View source for W3F1-2008-0010, Revised Request for Alternative W3-R&R-006 - Proposed Alternative to ASME Code Requirements for Weld Overlay Repairs

{{Adams
| number = ML080560268
| issue date = 02/21/2008
| title = Revised Request for Alternative W3-R&R-006 - Proposed Alternative to ASME Code Requirements for Weld Overlay Repairs
| author name = Murillo R
| author affiliation = Entergy Nuclear South, Entergy Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000382
| license number = NPF-038
| contact person = 
| case reference number = W3-R&amp;R-006, W3F1-2008-0010
| document type = Letter type:W, Request for Additional Information (RAI)
| page count = 76
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:Entergy Nuclear South Entergy Operations, Inc.
17265 River Road Killona, LA 70057-3093
'-Enteigy                                                                       Tel 504-739-6715 Fax 504-739-6698 rmurill@entergy.com Robert J. Murillo Licensing Manager Waterford 3 W3F1-2008-0010 February 21, 2008 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk
 .Washington, DC 20555-0001

==SUBJECT:==
Revised Request for Alternative W3-R&R-006 - Proposed Alternative to ASME Code Requirements for Weld Overlay Repairs Waterford Steam Electric Station Station, Unit 3 Docket No. 50-382 License No. NPF-38

==REFERENCE:==
: 1. Entergy letter to NRC dated April 26, 2007, Request for Alternative W3-R&R-006 - Proposed Alternative to ASME Code Requirements for Weld Overlay Repairs (CNRO-2007-00021)
: 2. NRC letter to Entergy dated February 8, 2008, Request for Additional Information

==Dear Sir or Madam:==

By letter (Reference 1), Entergy Operations, Inc. (Entergy) proposed an alternative to the requirements of ASME Code, Section XI IWA-4000 for mitigating primary water stress corrosion cracking (PWSCC) on dissimilar metal welds using preemptive full structural weld overlays for Waterford 3. Several discussions have taken place between the NRC Staff and Entergy's Arkansas Nuclear One (ANO) representatives regarding a similar request, since the transmittal of the aforementioned letter. Those discussions resulted in a Request for Additional Information (RAI) to ANO and a similar Request for Additional Information (RAI) by the NRC Staff to Waterford 3 on February 8, 2008 (Reference 2). Entergy's response to the RAI is included in Enclosure 1. A summary of changes to Request for Alternative W3-R&R-006 is provided in Enclosure 2. A Revised Request for Alternative W3-R&R-006, which incorporates needed changes resulting from Entergy's response to the RAI along with other appropriate changes, will replace Reference 1 in its entirety and is contained in Enclosure 3.
Revision bars in the right hand margin identify the changes made to Reference 1.
ACS-P

W3F1-2008-0010 Page 2 This letter contains commitments that replace Reference 1 commitments in its entirety and is contained in Enclosure 4. Should you have any questions or require additional information, please contact Ron Williams at (504) 739-6255.
Sincerely, RJM/JGW/RLW

==Enclosures:==
: 1. Request for Additional Information Related to Request for Alternative W3-R&R-006
: 2. Summary of Changes Related to Revised Request for Alternative W3-R&R-006
: 3. Revised Request for Alternative W3-R&R-006
: 4. Licensee-Identified Commitments

W3Fl-2008-0010 Page 3 cc:    Mr. Elmo E. Collins, Jr.
Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 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. Kaly Kalyanam MS O-7D1 Washington, DC 20555-0001 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 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

ENCLOSURE I W3F1 -2008-0010 REQUEST FOR ADDITIONAL INFORMATION RELATED TO REQUEST FOR ALTERNATIVE W3-R&R-006 to W3F1-2008-0010 Page 1 of 4 REQUEST FOR ADDITIONAL INFORMATION RELATED TO REQUEST FOR ALTERNATIVE W3-R&R-006 By letter dated April 26, 2007, Entergy proposed an alternative (W3-R&R-006) to the requirements of American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (ASME Code), for mitigating primary water stress corrosion cracking on dissimilar metal welds using full structural weld overlays at Waterford Steam Electric Station, Unit 3 (Waterford 3). To complete its review, the staff requested the following additional information on February 8, 2008.
NRC Question #1 In the Apri 26, 2007 letter, the licensee requested NRC approval of Request for Alternative W3-R&R-006 to support the spring 2008 refueling outage (RF-15). However, the duration of the proposed alternative is not specified in the April 26, 2007 submittal other than for the Spring 2008 refueling outage. Please confirm/clarify the duration of the proposed alternative.
Include the dates of the current inservice inspection interval.
Entergy Response:
This request is applicable to the second 10-Year Interval at Waterford 3 which concludes on May 30, 2008. However, Entergy intends to implement the request during the fifteenth refueling outage (RF-1 5) at Waterford 3, which is scheduled for spring 2008. While this is the case, the inservice inspection requirements specified in Attachment 2, Section 3.0.c of W3-R&R-006 will be applied for the life of the weld overlays except as specified in Section V.A.3.j of the request.
Please note that the start date for the third 10-Year Interval at Waterford 3 has been changed to May 31, 2008. In the April 26, 2008 submittal, Entergy stated that Waterford 3 would begin its fourth 10-Year Interval prior to RF-15. Since then, Entergy has decided to extend the second 10-Year Interval to May 30, 2008 in accordance with the provisions of IWA-2430(d). The extension was necessary, in part, to minimize the impact on the Waterford 3 refueling outage which is scheduled to begin on or about April 27, 2008.
Affected sections of request W3-R&R-006 have been revised as a result of this change.
NRC Question #2 In Section V.A.3.c of Request for Alternative W3-R&R-006, the licensee discussed the inspection issues regarding cast austenitic stainless steel (CASS) safe ends as listed in  of the licensee's submittal dated Apri 26, 2007. The licensee stated correctly that the ultrasonicexamination (UT) has not been qualified in accordance with Appendix VIII, Supplement 11 of the ASME Code, Section X1, in the examination of cast austenitic stainless steel. The licensee stated further that a flaw with a depth of 75 percent of pipe thickness and circumference of 360 degrees will be assumed in the crack growth calculation for the cast stainless steel safe ends. In light of the limiting capability of the current UT technology in the*
CASS examination, the postulated 75 percent depth flaw may not be adequate to assess the structural integrity of the CASS component. In view of this, the licensee might consider to W3F1-2008-0010 Page 2 of 4 options such as:
: 1. Sizing the initial flaw depth at 100% through-wall for the crack growth calculations.
: 2. If the 100% through-wall flaw is impracticalor creates a hardshipin the overlay design or installation,assuming an initial flaw with 75% through-wall depth and adjusting inspection frequency for the inspection volume.
The licensee is requested to provide an approach to resolve the CASS issue in Alternative W3-R&R-006.
Entergy Response:
Entergy will implement NRC Option 2 as described below due to the significant impact on design and installation.
The subject weld shall be ultrasonically inspected during the first or second refueling outage following the weld overlay installation. If UT is performed prior to weld overlay installation and after installation without detecting any planar flaws in the original weld and the weld overlay, the first or second refueling outage UT may be eliminated. After the first ISI examination, the required inspection volume shall be ultrasonically inspected every 10 years from the date of the installation until such time when UT is qualified to examine the CASS portion of the required inspection volume in accordance with new performance demonstration requirements of ASME Code, Section Xl, Appendix VIII. After the subject weld is examined by qualified UT for the CASS material and no planar flaws are detected, the weld may be placed in the 25 percent sample inspection population per proposed relief request W3-R&R-006, Attachment 2, Section 3.0(c)(4). The inspection of the overlaid weld shall not be credited to satisfy the requirement of the twenty-five percent sample inspection every ten years of overlaid welds with non-CASS materials.
NRC Question #3 On page 6, second paragraph,of the April 26, 2007 submittal, the licensee stated that it may apply a butter (transitional)layer of austenitic stainless steel filler metal across the austenitic stainless steel base metal.
: 1. Discuss whether paragraph (e) of Code Case N-504-2 is applicable to the butter layer if austeniticstainless steel filler metal is applied. Paragraph(e) requires existence of certain delta ferrite content in the welded metal when austenitic stainless steel weld metal is used.
: 2. Identify the austeniticstainless steel weld filler metal that will be used for the butter layer.
: 3. Confirm that the Certified Material Test Report (CMTR) for the austenitic stainless steel filler wire shows a minimum delta ferrite of a specified amount. Please provide the maximum and minimum delta ferrite content for the heat of austenitic stainless steel filler wire to be used, as stated on the CMTR.
to W3F1-2008-0010 Page 3 of 4 Entergy Response:
As background, Code Case N-504-2 provides rules for installing austenitic stainless steel weld overlays onto austenitic stainless steel materials (i.e. welds and base materials) as a means of reducing a defect to a flaw of acceptable size. Code Case N-504-2 was originally developed as a repair method for austenitic stainless steel welds subject to intergranular stress corrosion cracking (IGSCC) in Boiling Water Reactor (BWR) systems.
While BWR austenitic stainless steels are susceptible to IGSCC, Pressurized Water Reactor (PWR) systems are not. IGSCC can. only occur when the following three essential conditions exist simultaneously at a given location: (1) a susceptible microstructure (i.e. sensitized austenitic material), (2) tensile stress, and (3) a susceptible environment having a critical oxygen content.                 The essential conditions are interdependent such that critical levels for each essential condition will vary depending upon the strength of the other two. Should any of these conditions be removed, then IGSCC cannot occur.
Paragraph (e) of N-504-2 requires weld reinforcement layers to have a deposited delta ferrite content of at least 7.5 FN. Alternatively, an as-deposited delta ferrite content of 5 FN is also acceptable provided this lower value is substantiated by evaluation. This delta ferrite requirement is applicable to stainless steel weld overlays that are subject to IGSCC.
Weld metals containing even small additions of delta ferrite are less susceptible to sensitization, and thereby, more resistant to IGSCC. As noted in paragraph 2.1 of NUREG-313, Revision 2, "weld metal with low carbon and controlled ferrite (such as 308L with 7.5% minimum ferrite) is resistant to sensitization and IGSCC." However, NUREG-313 also considers austenitic stainless steels with 5% delta ferrite resistant to sensitization and IGSCC depending on carbon content and other possible factors. As an additional benefit, small additions of one to three percent delta ferrite in austenitic weld deposits reduce the tendency for hot cracking or fissuring especially when welds are highly restrained.
Entergy does not believe that the delta ferrite requirement of Code Case N-504-2, paragraph (e) is applicable to the austenitic stainless steel butter layer of request W3-R&R-006 for the following reasons:
* IGSCC is a credible degradation mechanism for austenitic stainless steels in oxidizing BWRs environments; however, there is no industry experience to suggest that IGSCC is a concern for PWRs. In general, environmental conditions in PWRs are reducing and are not conducive for IGSCC. Therefore, IGSCC is not a credible degradation' mechanism for the Waterford 3 weld overlay locations.
* The delta ferrite requirements of Code Case N-504-2, paragraph (e) only apply to the structural layers of a weld overlay. They do not apply to nonstructural weld layers.
Conversely, paragraphs (c) and (d) of the code case do apply to nonstructural weld layers but clearly do not include any delta ferrite requirements. Therefore, if nonstructural layers for a weld overlay subject to IGSCC do not require delta ferrite testing, then a nonstructural stainless steel butter layer (for an Alloy 52M weld overlay) that is not subject to IGSCC certainly does not require delta ferrite testing.
to W3F1-2008-0010 Page 4-of 4 The stainless steel butter layers will be deposited with ER308L filler metal which has a maximum of 0.03% carbon. The use of low carbon filler metals greatly reduces the potential for sensitizing austenitic stainless steels weld deposits.
The ER308L filler metal to be used in the butter layer will have a delta ferrite content of between 5 - 15 FN as documented on the applicable CMTRs. This delta ferrite content is consistent with Code Case N-504-2 and NUREG-313, Revision 2. See discussion above.
It is also consistent with ASME Section III and Regulatory Guide 1.44, Control of the Use of Sensitized Stainless Steel. According to NB-2433.2 of ASME Section III, all austenitic stainless steel filler metals must have a minimum delta ferrite of at least 5 FN as reported on the CMTR. Regulatory Guide 1.44, paragraphs C.4.b and C.5.a provide exceptions to recommended controls for materials subject to sensitization based on a delta ferrite content of 5 FN. Regarding hot cracking, a minimum delta ferrite of 5 FN provides more than adequate resistance to fissuring as noted in Regulatory Guide 1.31, Control of Ferrite in Stainless Steel Weld Metal.

ENCLOSURE 2 W3FI-2008-0010

==SUMMARY==
OF CHANGES RELATED TO REVISED REQUEST FOR ALTERNATIVE W3-R&R-006 to W3F1-2008-0010 Page 1 of 2

==SUMMARY==
OF CHANGES RELATED TO REVISED REQUEST FOR ALTERNATIVE W3-R&R-006 (1) The start date of the third 10-Year Inservice Inspection Interval at Waterford 3 has been changed to May 31, 2008. In the April 26, 2008 submittal, Entergy stated that Waterford 3 would begin its fourth 10-Year Interval prior to RF-15. Since then, Entergy has decided to extend the second 10-Year Interval to May 30, 2008 in accordance with the provisions of IWA-2430(d). The extension was necessary, in part, to minimize the impact on the Waterford 3 refueling outage which is scheduled to begin on or about April 27, 2008. As a result of this change, the ASME Section XI code of record of the Third 10-Year Interval is now applicable to this request., The following sections of the request have been revised to support this change:
* Section I, Pages 1 (References 1 and 2 and inspection interval changed)
* Section II, Page 2 0    Section IV.B, Page 5
* Section V.A.2.a, Pages 8 and 9
* Table on Attachment 1, Page 21 (Note 7 deleted)
* Section 1 of Attachment 5, Page 50
* Section 2 of Attachment 5, Page 52 (2) The request has been revised to reflect a design change. In the April 26, 2007 submittal, Entergy stated that weld overlays for all nine (9) DMWs were being extended across the adjacent stainless steel welds to address inspection coverage issues. Since then, Entergy has determined that it is Unnecessary to extend the weld overlays across the stainless steel welds of the two (2) pressurizer relief valve nozzles and one (1) pressurizer spare nozzle (capped) since ASME Section XI coverage requirements can be met. The following sections of the request have been revised to support this change:
* Section III, Pages 3, 5
* Section IV, Page 5
* Section V.A, Page 6
    "    Table on Attachment 1, Page 21
    "    Figures 2 - 5 on Attachment 1, Pages 23-26 (Figure 2 added and figures renumbered)
(3) The request was revised, based on Entergy's response to NRC RAI-2. In this response, Entergy committed to perform inservice inspections at a higher inspection frequency when the DMW weld overlays involve cast austenitic stainless steel. The following sections of the request have been revised to support this change:
* Section V.A.3.c, Pages 12 - 13
* Section 3.0(c)(4) and (5) of Attachment 2, Pages 32 - 33 to W3F1-2008-0010 Page 2 of 2 (4) Section V.A.3.j, page 17 of the request was added to clarify proposed inservice inspection requirements for the weld overlays of the stainless steel welds. Note that six (6) of the nine (9) weld overlays are being extended across the adjacent stainless steel welds to resolve coverage inspection limitations.
(5) Section V.A, page 6 of the request was revised based on Entergy's response to NRC RAI question 3. RAI question 3 addressed the relevance of delta ferrite readings of the stainless steel butter layer.
(6) Miscellaneous minor editorial corrections were made to various paragraphs of the request.

