W3F1-2010-0014, Response to NRC Request for Additional Information Dated January 6, 2010 Waterford 3 Steam Electric Station, Unit 3 - Requests for Relief from ASME Section XI Volumetric Examination Requirements - Second 10-Year Inservice Inspection I

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Response to NRC Request for Additional Information Dated January 6, 2010 Waterford 3 Steam Electric Station, Unit 3 - Requests for Relief from ASME Section XI Volumetric Examination Requirements - Second 10-Year Inservice Inspection Interva
ML100470047
Person / Time
Site: Waterford Entergy icon.png
Issue date: 02/08/2010
From: Murillo R
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2010-0014
Download: ML100470047 (42)
v • d • e


Text

- ..-l .. I Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093 Entergy Tel 504-739-6715 Fax 504-739-6698 rmurill@entergy.com Robert J. Murillo Licensing Manager Waterford 3 W3F1-2010-0014 February 8, 2010 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Response to NRC Request for Additional Information dated January 6, 2010 Re: Waterford 3 Steam Electric Station, Unit 3 - Requests for Relief from ASME Section XI Volumetric Examination Requirements - Second 10-Year Inservice Inspection Interval Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38

REFERENCES:

1 Entergy letter dated June 1, 2009 "Requests for Relief from ASME Section XI Volumetric Examination Requirements - Second 10-Year Interval" (W3F1-2009-0026) (ADAMS Accession No. ML091540088) 2 NRC letter dated July 23, 2009 "Waterford 3 Steam Electric Station, Unit 3 - Requests for Relief from ASME Section XI Volumetric Examination Requirements - Second 10-Year Inservice Inspection Interval" (TAC Nos. ME1426, ME1427, ME1428, ME1429, ME1430, ME1431, ME1432, and ME1433) (ILN09-0069) 3 Electronic communication dated January 6, 2010, "Waterford 3 Relief Requests WF3-ISI-07, 008, 009, 010, 011, 012, 013, and 014" (ADAMS Accession No. ML100060172)

Dear Sir or Madam:

On January 6, 2010, Entergy received communication (Reference 3) from members of the NRC Staff requesting additional information associated with Entergy's relief requests from ASME Section Xl Volumetric Examination Requirements - Second 10-Year Inservice Inspection Interval" (Reference 1).

Attachment 1 contains Entergy's response to the NRC request. Attachment 2 contains information describing Waterford 3's ISI program extracted from the full program description and may be useful in understanding the response.

40(47

W3F11-2010-0014 Page 2 Additionally, Waterford 3 hereby withdraws relief request WF3-ISI-014 because it has been determined that it is not needed.

There are no new commitments contained in this letter.

If you have any questions or require additional information, please contact me at 504-739-6715.

Sincei Attachments:

1. Entergy's response to NRC information request
2. Extracted text from Waterford 3's ISI program

W3F17-2010-0014 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 Winston & Strawn ATTN: N.S. Reynolds 1700 K Street, NW Washington, DC 20006-3817 Morgan, Lewis & Bockius LLP ATTN: T.C. Poindexter 1111 Pennsylvania Avenue, NW Washington, DC 20004 Louisiana Department of Environmental Quality Office of Environmental Compliance Surveillance Division P. O. Box 4312 Baton Rouge, LA 70821-4312 American Nuclear Insurers Attn: Library 95 Glastonbury Blvd.

Suite 300 Glastonbury, CT 06033-4443

  • Attachment 1 To W3F1-2010-0014 Response to NRC Request for Additional Information dated January 6, 2010 Re:

Waterford 3 Steam Electric Station, Unit 3 Requests for Relief from ASME Section XI Volumetric Examination Requirements - Second 10-Year Inservice Inspection Interval Entergy's Response to NRC Information Request to W3F1 -2010-0014 Page 1 of 12 Response to Request for Additional Information 1.1 Requests for Relief WF3-ISI-007 through WF3-ISI-014, Examination Categories B-A. B-D. B-F, B-J, C-A. C-B1 C-F-I, and R-A 1.1.1 Based on the licensee's submittal, it is unclear which Edition and Addenda of ASME Code, Section X1, is applicable to the specific components listed in the individual relief requests. For example, in RR WF3-1SI-007, the licensee lists the 1980 Edition through the 1981 Addenda, 1992 Edition through the 1993 Addenda, and the 1995 Edition through the 1996 Addenda as having applicable ISI requirements for the subject components. The licensee states that the 1995 Edition through the 1996 Addenda of ASME Code was mandated for implementation of ASME Code, Section X1, Appendix VIII examinations during the interval, however, this does not clear up the multiple ASME Code applicability issues. Please confirm the ASME Code of record for the second interval inservice inspection program at Waterford 3, how the licensee arrived at this edition/addenda of the ASME Code, and the specific requirements for each of the subject components listed in each request for relief.

Response

The current Code of record is the 1992 Edition with portions of later Addenda as described in Section 2 of the Site's ISI Program Procedure (CEP-ISI-001 rev. 307)

(see attachment 2). The NRC authorized Waterford 3 (Reference GNRI 96-00244) to perform ultrasonic examinations in accordance with the 1980 Edition with the Winter of 1981 Addenda as specified in the ISI plan for the first interval. The use of the 1980 Edition with the Winter of 1981 Addenda was limited until such time when changes to 10 CFR 50.55a required the use of ASME Section XI, Appendix VIII. Section 2 of CEP-ISI-001 provides a detail listing of the applicable editions and addenda of Section X1 as it applies to ultrasonic examinations based on current 10 CFR 50.55a requirements. See the table below for specific requirements for the subject components.

Limitnd R-A IFxamnin~tionn Item Item  %

Number Comp. ID Description Coveraae Date examined/Code Year RPV Head to 10/29/2000- Code ASME Section XI B13.40 02-001 Flange Weld 64% Year 1980NV81 A RPV Head Peel Segment to Peel Segment at 10/28/2000- Code ASME Section XI B1.22 02-002 90, 18% Year 1980/W81 A RPV Head Peel Segment to Peel 10/28/2000- Code ASME Section XI B1.22 02-003 Segment at 0° 18% Year 1980NV81 A to W3F1-2010-0014 Page 2 of 12 I imitchd R..f Evnminnfinna Item Item  %

Number Comp. ID Description Coverage Date examined/Code Year 42" Hot Leg Nozzle to 3/30/2002- Code ASME Section XI B3.130 03-010 SG#1 86.5% Year 1980/W81 A 30"Cold leg to 5/17/2008- Code ASME Section Xl B3.130 03-011 SG#1 @450 66% Year 1995NW96 A 30"Cold leg to 5/17/2008- Code ASME Section XI B3.130 03-012 SG#1 @3150 66% Year 1995/W96 A Pressurizer Surge Nozzle 2/25/1999- Code ASME Section Xl B3.1 10 05-009 to Head Weld 64% Year 1980/W81 A Pressurizer Spray Nozzle 2/25/1999- Code ASME Section XI B3.1 10 05-010 to Head Weld 74.8% Year 1980/W81 A Pressurizer Safety Nozzle 2/25/1999- Code ASME Section XI B3.1 10 05-011 to Head Weld 65.9% Year 1980/W81 A Pressurizer Safety Nozzle 2/25/1999- Code ASME Section XI B3.110 05-012 to Head Weld 65.9% Year 1980MW81 A Pressurizer Safety Nozzle 2/25/1999- Code ASME Section XI B3.110 05-013 to Head Weld 65.9% Year 1980/W81 A Pressurizer Surge Nozzle 2/26/1999- Code ASME Section XI B3.120 05-014 Inner Radius 29.4% Year 1980/W81 A Pressurizer Spray Nozzle 2/25/1999- Code ASME Section XI B3.120 05-015 Inner Radius 60.4% Year 1980/W81 A Pressurizer Safety Nozzle 2/25/1999- Code ASME Section Xl B3.120 05-016 Inner Radius 72% Year 1980MW81 A Pressurizer Safety Nozzle 2/25/1999- Code ASME Section XI B3.120 05-017 Inner Radius 72% Year 1980/W81 A Pressurizer Safety Nozzle 2/25/1999- Code ASME Section XI B3.120 05-018 Inner Radius 72% Year 1980/W81 A to W3F1-2010-0014 Page 3 of 12 Limited B-F Examinations Item Item  %

Number Comp. ID Description Coverage Date examined/Code Year PZR Nozzle to 8" x 6" Reducing Safe B5.40 26-006 end Weld 63% 11/5/2000- Code ASME Section XI Year 1980/W81 A Pressurizer Safety Nozzle to 8" x 6" Reducing Safe B5.40 26-001 end Weld 70% 11/6/2000- Code ASME Section XA Year 1980/W81 A Limited B-J Examinations Item Item  %

