View source for 1CAN100901, Response to Request for Additional Information on the Third 10-Year Inservice Inspection Interval, Requests for Relief

{{Adams
| number = ML093070060
| issue date = 10/28/2009
| title = Response to Request for Additional Information on the Third 10-Year Inservice Inspection Interval, Requests for Relief
| author name = Bice D B
| author affiliation = Entergy Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000313
| license number = DPR-051
| contact person = 
| case reference number = 1CAN100901
| document type = Letter type:
| page count = 30
| project = 
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:ntergy Entergy Operations, Inc.1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4710 David B. Bice Acting Manager, Licensing Arkansas Nuclear One 1 CAN100901 October 28, 2009 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 

==SUBJECT:==
REFERNCES:
Response to Request for Additional Information on the Third 10-Year Inservice Inspection Interval Requests for Relief Arkansas Nuclear One, Unit 1 Docket No. 50-313 License No. DPR-51 1. Entergy letter to the NRC, dated May 29, 2009, "Requests for Relief from ASME Section XI Volumetric, Surface and Visual Examination Requirements 
-Third 10-Year Interval" (1CAN050902)
: 2. Email from Kaly Kalyanam (NRC) to Robert W. Clark (Entergy), dated August 5, 2009, "RAI on Relief Requests for Limited Exams during Third 10-Year Interval (TAC Nos. ME1439, 1440, 1441, 1442, 1443, and 1444)" 

==Dear Sir or Madam:==
By Reference 1, Entergy Operations, Inc. (Entergy) submitted its third 10-year inservice inspection (ISI) interval requests for relief for Arkansas Nuclear One, Unit 1 (ANO-1). The relief requests, ANO1-ISI-015 through -020, were submitted in accordance with 10 CFR 50.55a(g)(5)(iii).
The subject requests are for limited examinations in multiple American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI, examination categories.
The ASME Code requires that 100% of the examination volumes, or surface areas, described in ASME Code, Section XI, Table IWB-2500 and IWC-2500 be performed during each 10-year interval.10 CFR 50.55a(g)(5)'(iii) requires information to be submitted to the NRC to support the determination that the ASME requirements were impractical.
Based on the NRC's acceptance review of the Reference 1 submittal, it was determined that additional information was required to support the review of the relief requests.
The Staff requested detailed and specific information to support the bases for limited examination in all requests, and therefore, demonstrate impracticality.
The request for additional information (RAI) was provided to ANO-1 AD4l 1CAN100901 Page 2 of 2 via Reference 
: 2. The response to the RAI is due 90'days after the date of transmission of Reference 
: 2. Attached are the responses for ANO-1.This report includes no new commitments.
If you have any questions or require additional information, please contact me.Sincerely, DBB/rwc 

==Attachment:==

Responses to NRC's RAIs on Third 10-Year Inservice Inspection Interval Requests for Relief cc: Mr. Elmo E. Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector Arkansas Nuclear One P. O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Kaly Kalyanam MS 0-8 B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Attachment to 1CAN100901 Responses to NRC's RAIs on Third 10-Year Inservice Inspection Interval Requests for Relief Attachment to 1CAN100901 Page,1 of 27 Response to Request for Additional Information The NRC requested Arkansas Nuclear One, Unit 1 (ANO-1) to provide detailed and specific information to support the bases for limited examination in all requests for relief submitted on May 29, 2009, and therefore, demonstrate impracticality.
The questions for each relief request are as follows: a) Include descriptions (written and/or sketches, as necessary) of the interferences to applied nondestructive examination (NDE) techniques.
b) As applicable, describe NDE equipment (ultrasonic scanning apparatus), details of the listed obstructions (size, shape, proximity to the weld, etc.) to demonstrate accessibility limitations, and discuss whether alternative methods or advanced technologies could be employed to maximize American Society of, Mechanical Engineers (ASME) Code coverage.c) Fully clarify the wave modality and insonification angles used for all ultrasonic examinations.
d) Show cross-sectional coverage plots to describe ASME Code volumes examined.e) If surface examination is required by the ASME Code in addition to the volumetric examination, state whether surface examinations were performed on any of the subject components and examination coverage that was obtained.f) If not included, state whether any indications were discovered as a result of Code-required examinations, and how these indications have been dispositioned.