ENCLOSURE 3 W3FI-2008-0010 REVISED REQUEST FOR ALTERNATIVE W3-R&R-006

ENTERGY OPERATIONS, INC.
WATERFORD STEAM ELECTRIC STATION, UNIT 3 REVISED REQUEST FOR ALTERNATIVE W3-R&R-006 COMPONENTS Component /       Pressurizer RC MPZROO01 Number:           Pressurizer Surge Line 1 RC1 2-1 1A/B Hot Leg Loop 1 RC42-1 RL1 Hot Leg Loop 1 RC42- 2RL2 Shutdown Cooling Lines 1RC14-44RL1 and 1RC14-45RL2 Hot Leg Drain 1RC2-50AJB

==
Description:==
Pressurizer Nozzle to Surge Line Pressurizer Nozzle to Relief Valve (2 locations)
Pressurizer Spare Nozzle (capped)
Pressurizer Nozzle to Spray Line Hot Leg Loop 1 Nozzle to Surge Line Hot Leg Loop 1 Nozzle to Drain Line Hot Leg Loop 1 Nozzle to Shut Down Cooling (SDC) Line Hot Leg Loop 2 Nozzle to SDC Line Code Class:       1

==References:==
      .1. ASME Code, Section X1, 1992 Edition with portions of the 1993 Addenda as listed in Reference 6
: 2. ASME Section Xl, 1995 Edition through 1996 Addenda is used for Appendix VIII, Performance Demonstrationfor UltrasonicExaminations Systems
: 3. ASME Ill, Subsection NB, 1971 Edition through Summer 1971 Addendum with Summer 1972 Addenda for Fracture Toughness (Original Construction Code for Pressurizer) 4.. ASME III, Subsection NB, 1971 Edition through Winter 1971 Addendum with Winter 1972 Addenda for Fracture Toughness (Original Construction Code for Piping)
: 5. ASME Section III, Subsection NB, 1989 Edition
: 6. CEP-ISI-001, Waterford 3 SES Inservice Inspection Plan
: 7. EPRI Report 1011898, Justification for the Removal of the 100 Square Inch Temperbead Weld RepairLimitation
: 8. EPRI Report GC-1 11050, Ambient Temperature Preheatfor Machine G TAW Temperbead Applications 1 of 61
: 9. EPRI Report 1006696, Crack Growth Rates for Evaluating PWSCC of Alloy 82, 182, and 132 Welds (MRP-1 15)
: 10. ASME Code Case N-740
: 11. ASME Code Case N-504-2
: 12. ASME Code Case N-638-1
: 13. EPRI Report 1013558, Temper Bead Welding Applications -
48 hour Hold for Ambient Temperature Temper Bead Welding
: 14. EPRI Report 1010087, PrimarySystem Piping Butt Weld Inspection and Evaluation Guidelines (MRP-139)
: 15. IR-2006-116, EPRI Review of Waterford, Unit 3 Dissimilar Metal Weld Walkdown Information Unit/Inspection         Waterford 3 Steam Electric Station (Waterford 3) / Second (2nd)
Interval:               10-Year Interval CODE REQUIREMENTS NOTE This request is applicable to weld overlay activities that are scheduled for the spring 2008 refueling outage (RF15) at Waterford 3. As of the submittal date of this request, Waterford 3 is in the final period of its second 10-Year Inservice Inspection (ISI) interval. The third 10-Year Interval for Waterford 3 will commence on May 31, 2008.
IWA-4170(b) of the 1992 Edition of ASME Section XI requires that repairs and installation of replacement items be performed (and examined) in accordance with the Owner's Design Specification and the original Construction Code of the component or system. Alternatively, IWA-4170(b) allows for use of later Editions/Addenda of the Construction Code or ASME Section II1. IWA-4300 and IWA-4500 provide defect removal and alternative welding methods when the requirements of IWA-4170(b) cannot be met. IWA-4800 requires the performance of preservice examinations based on IWB-2200 for Class 1 components. Table IWB-2500, Categories B-F and B-J, prescribes inservice inspection requirements for Class 1 butt welds. Appendix VIII, Supplement 11 of ASME Section XI (1995 Edition/1 996 Addenda) specifies performance demonstration requirements for ultrasonic examination of weld overlays.
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III. REASON FOR PROPOSED ALTERNATIVE Primary water stress corrosion cracking (PWSCC) of Alloy 600 components and welds exposed to pressurized water reactor (PWR) primary coolant has become a growing concern in the nuclear industry over the past decade. In particular, dissimilar metal welds (DMWs) made with Nickel Alloy 82 and 182 weld metal exposed to elevated operating temperatures, such as pressurizer and hot leg DMWs, are believed to pose a heightened propensity to PWSCC. Due to this concern, Entergy has concluded that the application of preemptive full structural weld overlays to the subject DMWs is the most appropriate course of action to ensure Reactor Coolant System (RCS) pressure boundary integrity and improve future inspectability.
Structural weld overlays have been used for several years on piping of both boiling water reactors (BWRs) and PWRs to arrest the growth of existing flaws while establishing a new structural pressure boundary. While this is the case, no evidence of PWSCC has been found in the subject DMWs at Waterford 3. However, PWSCC is difficult to detect except when the inspection is performed in accordance with the stringent requirements of ASME Section XI, Appendix VIII as implemented by the Performance Demonstration Initiative (PDI) Program. This request for alternative is applicable to nine (9) DMWs. It should be noted that seven (7) of the nine (9) DMWs cannot be inspected in accordance with the requirements of Appendix VIII of ASME Section Xl due to adjoining cast austenitic stainless steel safe ends and/or weld surface conditions or configurations that are not conducive to PDI inspection. Additionally, six (6) of the nine (9) preemptive full structural weld overlays associated with this request are being extended to overlay the adjacent stainless steel butt welds. Extension of the weld overlays across the adjacent stainless steel welds is necessary due to inspection interference that would occur if only the DMWs were overlaid.
Currently, there are no generically accepted Code-approved criteria for a licensee to preemptively apply a full structural weld overlay to DMWs constructed of Alloy 82/182 weld material. For that matter, preemptive full structural weld overlay requirements for DMWs are not presently included in any Edition/Addenda of ASME Section XI (including Code Cases) approved by the NRC.
Nozzle-to-safe-end weld overlays have been applied as repairs to other plants in accordance with ASME Code Cases N-504-2 and N-638-1, which are "conditionally accepted" for use in Regulatory Guide 1.147. Applying these code cases to nozzle DMWs requires a series of relief requests since Code Case N-504-2 was written specifically for stainless steel pipe-to-pipe welds and Code Case N-638-1 contains some restrictions and requirements that are not applicable to weld overlays. Code Case N-740 has recently been approved by the ASME Code Committee to specifically address weld overlays on DMWs. It also incorporates changes to the latest approved version of Code Case N-638 (i.e., N-638-3). However, Code Case N-740 does not specifically address preemptive weld overlays and has not yet been accepted by the NRC in Regulatory Guide 1.147.
This request for alternative is specific to the nine (9) DMWs described below. These welds are associated with the Waterford 3 Pressurizer and Hot Leg piping.
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. Pressurizer Nozzle to Surqe Line (1 location)
The pressurizer surge line nozzle, which is low alloy steel (P-No. 3, Group 3), is welded to a cast stainless steel (P-No. 8) safe-end, which is, in turn, welded to a (P-No. 8) cast stainless steel pipe. The weld joining the nozzle to the safe-end is an 82/182 DMW, and the weld joining the safe-end and pipe is a stainless steel similar metal weld. See Attachment 1 for additional details.
Pressurizer Nozzle to Relief Valve (2 locations)
The pressurizer relief valve nozzles, which are low alloy steel (P-No. 3, Group 3),
are welded to cast stainless steel (P-No. 8) safe-ends, which are, in turn, welded to (P-No. 8) stainless steel elbows. The welds joining the nozzles to safe-ends are 82/182 DMWs, and the welds joining the safe-ends and elbows are stainless steel similar metal welds. See Attachment 1 for additional details.
Pressurizer Spare Nozzle - Capped (1 location)
The pressurizer spare nozzle, which is low alloy steel (P-No. 3, Group 3), is welded to a cast stainless steel (P-No. 8) safe-end, which is, in turn, welded to a (P-No. 8) stainless steel pipe cap. The weld joining the nozzle to safe-end is an 82/182 DMW, and the weld joining the safe-end and pipe cap is a stainless steel similar metal weld. See Attachment 1 for additional details.
 " Pressurizer Nozzle to Spray Line (1 location)
The pressurizer spray line nozzle, which is low alloy steel (P-No. 3, Group 3), is welded to a stainless steel (P-No. 8) safe-end, which is, in turn, welded to a (P-No.
: 8) stainless steel pipe. The weld joining the nozzle to safe-end is an 82/182 DMW, and the weld joining the safe-end and pipe is a stainless steel similar metal weld.
See Attachment 1 for additional details.
* Hot Leg Loop 1 Nozzle to Shut Down Cooling (SDC) Line (1 location)
The hot leg loop 1 SDC nozzle, which is carbon steel (P-No. 1), is welded to a cast stainless steel (P-No. 8) safe-end, which is, in turn, welded to a (P-No. 8) stainless steel pipe. The weld joining the nozzle to the safe-end is an 82/182 DMW, and the weld joining the safe-end and pipe is a stainless steel similar metal weld. See Attachment 1 for additional details.
* Hot Leg Loop 2 Nozzle to SDC Line (1 location)
The hot leg loop 2 SDC nozzle, which is carbon steel (P-No. 1), is welded to a cast stainless steel (P-No. 8) safe-end, which is, in turn, welded to a (P-No. 8) stainless steel pipe. The weld joining the nozzle to the safe-end is an 82/182 DMW, and the weld joining the safe-end and pipe is a stainless steel similar metal weld. See Attachment 1 for additional details.
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Hot Leg Loop 1 Nozzle to Surge Line (1 location)
The hot leg loop 1 surge nozzle, which is carbon steel (P-No. 1), is welded to a cast stainless steel (P-No. 8) safe-end, which is, in turn, welded to a (P-No. 8) cast stainless steel pipe. The weld joining the nozzle to the safe-end is an 82/182 DMW, and the weld joining the safe-end and pipe is a stainless steel similar metal weld. See Attachment 1 for additional details.
* Hot Leg Loop 1 Nozzle to Drain Line (1 location)
The hot leg loop 1 drain nozzle, which is carbon steel (P-No. 1), is welded to a stainless steel (P-No. 8) safe-end, which is, in turn, welded to a (P-No. 8) stainless steel pipe. The weld joining the nozzle to the safe-end is an 82/182 DMW, and the weld joining the safe-end and pipe is a stainless steel similar metal weld. See Attachment 1 for additional details.
A preemptive full structural weld overlay is proposed for each of the above DMW locations. The full structural weld overlays will be applied by depositing Alloy 52M (ERNiCrFe-7A) weld metal on the outside surface of the DMWs and adjacent base materials. To facilitate inspection of the adjacent stainless steel welds after installation of the preemptive structural weld overlays, the weld overlays for six (6) DMWs will be extended across the stainless steel welds.
IV. PROPOSED ALTERNATIVE Pursuant to 10 CFR 50.55a(a)(3)(i), Entergy Operations, Inc. (Entergy) proposes the following as alternatives to the Code requirements specified in Section I1above. The proposed alternatives are applicable to the DMWs and adjacent stainless steel welds identified in Section III above.
A. Install preemptive full structural weld overlays in accordance with the proposed alternatives specified in Attachments 2 and 3. These alternatives are based on the methodology of ASME Section Xl Code Case N-740.
* Attachment 2 specifies an alternative applicable to the design, fabrication, examination, pressure testing, and inservice inspection of preemptive full structural weld overlays.
* Attachment 3 specifies an alternative applicable to ambient temperature temperbead welding. The Attachment 3 alternative will be applied to the welds as an alternative to the postweld heat treatment requirements of ASME Section III.
B. Perform ultrasonic examinations of the proposed preemptive full structural weld overlays in accordance with Appendix VIII, Supplement 11 of the 1995 Edition/1996 Addenda of ASME Section Xl except as modified by PDI. The proposed PDI alternatives to Appendix VIII, Supplement 11 are specified in Attachment 6.
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V. BASIS FOR PROPOSED ALTERNATIVE A. Proposed Alternative for Preemptive Structural Weld Overlays Entergy intends to install preemptive full structural weld overlays to the nine (9)
DMWs (Inconel 82/182) identified in Section III, above, in accordance with proposed alternative of Attachment 2. The weld overlays also will be extended across six (6) of the adjacent stainless steel butt weld as described in Section III of this request. A tabular comparison of the proposed alternative of Attachment 2 with Code Case N-504-2 and Appendix Q of ASME Section XI has been performed and is provided in Attachment 4.
NOTE ASME Code Case N-504-2 has been conditionally approved by the NRC in Regulatory Guide 1.147 with the condition that the provisions of ASME Section Xl, Appendix Q be met when using the Case.
This proposed alternative provides an acceptable methodology for preventing potential failures due to PWSCC based on the use of filler metals that are resistant to PWSCC (e.g., Alloy 52M), procedures that create compressive residual stress profiles in the original weld, and post-overlay preservice and inservice inspection requirements that ensure structural integrity for the life of the plant. The proposed weld overlays will also meet the applicable stress limits from ASME Section II1.
Crack growth evaluations for PWSCC and fatigue of any conservatively postulated flaws will demonstrate that structural integrity will be maintained.
Please note that as stated above, preemptive weld overlays will be installed using Alloy 52M filler metal in accordance with Attachment 2. However, Alloy 52M weld metal has demonstrated sensitivity to certain impurities, such as sulfur, when deposited onto austenitic stainless steel base materials. Therefore, a butter (transitional) layer of ER308L austenitic stainless steel filler metal will be applied across the austenitic stainless steel base material. The ER308L filler metal will have a delta ferrite content of 5 - 15 FN as reported on the Certified Material Test Report. It will be deposited with a welding procedure that has been qualified in accordance with ASME Section IX. Liquid penetrant (PT) examinations will be performed prior to and after deposition of the butter layer. The second PT examination is performed to ensure that the completed butter layer is free from
      .cracks and other unacceptable indications prior to deposition of the Alloy 52M weld overlay. The austenitic stainless steel butter layer will not be included in the structural weld overlay thickness as defined in Attachment 2.
: 1. Weld Overlay Desigqn and Verification The fundamental design basis for full structural weld overlays is to maintain the original design margins with no credit taken for the underlying PWSCC-susceptible weldments. The assumed design basis weld flaw for the purpose of structural sizing the weld overlays is 3600 and 100% through the original wall thickness of the DMWs. Regarding the crack growth analysis for the preemptive full structural weld overlay, a weld flaw originating from the inside diameter with a depth of 75% and a circumference of 3600 will be 6 of 61