Number Comp. ID Description Coverage Date examined/Code Year 14" Shutdown Cooling Nozzle to Safe 10/27/2000- Code ASME Section Xl B9.1 1 06-006 end Weld 86.5% Year 1995NV96 A RCS 30" Elbow to 450 11/01/2003- Code ASME Section XI B9.11 07-013 Elbow Weld 82.2% Year 1995/W96 A 30" Pipe to 10/10/1995- Code ASME Section XI B9.11 08-014 Safe end Weld 71% Year 1980/W81 A SG Nozzle Ext. Piece to 30"'Elbow Ext. 11/3/2003- Code ASME Section XI B9.1 1 09-002 Piece Weld 87% Year 1995/W96 A 450 Elbow to 30" Elbow 11/3/2003- Code ASME Section XI B9.1 1 09-005 Weld 85% Year 1995/W96 A 30" Elbow to Safe end Weld 11/02/2000- Code ASME Section XI B9.11 09-016 (RCP 1B Inlet) 52.5% Year 1995NW96 A 30" Safe end to RCP 1B 11/02/2000- Code ASME Section XI B9.11 09-017 Weld 17.5% Year 1995MW96 A RCP 1 B to 30" 11/03/2000- Code ASME Section XI B9.1 1 10-001 Safe end Weld 18% Year 1995/W96 A Safe end to 30" Pipe Weld (RCP 1 B 11/03/2000- Code ASME Section XI B9.1 1 10-002 Outlet) 44.2% Year 1995/W96 A SG#2 30" Nozzle to Nozzle Extension 11/06/2000- Code ASME Section XI B9.11 13-001 Weld 62.5% Year. 1995/W96 A to W3F1-2010-0014 Page 4 of 12 I '. +A.P I F:m nmfina Item Item  %

Number Comp. ID Description Coverage Date examined/Code Year 12" Pipe to 4/22/1997- Code ASME Section XI B9.11 17-033 Reducer Weld 57% Year 1980NW81 A 12" Pipe to 10/12/1989- Code ASME Section XI B9.11 19-006 Valve Weld 50% Year 1980/W81 A Valve end to 11/6/2003- Code ASME Section XI B9.11 19-008 12" Pipe Weld 50% Year 1995/W96 A 14" Pipe to 10/31/2000- Code ASME Section XI B9.1 1 21-066 Valve Weld 50% Year 1995/W96 A Elbow to 14" 10/26/2000- Code ASME Section Xl B9.11 22-023 Pipe Weld 88% Year 1995NW96 A 4" Pipe to 4" x 4" x 3" Tee 10/22/2000- Code ASME Section XI B9.11 25-009 Weld 75% Year 1995NW96 A 4" x 4" x 3" Tee to 4" Pipe 11/02/2000- Code ASME Section XI B9.1 1 25-015 Weld 75% Year 1995/W96 A 4" Pipe to Valve end 10/22/2000- Code ASME Section Xl B9.11 25-016 Weld 50% Year 1995NV96 A Valve end to 10/22/2000- Code ASME Section XI B9.1 1 25-018 4" Pipe Weld 50% Year 1995NW96 A 4" Pipe to 10/22/2000- Code ASME Section XI B9.1 1 25-019 Elbow weld 75% Year 1995/W96 A Elbow to 4" 10/22/2000- Code ASME Section Xl B9.1 1 25-020 Pipe Weld 75% Year 1995NW96 A Tee to 4" Branch Connection 10/22/2000- Code ASME Section XI B9.1 1 25-022 Weld 62% Year 1995/W96 A 8" x 6" Reducing Safe-end to 6" 10/20/2000- Code ASME Section XI B9.1 1 26-002 Elbow Weld 50% Year 1995/W96 A 8" x 6" Reducing Safe-end to 6" 10/20/2000- Code ASME Section XI B9.1 1 26-007 Elbow Weld 52% Year 1995/W96 A 2" Drain Nozzle to Safe 11/01/2000- Code ASME Section XI B9.21 15-006 end Weld 85.5% Year 1995/W96 A 2" Pipe to 10/22/2000- Code ASME Section XI B9.21 27-002 Elbow Weld 75% Year 1995/V96 A 2" Pipe to 10/22/2000- Code ASME Section Xl B9.21 27-004 Elbow Weld 75% Year 1995MV96 A Elbow to 2" 10/22/2000- Code ASME Section Xl B9.21 27-005 Pipe Weld 75% Year 1995/W96 A 2" Pipe to 10/22/2000- Code ASME Section Xl B9.21 27-006 Elbow Weld 75% Year 1995/W96 A to W3F1 -2010-0014 Page 5 of 12 I imit~irI R~I Fy~min~a$innQ Item Item  %

Number Comp. ID Description Coverage Date examined/Code Year Elbow to 2" 10/22/2000- Code ASME Section XI B9.21 27-007 Pipe Weld 75% Year 1995NV96 A 2" Pipe to 10/22/2000- Code ASME Section XI B9.21 27-008 Elbow Weld 75% Year 1995/N96 Add Elbow to 2" 10/22/2000- Code ASME Section Xl B9.21 27-009 Pipe Weld 75% Year 1995/W96 A 2" Pipe to 10/26/2000- Code ASME Section XI B9.21 27-010 Elbow Weld 75% Year 1995/W96 A.

Elbow to 2" 10/26/2000- Code ASME Section Xl B9.21 27-011 Pipe Weld 75% Year 1995/W96 A Tee to 2" Pipe 10/26/2000- Code ASME Section XI B9.21 27-037 Weld 62% Year 1995/W96 A Elbow to 2" 10/26/2000- Code ASME Section XI B9.21 27-038 Pipe Weld 75% Year 1995MV96 A 2" Pipe to 10/28/2000- Code ASME Section XI B9.21 27-054 Elbow Weld 75% Year 1995/W96 A Elbow to 2" 10/28/2000- Code ASME Section XI B9.21 27-055 Pipe Weld 75% Year 1995/W96 A 2" Pipe to 10/19/2000- Code ASME Section XI B9.21 28-001 Elbow Weld 75% Year 1995NW96 A Elbow to 2" 10/19/2000- Code ASME Section XI B9.21 28-002 Pipe Weld 75% Year 1995NW96 A 2" Pipe to 10/19/2000- Code ASME Section Xl B9.21 28-008 Elbow Weld 75% Year 1995/W96 A Elbow to 2" 10/19/2000- Code ASME Section XI B9.21 28-009 Pipe Weld 75% Year 1995/W96 A 2" pipe to 2" x 2" x 2" Tee 10/20/2000- Code ASME Section XI B9.21 28-012 Weld 70% Year 1995/W96 A 2" x 2" x 2" Tee to 2" Pipe 10/19/2000- Code ASME Section XI B9.21 28-013 Weld 75% Year 1995/W96 A 2" x 2" x 2" Tee to 2" Branch Connection 10/20/2000- Code ASME Section Xl B9.21 28-016 Weld 51% Year 1995NW96 A 2" pipe to 2" x 2" x 2" Tee 10/19/2000- Code ASME Section Xl B9.21 28-074 Weld 75% Year 1995/W96 A 2" x 2" x 2" Tee to 2" Pipe 10/19/2000- Code ASME Section XI B9.21 28-075 Weld 75% Year 1995/V96 A Tee to 2" Pipe 10/19/2000- Code ASME Section XI B9.21 28-076 Weld 62% Year 1995/W96 A 2" Pipe to 10/19/2000- Code ASME Section XI B9.21 28-077 Elbow Weld 75% Year 1995/V96 A Elbow to 2" 10/19/2000- Code ASME Section XI B9.21 28-078 Pipe Weld 75% Year 19951W96 A to W3F1-2010-0014 Page 6 of 12 Limited B-J Examinations Item Item  %

Number Comp. ID Description Coverage Date examined/Code Year 12" Safety Injection Nozzle to 30" 4/02/2002- Code ASME Section XI B9.31 08-008 Pipe Weld 50% Year 1995/W96 A Limited C-A Examinations Item Item  %

Number Comp. ID Description Coveraae Date examined/Code Year SG#2 Intermediate Shell to 3/3/1999- Code ASME Section XI Conical Shell Year 1980/W81A C1.10 04-026 Weld 56%

SG#2 Top Head Torus to 4/29/2005- Code ASME Section XI Top Head Year 1980/W81 A C1.20 04-029 Dome Weld 89%

Shut Down Heat /

Exchanger Shell to Flange Weld 9/04/2007- Code ASME Section XI C1.20 54-074 88% Year 1992/93 A Shut Down Heat Exchanger Shell to Flange Weld 9/04/2007- Code ASME Section XI C1.20 54-075 85% Year 1992/93 A Limited C-B Examinations Item Item %_

Number Comp. ID Description Coverage Date examined/Code Year SG#2 MS Nozzle to Top Head Dome 4/30/2005- Code ASME Section Xl 04-030 Weld 86% Year 1980/W81 .A C2.21 Limited C-F-1 Examinations Item Item %_

Number Comp. ID Description Coverane Date examined/Code Year C5.11 55-051 8" Pipe to 45.5%

Valve Weld 3/2/1999- Code ASME Section XI Year 1980/W81 A to W3F1-2010-0014 Page 7 of 12 Limited C-F-1 Examinations Item Item  %

Number Comp. ID Description Coverage Date examined/Code Year C5.11 64-001 Valve to 10" 50%

Pipe Weld 7/12/2000-Code ASME Section Xl Year 1995/96 A C5.11 56-001 LPSI Valve to 50%

10" Pipe Weld 1/28/2003- Code ASME Section XI Year 1995/96 A C5.11 56-002 LPSI 10" Pipe 50%

to Tee Weld 1/28/2003- Code ASME Section Xl Year 1995/96 A C5.11 56-003 LPSI Tee to 50%

10" Pipe Weld 1/28/2003- Code ASME Section XI.