The questions apply to each of the following relief requests.ANO1-ISI-015 ANO1-ISI-016 ANO1-ISI-017 ANO1-ISI-018 ANO1-ISI-019 ANO1-ISI-020 CATEGORY B-A, PRESSURE RETAINING WELDS IN REACTOR VESSEL CATEGORY B-D, FULL PENETRATION WELDED NOZZLES IN VESSELS CATEGORY B-G-1, PRESSURE RETAINING BOLTING GREATER THAN 2 INCHES IN DIAMETER CATEGORY B-J, PRESSURE RETAINING WELDS. IN PIPING CATEGORY B-K, WELDED ATTACHMENTS FOR VESSELS, PIPING, PUMPS, AND VALVES CATEGORY F-A, SUPPORTS OTHER THAN PIPING SUPPORTS Attachment to 1 CAN 100901 Page 2 of 27 Request for Relief ANO1-ISI-015 Limited B-A Examinations Item Comp. Item % Reason for Limitation Response to NRC Request for Additional Number ID Description Coverage Information B1.11 01-005 Lower Shell to Lower Reactor Pressure Vessel (RPV) Head Weld App. VIII 36.38%This examination is performed from the interior of the RPV. Coverage is physically limited due to the core support lugs and flow diverters attached to the RPV.a) See attached sketches derived from WesDyne examination program plan 2008 (sheets 1 and 8 of 20) on file at ANO.b) Automated ultrasonic testing (UT) examination performed by WesDyne International, utilizing an eight (8) transducer sled measuring 5.38" wide, 9.51" in length.Thirteen (13) core stop-lugs and twelve (12) flow diverters precluded coverage of the full weld volume. See attached sketch.As stated in Section III of the request for-relief, there are no alternative methods or advanced technologies which could be reasonably employed to maximize ASME Code coverage.c) Wave modality used include shear and refracted longitudinal.
Insonification angles employed included a 45* shear and a 450 refracted longitudinal.
For additional coverage, the transducer sled was rotated for both parallel and perpendicular scans beneath the core stop lugs.
Attachment to 1 CAN 100901 Page 3 of 27 d) See attached sketch derived from WesDyne examination program plan 2008 (sheets 1 and 8 of 20) on file at ANO.e) Surface examination was not required.f) No indications were reported as a result of Code-required examinations.
B1.21 01-006 Bottom RPV App. VIII This examination is a) See attached sketches derived from WesDyne Head Weld performed from the interior examination program plan 2008 (sheets 1 and 9 59.07% of the RPV. Coverage is of 20) on file at ANO.physically limited due to the location of the twelve b) Automated UT examination performed by (12) flow diverters attached WesDyne International, utilizing an eight (8)to the bottom head. transducer sled measuring 5.38" wide, 9.51" in length.Twelve (12) flow diverters precluded coverage of the full weld volume. See attached sketch.As stated in Section III of the request for relief, there are no alternative methods or advanced technologies which could be reasonably employed to maximize ASME Code coverage.c) Wave modality used include shear and refracted longitudinal.
Insonification angles employed included a 450 Shear and a 450 refracted longitudinal.
For additional coverage, the transducer sled was rotated were possible.
Attachment to 1 CAN100901 Page 4 of 27 d) See attached sketch derived from WesDyne examination program plan 2008 (sheets 1 and 9 of 20) on file at ANO.e) Surface examination was not required.f) No indications were reported as a result of Code-required examinations.