assumed. A 75% through-wall flaw is the largest weld flaw that could remain undetected. A preservice volumetric examination will be performed after application of the weld overlay using an ASME Section Xl, Appendix VIII (as implemented through PDI) examination procedure. This examination will verify that there is no cracking in the upper 25% of the original weld and base material except as described in paragraph V.A.3.c of this request. The preservice examination will also demonstrate that the assumption of a 75%
through-wall crack is conservative. However, if any crack-like flaws are identified in the upper 25% of the original weld or base material by the preservice examination, then the as-found flaw (postulated 75% through-wall flaw plus the portion of the flaw in the upper 25%) will be used in the crack growth analysis.
The specific analyses and verifications to be' performed are summarized below.
Nozzle-specific stress analyses will be performed to establish a residual stress profile in each nozzle. Severe internal diameter weld repairs will be assumed in these analyses that effectively bound any actual weld repairs that may have occurred in the nozzles. The analyses will then simulate application of the weld overlays to determine the final residual stress profiles. Post-weld overlay residual stresses at normal operating conditions will be shown to result in beneficial compressive stresses on the inside surface of the components, assuring that further crack initiation due to PWSCC is highly unlikely.
"     Fracture mechanics analyses will also be performed to predict crack growth for postulated flaws. Crack growth due to PWSCC and fatigue will be analyzed for the original DMW. The crack growth analyses will consider all design loads and transients, plus the post-weld overlay and through-wall residual stress distributions. It will demonstrate that the postulated cracks will not grow beyond the design basis for the weld overlays.
* The analyses will demonstrate that applying the weld overlays does not impact the conclusions of the existing nozzle stress reports. The ASME Code, Section III stress and fatigue criteria will be met for regions of the overlays remote from assumed cracks.
* Shrinkage will be measured during the overlay application. Shrinkage stresses at other locations in the piping systems arising from the weld overlays will be demonstrated not to have an adverse effect on the systems. Clearances of affected supports and restraints will be checked after the overlay repair, and will be reset within the design ranges as required.
* The total added weight on the piping systems due to the overlays will be evaluated for potential impact on piping system stresses and dynamic characteristics.
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* The as-built dimensions of the weld overlays will be measured and evaluated to demonstrate that they meet or exceed the minimum design dimensions of the overlays.
: 2. Suitability of Proposed Ambient Temperature Temperbead Technique An ambient temperature temperbead welding technique will be used when welding on the ferritic base materials'of the nozzles in lieu of the post-weld heat treatment requirements of ASME Section III. Research by the Electric Power Research Institute (EPRI) and other organizations on the use of an ambient temperature temperbead process using the machine gas tungsten arc welding (GTAW) process is documented in EPRI Report GC-1 11050 (Ref. 8).
According to the EPRI report, repair welds performed with an ambient temperature temperbead procedure utilizing the machine GTAW welding process exhibit mechanical properties equivalent to or better than those of the surrounding base material. Laboratory testing, analysis, successful procedure qualifications, and successful repairs have all demonstrated the effectiveness of this process.
: a. Suitability of Ambient Temperature Temperbead Weldinq The effects of the ambient temperature temperbead welding process of Attachment 3 on mechanical properties of welds, hydrogen cracking, and cold restraint cracking are addressed in the following paragraphs:
* Mechanical Properties The principal reasons to preheat a component prior to repair welding is to minimize the potential for cold cracking. The two cold cracking mechanisms are hydrogen cracking and restraint cracking. Both of these mechanisms occur at ambient temperature. Preheating slows down the cooling rate resulting in a ductile, less brittle microstructure thereby lowering susceptibility to cold cracking. Preheat also increases the diffusion rate of monatomic hydrogen that may have been trapped in the weld during solidification.
As an alternative to preheat, the ambient temperature temperbead welding process utilizes the tempering action of the welding procedure to produce tough and ductile microstructures. Because precision bead placement and heat input control are utilized in the machine GTAW process, effective tempering of weld heat affected zones (HAZ) is possible without applying preheat. According to Section2-1 of EPRI Report GC-1 11050, "the temperbead process is carefully designed and controlled such that successive weld beads supply the appropriate quantity of heat to the untempered HAZ such that the desired degree of carbide precipitation (tempering) is achieved. The resulting microstructure is very tough and ductile."
The IWA-4530 temperbead process also includes a post-weld soak requirement. Performed at 450&deg;F - 550&deg;F for 4 hours for P-No. 3 base materials and for 2 hours for P-No. 1 base materials, this post-weld soak assists diffusion of any remaining hydrogen from the repair 8 of 61

weld. As such, the post-weld soak is a hydrogen bake-out and not a post-weld heat treatment as defined by the ASME Code. At 300 0 F, the post-weld soak does not stress relieve, temper, or alter the mechanical properties of the weldment in any manner.
The alternative in Attachment 3 establishes detailed welding procedure qualification requirements for base materials, filler metals, restraint, impact properties, and other procedure variables. The qualification requirements contained in Attachment 3 provide assurance that the mechanical properties of repair welds will be equivalent to or superior to those of the surrounding base material.
Hydrogen Cracking Hydrogen cracking is a form of cold cracking. It is produced by the action of internal tensile stresses acting on low toughness HAZs. The internal stresses are produced from localized build-ups of monatomic hydrogen. Monatomic hydrogen forms when moisture or hydrocarbons interact with the welding arc and molten weld pool.
The monatomic hydrogen can be entrapped during weld solidification and tends to migrate to transformation boundaries or other microstructure defect locations. As concentrations build, the monatomic hydrogen will recombine to form molecular hydrogen, thus generating localized internal stresses at these internal defect locations. If these stresses exceed the fracture toughness of the material, hydrogen-induced cracking will occur. This form of cracking, requires the presence of hydrogen and low toughness materials. It is manifested by intergranular cracking of susceptible materials and normally occurs within 48 hours of welding.
IWA-4500 establishes elevated preheat and post-weld soak requirements. The elevated preheat temperature of 300'F increases the diffusion rate of hydrogen from the weld. The 450&deg;F - 550&deg;F post-weld soak facilitates diffusion of (bakes-out) any remaining hydrogen from the weldment. However, while hydrogen cracking is a concern for shielded metal arc welding (SMAW), which uses flux covered electrodes, the potential for hydrogen cracking is significantly reduced when using the machine GTAW welding process.
The machine GTAW welding process is inherently free of hydrogen.
Unlike the filler used in the SMAW process, GTAW welding filler metals do not rely on flux coverings, which may be susceptible to moisture absorption from the environment. Conversely, the GTAW process utilizes dry inert shielding gases that cover the molten weld pool from oxidizing atmospheres. Any moisture on the surface of the component being welded will be vaporized ahead of the welding torch. The vapor is prevented from being mixed with the molten weld pool by the inert shielding gas that blows the vapor away before it can be mixed. Furthermore, modern filler metal manufacturers produce wires having very low residual hydrogen. This is important because filler metals and base materials are the most realistic sources of 9 of 61