Year 1995/96 A C5.11 61-071 14"x 8" 50%

Reducing Elbow to Flange Weld 6/27/2006- Code ASME Section XI Year 1995/96 A C5.11 55-001 10" valve to 50%

stainless pipe weld 8/28/2008- Code ASME Section Xl Year 1995/96 A C5.11 56-005 Tee to 10" 50%

Pipe Weld 1/28/2003- Code ASME Section XI Year 1995/96 A C5.11 56-043 10" Pipe to 50%

10" x 6" Reducer Weld 8/11/2003- Code ASME Section XI Year 1995/96 A C5.11 56-077 8" Pipe to 50%

Cont.

Penetration Weld 8/11/2003- Code ASME Section XI Year 1995/96 A C5.11 52-004 14" Elbow to 50%

Tee Weld 5/4/2005- Code ASME Section Xl Year 1995/96 A C5.21 60-131 4" Pipe to Tee 79% 2/4/2003- Code ASME Section Xl Year 1995/96 A C5.21 60-468 3" Elbow to 50%

Pipe Weld' 10/25/2000- Code ASME Section XI Year 1995/96 A C5.21 60-469 Pipe to 50%

Penetration Weld 10/25/2000- Code ASME Section Xl Year 1995/96 A to W3F1 -2010-0014 Page 8 of 12 1.1,2 Provide the start and end dates for the Waterford 3 second 10-year interval inservice inspection program.

Response

The second 120-month interval began on July 1, 1997 and ended May 31, 2008.

1.2 Request for Relief WF3-ISI-007, Examination Category B-A, Items B1.12. B 1.22, B1.30 and B1.40, Pressure Retaining Welds in Reactor Vessel 1.2.1 In the front portion of the licensee's submittal, ASME Code, Item Numbers B1.12, B13.22, B1.30, and B1.40 are listed for RR WF3-ISI-007. However, Table 1 only lists two item numbers (B13.22 and B13.40) with limited examination descriptions. Clarify whether there are only two ASME Code Item Numbers included within this request, or provide additional limited examination descriptions for Item Numbers B1.12 and B1.30 in Table 1.

Response

There are only 2 Code Items with limited code required examination volume coverage, B1.40 and B1.22. Items B1.12 and B1.30 were listed in error.

1.3 Request for Relief WF3-1SI-008, Examination Category B-D, Items B3.10, B3.20, and B3.30, Full Penetration Welded Nozzles in Vessels 1.3.1 The licensee states that during the second 10-year inservice inspection interval, 10 CFR 50.55a(g)(6)(ii)(C) mandated an implementation schedule for licensees to begin using Supplements to the 1995 Edition through the 1996 Addenda of the ASME Code,Section XI, Appendix VIII. However, the licensee further states that all examinations listed for Examination Category B-A were performed prior to this implementation schedule, and these reactor pressure vessel shell weld examinations used ASME Code,Section V, Article 4 of the 1980 Edition through Winter 1981 Addenda.

Specify which ASME Code section was used (Section V, Article 4 or Section XI, Appendix VIII) to determine code coverage for each of the subject welds and the date when each weld examination was performed.

Response

Waterford 3's Second Ten Year Interval is using Inspection Program "B" and not Inspection Program "A". Note that request numbered 1.3 above was for items B3.10, B3.20, and B3.30 as originally submitted by Waterford 3; the correct title for this request is associated with Items B3.1 10, B3.120 and B3.130. Waterford 3 Condition Report CR-WF3-2010-0729 documents Waterford 3's administrative errors associated with this submittal. WF3-ISI-008 Attachment 2 page 2 and 3 had the correct Code item numbers for the limited examinations. Also reflected in the request above was that Waterford 3 had stated that all examinations listed for Examination Category B-A were performed prior to this implementation schedule...; in actuality, Waterford 3 had stated to W3F1-2010-0014 Page 9 of 12 that the examinations were for Category B-D. Based on recognition of the NRC's intent for the request, Waterford 3 has provided the response for Examination Category B-D. See the table below for specific ASME Codes used to determine code coverage and dates of each examination.

I imit.~rI R-fl F~min~tinn~

Item Item  %

Number Comp2. ID Description Coverage Date examined/Code Year 42" Hot Leg Nozzle to 3/30/2002- Code ASME Section XI B3.130 03-010 SG#1 86.5% Year 1980/W81 A 30"Cold leg to 5/17/2008- Code ASME Section XI B3.130 03-011 SG#1 @450 66% Year 1995/W96 A 30"Cold leg to 5/17/2008- Code ASME Section Xl B3.130 03-012 SG#1 @3150 66% Year 1995/W96 A Pressurizer Surge Nozzle 2/25/1999- Code ASME Section XI B3.110 05-009 to Head Weld 64%, Year 1980/W81 A Pressurizer Spray Nozzle 2/25/1999- Code ASME Section XI B3.110 05-010 to Head Weld 74.8% Year 1980IW81 A Pressurizer Safety Nozzle 2/25/1999- Code ASME Section XI B3.110 05-011 to Head Weld 65.9% Year 1980/W81 A Pressurizer Safety Nozzle 2/25/1999- Code ASME Section XI B3.110 05-012 to Head Weld 65.9% Year 1980/W81 A Pressurizer Safety Nozzle 2/25/1999- Code ASME Section XI B3.110 05-013 to Head Weld 65.9% Year 1980/W81 A Pressurizer Surge Nozzle 2/26/1999- Code ASME Section I1 B3.120 05-014 Inner Radius 29.4% Year 1980/W81 A Pressurizer Spray Nozzle 2/25/1999- Code ASME Section XI B3.120 05-015 Inner Radius 60.4% Year 1980/W81 A Pressurizer*

Safety Nozzle 2/25/1999- Code ASME Section XI B3.120 05-016 Inner Radius 72% Year 1980/W81 A Pressurizer Safety Nozzle 2/25/1999- Code ASME Section XI B3.120 05-017 Inner Radius 72% Year 1980/W81 A Pressurizer Safety Nozzle 2/25/1999- Code ASME Section XI B3.120 05-018 Inner Radius 72% Year 1980/W81 A I_

to W3F1-2010-0014 Page 10 of 12 1.4 Request for Relief WF3-ISI-009, Examination Category B-F, Item B5.40, Pressure Retaining Dissimilar Metal Welds in Vessel Nozzles 1.4.1 In the response to the request for additional information, the licensee states that no surface examinations were performed for the subject pressure retaining dissimilar metal welds in vessel nozzles. However, the 1992 Edition through the 1999 Addenda of the ASME Code,Section XI, requires both volumetric and surface examinations for Item Number B5.40. Please confirm whether or not the required surface examinations were performed for the subject welds. If the required surface examinations were not performed, please provide the reference for the NRC document indicating approval for such exemptions.

Respon'se:

Waterford 3 was granted approval by the NRC (CNRI2003-00010, 8/26/03) to utilize Code Case N-663; therefore, the surface examinations were not required to be performed on the subject welds.

1.5 Request for Relief WF3-ISI-010, Examination Category B-J, Items B9.11, B9.21, and B9.31, Pressure Retaining Welds in Piping 1.5.1 Confirm that examination procedures, personnel and equipment were qualified in accordance with the ASME Code,Section XI, Appendix VIII for these piping welds.

Response

All examinations of B-J welds after the required implementation date of 1OCRF50.55a were in compliance with Appendix VIII. See response to 1.1.1 1.5.2 In the response to the request for additional information, the licensee does not show that both surface and volumetric examinations were applied for all of the subject welds. The 1992 Edition through 1993 Addenda of the ASME Code, Section X1 requires both volumetric and surface examinations for the subject components.

Please confirm whether or not the required surface examinations were performed for the subject welds. If the required surface examinations were not performed, please provide the reference for the NRC document indicating approval for such exemptions.

Response

Waterford 3 was granted approval by the NRC (CNRI2003-00010, 8/26/03) to utilize Code Case N-663; therefore, the surface examinations were not required to be performed on the subject welds.

to W3F1-2010-0014 Page 11 of 12 1.6 Request for Relief WF3-ISI-0011. Examination Category C-A, Items CI.10, and C1.20, Pressure Retaining Welds in Pressure Vessels 1.6.1 For steam generator Intermediate Shell-to-Conical Shell Weld 04-026, and Top Head Torus-to-Top Head Dome Weld 04-029, Table 1 lists the ultrasonic examination as being obstructed by a 4-inch wide insulation support ring and 14 insulation lugs, respectively. Provide further information to discuss whether the limited volumetric coverage could be increased by removal of the subject insulation and supporting appurtenances.

