIEF WF3-ISI-012 Components/Numbers: See Table 1 Code Classes: ASME Code Class 2

References:

ASME Section Xl 1992 Edition, Table IWC-2500-1 ASME Section Xl 1980 Edition with the Winter of 1981 Addenda for ultrasonic examinations ASME Section XI 1992 Edition with 1993 Addenda ASME Section Xl 1995 Edition with 1995 & 1996 Addenda Examination Category: C-B

Description:

Pressure Retaining Nozzle Welds in Vessels Item Number(s): C2.21 Unit / Inspection Waterford 3 Nuclear Station (WF3), Second (2 nd) 10-year interval Interval Applicability:

I. Code Requirement(s)

ASME Section XI, Table IWC-2500-1, Examination Category C-A, Pressure Retaining Welds in Pressure Vessels.

1. Items C2.21 - Requires 100% volumetric examination of the Class 2 Pressure Retaining Nozzle Welds in Vessels

11. Relief Requested Pursuant to 10CFR50.55a(g)(6)(i),.Entergy Operations, Inc. (Entergy) requests relief from achieving greater than 90% coverage as allowed by Code Case N-460, when performing volumetric examinations on the following welds.

Table 1. Limited C-B Examinations Item Item  %

Number Item ID Description Coveraqe Reason for Limitation 14% of circumference of weld partially SG#2 MS limited due to 8 insulation lugs located 5.25" Nozzle to Top from the weld centerline every 24" around Head Dome the circumference. 45°s and 60 0 s used for 04-030 Weld 86% scanning, where accessible.

C2.21 to W3F1-2009-0026 Page 2 of 2 Ill. Basis for Relief During ultrasonic examination of the piping welds listed in Table 1 of this relief request, 100%

coverage of the required examination volume could not be obtained.

Class 1 piping and components are often designed with welded joints such as nozzle-to-pipe, pipe-to-valve and pipe-to-pump which can physically obstruct a large portion of the required examination volume. For the welds listed in Table 1 (above), the examinations were performed after November 22, 2002, the 10CFR50.55a mandatory implementation date for Appendix VIII of Section Xl, and code coverage percentages, provided, reflect what is currently allowed by qualified Appendix VIII techniques. Appendix VIII qualified (PDI) procedures have demonstrated that sound beams may potentially be attenuated and distorted when required to pass through austenitic weld metal. Still, the PDI qualified methods employ the best available technology for maximizing examination coverage of these types of welds. For the components listed in this relief request, examination was extended to the far side of the weld to the extent permitted by geometry as qualified through PDI.

Entergy has used the best available techniques to examine the subject piping welds. To improve.

upon these examination coverage percentages, modification and/or replacement of the component would be required. Consistent with the ASME Section Xl sampling approach, examination of the subject welds, when combined with examinations that have been performed on other welds within the same Examination Category, is adequate to detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity.

IV. Proposed Alternative Examinations No alternative testing is proposed at this time. Entergy has examined the subject welds to the extent practical and will continue to perform pressure testing on the subject welds as required by the Code.

Entergy will use pressure test and VT-2 visual examination to compliment the limited examination coverage after each refueling outage.

V. Conclusion 10CFR50.55a(g)(6)(i) states:

The Commission will evaluate determinations under paragraph (g)(5) of this section that code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and-will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility. /

Entergy believes that it is impractical to obtain greater examination coverage on these areas. To obtain additional coverage would necessitate modification and/or replacement of the component.

The examinations performed on the subject areas, in addition to the examination of similar welds contained in the program would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity. Therefore, we request the proposed alternative be authorized pursuant to 10CFR50.55a(g)(6)(i).

to W3F1-2009-0026 Request for Relief WF3-ISI-013 to W3F17-2009-0026 Page 1 of 4 REQUEST FOR RELIEF WF3-ISI-01 3 Components/Numbers: See Table 1 Code Classes: ASME Code Class 2

References:

ASME Section XI 1992 Edition, Table IWC-2500-1 Examination Category: C-F-1

==

Description:==

Pressure Retaining Welds in Austenitic Stainless Steel or High Alloy Piping Item Number(s): C5.11, C5.21 Unit / Inspection Interval Waterford 3 Nuclear Station (WF3)/ Second ( 2 nd) 10-year Applicability: Interval Code Requirement(s)

ASME Section Xl, Table IWC-2500-1, Examination Category C-F-i, Pressure Retaining Welds in, in Austenitic Stainless Steel or High Alloy Piping

1. Item C5.11 - Requires 100% volumetric examination of Piping Welds > 3/8 in. Nominal Wall Thickness for Piping > NPS 4, Circumferential Welds

2. Item C5.21- Requires 100% volumetric examination of Piping Welds > 1/5 in. Nominal Wall Thickness for Piping > NPS 4, Circumferential Welds I1. Relief Requested Pursuant to 10CFR50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving greater than 90% coverage as allowed by Code Case N-460, when performing volumetric examinations on the following welds.