hydrogen for automatic or machine GTAW temperbead welding.
Therefore, the potential for hydrogen-induced cracking is greatly reduced by using the machine'GTAW process.
In the unlikely case that hydrogen cracking occurs, nondestructive examination (NDE) of the weldment will be performed 48 hours after completion of the third weld layer, thereby providing assurance that the cracking would be identified. See paragraph V.A.3.g for additional technical justification.
* Cold Restraint Cracking Cold cracking generally occurs during Cooling at temperatures approaching ambient temperature. As stresses build under a high degree of restraint, cracking may occur at defect locations. Brittle microstructures with low ductility are subject to cold restraint cracking.
However, the ambient temperature temperbead process is designed to provide a sufficient heat inventory so as to produce the desired tempering for high toughness. Because the machine GTAW temperbead process provides precision bead placement and control of heat, the toughness and ductility of the HAZ will typically be superior to the base material. Therefore, the resulting structure will be appropriately tempered to exhibit toughness sufficient to resist cold cracking.
: b. Exceptions to ASME Code Case N-638-1 Conditions The ambient temperature temperbead technique of Code Case N-638-1 was conditionally approved by the NRC in Regulatory Guide 1.147. The proposed ambient temperature temperbead welding technique of Attachment 3 is identical to Code Case N-638-1 with the following exceptions:
* Code Case N-638-1, paragraph 1.0(a) limits the maximum area of an individual weld to 100 square inches. The proposed alternative limits the surface area to 500 square inches. The technical basis for this change is provided in Attachment 5.
* Code Case N-638-1, paragraph 1.0(a) states that "the depth of the weld shall not be greater than one-half of the ferritic base metal thickness". Because the proposed alternative applies to deposition of weld overlays for which there are no weld or base material excavations, this limitation does not apply and is not included in Attachment 3.
* When welding is to be performed in a pressurized environment (e.g.,
an enclosed environment that is pressurized to prevent leakage so that welding can be performed), Code Case N-638-1, paragraph 2.1 (b) requires that the pressurized environment be duplicated in the procedure qualification test assembly. Because this condition does not exist when applying weld overlays in the request, this requirement is not included in Attachment 3.
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* When welding is performed in the core beltline region of the reactor pressure vessel, Code Case N-638-1, paragraph 2.1(c) requires that the effects of irradiation on the properties of the materials be considered. Because weld overlays will not be applied to the core beltline region of the reactor pressure vessel, this requirement is not included in Attachment 3.
* Code Case N-638-1, paragraph 2.1 (h) requires the performance of Charpy V-notch testing of the ferritic weld metal of the procedure qualification test coupon. Because austenitic weld metal (i.e., Inconel Alloy 52 "Modified") will be used to fabricate the proposed weld overlays, this requirement does not apply and is not included in Attachment 3..
* Code Case N-638-1, paragraph 2.1 (j) specifies acceptance criteria for Charpy V-notch tests of the HAZ. According to paragraph 2.1(j), the "average values of the three HAZ impact tests shall be equal to or greater than the average values of the three unaffected base metal tests". Although not explicitly stated, the average values referred to in paragraph 2.1 (j) are the average lateralexpansion values of the HAZ and base material specimens. Because this is the case, the acceptance criteria for Charpy V-notch testing of the HAZ is also based on average lateralexpansion values in the proposed alternative. The technical basis for this change is provided in Attachment 5.
Code Case N-638-1, paragraph 3.0(c) requires the deposition and removal of at least one weld reinforcement layer for "similar materials" (i.e., ferritic materials). This requirement is only applicable when welding is performed using ferritic filler weld metal. When temperbead welding is performed with ferritic filler metal, each ferritic weld layer must be tempered by the heat supplied from a subsequent weld layer. Because the last layer of a weld or weld repair would be untempered without the deposition of one additional weld layer, paragraph 3.0(c) requires the deposition and removal of a reinforcement layer to provide the required tempering. Since only austenitic filler metal (i.e., Alloy 52M) will be used to fabricate the proposed weld overlays, depositing and removing a weld reinforcement layer is not required. Therefore, this requirement is not included into Attachment 3.
Code Case N-638-1, paragraph 3.0 does not specifically address monitoring or verification of welding interpass temperatures. Because this.is the case, interpass temperature controls are specified in Attachment 3.. The proposed interpass temperature controls are based on field experience with depositing weld overlays. Interpass temperature beyond the third layer has no impact on the metallurgical properties of the low alloy steel HAZ.
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As an alternative to the examination requirements of Section 4.0 of Code Case N-638-1, the weld overlay will be examined in accordance with the examination and inspection requirements of Attachment 2, Section 3.0. The suitability of the proposed examinations is described in Section V.A.3, below.
: 3. Suitability of Proposed NDE The length, surface finish, and flatness requirements of the weld overlay will be specified in the design to provide for examination volume of the weld overlay as shown in Attachment 2, Figures 1 and 2. Furthermore, the examinations and inspections specified in this proposed alternative will provide adequate assurance of structural integrity for the following reasons:
: a. Weld overlays have been used for repair and mitigation of cracking in BWRs since the early 1980s. In Generic Letter 88-01, NRC Position on IntergranularStress Corrosion Cracking (IGSCC) in BWR Austenitic Stainless Steel Piping, the NRC approved the use of Section XI acceptance standards for determining the acceptability of installed weld overlays.
: b. The ultrasonic examinations performed in accordance with the proposed alternative are in accordance with ASME Section XI, Appendix VIII, Supplement 11 as implemented through the PDI. Except as described in paragraph V.A.3.c below, these examinations are considered more sensitive for detecting fabrication and service-induced flaws than the ASME Section III radiographic or ultrasonic examination methods.
Furthermore, construction-type flaws have been included in the PDI qualification sample sets for evaluating procedures and personnel.
: c.   "Best effort" preservice and inservice examinations are proposed for the DMWs adjoined to cast austenitic stainless steel materials which are identified in Attachment 1. As stated in paragraph V.A.3.b above, ultrasonic examination procedures for weld overlays are qualified in accordance with ASME Section XI, Appendix VIII, Supplement 11 as implemented through the PDI. However, these procedures have not been qualified to examine the upper 25% of cast austenitic stainless steel below the weld overlay. This limitation is addressed in Sections 3.0(b) and (c) of Attachment 2. As a result, a "best effort" examination of this region (i.e.,
upper 25% of the cast austenitic stainless steel) has been proposed urntil procedures with the appropriate detection and/or sizing capability are qualified. The "best effort" examination of the cast stainless steel will be performed in accordance with Appendix III of ASME Section XI. The use of Appendix III for examination of cast stainless steel is consistent with requirements in paragraph VIII-3110(c) of Appendix VIII. Entergy is actively working with the industry to resolve this issue. Once procedures have been qualified with the required detection and/or sizing capability, Entergy will implement these procedures at the next scheduled examination as stipulated in Attachment 2.
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The proposed "best effort" preservice and inservice examinations for the DMW weld overlays provide reasonable assurance that the structural integrity of the weld overlays will be maintained as discussed below.
The full structural weld overlays are being preemptively installed over existing 82/182 DMWs due to their susceptibility to PWSCC.
However, PWSCC is not a concern for austenitic stainless steels; there is no industry experience to suggest that PWSCC can occur in any austenitic stainless steel materials including castings. That said, should a preexisting PWSCC crack begin to propagate, its growth would be dictated by the stress distribution within the 82/182 weld. If the PWSCC crack comes into contact with the cast austenitic stainless steel, it would blunt and cease to grow as noted in Section 2.5 of EPRI Report 1010087 (MRP-139), which states: "Second, if' axial cracks developed in the Alloy 82/182 butt welds, the cracks can continue to propagate into the Alloy 600 base metal rather than arresting as would be the case for welds to low-alloy steel nozzles or stainless'steel components." Therefore, there is no concern for growth of a crack by PWSCC into the cast stainless steel.
Regarding crack growth by fatigue, a preexisting weld crack could potentially grow by this mechanism into the cast stainless steel depending on its location in the weld. However, this condition is conservatively bounded by the crack growth evaluation described in paragraph V.A. 1 of this request. This evaluation postulates a flaw initiated in the weld from the inside diameter with a depth of 75% and circumference of 3600. This is the largest possible weld flaw that could remain undetected by the preservice and inservice examinations of Attachment 2. Because this flaw is analyzed for fatigue, the potential growth of a weld crack by fatigue into the cast stainless steel is also addressed.
Inservice inspection of the DMW weld overlays with cast stainless steel safe ends will be performed at a higher frequency than those without cast stainless steel safe ends. First, the initial UT inspection of the DMW weld overlays will be performed during the first or second refueling outage after installation. Then, instead of being inspected on a twenty-five percent sample basis, these weld overlays will be UT examined once every ten years from the date of installation until such time when a technique is qualified to examine cast stainless steel in accordance with the PDI Program. Once the subject DMW overlays are UT examined by a qualified PDI technique (for cast stainless steel) and no planar flaws are detected, then the DMW overlays will be placed into a population in which 25% of that population is examined once every 10 years. Until such time, the UT inspections of the subject DMW overlays (with cast stainless steel safe ends) will not be credited to satisfy the 25% sample inspection requirement.
See Section 3.0(c) of Attachment 2 for additional details.
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: d. Per Section 3.0(a)(3) of Attachment 2, any planar flaws found during either the acceptance or preservice examination are required to meet the requirements of Table IWB-3514-2. This approach was previously determined to be acceptable in the NRC Safety Evaluation Report (SER) dated July 21, 2004 for Three Mile Island, Unit 1. However, within the same SER, the NRC had issues regarding the application of Table IWB-3514-3 to laminar flaws in a weld overlay. The SER stated, "Applying Table IWB-3514-3 to a weld overlay exposes several inherent oversights.
For instance, the acceptance of a laminar flaw size is independent of the weld overlay size, and the acceptance criteria are silent on the inaccessible volume beneath the lamination which may hide other flaws beneath the lamination." These issues are addressed, as follows:
* Per Section 3.0(a)(3)(i) of Attachment 2, Table IWB-3514-3 has been restricted so that the total laminar flaw shall not exceed 10% of the weld surface area and no linear dimension of the laminar flaw shall exceed 3 inches.
   "     Per Section 3.0(a)(3)(ii) of Attachment 2, the reduction in coverage due to laminar flaws shall be less than 10%. The dimensions of the un-inspectable volume are based on the coverage obtained by angle beam examinations of the weld overlay.
* Per Section 3.0(a)(3)(iii) of Attachment 2, any un-inspectable volume in the weld overlay shall be assumed to contain the largest radial planar flaw that could exist within that volume. This assumed flaw shall meet the inservice examination standards of Table IWB-3514-2.
Alternately, the assumed flaw shall be evaluated and meet the requirements of IWB-3640. Both axial and circumferential planar flaws shall be assumed.
: e. Weld overlays for repair of cracks in piping are not addressed by ASME Section II1. Section III utilizes NDE procedures and techniques with flaw detection capabilities that are well within the practical limits of workmanship standards for welds. These standards are most applicable to volumetric examinations conducted by radiographic examination.
Radiography (RT) of weld overlays is not appropriate because of the potential for radioactive material in the Reactor Coolant System and water in piping and components. Section III acceptance standards are written for a range of fabrication flaws including lack of fusion, incomplete penetration, cracking, slag inclusions, porosity, and concavity. However, experience and fracture mechanics have demonstrated that many of the flaws that are rejected using Section III acceptance standards do not have a significant effect on the structural integrity of the component.
Furthermore, utilizing ASME Section III acceptance standards on weld overlays would be inconsistent with years of NRC precedence and is without justification given the evidence of past NRC approvals and operating experience.
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Regarding hydrogen cracking concerns, NDE required by paragraphs 3.0(a)(2) and 3.0(a)(3) of Attachment 2 is more than capable of detecting hydrogen cracking in ferritic materials. First of all, if hydrogen cracking were to occur, it would occur in the HAZ of the ferritic base material either below or immediately adjacent to the weld overlay. Therefore, it is unnecessary to examine the entire 1.5T band defined in paragraph 1.0(e) of Attachment 3. Hydrogen cracking is not a concern in austenitic materials. If it occurs in the ferritic base material below the weld overlay, it will be detected by the ultrasonic examination which will interrogate the entire weld overlay including the interface and HAZ beneath the weld overlay. If it occurs in the ferritic base material immediately adjacent to the weld overlay, it will be detected by the liquid penetrant examination which is performed at least 1/2 inch on each side of the weld overlay.
Finally, when ambient temperature temperbead welding is performed over ferritic materials, the liquid penetrant and ultrasonic examinations will not be performed until at least 48 hours after completing of the third layer of the weld overlay. Technical justification for initiating the 48-hour hold after completing the third layer is provided in paragraph V.A.3.g.
: g. Based on Code Case N-740, the 48-hour hold for performing NDE starts after the weld overlay cools to ambient temperature when performing ambient temperature temperbead welding. This 48-hour hold is specified to allow sufficient time for hydrogen cracking to occur (if it is to occur) in the HAZ of ferritic materials prior to performing final NDE. However, based on extensive research and industry experience, the Energy Power Research Institute (EPRI) has provided a technical basis for starting the 48-hour hold after completing the third temperbead weld layer rather than waiting for the weld overlay to cool to ambient temperature. (Weld layers beyond the third layer are not designed to provide tempering to the ferritic HAZ when performing ambient temperature temperbead welding.) EPRI has documented their technical basis in technical report 1013558, Temper Bead Welding Applications- 48 Hour Hold Requirements for Ambient Temperature Temper Bead Welding (Ref. 12). The technical data provided by EPRI in their report is based on testing of SA-508, Class 2 low alloy steel which is also the PZR nozzle material. Although the hot leg nozzles were manufactured from SA-1 05, Grade 2 materials, the conclusions of the report are bounding for and applicable to P-Number 1 materials such as SA-1 05, Grade 2 which have a lower carbon equivalent and lower hardenability. After evaluating the issues relevant to hydrogen cracking such as microstructure of susceptible materials, availability of hydrogen, applied stresses, temperature, and diffusivity and solubility of hydrogen in steels, EPRI concluded the following on page 5-2 of the report: "There appears to be no technical basis for waiting 48-hours after cooling to ambient temperature before beginning the NDE of the completed weld. There should be no hydrogen present, and even if it were present, the temper bead welded component should be very tolerant of the moisture." Page 5-2 of the report also notes that over 20 weld overlays and 100 repairs have been performed using temper bead techniques on low alloy steel components over the last 20 years. During this time, there has never been an indication of hydrogen cracking by the nondestructive examination performed after the 48-hour hold or by 15 of 61

subsequent inservice inspection.
In addition, the ASME Section Xl Committee approved Revision 4 to Code Case N-638 (i.e., N-638-4) in October 2006 to allow the 48-hour hold to begin after completing the third weld layer when using austenitic filler metals. Paragraph 4(a)(2) of the code case states in part: "When austenitic materials are used, the weld shall be nondestructively examined after the three tempering layers (i.e., layers 1, 2, and 3) have been in place for at least 48 hours." The ASME Section Xl technical basis for this change is documented in the White Paper in ASME C&S Connect for Code Case N-638-4. The ASME White Paper points out that introducing hydrogen to the ferritic HAZ is limited to the first weld layer since this is the only weld layer that makes contact with the ferritic base material. While the potential for introducing hydrogen to the ferritic HAZ is negligible during subsequent weld layers, these layers provide a heat source that accelerates the dissipation of hydrogen from the ferritic HAZ in non-water backed applications. Furthermore, the solubility of hydrogen in austenitic materials such as Alloy 52M is much higher than that of ferritic materials while the diffusivity of hydrogen in austenitic materials is lower than that of ferritic materials. As a result, hydrogen in the ferritic HAZ tends to diffuse into the austenitic weld metal which has a much higher solubility for hydrogen. This diffusion process is enhanced by heat supplied in subsequent weld layers. Like the EPRI report, the ASME White Paper concludes that there is sufficient delay time to facilitate detecting potential hydrogen cracking when NDE is performed 48 hours after completing the third weld layer.
: h. The successive examination requirements of Attachment 2, paragraph 3.0(c) ensure that cracks identified by inservice inspections are appropriately monitored. According to paragraph 3.0(c) of Attachment 2, the weld overlay "shall be reexamined during the first or second refueling outage following discovery of the growth or new cracking." If additional crack growth or a new crack is discovered during a successive examination, then the successive examination of the weld overlay would be re-performed within the next two refueling outages. However, if the successive examination of the weld overlay reveals no additional indication of crack growth or new cracking, the weld overlay shall be placed into a population to be examined on a sample basis. Twenty-five percent (25%) of this population shall be examined once every ten (10) years. This successive examination schedule is identical to that specified in paragraph Q-4300 of ASME Section Xl, Appendix Q which has been imposed as a condition to using Code Case N-504-2 by the NRC in Regulatory Guide 1.147.
The examination and inspection requirements in Attachment 2, Section 3.0 are equivalent to or more conservative than the examination and inspection requirements of Appendix Q of ASME Section Xl as demonstrated in the comparison provided in Attachment 4 of this request.
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: j. Preservice and inservice examinations of the extended weld overlays for adjacent stainless steel welds will also be performed in accordance with Sections 3.0(b) and (c) of Attachment 2 with one exception. As an alternative to the inspection frequency requirements of paragraphs 3.0(c)(1) and (4) of Attachment 2, the weld overlays of the stainless steel welds will be inspected when required by the Waterford 3 Inservice Inspection Program. Entergy believes that these requirements provide assurance that the structural integrity of the subject weld overlays will be maintained.
Regarding the weld overlays of stainless steel welds associated with cast austenitic stainless steel materials, "best effort" preservice and inservice examinations are proposed. While this is the case, there is no industry experience to suggest that PWSCC can occur in any austenitic stainless steel materials including castings. Secondly, although an undetected crack could potentially grow in the stainless steel materials by fatigue, this condition is conservatively bounded by the crack growth evaluation described in paragraph V.A. 1 of this request.
: 4. NRC Submittals
: a. Entergy will submit the following information to the NRC within fourteen (14) days from completing the final ultrasonic examinations of the completed weld overlays:
* Weld overlay examination results including a listing of indications detected1 .
* Disposition of indications using the standards of ASME Section Xl, IWB-3514-2 and/or IWB-3514-3 criteria and, if possible, the type and nature of the indications 2.
* A discussion of any repairs to the weld overlay material and/or base metal and the reason for the repairs.
: b. Entergy will also submit to the NRC a stress analysis summary demonstrating that the subject nozzles will perform their intended design functions after the weld overlay installation. The stress analysis report will include results showing that the requirements of NB-3200 and NB-3600 of the ASME Code, Section III are satisfied. The stress analysis will also include results showing that the requirements of IWB-3000 of the ASME The recording criteria of the ultrasonic examination procedure to be used for examining the Waterford 3 hot leg overlays requires that all indications, regardless of amplitude, be investigated to the extent necessary to provide accurate characterization, identity, and location. Additionally, the procedure requires that all indications, regardless of amplitude, that cannot be clearly attributed to the geometry of the overlay configuration be considered flaw indications.
2 The  ultrasonic examination procedure requires that all suspected flaw indications are to be plotted on a cross-sectional drawing of the weld and that the plots should accurately identify the specific origin of the reflector.
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Code, Section XI, are satisfied. The results will show that the postulated crack including its growth in the nozzles will not adversely affect the integrity of the overlaid welds. This information will be submitted to the NRC prior to entry into Mode 4 start-up from Waterford 3's spring 2008 refueling outage&#xfd; (RF15).
B. Proposed Alternative to ASME Section XI Appendix VIII, Supplement 11 Appendix VIII, Supplement 11 of the 2001 Edition of ASME Section Xl specifies requirements for performance demonstration of ultrasonic examination procedures, equipment, and personnel used to detect and size flaws in full structural overlays of wrought austenitic piping welds. Entergy modifies the Appendix VIII, Supplement 11 qualification requirements by the proposed alternatives in the PDI program as indicated in Attachment 6 of this request because the industry cannot meet the requirements of Appendix VIII, Supplement 11. Therefore, the PDI initiatives to Appendix VIII, Supplement 11 as described in Attachment 6 will be used for qualification of ultrasonic examinations used to detect and size flaws in the preemptive full structural weld overlays of this request.
VI. CONCLUSION 10 CFR 50.55a(a)(3)(i) states:
     "Proposed alternatives to the requirements of (c), (d), (e), (f), (g), and (h) of this section or portions thereof may be used when authorized by the Director of the Office of Nuclear Reactor Regulation. The applicant shall demonstrate that:
(i) The proposed alternatives provide an acceptable level of quality and safety, or (ii) Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety."
Entergy believes that the proposed alternatives of this request provide an acceptable level of quality and safety. The preemptive weld overlays will be installed using Nickel Alloy 52M filler metal that is resistant to PWSCC. While this is the case, the overlays will also create compressive residual stresses along the inside diameter of the original weld, which prevents the initiation of new PWSCC. Finally, preservice and inservice inspection of the weld overlays will be performed to ensure structural integrity is maintained. Therefore, Entergy requests that the NRC staff authorize the proposed alternative in accordance with 10 CFR 50.55a(a)(3)(i).
VII. ATTACHMENTS Attachment 1:        Dissimilar Metal Weld Details and Figures Attachment 2:        Proposed Alternative for Preemptive Full Structural Weld Overlays Attachment 3:        Proposed Ambient Temperature Temperbead Technique 18 of 61
: Comparison of ASME Code Case N-504-2 and Appendix Q of ASME Section XI with the Proposed Alternative of Attachment 2 for Preemptive Full Structural Weld Overlays : Technical Basis for Alternatives to ASME Code Case N-638-1, Ambient Temperature Temperbead Welding : Comparison of ASME Section Xl Appendix VIII, Supplement 11 to Performance Demonstration Initiative (PDI) 19 of 61