Response

Shell-to-Conical Shell Weld 04-026 was limited by the 4" wide insulation support ring.

Removal of this ring to increase coverage would present a hardship in increased dose to personnel removing the insulation below the ring to the bottom of the Steam Generator without a compensating increase in the level of quality and safety. Removal of the insulation would only increase the volumetric exam by approximately 2%.

Examination Volume Weld 04-029 was limited by 14 insulation lugs that are welded in place and cannot be removed. For informational purposes only, the Steam Generators are scheduled to be replaced in our next refueling outage, RF17.

1.7 Request for Relief WF3-ISI-012, Examination Category C-B, Item C2.21, Pressure Retaining Nozzle Welds in Vessels 1.7.1 The licensee's submittal states that limited ultrasonic examination is caused by eight insulation lugs located 5.25-inch from the weld centerline of the Nozzle-to-Top Head Dome Weld 04-030. Provide further information to discuss whether the limited volumetric coverage could be increased by removal of the subject insulation and supporting appurtenances.

Response

Weld 04-030 was not limited by insulation and insulation removal would not increase volumetric coverage. The insulation lugs affecting the volumetric coverage on Weld 04-030 are themselves welded in place and cannot be removed. For informational purposes only, the Steam Generators are scheduled to be replaced in our next refueling outage, RF17.

1.7.2 In the response to the request for additional information, the licensee states that no surface examinations were performed for the subject pressure retaining nozzle welds.

However, the 1992 Edition'through the 1993 Addenda of the ASME Code,Section XI requires both volumetric and surface examinations for Item Number C2.21 nozzle welds. Please confirm whether or not the required surface examinations were performed for the subject welds. If the required surface examinations were not performed, please provide the reference for the NRC document indicating approval for such exemptions.

to W3F1-2010-0014 Page 12 of 12

Response

A review of the ISI/NDE records indicated that the surface examination was not performed as required by the ASME Section XI Code of Record. This issue was documented in Waterford 3's corrective action process (CR-WF3-2010-0352). The last surface examination was completed on 10/13/92 with no indications found.

1.8 Request for Relief WF3-S1-013. Examination Category C-F-l, Items C5.11. and C5.21, Pressure Retaining Welds in Austenitic Stainless Steel or High Alloy Pipingi 1.8.1 In the response to the request for additional information, the licensee does not show that both surface and volumetric examinations were applied to all of the subject welds. The 1992 Edition through the 1993 Addenda of the ASME Code,Section XI requires both volumetric and surface examinations for both Item Number C5.11 and C5.21 piping welds. Please confirm whether or not the required surface examinations were performed for the subject welds. If the required surface examinations were not performed, please provide the reference for the NRC document indicating approval for such exemptions.

Response

Waterford 3 was granted approval by the NRC (CNRI2003-00010, 8/26/03) to utilize Code Case N-663; therefore, the surface examinations were not required to be performed on the subject welds.

1.9 Request for Relief WF3-ISI-014, Examination Category R-A, Item R1.20, Risk-Informed Piping Examinations 1.9.1 The licensee states ASME Code,Section XI, Code Case N-716, Alternative Piping Classificationand Examination Requirements, Section X1, Division 1, requirements were implemented for the subject weld volumetric examinations. However, the licensee's submittal does not discuss NRC approval for use of this Code Case.

Please provide the reference for the NRC Safety Evaluation, indicating approval, for performing the subject weld examinations under the requirements of ASME Code, SectionXI, Code Case N-716. State whether any conditions were imposed by NRC for the use of the Code Case, and how these conditions were satisfied.

Response

A review of Category R-A Item R1.20 determined that there were no limited ultrasonic examinations during the 2 nd inspection interval. This Request for Relief, WF3-1SI-014, Examination Category R-A, Item R1.20, Risk-Informed Piping Examinations is hereby withdrawn as noted in the cover letter to this response.

Attachment 2 To W3F1-2010-0014 Response to NRC Request for Additional Information dated January 6, 2010 Re:

Waterford 3 Steam Electric Station, Unit 3 Requests for Relief from ASME Section XI Volumetric Examination Requirements - Second 10-Year Inservice Inspection Interval Extracted Text from Waterford 3's ISI Program j

SECTION 1: Program Section No: CEP-ISI-001 INTRODUCTION Revision No.: 10 Page No., 8 of 17 TABLE OF CONTENTS VOLUME I (Inservice Inspection Requirements) EFFECTIVE REVISION SECTION 1 - INTRODUCTION 10 SECTION 2- LATER EDITIONS AND ADDENDA 10 SECTION 3- CODE CASES 10 SECTION 4- RELIEF REQUESTS 10 SECTION 5- PRESSURE TESTING 10 SECTION 6- CALIBRATION STANDARDS 10 SECTION 7- CLASS 1 PUMPS AND VALVES 10 SECTION 8 - EXAMINATION SELECTION

SUMMARY

(Information moved to Scheduleworks) 10 SECTION 9 - SUCCESSIVE EXAMINATIONS 10 SECTION 10 - RISK-INFORMED SELECTIONS 10 SECTION 1I- ,jAUGMENTED EXAMINATIONS 10 SECTION 12 - PROGRAM CHANGE NOTICE 10 APPENDICES A ISI Line List 10 B Period I Exams (Information moved to Scheduleworks) .10 C Period 2 Exams (Information moved to Scheduleworks) 10 D Period 3 Exams (Information moved to Scheduleworks) 10 E Drawing Index 10 F Class I ISI Drawings 10 G

  • Class 2 ISI Drawings 10 H-Z Reserved 10

CEP-ISI-00 I-PCN-21, CE.P-ISI-001 -

PCN-23t SECTION 1: Program Section No: CEP-ISI-001 INTRODUCTION Revision No.: 10 Page No.: 9 of 17 1.0 GENERAL PLANT DESCRIPTION AND PROGRAM REQUIREMENTS This Program Section contains the details for the second 120-month Inservice Inspection (ISI) Program interval for the inspection of Class 1, 2, and 3 pressure retaining components and their supports- at the Waterford 3 Steam 'Electric Station, which is a Combustion Engineering two loop PWR design.

The initial 120-month ISI Program commenced with commercial operation on September 24, 1985. However, by authorization from the Director of the Office of Nuclear Regulation (Reference GNRI 96-00244) the first 120-month interval was extended until June 30, 1997. The second 120-month interval began on July 1, 1997 and will continue through May 3 1, 2008. All ENS sites including Waterford will align the start of their third interval on May 31, 2008. The coordination of refuiel outages' and periods within the second interval is shown in Figure 1.1.

Changes to the contents of this Program Section shall be requested in accordance with Section 12, Program Change Notice.

2.0 CODE OF RECORD FOR THE SECOND INTERVAL The current Code of record is the 1992 Edition with portions of later Addenda as described in Section 2 of this Program Section. Due to the unknown implementation schedule for Section XI-Appendix VIII, the NRC authorized W3 (Reference GNRI 96-00244) to perform ultrasonic examinations in accordance with the 1980 Edition with the Winter of 1981 Addenda as specified in the ISI plan for the first interval. The use of the 1980 Edition with the Winter of 1981 Addenda is limited until such time when changes to 10 CFR 50.55a require the use of ASME Section XI, Appendix VIII. Section 2 provides a detail listing of the applicable editions and addenda of Section XI as it applies to ultrasonic examinations based on current 10 CFR 50.5 5a requirements.

Section 3 of this Program Section, Code Cases, lists the adopted Code Cases for Waterford 3. Section 4 of this Program Section, list the Relief Request used in this program.

3.0 SCOPE The ISI program includes this program section along with the Scheduleworks module of the IDDEAL database. This Program Section along with Scheduleworks identifies items, such as welds, equipment, and supports that are subject to examination during the second ten-year interval in accordance with ASME Section XI and items requiring "augmented" examinations. These augmented examinations are the result of regulatory input (Generic Letters, IE Bulletins, Licensing Commitments, etc.) and/or service history (NSSS vendor correspondence, condition reports, etc.) and are performed in conjunction with or in addition to Code examinations.

SECTION 1: Program Section No: CEP-ISI-00 1 INTRODUCTION Revision No.: 9 Page No.: 10 of 17 The ISI Program includes the following:

  • Piping weld examination

" Pipe and equipment support examination

  • Pump and valve body internal examination
  • Bolting examination
  • Pressure tests For each component, this Program Section also provides information regarding examination method and the inspection period during which the component is scheduled to be examined. ISI piping isometric drawings and equipment sketches depicting the location of the components are included.

The Pump and Valve Inservice Test (IST) Program is a separate independent Program Section. The requirements for IST are not included in the scope of this Program Section.

Snubbers are selected and functionally tested in accordance with W-3 Technical Specification 3/4.7.8, "Snubbers", as opposed to ASME Section XI Code requirements.

All component supports associated with snubbers are visually examined (VT-3) in accordance with the ASME Code Section XI, 1992 Edition, in conjunction with the Snubber test program. The Snubber Test Program is not included in the scope of this Program Section.