Attachment to 1CAN 100901 Page 5 of 27 Scanning Limitations for Welds 01 -005 and 01 -006 SCALED fe ]ID SrJkFC.ARKANSAS NUCLEAR ONE- UNIT I Wes~yne InternwtionaL
&#xfd;p Vessel Rollout EXAMINATION PROGRAM PLAN 2008 ALL DlIMENS ON;' INE INCHES'UNIOTES R kISEN0TESHEET I OF 20 Attachment to 1CAN 100901 Page 6 of 27 Scan Path for Weld 01-005 289.50-- 291.94\orking Point 8.44 (82.56&deg;) 303.10 -(,79.13&deg;)
308,43 (77,09') 312.64 299,13\"85,19")
Top Perp\ r:1 301.39 (83.690) Top Parallel 309.50 313.06 (75.97') Bottom Parat[le-313.35 (75,76&deg;) Bottom Perp/ R87,06 Note: For additional coverage the sled may be rotated for both parallel and perpendicular scans beneath the lugs on W4, Tooling limitations will constitute the appropriate moves, W/P Scan Increment 
= 0,329' (0.5') for Parallel Scans= 0.329' (0,50') for Perp Scans Verify robot sequence For Perp & Para sled rotation ARKANSAS NUCLEAR ONE UNIT 1 Parallet Scan Limits +/- 5,0' Either Side of Core Guide Lugs Perp Scan Limits +/- 3,1 Either Side of Core Guide Lugs VesDyne Internationa&#xfd;Transition to Lower Shel Circ Veld EXAMINATION PROGRAM PLAN 2008 ALL DIMENSIONS IN INCHES 8 1l UNLESS OTHERWISE NOTF 20 Attachment to 1 CAN 100901 Page 7 of 27 Scan Path for Weld 01-006-291.94 Tangent (worklng point)Eievation To maximize scan coverage the sled may be rotated- see robot scan plan for affected scans.PorIlel Top Perp Top Perp Bottom PoroALet Botto,.W-5 (01-006)ARKANSAS NUCLEAR ONE UNIT I Scan [ncrement 
= 0.329* (0.5') for Parallel Scans= 0.329' (0.50') for Perp Scans Wes~lyne InternationoJ.
Lower Head to Transition Circ Weld EXAMINATION PROGRAM PLAN 2008 ALL I NCHES a 9 OF Attachment to 1 CAN 100901 Page 8 of 27 Request for Relief ANO1-ISI-016 Limited B-D Examinations Item Comp. Item % Reason for Limitation Response to NRC Request for Additional Number ID Description Coverage Information B3.1 10 05-014 Pressurizer 28.7% This is essentially a single a) See attached sketches derived from UT (PZR) Relief sided exam due to the examination report 1021SlUT01 1 on file at ANO.Nozzle-to-component configuration.
Head Scan paths were also b) Manual UT examination.
Circumferential limited due to close (Circ) Weld proximity of adjacent A detailed sketch of the limitations and their nozzles and welded lifting proximity to the component are attached.lugs as well as the curvature of the PZR c) Wave modality used included shear and head. longitudinal.
Insonification angles included 0% 450, 600, and 70&deg;" d) See attached sketches derived from UT examination report 1021SlUT01 1 on file at ANO.e) Surface examination was not required.f) Intermittent geometric indications from the nozzle bore were observed.B3.1 10 05-015 PZR Relief 28.7% This is essentially a single a) See the attached sketches derived from UT Nozzle-to-sided exam due to the examination report 1021SlUT024 on file at ANO.Head Circ component configuration.
Weld Scan paths were also b) Manual UT examination.
limited due to the close proximity of adjacent A detailed sketch of the limitations and their Attachment to 1CAN100901 Page 9 of 27 nozzles and welded lifting lugs.proximity to the component are attached.c) Wave modality used included shear and longitudinal.
Insonification angles included 0', 45%, 60%, and 70'.d) See attached sketches derived from UT examination report 1021SlUT024 on file at ANO.e) Surface examination was not required.f) Intermittent geometric indications from the nozzle bore were observed.I + 1- 1 B3.110 1 05-021 PZR Surge Nozzle-to-Head Circ Weld 32%This is essentially a single sided exam due to the component configuration.
Scan paths were also limited due to the close proximity of adjacent nozzles and welded lifting lugs.a) See the attached sketches derived from UT examination report ISI-UT-07-027 on file at ANO.b) Manual UT examination.
A detailed sketch of the limitations and their proximity to the ISI component are attached.c) Wave modality used included shear and longitudinal.
Insonification angles included 0Q, 45% 60', and 70*" d) See attached sketches derived from UT examination report ISI-UT-07-027 on file at ANO.
Attachment to 1CAN100901 Page 10 of 27 e) Surface examination was not required.f) No indications were reported as a result of Code-required examinations.
Attachment to 1CAN 100901 Page 11 of 27 Scanning Limitations for Welds 05-014 and 05-015 Attachment to 1 CAN100901 Page 12 of 27 Scan Path for Welds 05-014 and 05-015 F ~ JS(cAA' PA-rN~7 0 (701 "".N o"5.,P4T14/0'
-7&deg;&deg;qA"fYAT) 4 mr " )"", OOO , ,, CL)i t gU Attachment to ICAN100901 Page 13 of 27 Scan Limitations and Coverage for Weld 05-021----&#xfd;PrTc' P,, ci ?j iii M P Smz $m 150r, 17e ~izflu 11tch &#xfd; in9h Q2s 4a _I Figure 9.4.2 (a-,c)Probe Scan Limits and Examination Coverage.