REVISED REQUEST FOR ALTERNATIVE W3-R&R-006 ATTACHMENT 1 DISSIMILAR METAL WELD DETAILS AND FIGURES 20 of 61 to W3-R&R-006 DISSIMILAR METAL WELD DETAILS Material Identification Nozzle Type                   Nozzle           ISI Weld           Safe End (SE)          ISI Weld        Pipe/Fitting (SST)      Pipe Size    Figure No.
PZR to Surge Line           SA-508, Cl. 2  1     DMW 82/182          SA-351, CF8M          SST Weld'          SA-351, CF8M           12" NPS          1 w/ SST Clad           ID 16-017           (Cast SST)           ID 16-016              (Pipe)
PZR to Relief Valve         SA-508, CI. 2  1     DMW 82/182          SA-351, CF8M           SST Weld         SA-403, WP304           6" NPS           2 (RC-317A)               w/ SST Clad           ID 26-006           (Cast SST)           ID 26-007             (Elbow)
PZR to Relief Valve         SA-508, Cl. 2  1     DMW 82/182          SA-351, CF8M           SST Weld         SA-403, WP304           6" NPS           2 (RC-317B)               w/ SST Clad           ID 26-001           (Cast SST)           ID 26-002             (Elbow)
PZR Spare Nozzle            SA-508, CI. 2        DMW 82/182          SA-351, CF8M           SST Weld       SA-403, WP304/316         6" NPS           2 (Capped)               w/ SST Clad           ID 26-010           (Cast SST)           ID 26-011           (End Cap)
PZR to Spray Line          SA-508, Cl. 2 1      DMW 82/182        SA-182, Type 316        SST Weld 5        SA-376, TP304           4" NPS           3 w/ SST Clad           ID 25-029                                ID 25-028              (Pipe)
Hot Leg 1 to SDC Line         SA-105, Gr. 2 2      DMW 82/182          SA-351, CF8M          SST Weld 5       SA-358, Type 304         14" NPS          4 w/ SST Clad           ID 15-008           (Cast SST)           ID 21-001              (Pipe)
Hot Leg 2 to SDC Line         SA-105, Gr. 2  2     DMW 82/182          SA-351, CF8M          SST Weld         SA-358, Type 304         14" NPS          4 w/ SST Clad           ID 06-006           (Cast SST)           ID 22-001              (Pipe)
Hot Leg 1 to Surge Line       SA-105, Gr. 2 2      DMW 82/182          SA-351, CF8M          SST Weld 5         SA-351, CF8M           12" NPS          4 w/ SST Clad           ID 15-009           (Cast SST)           ID 16-001              (Pipe)
Hot Leg 1 to Drain         SA-105, Gr. 2 2      DMW 82/1 82       SA-182, Type 316        SST Weld 6        SA-376, TP304           2" NPS           5 w/ SST Clad           ID 15-006                                ID 32-001              (Pipe)
: 1. Nozzle material is low-alloy steel.
: 2. Nozzle material is carbon steel.
: 3. These ISI welds are DMWs and require preemptive structural weld overlays. Each DMW includes butter and weld.
: 4. These ISI welds are stainless welds joining stainless steel base materials.
: 5. To facilitate preservice/inservice inspection of these austenitic stainless steel welds, the preemptive structural weld overlay for each DMW will be extended across the stainless steel weld.
: 6. The drawings in Figures 1, 2, 3, 4, and 5 are schematics that do not include any design dimensions.
21 of 61 to W3-R&R-006 T
FIGURE 1 22 of 61 to W3-R&R-006 I ALLOY 52M OVERLAY I
                                                              '1=
WELD/BUTTER35       SS SAFE-END
                                    'ALLOY 821182 33 WELD CF8M I NOZZLE. SA-5O8. CL I
ZlI
                                 ,u m
FIGURE 2 23 of 61 to W3-R&R-006 ALLOY  52M  OVERLAY
                                *I                                  T     I ss    WELD/BUTTER SSWL D ALLOY 82/182            SS SAFE-END SA-182 TYPE 316 NOZZLE, SA-508, CL                                              Ss PIPE FIGURE 3 24 of 61 to W3-R&R-006 ALLOY 52M OVERLAY d
                 .1.                 -~
S*   WELD/BUTTER SSWL ALLOY 82/182            SAFE-END SS SA-351
* CF8M m
NOZZLE, SA-7105, GR72 Lr~j FIGURE 4 25 of 61 to W3-R&R-006 FIGURE 5 26 of 61

REVISED REQUEST FOR ALTERNATIVE W3-R&R-006 ATTACHMENT 2 PROPOSED ALTERNATIVE FOR PREEMPTIVE FULL STRUCTURAL WELD OVERLAYS 27 of 61 to W3-R&R-006 PROPOSED ALTERNATIVE FOR PREEMPTIVE FULL STRUCTURAL WELD OVERLAYS 1.0  GENERAL REQUIREMENTS (a)  Weld overlays may be applied to the 82/182 dissimilar metal welds joining the materials listed below. Weld overlays may be extended across adjacent stainless steel welds joining stainless steel (P-No. 8) materials.
(1)   Low alloy steel (P-No. 3, Group 3) to stainless steel (P-No. 8).
(2)   Carbon steel (P-No. 1) to stainless steel (P-No. 8)
(b)  Weld overlay filler metal shall be austenitic Nickel Alloy 52M (ERNiCrFe-7A) filler metal having a chromium content of at least 28%. The weld overlay is applied 3600 around the circumference of the item, and shall be deposited using a Welding Procedure Specification (WPS) for groove welding, qualified in accordance with the Construction Code and Owner's Requirements, and identified in the
         'Repair/Replacement Plan. As an alternative to the post-weld heat treatment requirements of the Construction Code and Owner's requirements, the provisions for "Ambient Temperature Temperbead Welding" may be used on the ferritic nozzle as described in Attachment 3.
(c)  Prior to deposition of the weld overlay, the surface to be repaired shall be examined by the liquid penetrant method. Indications larger than 1/16 inch (1.5 mm) shall be removed, reduced in size, or corrected in accordance with the following requirements.
(1)   One or more layers of weld metal shall be applied to seal unacceptable indications in the area to be repaired with or without excavation. The thickness of these layers shall not be used in meeting weld reinforcement design thickness requirements. Peening the unacceptable indication prior to welding is permitted.
(2)   If correcting indications identified in 1.0(c) is required, the area where the weld overlay is to be deposited, including any local repairs or initial weld overlay layer, shall be examined by the liquid penetrant method. The area shall contain no indications greater than 1/16 in. (1.5 mm) prior to applying the structural layers of the weld overlay.
(d)  Weld overlay deposits shall meet the following requirements:
The austenitic nickel alloy weld overlay shall consist of at least two weld layers deposited with a filler material such as identified in 1.0(b) above. The first layer of weld metal deposited may not be credited toward the required thickness.
Alternatively, a diluted layer may be credited toward the required thickness, provided the portion of the layer over the austenitic base material, austenitic weld, and the associated dilution zone from an adjacent ferritic base material contains at least 24% chromium. The chromium content of the deposited weld metal may be determined by chemical analysis of the production weld or from a representative coupon taken from a mockup prepared in accordance with the WPS (or representative WPS) for the production weld.
28 of 61 to W3-R&R-006 (e)  A new weld overlay shall not be installed on top of an existing weld overlay that has been in service.
2.0  CRACK GROWTH CONSIDERATIONS AND DESIGN (a)  Crack Growth Because the full structural weld overlays are being installed preemptively, a flaw with a depth of 75% and a circumference of 3600 will be assumed. The size of the assumed flaws shall be projected to the end of the design life of the overlay.
Crack growth, including both stress corrosion and fatigue crack growth, shall be evaluated in the materials in accordance with IWB-3640. If the flaw is at or near the boundary of two different materials, evaluation of flaw growth in both materials will be performed.
(b)  Structural Design The design of the weld overlay shall be analyzed and shown to satisfy the following, using the assumptions and flaw characterization restrictions in 2.0(a):
(1)   The axial length and end slope of the weld overlay shall cover-the weld and the heat affected zones (HAZs) on each side of the weld, and shall provide for load redistribution from the item into the weld overlay and back into the item without violating applicable stress limits of NB-3200. Any laminar flaws in the weld overlay shall be evaluated in the analysis to ensure that load redistribution complies with the above. These requirements will Usually be satisfied if the weld overlay full thickness length extends axially beyond the projected flawby at least 0.75*/Rt, where "R" is the outer radius of the item and "t" is the nominal wall thickness of the item.
(2)    Unless'specifically analyzed in accordance with 2.0(b)(1) above, the end transition slope of the overlay shall not exceed 450. A slope of not more .than 1:3 is recommended.
(3)    Because the full structural weld overlays are being installed preemptively, flaws shall be assumed to be 100% through the original wall thickness for the entire circumference.
(4)   The overlay design thickness of items meeting 2.0(b)(3) above shall be based on the measured diameter using only the weld overlay thickness conforming to the deposit analysis requirements of 1.0(d) above.. The combined wall thickness at the weld overlay, any planar flaws in the weld overlay, the flaw size assumptions of 2.0(b)(3) above, and the effects of any discontinuity (e.g., another weld overlay or reinforcement for a branch connection) within a distance of 2.54Rt from the toes of the weld overlay, shall be evaluated and shall meet the requirements of IWB-3640.
Note: Although planar flaws are considered in the IWB-3640 evaluation of the combined wall thickness in paragraph 2.0(b)(4), these planar flaws must meet the acceptance standards of IWB-3500 as required by paragraphs 3.0(a) and (b).
                                             . 29 of 61 to W3-R&R-006 (5)    The effects of any changes in applied loads, as a result of weld shrinkage from the entire overlay, on other items in the piping system (e.g., support loads and clearances, nozzle loads, changes in system flexibility and weight due to the weld overlay) shall be evaluated. Existing flaws previously accepted by analytical evaluation shall be evaluated in accordance with IWB-3640.
3.0  EXAMINATION AND INSPECTION In lieu of all other examination requirements, the examination requirements proposed herein shall be met. Nondestructive examination (NDE) methods shall be in accordance with IWA-2200, except as specified herein. NDE personnel shall be qualified in accordance with IWA-2300. Ultrasonic examination procedures and personnel shall be qualified in accordance with Appendix VIII, Section Xl except as noted in Sections 3.0(b) and 3.0(c) for weld overlays involving cast stainless steel.
(a)     Acceptance Examination (1)    The weld overlay shall have a surface finish of 250 micro-inches (6.3 micrometers) RMS or better and a flatness that is sufficient to allow for adequate examination in accordance with procedures qualified per Appendix VIII. The weld overlay shall be examined to verify acceptable configuration.
(2)    The weld overlay and the adjacent base material for at least 1/2 inch (13 mm) from each side of the weld shall be examined using the liquid penetrant method. The weld overlay shall satisfy the surface examination acceptance criteria for welds of the Construction Code or ASME Section III, NB-5300.
The adjacent base metal shall satisfy the surface examination acceptance criteria for base material of the Construction Code or ASME Section III, NB-2500. If ambient temperature temperbead welding is used, liquid penetrant examination shall be conducted at least 48 hours after completing the third layer of the weld overlay.
(3)    The examination volume A-B-C-D in Figure 1 (below) shall be ultrasonically examined to assure adequate fusion (i.e., adequate bond) with the base metal and to detect welding flaws, such as inter-bead lack of fusion, inclusions, or cracks. The interface C-D shown between the overlay and the weld includes the bond and the HAZ from the overlay. If ambient temperature temperbead welding is used, the ultrasonic examination shall be conducted at least 48 hours after completing the third layer of the weld overlay. Planar flaws shall meet the preservice examination standards of Table IWB-3514-2. In applying the acceptance standards, wall thickness "tw" shall be the thickness of the weld overlay. Laminar flaws shall meet the following:
(i)   Laminar flaws shall meet the acceptance standards of Table IWB-3514-3 with the additional limitation that the total laminar flaw shall not exceed 10% of the weld surface area and that no linear dimension of the laminar flaw area exceeds 3.0 inches (76 mm).
30 of 61 to W3-R&R-006 (ii)  The reduction in coverage of the examination volume in Figure 1 due to laminar flaws shall be less than 10%. The dimensions of the un-inspectable volume are dependent on the coverage achieved with the angle beam examination of the overlay.
(iii) Any un-inspectable volume in the weld overlay shall be assumed to contain the largest radial planar flaw that could exist within that volume.
This assumed flaw shall meet the inservice examination standards of Table IWB-3514-2. Alternately, the assumed flaw shall be evaluated and shall meet the requirements of IWB-3640. Both axial and circumferential planar flaws shall be assumed.
(4)   If a weld overlay does not meet the acceptance standards specified in 3.0(a)(2) and (3)above, the weld overlay shall be corrected by a repair/replacement activity in accordance with IWA-4000.
(5)   After completing welding activities, affected restraints, supports, and snubbers shall be VT-3 visually examined to verify that design tolerances are met.
(b)  Preservice Inspection NOTE The examination volume A-B-C-D of Figure 2 for each weld overlay will be examined using ultrasonic examination procedures and personnel qualified in accordance with ASME Section XI, Appendix VIII (as implemented through PDI).
However, as of the submittal date of this request, PDI-qualified procedures to examine the upper 25% of the cast austenitic stainless steel are not available.
Therefore, unless PDI procedures are qualified in time to support the preservice examinations required by this attachment, Entergy will perform a "best effort" preservice examination of the Figure 2 examination volume in accordance with Appendix VIII to the extent practical and the cast stainless steel volume will be examined in accordance with Appendix 111.
(1)   The examination volume A-B-C-D in Figure 2 shall be ultrasonically examined. The angle beam shall be directed perpendicular and parallel to the piping axis, with scanning performed in four directions to locate and size any cracks that might have propagated into the upper 25% of the weld, base material, or into the weld overlay. If ambient temperature temperbead welding is used, the ultrasonic examination shall be conducted at least 48 hours after completing the third layer of the weld overlay.
(2)   The preservice examination acceptance standards of Table IWB-3514-2 shall be met for the weld overlay. In applying the acceptance standards, wall thickness, tw, shall be the thickness of the weld overlay. Cracks in the outer 25% of the base metal shall meet the design analysis requirements of 2.0 above.
31 of 61 to W3-R&R-006 (c)  Inservice Inspection NOTE The examination volume A-B-C-D of Figure 2 for each weld overlay will be examined using ultrasonic examination procedures and personnel qualified in accordance with ASME Section Xl, Appendix VIII (as implemented through PDI).
However, as of the submittal date of this request, PDI-qualified procedures to examine the upper 25% of the cast austenitic stainless steel are not available.
Therefore, until such procedures are qualified, Entergy will perform "best effort" inservice inspections of the Figure 2 examination volume in accordance with Appendix VIII to the extent practical and the cast stainless steel volume will be examined in accordance with Appendix Ill. Once qualified, Entergy will implement these PDI procedures at the next scheduled inservice inspection as required by paragraph 3.0(c) of this attachment.
(1)   The weld overlay examination volume A-B-C-D in Figure 2 shall be added to the inspection plan and shall be ultrasonically examined during the first or second refueling outage following application.
(2)   The weld overlay examination volume in Figure 2 shall be ultrasonically examined to determine if any new or existing cracks have propagated into the upper 25% of the weld or base material or into the overlay. The angle beam shall be directed perpendicular and parallel to the piping axis, with scanning performed in four directions.
(3)   The acceptance standards for the ultrasonic examination of the weld overlay are specified in Table IWB-3514-2. However, if the weld overlay fails to meet the acceptance standards of Table IWB-3514-2, it can be accepted based on an analytical evaluation meeting the requirements and acceptance criteria of IWB-3600. However, flaws identified as primary water stress corrosion cracking (PWSCC) cannot be accepted by an IWB-3600 analytical evaluation. Cracks in the outer 25% of the base metal shall meet the design analysis requirements of 2.0 above.
(4)   Weld overlay examination volumes that show no indication of crack growth or new cracking shall be examined as follows:
(i)   Weld overlay examination volumes that include cast stainless steel materials shall be placed into a population to be examined once every ten years starting from the date of installation until such time when an ultrasonic technique is qualified by the PDI Program to examine cast stainless steel. Once the weld overlays are examined by the qualified PDI technique and no planar flaws are detected, then the weld overlays may be placed into the sample population of paragraph 3.0(c)(4)(ii) in which 25% of that population is ultrasonically examined once every 10 years. However, prior to satisfactory performance of a PDI qualified examination, these inservice inspections shall not be credited to satisfy the 25% sample inspection requirement of paragraph 3.0(c)(4)(ii).
32 of 61 to W3-R&R-006 (ii)   Weld overlay examination volumes that either do not contain cast stainless steel materials or meet the PDI examination requirements of paragraph 3.0(c)(4)(i) shall be placed into a population to be examined on a sample basis. Twenty-five percent (25%) of this population shall be examined once every ten (10) years.
(5)    If inservice examinations reveal crack growth, or new cracking, meeting the acceptance standards, the weld overlay examination volume shall be reexamined during the first or second refueling outage following discovery of the growth or new cracking. Weld overlay examination volumes that show no additional indication of crack growth or new cracking shall be placed into a population to be examined at the frequencies specified in paragraph 3.0(c)(4).
(6)    For weld overlay examination volumes that fail to meet the acceptance criteria as described in 3.0(c)(3) above, the weld overlay shall be removed, including the original defective weld, and the item shall be corrected by a repair/replacement activity in accordance with IWA-4000.
(d)  Additional Examinations If inservice examinations reveal an unacceptable indication, crack growth into the weld overlay design thickness, or axial crack growth beyond the specified examination volume, additional weld overlay examination volumes, equal to the number scheduled for the current inspection period, shall be examined prior to return to service. If additional unacceptable'indications are found in the second sample, 50% of the total population of weld overlay examination volumes shall be examined prior to operation. If additional unacceptable indications are found, the entire remaining population of weld overlay examination volumes shall be examined prior to return to service.
4.0   PRESSURE TESTING A system leakage test shall be performed in accordance with IWA-5000.
5.0   DOCUMENTATION Use of this alternative shall be documented on Form NIS-2A as described in the Waterford 3 ISI Plan (Ref. 6).
33 of 61 to W3-R&R-006 A                                  B C I t
I Examination Volume A-B-C-D FIGURE 1 ACCEPTANCE EXAMINATION VOLUME 34 of 61 to W3-R&R-006 1/2 inch (13 mm)         A                                      1/2 inch (13 mm) (see note)
As-Found Flaw Examination Volume A-B-C-D NOTE For axial or circumferential flaws, the axial extent of the examination volume shall extend at least 1/2 inch (13 mm) beyond the as-found flaw and at least 1/2 inch (13 mm) beyond the toes of the original weld, including weld end butter, where applied.
FIGURE 2 PRESERVICE AND INSERVICE EXAMINATION VOLUME 35 of 61