The Inservice Inspection (ISI) Program for Containment is a separate independent Program Section. The requirements for ISI of the containment are not included in the scope of this Program Section.

4.0 REGULATORY GUIDANCE The ISI program incorporates the augmented examination requirements of the following Regulatory Guides, IE Bulletins, NUREGS, Standard Review Plans and Generic Letters:

Reg. Guide 1.14 Reactor Coolant Pump Flywheel Integrity.

Reg. Guide 1.150 Ultrasonic Testing of Reactor Vessel Welds during Preservice and Inservice Examination SRP 3.6.1 Plant Design For Protection Against Postulated Piping Failures In Fluid Systems Outside Containment" (NUREG-0800)

SRP 3.9.3 ASME Code Class 1, 2 and 3 Components, Component Supports, and Core Support Structures" (NUREG-0800)

SECTION 1: Program Section No: CEP-ISI-001 INTRODUCTION Revision No.: 9 Page No.:. 11 of 17 SRP 5.2.4 Reactor Coolant Pressure Boundary Inservice Inspection and Testing (NUREG-0800)

SRP 5.4.1.1 Pump Flywheel Integrity'(NUREG-0800)

SRP 6.6 Inservice Inspection of Class 2 and 3 components (NUREG-0800)

IE Bulletin 88-08 Thermal Stresses in Piping Connected to Reactor Coolant Systems.

5.0 EXAMINATIONS 5.1 Examination Criteria The selection of items for inservice inspection is based on application of ASME Section XI examination criteria in paragraphs IWB-1200, IWC-1200, IWD-1200 and IWF-1200 and on augmented inspection requirements identified in Section 11, Augmented Examinations, of this Program Section. The piping exempted per IWB-1220, IWC-1220 and IWD-1220 is listed in Appendix A, Line List, of this Program Section. Class 2 components were exempted from volumetric and surface examination using the criteria contained in IWC-1220, except asfollows, stainless steel piping with nominal wall thickness less than 3/8-inch and nominal pipe size > 4-inch, has been included as Examination Category C-F-i, Item Number C5.10. This piping had received volumetric examinations during the First Interval under a "supplemental' program. Per IWF-1230, the supports on exempt piping and associated equipment and components are also exempt.

The performance of Inservice inspection and NDE activities including the qualification of inspection and NDE personnel shall be in accordance with ASME Section XIas defined in Section 2.0.

Items that cannot be examined per ASME Section XI requirements are identified in Relief Requests contained in Section 4 of this Program Section.

5.2 Pump/Valve Examination Internal surfaces of Class 1 valve bodies exceeding 4 inch nominal size are subject to visual examination per Exam Category B-M-2. The grouping of Class 1 valve bodies is discussed in Section 7 of this Program Section.

' /-,lC- -X3r i 45 SECTION 1: Program Section No: CEP-ISI-001 INTRODUCTION Revision No.: l0t, Page No.: 12 of 17 5.3 Pressure Testing Class 1, 2, and 3 pressure retaining boundaries are defined on the Flow Diagrams.

These boundaries shall be subject to pressure test as specified in Section 5 of this Program Section.

5.4 Integral Attachments Integral attachments are examined in accordance with Code Case N-509. As required by the NRC's approval, a minimum of 10% of all nonexempt integral attachments are required to be examined. Additionally, when evidence of component support deformation (e.g., broken, bent, or pulled out parts) is identified during operation, refueling, maintenance, examination, inservice inspection, or testing, the associated integral attachments shall be examined in accordance with'the requirements of the Code Case. If conditions are detected that do not meet the acceptance criteria of the Code Case, additional and successive examinations shall be performed in accordance with IWB, IWC or IWD 2420 and 2430. Integral attachments examined because of support deformation cannot be credited towards the examination requirements for the period or interval.

5.5 Incomplete or Missed Examinations Resolution and tracking of incomplete or missed examinations shall be in accordance with the PCN/CR process as described below:

5.5.1 The implementer should submit a PCN to CEP in a timely manner. The PCN should contain the following:

5.5.1.1 The affected component.

5.5.1.2 The examination requirement that has not been, or will not be, met.

5.5.1.3 Reason for incomplete or missed examination.

5.5.1.4 Alternate examinations performed or recommended, (i.e. best effort vs. VT-i, etc.) to include reasons why this is acceptable.

5.5.1.5 For partial examinations, the extent of coverage the component received or will receiveusing approved methods.

5.5.2 CEP should disposition the PCN as necessary.

5.5.3 If a relief request is required:

5.5.3.1 CEP should develop and submit the necessary documentation to the NRC.

SECTION 1: Program Section No: CEP-ISI-001 INTRODUCTION Revision No.: 10 Page No.: 12oof 17, 5.5.3.2 If the relief request is approved, CEP should incorporate the PCN into the program plan.

5.5.3.3 If the relief request is disapproved, CEP should initiate a CR.

5.5.4 If it is discovered that a required examination has been missed and cannot be examined before the end of the inspection period in accordance with the Program Plan, a CR should be initiated 6.0 REPORTS 6.1 ISI Summary Report 6.1.1 Waterford 3 has adopted Code Case N-532-1 "Alternative Requirements to Repair and Replacement Documentation Requirements and Inservice Summary Report Preparation and S ubmission a s Required b y I WA-4000 and IWA-6000."

6.1.2 Code Case N-532-1 requires completion of Form OAR- I "Owners Activity Report" after each refueling outage.

6.1.2.1 It is to include ASME Activities performed during the outage and the previous operating cycle.

6.1.2.2 It shall be completed and submitted to the NRC within 90 days of Q-completion of the refueling outage.

SECTION 1: Program Section No: CEP-ISI-001 INTRODUCTION Revision No.: 10 Page No.: 13 of 17 6.1.3 Waterford had adopted Code Case N-532 through a request for alternative which committed to submit all OAR reports generated at the end of the period. This request was authorized until such time as the Code Case was adopted in Regulatory (Reg) Guide 1.147. Code Case N-532 has not been Q.

adopted in the Reg Guide. However, Revision 13 to Reg Guide 1.147 did approve Code Case N-532-1. Entergy has elected to voluntarily update to 15 Rev 1 of the Code Case. Waterford 3 will submit the OAR asrequired Code Case N-532-1 commencing at the end of RF-12.

6.1.4 Each OAR-1 is to contain the following information formatted in accordance with Code Case N-532-1.

6.1.4.1 Table 1 "Abstract of Examinations and Tests" shall contain the following information for each examination category:

6.1.4.1.1 The examination category, 6.1.4.1.2 Total examinations required for the interval, 6.1.4.1.3 Total examinations credited for the period,,

6.1.4. i.4 Total examinations credited (%) for the period, 6.1.4.1.5 Percentage of total examinations credited for the interval, 6.1.4.1.6 Applicable remarks.

6.1.4.2 Table 2 "Items with flaws or relevant conditions that required evaluation for continued service" shall contain the following infoirnation for all items with flaws or other relevant conditions requiring evaluation for continued service:

6.1.4.2.1 The examination category, 6.1.4.2.2 Item number, 6.1.4.2.3 Item description, 6.1.4.2.4 Flaw characterization, 6.1.4.2.5 Whether the flaw or condition was found in a scheduled Section XI examination or test.

6.1.4.2.6 Table 3 "Abstract of repairs, replacements, or corrective measures required for continued service" shall be in accordance with CEP-R&R-001, ASME Section XI, Division 1, Repairs and Replacements.

e /_ /

c jP--L SS -o(0 -(

.v SECTION 1: Program Section No: CEP-ISI-001 INTRODUCTION Revision No.: 10 Page No.: 14 of 17 7.0 PROGRAM ARRANGEMENT 7.1. This ISI Program Section is divided into the following items:

7.1.1. Table of Contents 7.1.2. Section 1 - Introduction 7.1.3. Section 2 - Addenda Paragraphs 7.1.4. Section 3 - Code Cases 7.1.5. Section 4 - Relief Requests 7.1.6. Section 5 - Pressure Testing 7.1.7. Section 6 - Calibration Standards 7.1.8. Section 7-Class 1 Pumps and Valves 7.1.9. Section 8 - Examination Selection Summary (Information moved to Scheduleworks) 7.1.10. Section 9 - Successive Examinations 7.1.11. Section 10 - Risk-Informed Selections 7.1.12. Section 11 - Augmented Examinations 7.1.13. Section 12 - Program Change Notice 7.1.14 Inservice Inspection Examination Appendices B through D have been removed from the program. Scheduling and component information is controlled by the Scheduleworks module of the IDDEAL database in files SchedW3_iSI.mdb. The IDDEAL database is controlled in accordance with CEP-COS-100.

7.2. Appendices E through H contain the isometric drawings for the ISI Program. The isometric drawings identify locations of Class 1 and 2 piping and components that are. subject to inspection. Exempted piping may be shown when clarity or continuity is appropriate.