Table 1, Limited C-F-i Examinations Item 4 Number Item ID Item Description  % Coverage Reason for Limitation C5.11 55-051 8" Pipe to Valve 45.5% Single sided exam due to valve Weld configuration. Additional limitation on pipe side due to weld crown. 45's, 60' and 70°RL used for scanning, where accessible.

to W3F1-2009-0026 Page 2 of 4 Table 1 Limited C-F-1 Examinations Item Number Item ID Item Description  % Coverage Reason for Limitation C5. 11 64-001 Valve to 10" Pipe 50% Single sided exam due to valve Weld configuration. Additional limitation on pipe side due to weld crown. 450s, 60 0 s and 70 0 s used for scanning, where accessible (component is less than 0.50" in thickness).

C5.11 56-001 LPSI Valve to 10". 50% Scanning limited to pipe side only, Pipe Weld due to valve OD configuration. 45°s, 60 0 s, and 70 0 s used for scanning, where accessible (pipe nominal thickness .= 0.365").

C5.11 56-002 LPSI 10" Pipe to 50% Scanning limited to pipe side only, Tee Weld due to tee OD configuration. 45°s, 60 0 s, and 70°s used for scanning, where accessible (pipe nominal thickness = 0.365").

C5.11 56-003 LPSI Tee to 10" 50% Scanning limited to pipe side only, Pipe Weld due to tee OD configuration. 45°s, 600s, and 70 0 s used for scanning, where accessible (pipe nominal thickness = 0.365").

C5.11 61-071 14" x 8" Reducing 50% Scanning limited to elbow side only, Elbow to Flange due to flange OD configuration. 45°s, Weld 60 0 s and 700 shear used for scanning, where accessible. (Thickness is less than 0.50")

C5.11 55-001 10" valve to 50% Scanning limited to pipe side only, stainless pipe weld due to valve OD configuration. 45°s and 70°s used for scanning where accessible.

C5.11 56-005 Tee to 10" Pipe 50% Scanning limited to pipe side only, Weld due to tee OD configuration. 45 0 s, 60 0 s, and 70 0 s used for scanning, where accessible (pipe nominal thickness = 0.365").

C5.11 56-043 10" Pipe to 10" x 50% Scanning limited to pipe side due to 6" Reducer Weld reducer OD configuration. 45°s and 700s used for scanning, where accessible (less than 0.5" thickness).

to W3F1-2009-0026 Page 3 of 4 Table 1, Limited C-F-1 Examinations Item Number Item ID Item Description  % Coverage Reason for Limitation C5.11 56-077 8" Pipe to Cont. 50% Scanning limited to pipe side only, Penetration Weld due to OD configuration of penetration side. 45°s and 60°RL used for scanning, where accessible.

C5.11 52-004 14" Elbow to Tee 50% Scanning limited to elbow side only,ý Weld due to tee OD configuration. 45's, 60°s,700 s, and 60°RL used for scanning, where accessible.

C5.21 60-131 4" Pipe to Tee 79% Scanning limited due to Tee to pipe configuration, 6" total inches was not scanned due to interference.

C5.21 60-468 3" Elbow to Pipe 50% Scanning limited to 50%

Weld circumference on the elbow side due to the intrados radius. 45-70°s used for scanning, where accessible.

C5.21 60-469 Pipe to 50% Single sided exam due to penetration Penetration Weld configuration. 45-70°s used for, scanning, where accessible.

Ill. Basis for Relief During the 2 nd 10-year ISI interval at WF3, 10CFR50.55a(g)(6)(ii)(C) mandated an implementation schedule for all licensees to begin use of Appendix VIII of the 1995 Edition, with 1996 Addenda of ASME Section XI. As a result, the examinations listed in this relief request were performed utilizing procedures written in accordance with the PDI Generic UT Procedures and Appendix VIII. With the implementation of Appendix VIII, only Y2 Vee path examinations have been allowed to be used in austenitic materials, and angle beams are no longer credited to extend beyond the centerline of austenitic welds for consideration of Code coverage, in accordance with qualified PDI procedures. Additional discussion, as to the examination coverage determination process when using Appendix VIII techniques on single-sided austenitic welds, is provided in Section II1 of this relief request.

IV. Proposed Alternative Examinations No alternative testing is proposed at this time. Entergy has examined the subject welds to the extent practical and will continue to perform pressure testing on the subject lines of the welds as required by the Code.