REVISED REQUEST FOR ALTERNATIVE W3-R&R-006 ATTACHMENT 3 PROPOSED AMBIENT TEMPERATURE TEMPERBEAD TECHNIQUE 36 of 61 to W3-R&R-006 PROPOSED AMBIENT TEMPERATURE TEMPERBEAD TECHNIQUE 1.0  GENERAL REQUIREMENTS (a)   This appendix applies to dissimilar austenitic filler metal welds joining the following materials:
(1)   Low alloy steel (P-No. 3, Group 3) to stainless steel (P-No. 8).
(2)   Carbon steel (P-No. 1) to stainless steel (P-No. 8)
(b) The maximum area of an individual weld overlay based on the finished surface over the ferritic base material shall be 500 square inches.
(c)   Repair/replacement activities on a dissimilar-metal weld in accordance with this attachment are limited to those along the fusion line of a nonferritic weld to ferritic base material on which 1/8 inch, or less of nonferritic weld deposit exists above the original fusion line.
(d)   If a defect penetrates into the ferritic base material, repair of the base material, using a nonferritic weld filler material, may be performed in accordance with this attachment, provided the depth of repair in the base material does not exceed 3/8 inch.
(e)   Prior to welding the area to be welded and a band around the area of at least 1-1/2 times the component thickness or 5 inches, whichever is less, shall be at least 50&deg;F (100C).
(f)   Welding materials shall meet the Owner's Requirements and the Construction Code and Cases specified in the Repair/Replacement Plan. Welding materials shall be controlled so that they are identified as acceptable until consumed.
(g)  Peening may be used, except on the initial and final layers.
2.0   WELDING QUALIFICATIONS Welding procedures and welding operators shall be qualified in accordance with ASME Section IX and the requirements of Sections 2.1 and 2.2 below.
2.1    Procedure Qualification (a)   The base materials for the welding procedure qualification shall be of the same P-Number and Group Number, as the materials to be welded. The materials shall be post-weld heat treated to at least the time and temperature that was applied to the materials being welded.
(b)   The root width and included angle of the cavity in the test assembly shall be no greater than the minimum specified for the repair.
(c)   The maximum interpass temperature for the first three layers of the test assembly shall be 150OF (660C).
37 of 61 to W3-R&R-0d6 (d)   The test assembly cavity depth shall be at least 1 inch (25 mm). The test assembly thickness shall be at least twice the test assembly cavity depth.
The test assembly shall be large enough to permit removing the required test specimens. The test assembly dimensions surrounding the cavity shall be at least the test assembly thickness and at least 6 inches (150 mm). The qualification test plate shall be prepared in accordance with Figure 1-1.
(e)   Ferritic base material for the procedure qualification test shall meet the impact test requirements of the Construction Code and Owner's Requirements. If such requirements are not in the Construction Code and Owner's Requirements, the impact properties shall be determined by Charpy V-notch impact tests of the procedure qualification base material at or below the lowest service temperature of the item to be repaired. The location and orientation of the test specimens shall be similar to those required in (f) below, but shall be in the base metal.
(f)   Charpy V-notch tests of the ferritic heat-affected zone (HAZ) shall be performed at the same temperature as the base metal test of (e) above.
Number, location, and orientation of test specimens shall be as follows:
(1)    The specimens shall be removed from a location as near as practical to a depth of one-half the thickness of the deposited weld metal. The coupons for HAZ impact specimens shall be taken transverse to the axis of the weld and etched to define the HAZ. The notch of the Charpy V-notch specimen shall be cut approximately normal to the material surface in such a manner as to include as much HAZ as possible in the resulting fracture. Where the material thickness permits, the axis of a specimen shall be inclined to allow the root of the notch to be aligned parallel to the fusion line.
(2)    If the test material is in the form of a plate or a forging, the axis of the weld shall be oriented parallel to the principal direction of rolling or forging.
(3)    The Charpy V-notch test shall be performed in accordance with SA-370.
Specimens shall be in accordance with SA-370, Fig. 11, Type A. The test shall consist of a set of three full-size 10 mm X 10 mm specimens.
The lateral expansion, percent shear, absorbed energy, test temperature, orientation and location of all test specimens shall be reported in the Procedure Qualification Record.
(g)   The average lateral expansion value of the three HAZ Charpy V-notch specimens shall be equal to or greater than the average lateral expansion value of the three unaffected base metal specimens.
2.2 Performance Qualification Welding operators shall be qualified in accordance with ASME Section IX.
38 of 61 to W3-R&R-006 3.0  WELDING PROCEDURE REQUIREMENTS The welding procedure shall include the following requirements.
(a)  The weld metal shall be deposited by the automatic or machine gas tungsten arc welding (GTAW) process.
(b)  Dissimilar metal welds shall be made using F-No. 43 weld metal (QW-432) for P-No. 8 to P-No. 1 or P-No. 3 weld joints.
(c)  The area to be welded shall be buttered with a deposit of at least three layers to achieve at least 1/8 inch (3mm) overlay thickness with the heat input for each layer controlled to within +/-10% of that used in the procedure qualification test. Particular care shall be.taken in the placement of the weld layers of the austenitic overlay filler material at the toe of the overlay to ensure that the HAZ and ferritic base metal are tempered. Subsequent layers shall be deposited with a heat input not exceeding that used for layers beyond the third layer in the procedure qualification.
(d)  The maximum interpass temperature for field applications shall be 350&deg;F (180 0 C) for all weld layers regardless of the interpass temperature used during qualification.
(e)  The preheat and interpass temperatures will be measured using a contact pyrometer. In the first three layers, the interpass temperature will be measured every three to five passes. After the first three layers, interpass temperature measurements will be taken every six to ten passes for the subsequent layers.
Contact pyrometers will be calibrated in accordance with approved calibration and control program documents.
(f)  Particular care shall be given to ensure that the weld region is free of all potential sources of hydrogen. The surfaces to be welded, filler metal, and shielding gas shall be suitably controlled.
39 of 61 to W3-R&R-006 Reduced SwOon Tensha Triruver Side Send HAZkWWp V.Nauh Trmuvwi Side Bond Reduced Secdon Twuhle Tranvere Skid Send Discard LI.Je    4,91AL Lim moV2C"Oa)
NOTE Base metal Charpy impact specimens are not shown.
FIGURE 1-1 QUALIFICATION TEST PLATE 40 of 61