7.3 Schedule of Inspection The ten year interval as it is divided into periods is depicted, included its coordination with refuel outages, in Figure 1.1. Inspection period 1 consists of the first thirty-six (36) calendar months of the interval. Inspection period 2 consists of forty-eight (48) calendar months following the first period and inspection period 3.

consists of the last thirty-six (36) months, making, a total of 120 months, or 10 years. Examinations are scheduled to meet the requirements of Tables IWB, C, D-2412-1 and IWF-2410-2 as applicable.

SECTION 1: Program Section No: CEP-IS1-001 INTRODUCTION Revision No.: 10 Page No.: 15 of 17 7.4. Symbols and Abbreviations 7.4.1. The following abbreviations are used in Scheduleworks. for examination items. In some instances, these abbreviations may be combined with the use of a hyphen "-" to describe two different items joined by a weld:

Abbreviation Description AC Chilled Water BD Steam Generator Blowdown BM Boron Management CA Containment Air CC Component Cooling Water CD Condensate CH Chemical And Volume Control CS Containment Spray DW Demineralized Water EA Emergency Diesel Generator Air Supply EF Emergency Feedwater EG Emergency Diesel FP PlantFire Protection FS Fuel Pool FW Main (and Emergency) Feedwater HPSI High Pressure Safety Injection HV Heating, Ventilation, Air Conditioning HX Heat Exchanger IA .Instrument Air LPSI Low Pressure Safety Injection LO Lube Oil MS Main Steam NG Nitrogen Gas PZR Pressurizer RC Reactor Coolant SA Station Air SI Safety Injection SL Sampling System WM Waste Management 7.5. Weld Examination Coverage- Examination coverage includes essentially 100% of the weld length except as permitted below:

7.5.1. Examination coverage may be reduced when allowed by Code or when specific relief from the Code required coverage has been granted by the

SECTION 1: Program Section No: CEP-ISI-001 INTRODUCTION Revision No.: 10 Page No.: 16 of 17 NRC. Where relief is granted, it is documented in Section 4 of this

( Program Section.

7.5.2. When essentially 100% of the examination volume or area cannot be examined due to component interference or part geometry, a reduction in examination coverage on any Class I or 2 weld is acceptable provided the reduction in coverage for that weld is less than 10%. Applicable examination records identify both the cause and % of reduced examination coverage. (As permitted by Code Case N-460)

CEP-ISI-001-PCN-25 CEP-ISI-001-PCN- 15 CEP-ISI-001-PCN- 11 SECTION 1: Program Section No: CEP-ISI-001 INTRODUCTION Revision No.: 10 Page No.: 17 of 17 RF 9 RF 10 RF 11 RF 12 RF 13 RF 14 RF 15 RF 16 4/99 9/00 4/02 9/03 3/0 5 9/06 4/08 10/09 1/9.7 1/98 1/99 1/00 1/01 1/02 1/03 1/04 1/05 1/06 1/07- 1/08 1/09 I I , V I I I V F I II , 9

    • 1 I I F

End of 1st Interval I

7I 6/97 6/00 6/04 6/0 1st Period 2nd Period 3rd Period ON , 1 36 Months - 01--4 48 Months 0j4 - 1 36 Mbnths End of 2nd I Interval Adjusted 3r Adjusted 2nd _ _ _ _ _ Period 1 year extension of -' ,9Period 1st Period CIEP-ISI-003 I Extension END 6/01. END RF13 RF16 FIGURE 1.1

SECTION 2 Program Section No: CEP-ISI-00 1 LATER EDITIONS Revision No.: 10 AND ADDENDA Page No.: 1 of 8 SECTION 2 LATER EDITIONS AND ADDENDA REVISION STATUS SHEET PAGE NO. REVISION 1 10 2 10 3 9 4 9 5 10 6 10 7 10 8 10

SECTION 2 Program. Section No: CEP-ISI-00I LATER EDITIONS Revision No.: 10 AND ADDENDA Page No.: 2 of 7.

1.0 Later Edition and Addenda 1.1 Within the provisions of ASME Section XI and 10 CFR 50.55a(g)(4)(iv), the use of later Editions and/or Addenda of ASME Section XI is permitted with specific NRC approval. This provision has been further clarified by the NRC (Reference Ltr # 0CNA109510 from the NRC Region IV Office) ), to mean that their prior approval for use of later Edition/Addenda listed in 10 CFR 50.55a(b)(2) is not required and that only notification within a reasonable time frame is necessary.

Additionally 10 CFR 50.55a(g)(4)(iv) requires that all related requirements of the edition or addenda are met.

1.2 Additionally, as the NRC determines appropriate through changes to 10 CFR 50.55a, they sometimes mandate the use of later portions of ASME Section XI.

Section 2 of this program section identifies those later Editions and/or Addenda that have been included into the W3 ISI program based on NRC approval or requirements.

2.0 1993 Addenda 2.1 Prior to the NRC approval of the 1992 Edition of ASME Section XI, by incorporation into 10 CFR 50.55a(b), the NRC authorized the use of the 92 Edition with select portions of the 1993 Addenda at W3 (Reference GNRI 96-00244). Table 2.1 identifies the portions of the 1993 Addenda that have been adopted by Entergy and approved by the NRC for use with the W3 ISI program.

TABLE 2.1 1993 ADDENDA Code Paragraph Code Change Description

1. Table IWA-5210-1 Table IWA-5210-1 is revised to reflect a change in referenced paragraphs for Test Temperature requirements from IWB/IWC-5230 to LWB/IWC-5240 to be consistent with changes in paragraph numbers in IWB and IWC. This change has no impact on examination and test requirements.
2. Paragraphs IWA-5250(a)(2) Paragraph IWA-5250(a)(2) is revised to delete the requirement for removal and examination of bolting in leaking bolted connections in gaseous systems.
3. IWA-5265(b): Paragraph IWA-5265(b) is revised to clarify that even if the test pressure at the highest elevations is

SECTION 2 Program Section No: CEP-ISI-001 LATER EDITIONS Revision No.: 9 AND ADDENDA PageNo.: 3 of 7 TABLE 2.1 1993 ADDENDA Code Paragraph Code Change Description not achieved, the maximum test pressure that any component is allowed to see is 106% of the specified test pressure.

4. Table IWB-2500-1, Table IWB-2500-1, Examination Category B-P is Examination Categories B-P revised to delete the requirement for the Class I hydrostatic test once per interval.
5. Table IWB-2500-1, Table IWB-2500-1, Examination Category B-E is Examination Categories B-E deleted. The requirements of this category involved duplicate examinations that were already addressed in Category B-P. This change has no affect on examinations and is considered to be a clarification.
6. Article IWB-5000 in its entirety Article IWB-5000 is rewritten for clarity. Also the boundary requirements have been revised to change the end of the interval test boundary requirements for the hydrostatic test to the end of the interval requirements for the system leakage test. This is consistent with deletion of the periodic hydrostatic test requirement from Category B-P.

7 Table IWC-2500-1, Table IWC-2500-1, Examination Category C-H is Examination Category C-H revised to delete the requirement for the Class 2 hydrostatic test once per interval.

8 Article IWC-5000 in its entirety Article IWC-5000 is rewritten for clarity. Also, the boundary requirements have been revised to exempt open-ended discharge piping from the system leakage test.

9. Article IWD-5000 in its entirety Article IWD-5210(b) has been rewritten for clarity.

Paragraph IWD-5222(g) which required pressure tests of open-ended piping discharging to the suppression pool is deleted and IWD-5222(f) is rewritten to exempt all open-ended piping (including open-ended suppression pool piping). The boundary requirements have been revised to exempt open-ended discharge piping from the system leakage test.

e-,E 0 ~6 V P.;~j-i 1?

SECTION 2 Program Section No: CEP-ISI-001 LATER EDITIONS Revision No.: 10 AND ADDENDA Page No.: 4 of 8 3.0 1995 Edition through and Including the 1995 Addenda 3.1 As discussed in Paragraph 1.1, the NRC has approved the use of the 1995 Edition, through the 1995 Addenda in 10 CFR 50.55a(b). Table 2.2 identifies the portions of the 1995 Addenda that have been adopted by Entergy, for use with the W3 ISI program TABLE 2.2 1995 ADDENDA Related Code Code Change Description Requirements Paragraph

1. IWA-5213 IWA-5213 is revised to reflect a change in the required None hold time after pressurization to test conditions prior to, performing the visual examinations during the conduct of a system leakage test. This change eliminates the hold time after attaining the test pressure and temperature for periodic pressure testing.

Repair/Replacement pressure testing hold times remain unchanged..

4.0 1995 Edition Through and Including the 1996 Addenda 4.1 On September 22, 1999 10 CFR 50.55a was revised mandating the implementation of the 1995 Edition, through and including the 1996 Addenda of ASME Section XI; Appendix VIII, "Performance Demonstration for Ultrasonic Examination Systems". Appendix VIII is comprised of multiple supplements for varying scopes of ultrasonic application. The NRC has mandated each supplement's use in accordance with a specific schedule for implementation.

Additionally, by implementing Appendix V.111 for each of the specific supplements, it also requires the use of Appendix VII from the 1995 Edition through the 1996 Addenda within the same schedule.