Minimum and maximum probe R positions and the associated, portion of the'examination Volume covered.Pressurizer Surge Nozzle, 70/32b Z C,. *:~ 6 6 v~. i~ i~. i~ j~ ~i)R f (a) Scan Limits & Coverage for Blend Procedure 70132 Attachment to 1CAN 100901 Page 14 of 27 Scan Path for Weld 05-021 I t i 0&0,1~ R .-, S&#xfd;,U Nok,.01-=
Attachment to 1 CAN100901 Page 15 of 27 Request for Relief ANO1-ISI-017 Limited B-G-1 Examinations Item Comp. Item % Reason for Limitation Response to NRC Request for Additional Number ID Description Coverage Information B6.40 01-F-01 through 01-F-60 Threads in Reactor Vessel (RV)Flange 79%Reactor Vessel Head (RVH) sealing surface precludes-a 3600 scan around each of the 60 RPV threaded stud holes.Additionally, RVH guide pins in stud holes #15 and#45 further limited the examination of those items.a) The exam volume is 1" around the outside of each stud hole in the RPV flange for one stud diameter deep into the material.
See the attached sketch derived from UT examination reports 1961SlUT014 and 1991SlUT037 on file at ANO.b) Manual UT examination.
A detailed sketch of the limitations and their proximity to the component are attached..There was no alternative methods or advanced technologies which could be employed to maximize ASME Code coverage.c) Wave modality used a 0' longitudinal transducer.
d) The exam volume is 1" around the outside of each stud hole in the RPV flange for one stud diameter deep into the material.
See the attached sketch derived from UT examination reports 1961SlUT014 and 1991SIUT037 on file at ANO.e) A surface examination was not required.
Attachment to 1 CAN100901 Page 16 of 27 Attachment to 1CAN 100901 Page 17 of 27 Scan Limitations and Coverage 01-F-01 through 01-F-060_x ,on ,,.,,,,, i r r... , 4 :ete s fce v I brT~vW ODA Attachment to 1CAN 100901 Page 18 of 27 Request for Relief ANO1-ISI-018 Limited B-J Examinations Item Comp. ID Item % Reason for Limitation Response to NRC Request for Additional Information Number , Description Coverage B9.1 1 09-001 "D" Reactor 50.0% This is a single sided a) See attached sketch derived from NDE report Coolant examination from the 101 ISIUT037 on file at ANO.Pump pipe side only of the (RCP) pump to 28" pipe b) Manual UT examination.
Pump to configuration.
Pipe Circ A detailed sketch of the scanning restriction is Weld attached.c) Wave modality used included shear and refracted longitudinal.
Insonification angles included 45' and 600.d) See attached sketch derived from NDE report 101 1SlUT037 on file at ANO.e) Surface examination was not required.f) No indications were reported as a result of Code required examinations.
B9.32 09-006 Pipe-to-High 50% This is a single sided a) See attached sketch derived from NDE report Pressure examination from the 101 ISIUT038 on file at ANO.Injection pipe side only of the 6" (HPI) nozzle to 28" pipe b) Manual UT examination.
Nozzle Circ configuration Weld A detailed sketch of the scanning restriction is Attachment to 1CAN 100901 Page 19 of 27 attached.c) Wave modality used included shear and refracted longitudinal.
Insonification angles included 45*.d) See attached sketch derived from NDE report 101 ISIUT038 on file at ANO.e) Surface examination was not required.f) No indications were reported as a result of Code-required examinations.
4- 4 +B9.21 18-010 PZR Spray Valve-to-Pipe Circ Weld 50%This is a single sided examination from the pipe side only of the 2.5" valve to 2.5" pipe configuration a). See attached sketch derived from NDE report ISI-UT-07-014 on file at ANO.b) Manual UT examination.
A detailed sketch of the scanning restriction is attached.c) Wave modality is shear.Insonification angles included 45%, 60%, and 70*.d) See attached sketch derived from NDE report ISI-UT-07-014 on file at ANO.e) Surface examination was not required.f) One indication was recorded with the 700 shear and dispositioned as a geometric reflector.
Attachment to 1CAN 100901 Page 20 of 27 B9.21 23-055 HPI to B2 Loop Elbow-to-Valve Circ Weld 41%This is a single sided examination from the pipe side only of the 2.5" pipe to valve configuration.