V. Conclusion 10CFR50.55a(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 to W3F1-2009-0026 Page 4 of 4 alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

Entergy believes that it is impractical to obtain greater examination coverage on this item. To obtain additional coverage would necessitate modification and/or replacement of the component.

The examinationsperformed on the subject item, in addition to the examination of similar items contained in the program would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity. Therefore, we request the proposed alternative be authorized pursuant to 10CFR50.55a(g)(6)(i).

Attachment 8 to W3F1-2009-0026 Request for Relief WF3-ISI-014 to W3F1-2009-0026 Page 1 of 3 REQUEST FOR RELIEF WF3-ISI-014 Components/Numbers: See Table 1 Code Classes: ASME Code Class 1

References:

ASME Section Xl 1992 Edition, Table IWB-2500-1 ASME Section XI 1980 Edition with the Winter of 1981 Addenda for ultrasonic examinations ASME Section XI 1992 Edition with 1993 Addenda ASME Section Xl 1995 Edition with 1995 & 1996 Addenda ASME Section Xl Code Case N-716 Examination Category: R-A,

==

Description:==

Alternative Piping Classification and Examination Requirements Item Number(s): R1.20 Unit / Inspection Interval Waterford 3 Nuclear Station (WF3), Second (2nd)10-year interval Applicability:

Code Requirement(s)

ASME Section XI, Code Case N-716 Examination Category R-A, Pressure Retaining Welds in Class 1 and 2 Piping - Inspection Program B:

1) Item R1.20 - Elements not Subject to a Degradation Mechanism During the 2 nd 10-year ISI interval at WF3, 10CFR50.55a(g)(6)(ii)(C) mandated an implementation schedule for all licensees to begin use of Appendix VIII of the 1995 Edition, with 1996 Addenda of ASME Section XI. As a result, the examinations listed in this relief request were performed utilizing procedures written in accordance with the PDI Generic UT Procedures and Appendix VIII. With the implementation of Appendix VIII, only 1/2 Vee path examinations have been allowed to be used in austenitic materials, and angle beams are no longer credited to extend beyond the centerline of austenitic welds for consideration of Code coverage, in accordance with qualified PDI procedures. Additional discussion, as to the examination coverage determination process when using Appendix VIII techniques on single-sided austenitic welds,, is provided in Section III of this relief request.

II. Relief Requested Pursuant to 10CFR50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving greater than 90% coverage as allowed by Code Case N-460, when performing volumetric examinations on the following welds.

to W3F1-2009-0026 Page 2 of 3 Talkla I I imil'wr~ IDA I maninai,,.n, Item Item 1 Number Comp.ID Description  % Coverage Reason for Limitation Reactor Coolant 42" Elbow to Pipe Limited scan due to permanent Concrete saddle weld 89% type support R1.20 06-007 Reactor Limited up stream scan due to permanent Coolant 42" Concrete saddle type support and down stream Pipe to Elbow limitation due to Shutdown cooling nozzle and weld 84% surge nozzle configuration R1.20 15-011 Ill. Basis for Relief During ultrasonic examination of the piping welds listed in Table 1 of this relief request, 100%

coverage of the required examination volume could not be obtained.

Class 1 and 2 piping and components are often designed with welded joints such as nozzle-to-pipe, pipe-to-valve, and pipe-to-pump or supports which can physically obstruct a large portion of the required examination volume. For many of the welds listed in Table 1 (above), the examinations were performed after the 10CFR50.55a mandatory implementation date for Appendix VIII of Section Xl, and code coverage percentages, provided, reflect what is currently allowed by qualified Appendix VIII techniques. Appendix VIII qualified (PDI) procedures have demonstrated that sound beams may potentially be attenuated and distorted when required to pass through austenitic weld metal. Still, the PDI qualified methods employ the best available technology for maximizing examination coverage of these types of welds. For all the components listed in this relief request, examination was extended to the far side of the weld to the extent permitted by geometry, but this portion of the examination is not included in the reported coverage for welds examined under PDI and Appendix VIII rules. Entergy has used the best available techniques to examine the subject piping welds. To improve upon these examination coverage percentages, modification and/or replacement of the component would be required.

Consistent with the ASME Section XI sampling approach, examination of the subject welds, when combined with examinations that have been performed on other welds within the same Examination Category, is adequate to detect generic degradation, if it existed, therefore demonstrating an. acceptable level of integrity.

IV. Proposed Alternative Examinations 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 welds as required by the Code. C V. Conclusion 10CFR50.55a(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 to W3F1-2009-0026 Page 3 of 3 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.

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. Therefore, we request the proposed alternative be authorized pursuant to 1 OCFR50.55a(g)(6)(i).

,1