4.2 For those items pertaining to paragraph 4.1 above, the Examination Category Item I Numbers listed in Table 2.3 shall be ultrasonically examined in accordance with.

ASME Section XI, 1980 Edition through and including the 1981 Winter Addenda until the specified date. Beginning with the specified date, the ultrasonic examinations (preservice and inservice) shall be in accordance with ASME Section XI, Appendix VIII, 1995 Edition through and including the 1996 Addenda and the additional requirements of 10 CFR 50.55a.

SECTION 2 Program Section No: CEP-ISI-001 LATER EDITIONS Revision No.: 10 AND ADDENDA Page No.' 5 of 8 4.3 Personnel performing ultrasonic examination of the Examination Category Item Numbers listed in Table 2.3 shall be qualified in accordance with ASME Section XI, Appendix VII, 1992 Edition until the specified date. Beginning with the specified date, personnel performing these examinations (preservice and inservice) shall be qualified in accordance with ASME Section XI, Appendix VII, 1995 Edition through and including the 1996 Addenda and the additional requirements of 10 CFR 50.55a. When updating to the requirements of Appendix VII, 1995 Edition, 1996 Addenda, IWA-2300 accepts existing qualifications using SNT-TC-1A until the re-qualification is required. Re-qualification shall be in full compliance with the 1995 Edition through the 1996 Addenda including the use of CP-189.

4.4 On January 5, 2006 the NRC granted permission for all ENS Sites to use the 1995 Edition, 1996 Addenda for ultrasonic examinations performed on items not covered under Appendix VIII. See Section 4 for reference to approved request.

TABLE 2.3 1995 EDITION, 1996 ADDENDA IMPLEMENTATION SCHEDULE Specified Date to New Appendix VIII Begin New Examinations New Certification Item Number Requirements Requirements Requirements Notes Examination Category: B-A B1.1 1 11/20/00 Supps. i, 4 & 6 App. VII, 95E, 96A B 1.12 11/20/00 Supps. 1,4 & 6 App. VII, 95E, 96A B1.21 Clad 11/20/00 Supps. 1, 4 & 6 App. VII, 95E, 96A B1.22 Clad 11/20/00 Supps. 1, 4 & 6 App. VII, 95E, 96A B1.30 1/5/2006 Appendix VIII does App. VII, 95E, 96A

  • ______not apply B1.40 1/5/2006 Appendix VIll does App. VII, 95E, 96A not apply B1I.51 11/20/00 Supps. 1, 4 & 6 App. VII, 95E, 96A Examination Cate ory: B-B B2.1 1 1/5/2006 Appendix VIIi does App. VII, 95E, 96A not apply B2.12 1/5/2006 Appendix VIII does App. VII, 95E, 96A not apply B2.21 1/5/2006 Appendix VIII does App. VII, 95E, 96A not apply B2.22 1/5/2006 Appendix VIII does App. VII, 95E, 96A not apply B2.31 1/5/2006 Appendix VIII does App. VII, 95E, 96A not apply B2.32 1/5/2006 Appendix VIII does App. VII, 95E, 96A not apply

SECTION 2 Program Section No: CEP-ISI-001 LATER EDITIONS Revision No.: 10 AND ADDENDA Page No.: 6 of 8 TABLE 2.3 1995 EDITION, 1996 ADDENDA IMPLEMENTATION SCHEDULE Specified Date to New Appendix VIII Begin New Examinations New Certification Item Number Requirements Requirements Requirements Notes B2.40 1/5/2006 Appendix VIII does App. VII, 95E, 96A not apply B2.51 1/5/2006 Appendix VIII does App. VII, 95E, 96A not apply B2.52 1/5/2006 Appendix VIII does App. VII, 95E, 96A not apply B2.60 1/5/2006 Appendix VIII does App. VII, 95E, 96A

."....- ... ...... no t app ly......

B2.70 1/5/2006 Appendix VIII does. App. VII, 95E, 96A not apply B2.80 1/5/2006 Appendix VIII does App. VII, 95E, 96A

_not apply Examination Category: B-D B3.90 11/22/02 Supps. 1 & 7 App. VII, 95E, 96A B3.100 11/22/02 Supps. I & 5 App. VII, 95E, 96A B3.1 10 1/5/2006 Appendix VIII does App. VII, 95E, 96A not apply B3.120 1/5/2006 Appendix VIII does App. VII, 95E, 96A not apply B3.130 1/5/2006 Appendix VIII does App. VII, 95E, 96A not apply B3.140 1/5/2006 Appendix VIII does App. VII, 95E, 96A not apply B3.150 1/5/2006 Appendix VIII does App. VII, 95E, 96A not apply B3.160 1/5/2006 Appendix VIII does App. VII, 95E, 96A B3.160 not apply Examination Category: B-F B5.10 11/22/02 Supps. 1 & 10 App. VII, 95E, 96A B5.40 11/22/02 Supps. 1 & 10 App. VII, 95E, 96A B5.50 11/22/02 Supps. I & 10 App. VII, 95E, 96A Examination Cate gory: B-G-I I B6.20 5/22/00 Supps. I & 8 App. VII, 95E, 96A B6.30 5/22/00 Supps. 1 & 8 App. VII, 95E, 96A B6.40 5/22/00 Supps. 1 & 8 App. VII, 95E, 96A 36.150 5/22/00 Supps. I & 8 App. VII, 95E, 96A B6.180 5/22/00 Supps. I & 8 App. VII, 95E, 96A B6.210 5/22/00 Supps. 1 & 8 App. VII, 95E, 96A Examination Category: B-J B9.11 Stainless 5/22/00 Su 1 & 2.

1s. Ap. VII, 95E, 96A

SECTION 2 Program- Section No: CEP-ISI-001 LATER EDITIONS Revision No.: 10 AND ADDENDA Page No.: 7 of 8 TABLE 2.3 1995 EDITION, 1996 ADDENDA IMPLEMENTATION SCHEDULE Specified Date to New Appendix VIII Begin New Examinations New Certification Item Number Requirements Requirements Requirements Notes B9.12 Stainless 5/22/00 Supps. 1 & 2 App. VII, 95E, 96A B9.31 Stainless 5/22/00 Supps. I & 2 App. VII, 95E, 96A B9.11 Ferritic 5/22/00 Supps. I & 3 App. VII, 95E, 96A B9.12 Ferritic 5/22/00 Supps. 1 & 3 App. VII, 95E, 96A B9.31 Ferritic 5/22/00 Supps. 1 & 3 App. VII, 95E, 96A B9.11 Dissimilar 11/22/02 Supps. I & 10 App. VII, 95E, 96A B9.12 Dissimilar 11/22/02 Supps. I &10 App. VII, 95E, 96A B9.31 Dissimilar . t11/22/02 Supps. 1 & 10' App. VII, 95E, 96A Examination Cate ory: B-L- I AND B-M- I B12.10 1/5/2006 Appendix VIII does App. VII, 95E, 96A not apply B 12.40 1 1/5/2006 Appendix VIII does App. VII, 95E, 96A not apply Examination Cateory: B-0 B14.10 1/5/2006 Appendix VIII does App. VII, 95E, 96A 11 1 not apply Examination Category: C-A I

C 1.10 1/5/2006 Appendix VIII does App. VII, 95E, 96A

. not apply C .20 1/5/2006 Appendix VIII does App. VII, 95E, 96A not apply C1.30 1/5/2006 Appendix VIlI does App. VII, 95E, 96A

.__.not_ _ _ __ apply ....

Examination Category: C-B C2.21 1/5/2006 Appendix VIII does App. VII, 95E, 96A not apply C2.22 1/5/2006 Appendix VIII does App. VII, 95E, 96A not apply C2.32 1/5/2006 Appendix VIII does App. VII, 95E, 96A not apply Examination Category: C-D C4.10 5/22/00 Supps. 1 & 8 App. VII, 95E, 96A C4.20 5/22/00 Supps. I & 8 App. V1I, 95E, 96A C4.30 5/22/00 Supps. 1 & 8 App. VII, 95E, 96A C4.40 5/22/00 Supps. 1 & 8 App. VII, 95E, 96A Examination Category: C-F-i C5.11 SS or HA 5/22/00 Supps. 1 & 2 App. VII, 95E, 96A C5.12 SS or HA 5/22/00 Supps. I & 2 App. VII, 95E, 96A C5.21 SS or HA 5/22/00 Supps. 1 & 2 App. VII, 95E, 96A C5.22 SS or HA 5/22/00 Supps. I & 2 App. VII, 95E, 96A

<2 6 p ".--X-c -P 34 SECTION 2 Program Section No: CEP-ISI-001 LATER EDITIONS Revision No.: 10 AND ADDENDA Page No.: 8 of 8 TABLE 2.3 1995 EDITION, 1996 ADDENDA IMPLEMENTATION SCHEDULE Specified Date to New Appendix VIII Begin New Examinations New Certification Item Number Requirements Requirements Requirements Notes

-Ds a2Sp1 0. , ,

C5.11 Dissimilar 11/22/02 Supps. I & 10 App. VII, 95E, 96A C5.12 Dissimilar 11/22/02 Supps. 1 & 10 App. VII, 95E, 96A C5.21 Dissimilar 11/22/02 Supps. I & 10 App. VII, 95E, 96A C5.22 Dissimilar 11/22/02 Supps. I & 10 App. VII, 95E, 96A_____

Examination Category: C-F-2 C5.51 5/22/00 Supps. 1 & 3 App. VII, 95E, 96A C5.52 5/22/00 Supps. 1 & 3 App. VII, 95E, 96A C5.61 5/22/00 . &3 Supps.- &3 App. VII; 95E, 96A ........