The exam is further limited due to a welded name tag on the pipe for 180' around the circumference.
a) See attached sketch derived from NDE report ISI-UT-05-088 on file at ANO.b) Manual UT examination.
A detailed sketch of the scanning restriction is attached.
The position of the weld tag limits the axial movement of the transducer for -1800 around the circumference of the pipe allowing just 16%coverage in that area.c) Wave modality is shear.Insonification angle used is a 70*.d) See attached sketch derived from NDE report ISI-UT-05-088 on file at ANO.e) Surface examination was not required.f) No indications were reported as a result of Code-required examination.
Attachment to 1CAN100901 Page 21 of 27 Coverage Plot for Weld 09-001 Coverage Plot for Weld 09-06 Attachment to 1CAN 100901 Page 22 of 27 Coverage Plot for Weld 18-010 V,1~T Ci-j-Coverage Plot for Weld 23-055 FLow ->
Attachment to 1 CAN100901 Page 23 of 27 Request for Relief ANO1-ISI-019 Limited B-K-1 Examinations Item Comp. Item % Reason for Limitation Response to NRC Request for Additional Number ID Description Coverage Information B10.20 22- Pipe 38.5% The examination area on a) See attached sketch derived from NDE report 099W Support the restraint was limited 101 ISIPT019 on file at ANO.Integral due to the configuration of Attachment the hanger. b) A liquid penetrate surface examination was Weld performed.
There was no alternative methods or advanced technologies which could be employed to maximize ASME Code coverage.c) Not applicable.
d) See attached sketch derived from NDE report 101 ISIPT019 on file at ANO.e) A liquid penetrate surface examination was performed per Section XI requirements.
f) No indications were discovered as a result of Code-required examinations.
Attachment to 1CAN 100901 Page 24 of 27 Limitation Sketch for Weld 22-099W r ---7" -- ..,.N WE LD TO lupE.FwM Attachment to 1CAN 100901 Page 25 of 27 Item Comp. Item % Reason for Limitation Response to NRC Request for Additional Number ID Description Coverage Information F1.40 01-032 RPV 0.0% This support weld is a) See attached sketch derived from NDE report 1Sl-Support inaccessible for VT-07-121 on file at ANO.Skirt Circ examination due to Weld insulation blocks that are b) Not applicable.
Only a visual exam was impractical to remove, performed.
General area dose rates of 500 -600 mrem / hour c) Not applicable.
Only a visual exam was coupled with a confined performed.
area congested with incore instrumentation piping d) See attached sketch derived from NDE report ISI-preclude safe scaffold VT-07-121 on file at ANO.installation.
e) Not applicable.
Only a visual exam was performed.
f) No indications were reported as a result of Code-required examinations.
F1.40 01-033 RPV 70.0% This support weld was a) See attached sketch derived from NDE report ISl-Support examined with a VT-07-122 on file at ANO.Skirt to fiberscope deployed Flange through cut-outs in the b) Not applicable.
Only a visual exam was Weld skirt. Removal of performed.
insulation blocks for better access is impractical.
c) Not applicable.
Only a visual exam was General area dose rates of performed.
500 -600 mrem / hour coupled with a confined d) See attached sketch derived from NDE report ISl-Attachment to 1 CAN100901 Page 26 of 27 area congested with incore VT-07-122 on file at ANO.instrumentation piping preclude safe scaffold e) Not applicable.
Only a visual exam was installation, performed.
f) No indications were reported as a result of Code-required examinations.
F1.40 01-034 RPV 70.0% Support skirt bolting was a) See attached sketch derived from NDE report ISI-Support examined with a VT-07-123 on file at ANO.Skirt Flange fiberscope deployed under Bolting the insulation blocks and b) Not applicable.
Only a visual exam was through cut-outs in the performed.
skirt. Removal of insulation blocks for better c) Not applicable.
Only a visual exam was access is impractical.
performed.
General area dose rates of 500 -600 mrem / hour d) See attached sketch derived from NDE report ISI-coupled with a confined VT-07-123 on file at ANO.area congested with incore instrumentation piping e) Not applicable.
Only a visual exam was preclude safe scaffold performed.
installation.
f) No indications were reported as a result of Code-required examinations.
Light rust was noted on some bolting.
Attachment to 1 CAN 100901 Page 27 of 27 Limitation Sketch for Welds 01-032; 01-033; and 01-034......... 
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