REVISED REQUEST FOR ALTERNATIVE W3-R&R-006 ATTACHMENT 4 COMPARISON OF ASME CODE CASE N-504-2 AND APPENDIX Q OF ASME SECTION XI WITH THE PROPOSED ALTERNATIVE OF ATTACHMENT 2 FOR PREEMPTIVE FULL STRUCTURAL WELD OVERLAYS 41 of 61 to W3-R&R-006 COMPARISON OF ASME CODE CASE N-504-2 AND APPENDIX Q OF ASME SECTION Xl WITH THE PROPOSED ALTERNATIVE OF ATTACHMENT 2 FOR PREEMPTIVE FULL STRUCTURAL WELD OVERLAYS Code Case N-504-2 and Appendix Q of ASME Section Xl                                    Proposed Alternative of Attachment 2 Code Case N-504-2 provides requirements for reducing a defect to a      The proposed alternative of Attachment 2 provides requirements for flaw of acceptable size by deposition of weld reinforcement (weld        installing a preemptive full structural weld overlay by depositing weld overlay) on the outside surface of the pipe using austenitic stainless   reinforcement (weld overlay) on the outside surface of the item using Nickel steel filler metal as an alternative to defect removal. Code Case       Alloy 52M filler metal. Attachment 2 is applicable to DMWs associated with N-504-2 is applicable to austenitic stainless steel piping only.        ferritic and austenitic stainless steel materials. It is also applicable to According to Regulatory Guide 1.147, the provisions of Non-             similar metal welds in austenitic stainless steels. The proposed alternative mandatory Appendix Q of ASME Section XI must also be met when           of Attachment 2 is based on Code Case N-740.
using this Case. Therefore, the Code Case N-504-2 requirements presented below have been supplemented by Appendix Q of ASME Section XI.
General Requirements                                                     1.0 General Requirements Code Case N-504-2 and Appendix Q are only applicable to P-No. 8         As specified in paragraph 1.0(a) of Attachment 2, the proposed alternative austenitic stainless steels.                                             is applicable to dissimilar metal 82/182 welds joining P-No. 1 or P-No. 3 to P-No. 8 materials. It is also applicable to austenitic stainless steel welds joining P-No. 8 materials.
Basis: Code Case N-504-2 and Appendix Q are applicable to austenitic weld overlays of P-No. 8 austenitic stainless steel materials. Based on Code Case N-740, the proposed alternative of Attachment 2 was specifically written to address the application of weld overlays over dissimilar metal welds and austenitic stainless steel welds.
According to paragraph (b) of Code Case N-504-2 as supplemented         The weld filler metal and procedure requirements of Attachment 2, by Appendix Q, weld overlay filler metal shall be low carbon (0.035%     paragraph 1.0(b) are equivalent to Code Case N-504-2 and Appendix Q max.) austenitic stainless steel applied 360 degrees around the         except as noted below:
circumference of the pipe, and shall be deposited using a Welding Procedure Specification for groove welding, qualified in accordance           Weld
(     overlay filler metal shall be austenitic Nickel Alloy 52M with the Construction Code and Owner's Requirements and                       (ERNiCrFe-7A) filler metal which has a chromium content of at least identified in the Repair/Replacement Plan.                                    28%.
42 of 61 to W3-R&R-006 Code Case N-504-2 and Appendix Q of ASME Section XI                                       Proposed Alternative of Attachment 2 As an alternative to post-weld heat treatment, the provisions for ambient temperature temperbead welding may be used on. the ferritic nozzle as described in Attachment 3.
Basis: The weld overlay will be deposited with ERNiCrFe-7 (Alloy 52M) filler metal. It has been included into ASME Section IX as F-No. 43 filler metals. Containing 28.0 - 31.5% chromium (roughly twice the chromium content of 82/182 filler metal), this filler metal has excellent resistance to PWSCC. This point has been clearly documented in EPRI Technical Report MRP-115, Section 2.2. Regarding the WPS, paragraph 1.0(b) of Attachment 2 provides clarification that the WPS used for depositing weld overlays must be qualified as a groove welding procedure to ensure that mechanical properties of the WPS are appropriately established. Where welding is performed on ferritic nozzles, an ambient temperature temperbead WPS will be used. Suitability of an ambient temperature temperbead WPS is addressed in Section V.A.2 of this Request.
According to paragraph (e) of Code Case N-504-2 as supplemented            The weld overlay Attachment 2 is deposited using Nickel Alloy 52M filler by Appendix Q, the weld reinforcement shall consist of at least two        metal instead of austenitic stainless steel filler metals. Therefore, the basis weld layers having as-deposited delta ferrite content of at least 7.5      for crediting the first layer towards the required design thickness will be FN. The first layer of weld metal with delta ferrite content of at least   based on the chromium content of the nickel alloy filler metal. According to 7.5 FN shall constitute the first layer of the weld reinforcement that     paragraph 1.0(d) of Attachment 2, the first layer of Nickel Alloy 52M may be credited toward the required thickness. Alternatively, first        deposited weld metal may be credited toward the required thickness layers of at least 5 FN provided the carbon content is determined by       provided the portion of the layer over the austenitic base material, chemical analysis to be less than 0.02%.                                   austenitic weld, and the associated dilution zone from an adjacent ferritic base material contains at least 24% chromium. The chromium content of the deposited weld metal may be determined by chemical analysis of the production weld or from a representative coupon taken from a mockup prepared in accordance with the WPS for the production weld.
Basis: The weld overlay will be deposited with ERNiCrFe-7 (Alloy 52M) filler metal. Credit for the first weld layer may not be taken toward the required thickness unless it has been shown to contain at least 24%
chromium. This is a sufficient amount of chromium to prevent PWSCC.
Section 2.2 of EPRI Technical Report MRP-1 15 states the following: "The only well explored effect of the compositional differences among the weld alloys on PWSCC is the influence of chromium. Buisine, et al. evaluated 43 of 61 to W3-R&R-006 Code Case N-504-2 and Appendix Q of ASME Section Xl                                        Proposed Alternative of Attachment 2 the PWSCC resistance of nickel-based weld metals with various chromium contents ranging from about 15% to 30% chromium. Testing was performed in doped steam and primary water. Alloy 182, with about 14.5%
chromium, was the most susceptible. Alloy 82 with 18-20% chromium took three or four times longer to crack. For chromium contents between 21 and 22%, no stress corrosion crack initiation was observed..."
Design and Crack Growth Considerations                                      2.0 Design and Crack Growth Considerations The design and flaw characterization provisions of Code Case N-             The design and flaw evaluation provisions in the proposed alternative of 504-2, paragraphs (f) and (g) as supplemented by Appendix Q are             Attachment 2, Section 2.0 are the same as Code Case N-504-2 as summarized below:                                                           supplemented in Appendix Q with the exceptions below. Note that the (i) Flaw characterization and evaluation are based on the as-found          design and flaw evaluation provisions of Attachment 2 are based on flaw. Flaw evaluation of the existing flaws is based on IWB-          postulated flaws instead of as-found flaws since the structural weld 3640 for the design life.                                             overlays are being installed preemptively.
Multiple circumferential flaws shall be treated as one flaw of         For crack growth evaluations, a flaw with a depth of 75% and a circumference of 3600 will be assumed. The size of the assumed flaws length equal to the sum of the lengths of the individual flaws.       shall be projected to the end of the design life of the overlay. Crack
* Circumferential flaws are postulated as 100% through-wall               growth, including both stress corrosion and fatigue crack growth, shall for the entire circumference with one exception. When the              be evaluated in the materials in accordance with IWB-3640. If the flaw combined length of circumferential flaws does not exceed               is at or near the boundary of two different materials, evaluation of flaw 10% of the circumference, the flaws are only assumed to be            growth in both materials is required.
100% through-wall for the combined length of the flaws.                For design, flaws shall be assumed to be 100% through the original wall
* For axial flaws 1.5 inches or longer, or for five or more axial         thickness for the entire circumference.
flaws of any length, the flaws shall be assumed to be 100%        Basis: Preemptive weld overlays are being installed in accordance-with through-wall for the axial length of the flaw and entire          Attachment 2 to proactively address and mitigate any future PWSCC circumference of the pipe.                                        issues with the subject welds. Because these weld overlays are being (ii) For four or fewer axial flaws less than 1.5 inches in length, the      installed preemptively and not as a repair, postulated flaws are being weld overlay thickness need only consist of two or more layers        assumed. Regarding the crack growth analysis, a flaw originating from the of weld metal meeting the deposit analysis requirements.              inside diameter, with a depth of 75%, and a circumference of 360 degrees will be assumed. A 75% through-wall flaw is the largest flaw that could (iii) The axial length and end slope of the weld overlay shall cover        remain undetected. A preservice volumetric examination will be performed the weld and HAZs on each side of the weld, and shall provide         after application of the weld overlay using an ASME Section Xl, Appendix for load redistribution from the item into the weld overlay and       VIII [as implemented through PDI] examination procedure. This 44 of 61 to W3-R&R-006 Code Case N-504-2 and Appendix Q of ASME Section Xl                                      Proposed Alternative of Attachment 2 back into the item without violating applicable stress limits of the   examination will verify that there is no cracking in the upper 25% of the Construction Code. Any laminar flaws in the weld overlay shall         original weld and base material. The preservice examination will also be evaluated in the analysis to ensure that load redistribution        demonstrate that the assumption of a 75% through-wall crack is complies with the above. These requirements are usually met if         conservative. However, if any crack-like flaws are identified in the upper the weld overlay extends beyond the projected flaw by at least         25% of the original weld or base material by the preservice examination, 0.75 (Rt)11 2 .                                                        then the as-found flaw (postulated 75% through-wall flaw plus the portion of the flaw in the upper 25%) will be used for the crack growth analysis. With (iv) Unless specifically analyzed, the end transition slope of the regard to design, flaws are considered to be 100% through the original overlay shall not exceed 450, and a slope of not more than 1:3        weld and no structural credit is taken for the weld. All other requirements is recommended.                                                       are equivalent to Code Case N-504-2 as supplemented by Appendix Q.
(v)   The overlay design thickness of items shall be based on the measured diameter, using only the weld overlay thickness conforming to the deposit analysis requirements. The combined wall thickness at the weld overlay, any planar flaws in the weld overlay, and the effects of any discontinuity (e.g.,
another weld overlay or reinforcement for a branch connection) within a distance of 0.75 (Rt)11 2 from the toes of the weld overlay, shall be evaluated and meet the requirements of IWB-,
IWC-, or IWD-3640.
(vi) The effects of any changes in applied loads, as a result of weld shrinkage or existing flaws previously accepted by analytical evaluation shall be evaluated in accordance with IWB-3640, IWC-3640, or IWD-3640, as applicable.
Examination and Inspection                                                  3.0 Examination and Inspection Code Case N-504-2 does not include requirements for acceptance              Attachment 2, Section 3.0 of the proposed alternative specifies examination or inservice examination of weld overlays. Preservice           requirements applicable to weld acceptance examinations, preservice examination is addressed. However, Appendix Q, Article Q-4000               examinations, and inservice examinations.
does specify requirements applicable to weld acceptance examinations, preservice examinations, and inservice examinations.
45 of 61 to W3-R&R-006 Code Case N-504-2 and Appendix Q of ASME Section Xl                                     Proposed Alternative of Attachment 2 Acceptance Examination                                                  3.0(a) Acceptance Examination Q-4100(c) states that the examination volume in Figure Q-4100-1         The acceptance standards in paragraph 3.0(a)(3) of Attachment 2 are shall be ultrasonically examined to assure adequate fusion (i.e.,        identical to those of paragraph Q-4100(c) except that paragraph 3.0(a)(3) adequate bond) with the base metal and to detect welding flaws,          includes requirements and clarifications that are not included in Appendix such as inter-bead lack of fusion, inclusions, or cracks. Planar flaws   Q. First, it specifies that the ultrasonic examination shall be conducted at shall meet the preservice examination standards of Table                 least 48 hours after completing the third layer of the weld overlay when IWB-3514-2. Laminar flaws shall meet the following:                     ambient temperature temperbead welding is used. Secondly, it provides the following clarifications:
                                                                         "    The interface C-D between the weld overlay and the weld includes the bond and the HAZ from the weld overlay.
* In applying the acceptance standards, wall thickness "tw" shall be the thickness of the weld overlay.
                                                                        "     As of the submittal date of this request, PDI qualified procedures to examine the upper 25% of the cast austenitic stainless steel are not available. Therefore, until procedures are qualified for inspecting cast stainless steels, Entergy will perform a "best effort" preservice inspection of this region.
Basis: Appendix Q is applicable to austenitic stainless steel materials only; therefore, ambient temperature temperbead welding would not be applicable. It is applicable to welding performed in the proposed alternative. When ambient temperature temperbead welding is performed, nondestructive examinations must be performed at least 48 hours after completing the third layer of the weld overlay to allow sufficient time for hydrogen cracking to occur (if it is to occur). Technical justification for starting the 48-hour hold after completing the third layer of the weld overlay is provided in paragraph V.A.3.g of the request. Technical justification for the "best effort" ultrasonic examination is provided in paragraph V.A.3.c of the request. The other two changes are simply clarifications that-were added to ensure that the examination requirements were appropriately performed.
46 of 61 to W3-R&R-006 Code Case N-504-2 and Appendix Q of ASME Section XI                               Proposed Alternative of Attachment 2 Q-4100(c)(1) states that laminar flaws shall meet the acceptance   The acceptance standards in paragraph 3.0(a)(3)(i) of Attachment 2 are standards of Table IWB-3514-3.                                     identical to paragraph Q-4100(c)(1) except that paragraph 3.0(a)(3)(i) includes the additional limitation that the total laminar flaw shall not exceed 10% of the weld surface area and that no linear dimension of the laminar flaw area exceeds 3.0 inches.
Basis: These changes were made to provide additional conservatism to the weld overlay examination and to reduce the-size of the un-inspectable volume beneath a laminar flaw. See paragraph V.A.3.d of the request for additional information.
Q-4100(c)(4) allows the performance of radiography in accordance  The acceptance standards in paragraph 3.0(a)(3) of Attachment 2 do not with the Construction Code as an alternative to Q-4100(c) (3). include the radiographic alternative of paragraph Q-4100(c)(4).
Basis: The UT examinations performed in accordance with the proposed alternative are in accordance with ASME Section Xl, Appendix VIII, Supplement 11 as implemented through the PDI. These examinations are considered more sensitive for detection of defects, either from fabrication or service-induced, than either ASME Section III radiographic or ultrasonic methods. Furthermore, construction type flaws have been included in the PD1 qualification sample sets for evaluating procedures and personnel.
See Section V.A.3 of this request for additional justification.
Preservice Inspection                                              3.0(b) Preservice Inspection Q-4200(b) states that the preservice examination acceptance        The acceptance standards in paragraph 3.0(b)(2) of Attachment 2 are standards of Table IWB-3514-2 shall be met for the weld overlay. identical to paragraph Q-4200(b) except paragraph 3.0(b)(2) includes the Cracks in the outer 25% of the base metal shall meet the design'   following statement: "In applying the acceptance standards, wall thickness, analysis requirements of Q-3000.                                   tw, shall be the thickness of the weld overlay."
Basis: This provision is actually a clarification that the nominal wall thickness of Table IWB-3514-2 shall be considered the thickness of the weld overlay. It must be remembered that the acceptance standards were originally written for the welds identified in IWB-2500. Because IWB-2500 does not address weld overlays, this clarification was provided to avoid any potential confusion. However, defining the weld overlay thickness as the 47 of 61 to W3-R&R-006 Code Case N-504-2 and Appendix Q of ASME Section Xl                               Proposed Alternative of Attachment 2 nominal wall thickness of Table IWB-3514-2 has always been the practice since it literally becomes the new design wall of the piping or component.
nozzle.
Pressure Testing                                                  4.0 Pressure Testing (h) The completed repair shall be pressure tested in accordance   The pressure testing requirements of Section 4.0 of Attachment 1 are with IWA-5000. A system hydrostatic test is required if the flaw  similar to paragraph (h) of Code Case N-504-2 except that only a system penetrated the pressure boundary. A system leakage test may be    leakage test per IWA-5000 is required.
performed if pressure boundary is not penetrated.
48 of 61