C5.62 5/22/00 Supps. 1 & 3 App. VII, 95E, 96A

SECTION 3 Progrnir Section No: CEP-ISI-001 CODE CASES Revision No.: 10 PageNo.: 1 of 7 SECTION 3 CODE CASES REVISION STATUS SHEET PAGE NO. REVISION 1 10 2 9 3 10 4 10 Li 5 10 Hk 6 9 7 10

. ¸ I . i SECTION 3 Program Section No: CEP-ISI-001 CODE CASES Revision No.: 10 Page No.: 2 of 6 1.0 Adoption of Code Cases This Section addresses the adoption of Code Cases during the Second Inservice Inspection Interval. All Code Cases adopted for ASME Section XI activities for use during the Second Interval are listed in Tables 3.1, 3.2, and 3.3. The use of Code Cases is in accordance with ASME Section XI, IWA-2440, 10 CFR 50.55a, and Regulatory Guide 1.147. As permitted by ASME Section XL with the additional provisions of Regulatory Guide 1.147, ASME Section XI Code Cases may be adopted and used as described below.

1.1 Adoption of Code Cases Listed for Generic Use in Regulatory Guide 1.147 Code Cases that are listed for generic use in the latest revision of Regulatory Guide 1.147 may be included into the ISI program provided any additional provisions specified in the Regulatory Guide are also incorporated.

1.2 Adoption of Code Cases Not Listed in Regulatory Guide 1.147 Adoption of Code Cases that have been approved by the Board of Nuclear Codes and Standards, but that have not been listed for generic use in Regulatory Guide 1.147, may be requested in the form of a "Request for Alternative" in accordance with 10 CFR 50.55a(a)(3). Once approved, these Requests for Alternatives will be available for use until such time that the Code Cases are adopted into Regulatory Guide 1.147, at which time compliance with the provisions contained in the regulatory Guide is required.

Table 3.2 identifies those Code Cases approved through Requests for Alternatives. For convenience to the user of this ISI Plan, the appropriate internal correspondence number is provided to assist in retrieval from Entergy Document Control Centers. All other Requests for Alternatives and Relief Requests (those not associated with NRC approval of Code Cases) are addressed in Section 4 of this ISI Plan.

1.3 Use of Annulled Code Cases As permitted by Regulatory Guide 1.147, Code Cases that have been adopted for use in the current interval that are subsequently annulled by ASME, may be used for the remainder of the interval.

1.4 Code Case Revisions As permitted by Regulatory Guide 1.147, activities performed to a specific revision of an approved Code Case need not be changed because a subsequent revision of the Code Case is listed as the approved version in the Regulatory Guide. An exception to this provision would be the inclusion of a limitation or condition on the use of the Code Case which is necessary to enhance safety.

1.5 Adoption of Code Cases Issued Subsequent to Filing the Inservice Inspection Plan Code Cases issued by ASME Section XI subsequent to filing the Inservice Inspection Plan with the NRC may be incorporated within the provisions of paragraphs 1.1 or 1.2 by either a revision or a PCN to this ISI Plan.

SECTION 3 Program Section No: CEP-ISI-001 CODE CASES Revision No.: 10 PageNo.: 3 of 6 TABLE 3.1 CODE CASES ADOPTED from REGULATORY GUIDE 1.147 Code Title Reg. Guide NRC Limitations Case 1.147 Number Revision N-335-1 Rules for Ultrasonic Examination of Similar and 12 None Dissimilar Metal Piping Welds N-416-2 Alternative Pressure Test Requirements for Welded 13 1. Hold times contained in IWA-5213 of the 1989 Edition Repairs or Installation of Replacement Items by are to be used Welding, Class 1, 2, and 3 N-435-I Alternative Examination Requirements for Vessels 14 None with Wall Thickness 2 in. or Less N-460 Alternative Examination Coverage for Class l and 2 14 None Welds N-461 Alternative Rules for Piping Calibration Block 12 Thickness measurements and weld joint Thickness contour/component must be known and used by the inspector who conducts the UT examination N-481 Alternative Examination Requirements for Cast Austenitic Pump Casings 14 12 None None N-496-1 Helical Coil Threaded Inserts,Section XI Division 1 N-498-4 Alternative Rules for 10-Year Hydrostatic Pressure 13 Hold times contained in IWA-5213 of the 1989 Edition are Testing for Class 1, 2, and 3 Systems to be used N-508-1 Rotation of Serviced Snubbers and Pressure Relief 13 None-Valves for the Purposes of Testing N-509 Alternative Rules for the Selection and Examination 12 A minimum 10% sample of integrally welded attachment of Class 1, 2, and 3 Integrally Welded Attachments for each item in each Code Class per interval should be examined.

4 SECTION 3 Program Section No: CEP-ISI-001 CODE CASES Revision No.: 10 Page No.: 4 of 6 Code Title Reg. Guide. NRC Limitations Case 1.147 Number I Revision N-513 Evaluation Criteria for Temporary Acceptance of 1. Specific safety factors in paragraph 4.0 must be satisfied.

Flaws in Class 3 Piping 13 2. May not be applied to: (a) components other than pipe

- and tube, (b) Leakage through a gasket, (c) Threaded connections employing nonstructural seal welds for leakage prevention, (d) Degraded socket welds.

N-521 Alternative Rules for Deferral of Inspections of 12 None Nozzle-to-Vessel Welds, Inside Radius Sections, and Nozzle-to-Safe End Welds of a Pressurized Water Reactor (PWR) Vessel N-522 Pressure Testing of Containment Penetration Piping 14 None N-523-2 Mechanical Clamping Devices for Class 2 and 3 14 .None Piping N-524 Alternative Examination Requirements for 12 None Longitudinal Welds in Class I and 2 Piping /

N-532-1 Alternative Requirements to Repair and Replacement 14 The OAR Report must be submitted to the NRC within 90 Documentation Requirements and Ins&vice Summary days of the completion of each refueling outage.

Report Preparation and Submission as Required by IWA-4000 and IWA-6000 ___

N-546 Alternative Requirements for Qualification of VT-2 14 1. This Code case is applicable for inspection purpose only.

Examination Personnel N-588 Attenuation to Reference Flaw Orientation of 14 None Appendix G for Circumferential Welds in Reactor Vessels N-598 Alternative Requirements to Required Percentages of 14 None Examinations N-616 Alternative Requirements for VT-2 Visual 14 1. Insulation must be removed for VT-2 examination Examination of Classes 1, 2, 3 insulated Pressure during the system pressure test for any 17-4 Precipitation Retaining Bolted Connections Hardening stainless steel stud or bolt aged at a temperature

_____below I 100'F, or 410 stainless steel stud or bolt aged at a

c- -Z' r I - P4-j -16' SECTION 3 Program Section No: CEP-ISI-001 CODE CASES Revision No.: 10 Page No.: 5 of 6 Code Title Reg. Guide NRC Limitations Case 1.147 Number Revision temperature below 1100°F or with hardness above Rc 30.

2. For A-286 stainless steel studs or bolts, the preload must be verified to be below 100 Ksi or the thermal insulation must be removed and the joint visually examined.
3. Prior to conducting the VT-2 examination of Class 2 and Class 3 components not required to operate during normal plant operation, a 10 minute holding time is required after attaining test pressure. Prior to conducting the VT-2 examination of Class 2 and Class 3 components required to operate during normal plant operation, no holding time is required, provided the system has been in operation for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated components or 10 minutes for non-insulated components.

N-623 Deferral of Inspections of Shell-to-Flange and Head- 14 None to-Flange Welds of a Reactor Vessel N-624 Successive Inspections 14 None N-640 Alternative Reference Fracture Toughness for 14 None Development of P-T Limit Curves N-641 Alternative Pressure-Temperature Relationship and 14 None Low Temperature Overpressure Protection System Requirements N-663 Alternate Requirements for Classes 1 and 2 Surface 14 Examinations

4 SECTION 3 Program Section No: CEP-ISI-001 CODE CASES Revision No.: 10 PageNo.: 6 of 6 TABLE 3.2 CODE CASES APPROVED THROUGH REQUESTS FOR ALTERNATIVES Code Case Submittal Letter Approval Letter Number Title Number Number I

Table 3.2 Notes:

TABLE 3.3 CODE CASES ADOPTED from 10 CFR 50.55a C o d e C ase . . . . . . . . . . . . . . . . . . . . . . . .

Number Title Notes NONE Table 3.3 Notes:

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