REVISED REQUEST FOR ALTERNATIVE W3-R&R-006 ATTACHMENT 5 TECHNICAL BASIS FOR ALTERNATIVES TO ASME CODE CASE N-638-1, AMBIENT TEMPERATURE TEMPERBEAD WELDING 49 of 61 to W3-R&R-006 TECHNICAL BASIS FOR PROPOSED ALTERNATIVES TO ASME CODE CASE N-638-1, AMBIENT TEMPERATURE TEMPERBEAD WELDING
: 1. BASIS FOR AREA LIMITATION CHANGE TO 500 SQUARE INCHES IWA-4500 and versions of ASME Code Case N-638 through Revision 2 contained a 100 square-inch limitation on surface area of a temperbead weld over ferritic base metal.
Code Case N-638 Revision 3 changed the surface area limitation to 500 square inches.
The 500 square-inch surface area limitation Was incorporated into Code Case N-740'and is included in Attachment 3. It is anticipated that some overlays applied under this alternative will be greater than 100 square inches but less than 500 square inches.
Technical justification for allowing weld overlays on ferritic materials with surface areas up to 500 square inches is provided in the white paper supporting the changes in ASME Code Case N-638-3 and EPRI Report 1011898 (Ref. 7). The ASME white paper notes that the original limit of 100 square inches in Code Case N-638-1 was arbitrary. It cites evaluations of a 12-inch diameter nozzle weld overlay to demonstrate adequate tempering of the weld heat affected zone (HAZ) (Section 2a of the white paper), residual stress evaluations demonstrating acceptable residual stresses in weld overlays ranging from 100 to 500 square inches (Section 2b of the white paper), and service history in which weld repairs exceeding 100 square inches were NRC approved and applied to DMW nozzles in several BWR and PWR (Section 3c of the white paper) applications. Some of the cited repairs are greater than 15 years old, and have been inspected several times with no evidence of any continued degradation..
It is important to note that the above theoretical arguments and empirical data have been verified in practice by extensive field experience with temperbead weld overlays, with ferritic material coverage ranging from less than 10 square inches up to and including 325 square inches. The table below provides a partial list of such applications.
Nozzle Diameter     Approx. LAS Date               Plant
                                '          Component                      (n
                                                                        , (in)          oeae(n.
Coverage (in2),
November 2006    SONGS Unit 3        PZR spray nozzle            5.1875               40 Safety/relief nozzles            8               60 PZR surge nozzle              12.75             110 November 2006    Catawba Unit 1      PZR spray nozzle                 4               30 Safety/relief nozzles            6               50 PZR surge nozzle                14              120 November 2006    Oconee Unit 1       PZR spray nozzle               4.5               30 Safety/relief nozzles          4.5               30 PZR surge nozzle            10.875              105 HL Surge Nozzle               10.75              70 October 2006      McGuire Unit 2     PZR spray nozzle                 4               30 Safety/relief nozzles            6               50 PZR surge nozzle                14              120 50 of 61 to W3-R&R-006 Date'                                                Nozzle Diameter    Approx. LAS SPlant                      Component                   (in)         Coverage (in April 2006      Davis-Besse          Hot leg drain nozzle          4               16 February 2006   SONGS Unit 2         PZR spray nozzle              8               50 Safety/relief nozzles         6               28 November 2005   Kuosheng Unit 2      Recirc. outlet nozzle        22              250 April 2004      Susquehanna Unit 1   Recirc. inlet nozzle         12               100 Recirc. outlet nozzle        28              325 November 2003   TMI Unit 1           Surge line nozzle           11.5              75 October 2003    Pilgrim              Core spray nozzle            10               50 CRD return nozzle             5               20 October 2002    Peach Bottom         Core spray nozzle            10               50 Recirc. outlet nozzle        28              325 Units 2 & 3          CRD return nozzle             5               20 October 2002    Oyster Creek         Recirc. outlet nozzle        26              285 December 1999   Duane Arnold         Recirc. inlet nozzle         12               100 June 1999       Perry                Feedwater nozzle             12               100 June 1998       Nine Mile Point Unit Feedwater nozzle             12               100 2
March 1996      Brunswick Units 1 &  Feedwater nozzle             12               100 2
February 1996   Hatch Unit 1         Recirc. inlet nozzle         12               100 January 1991    River Bend           Feedwater nozzle             12               100 March 1986      Vermont Yankee       Core spray nozzle            10               50 It can be seen from the information above that the original DMW weld overlay was applied over 20 years ago, and weld overlays with low alloy steel coverage in the 100-square inch range have been in service for 5 to 15 years. Several overlays have been applied with low alloy steel coverage significantly greater than the 100 square inches. These overlays have been examined with PDI qualified techniques, in some cases multiple times, and none have shown any signs of new cracking or growth of existing cracks.
: 2. Clarification of Charpy V-Notch Acceptance Criteria Paragraph 2.10) of Code Case N-638-1 states, "The average of the three HAZ impact tests shall be equal to or greater than the average values of the three unaffected base metal tests." However, the Charpy V-notch test acceptance criteria in Code Case N-638-1 is misleading and inconsistent with the specified acceptance criteria in Section Xl 51 of 61 to W3-R&R-006 applicable to other Class 1 components, since it implies that all three parameters - lateral expansion, absorbed energy, and percent shear fracture - must be equal to or exceed the base material values.
Code Case N-638-2 corrected paragraph 2.1 (j)to state that Charpy V-notch acceptance criteria is based on the average lateralexpansion values rather than the average of all three values. This change clarified the intent of the code case and aligned its Charpy V-notch acceptance criteria with that of Sections III and Xl as demonstrated in the Code references provided below.
* ASME Section III - NB-4330, Impact Test Requirements
* ASME Section Xl - IWA-451 0, Similar Materials
* ASME Section Xl - IWA-4530, DissimilarMaterials The Attachment 3 acceptance criteria for Charpy V-notch testing of the weld HAZ is as specified in Code Case N-638-2. The ASME Section Xl basis for this change is documented in the White Paper in ASME C&S Connect for Code Case N-638-2.
52 of 61

REVISED REQUEST FOR ALTERNATIVE W3-R&R-006 ATTACHMENT 6 COMPARISON OF ASME SECTION XI, APPENDIX VIII, SUPPLEMENT 11 TO PERFORMANCE DEMONSTRATION INITIATIVE (PDI) 53 of 61 to W3-R&R-006 COMPARISON OF ASME SECTION Xl APPENDIX VIII, SUPPLEMENT 11 TO PERFORMANCE DEMONSTRATION INITIATIVE (PDI)
AppendixVIIi Supplement 11: Qualification Requirements for                                            PDI Program:
Full Structural Overlaid Wrought Austenitic Piping Welds            ,The     Proposed Alternative to Supplement 11 Requirements 1.0      SPECIMEN REQUIREMENTS 1.1 General. The specimen set shall conform to the following     No Change requirements.
(b) The specimen set shall consist of at least three specimens       (b) The specimen set shall consist of at least three specimens having having different nominal pipe diameters and overlay thicknesses,     different nominal pipe diameters and overlay thicknesses. They shall They shall include the. minimum and maximum nominal pip&-             include the minimum and maximum nominal pipe diameters for which the diameters for which the examination procedure is applicable. Pipe     examination procedure is applicable. Pipe diameters within a range of 0.9 diameters within a range of 0.9 to 1.5 times a nominal diameter       to 1.5 times a nominal diameter shall be considered equivalent. If the shall be considered equivalent. If the procedure is applicable to    procedure is applicable to pipe diameters of 24 inches or larger, the pipe diameters of 24 in. or larger, the specimen set must include at specimen set must include at least one specimen 24 inches or larger but least one specimen 24 in. or larger but need not include the         need not include the maximum diameter. The specimen set shall include maximum diameter. The specimen set must include at least one         specimens with overlays not thicker than 0.1 inch more than the minimum specimen with overlay thickness within -0.1 in. to +0.25 in. of the  thickness, nor thinner than 0.25 inch of the maximum nominal overlay maximum nominal overlay thickness for which the procedure is         thickness for which the examination procedure is applicable.
applicable.                                                          Basis: To avoid confusion, the overlay thickness tolerance contained in the last sentence was reworded.
(d) Flaw Conditions.
(1) Base metal flaws. All flaws must be cracks in or near the butt   (1) Base metal flaws. All flaws must be in or near the butt weld heat-weld heat-affected zone, open to the inside surface, and extending    affected zone, open to the inside surface, and extending at least 75%
at least 75% through the base metal wall. Flaws may extend 100%      through the base metal wall. Intentional overlay fabrication flaws shall not through the base metal and into the overlay material; in this case,   interfere with ultrasonic detection or characterization of the base metal intentional overlay fabrication flaws shall not interfere with       flaws. Specimens containing IGSCC shall be used when available. At least ultrasonic detection or characterization of the cracking. Specimens  70% of the flaws in the detection and sizing tests shall be cracks and the containing IGSCC shall be used when available,                       remainder shall be alternative flaws. Alternative flaw mechanisms, if used, shall provide crack-like reflective characteristics and shall be limited by the following:
54 of 61 to W3-R&R-006 Appendix VIII Supplement 11: Qualification Requirements for                                    PDI Program:
Full Structural Overlaid Wrought Austenitic Piping Welds          -The Proposed Alternative to Supplement 11 Requirements (a) The use of Alternative flaws shall be limited to when the implantation of cracks produces spurious reflectors that are uncharacteristic of actual flaws.
(b) Flaws shall be semi-elliptical with a tip width of less than or equal to 0.002 inch.
Basis: Paragraph 1.1(d)(1) requires that all base metal flaws be cracks.
Implanting a crack requires excavation of the base material on at least one side of the flaw. While this may be satisfactory for ferritic materials, it does not produce a useable axial flaw in austenitic materials because the sound beam, which normally passes only through base material, must now travel through weld material on at least one side, producing an unrealistic flaw response. To resolve this issue, the PDI program revised this paragraph to allow use of alternative flaw mechanisms under controlled conditions. For example, alternative flaws shall be limited to when implantation of cracks precludes obtaining an effective ultrasonic response, flaws shall be semi-elliptical with a tip width of less than or equal to 0.002 inch, and at least 70% of the flaws in the detection and sizing test shall be cracks and the remainder shall be alternative flaws.
The statement "intentional overlay fabrication flaws shall not interfere with ultrasonic detection or characterization of the base metal flaws" was included into paragraph 1.1(d)(1). Additionally, to avoid confusion, the phrase "and the remainder shall be alternate flaws" was added to the second to last sentence of this paragraph.
55 of 61 to W3-R&R-006 Appendix VIII Supplement i1:.Qualification Requirements for.                                              PDI Program:
Full Structural Overlaid Wrought Austenitic Piping Welds                    'The Proposed Alternative'to Supplement 11 Requirements (e) Detection Specimens (1) At least 20% but less than 40% of the flaws shall be oriented        (1) At least 20% but less than 40% of the base metal flaws shall be within +20 deg. of the pipe axial direction. The remainder shall be      oriented within +200 of the pipe axial direction. The remainder shall be oriented circumferentially. Flaws shall not be open to any surface to    oriented circumferentially. Flaws shall not be open to any surface to which which the candidate has physical or visual access. The rules of          the candidate has physical or visual access.
IWA-3300 shall be used to determine whether closely spaced flaws         Basis: The requirement for axially oriented overlay fabrication flaws in should be treated as single or multiple flaws.                           paragraph 1.1(e)(1) was excluded from the PDI Program as an improbable scenario. Weld overlays are typically applied using automated Gas Tungsten Arc Welding techniques with the filler metal being applied in a circumferential direction. Because resultant fabrication induced discontinuities would also be expected to have major dimensions oriented in the circumferential direction axial overlay fabrication flaws are unrealistic.
The requirement for, using IWA-3300 for proximity flaw evaluation in paragraph 1.1(e)(1) was excluded, instead, indications will be sized based on their individual merits.
(2) Specimens shall be divided into base and overlay grading units.      (2) Specimens shall be divided into base metal and overlay fabrication Each specimen shall contain one or both types of grading units.          grading units. Each specimen shall contain one or both types of grading units. Flaws shall not interfere with ultrasonic detection or characterization of other flaws.
(a)(1) A base grading unit shall include at least 3 in. of the length of (a)(1) A base metal grading unit includes the overlay material and the outer the overlaid weld. The base grading unit includes the outer 25% of       25% of the original overlaid weld. The base metal grading unit shall extend the overlaid weld and base metal on both sides. The base grading         circumferentially for at least 1 inch and shall start at the weld centerline and unit shall not include the inner 75% .of the overlaid weld and base      be wide enough in the axial direction to encompass one half of the original metal overlay material, or base metal-to-overlay interface,              weld crown and a minimum of 0.50 inch of the adjacent base material.
Basis: The phrase "and base metal on both sides", was inadvertently included in the description of a base metal grading unit. The PDI program intentionally excludes this requirement because some of the qualification samples include flaws on both sides of the weld. This paragraph was also modified to require that a base metal grading unit include at least 1 inch of the length of the overlaid weld, rather than 3 inches.
56 of 61 to W3-R&R-006 Appendix VIII Supplement 11: Qualification Requirements for                                               PDI Program:
Full Structural Overlaid Wrought Austenitic Piping Welds                    The Proposed Alternative to Supplement 11 Requirements (a)(2) When base metal cracking penetrates into the overlay             (a)(2) When base metal flaws penetrate into the overlay material, the base material, the base grading unit shall include the overlay metal within  metal grading unit shall not be used as part of any overlay fabrication 1 in. of the crack location. This portion of the overlay material shall grading unit.
not be used as part of any overlay grading unit.
(a)(3) When a base grading unit is designed to be unflawed, at          (a)(3) Sufficient unflawed overlaid weld and base metal shall exist on all least 1 in. of unflawed overlaid weld and base metal shall exist on     sides of the grading unit to preclude interfering reflections from adjacent either side of the base grading unit. The segment of weld length         flaws.
used gradingin one unit. base Base grading grading unit shall not bebeused unitshalldnot            in another usedninnory     base spaced     Basis: This paragraph was modified to require sufficient unflawed overlaid grading unit. Base grading units need not be uniformly spaced            weld and base metal to exist on all sides of the grading unit to preclude around the specimen.                                                     interfering reflections from adjacent flaws, rather than the 1 inch requirement.
(b)(1) An overlay grading unit shall include the overlay material and   (b)(1) An overlay fabrication grading unit shall include the overlay material the base metal-to-overlay interface of at least 6 *quare inch. The      and the base metal-to-overlay interface for a length of at least 1 inch.
overlay grading unit shall be rectangular, with minimum dimensions      Basis: This paragraph was modified to define an overlay fabrication of 2 inches.                                                            grading unit as including the overlay material and the base metal-to-overlay interface for a length of at least 1 inch, rather than the 6 square-inch requirement.
(b)(2) An overlay grading unit designed to be unflawed shall be         (b)(2) Overlay fabrication grading units designed to be unflawed shall be surrounded by unflawed overlay material and unflawed base metal-         separated by unflawed overlay material and unflawed base metal-to-overlay to-overlay interface for at least 1 in. around its entire perimeter. The interface for at least 1 in. at both ends. Sufficient unflawed overlaid weld specific area used in one overlay. grading unit shall not be used in     and base metal shall exist on both sides of the overlay fabrication grading another overlay grading unit. Overlay grading units need not be          unit to preclude interfering reflections from adjacent flaws. The specific spaced uniformly about the specimen.                                     area used in one overlay fabrication grading unit shall not be used in another overlay fabrication grading unit. Overlay fabrication grading units need not be spaced uniformly about the specimen.
Basis: This paragraph states that overlay fabrication grading units designed to be unflawed shall be separated by unflawed overlay material and unflawed base metal-to-overlay interface for at least 1 inch at both ends, rather than around its entire perimeter.
57 of 61 to W3-R&R-006 Appendix VIII Supplement 11: Qualification Requirements for "                                       PDI Program:
Full Structural Overlaid Wrought Austenitic Piping Welds                The Proposed Alternative to Supplement 11 Requirements (b)(3) Detection sets shall be selected from Table VIII-S2-1. The   (b)(3) Detection sets shall be selected from Table VIII-S2-1. The minimum minimum detection sample set is five flawed base grading units, ten detection sample set is five flawed base metal grading units, ten unflawed unflawed base grading units, five flawed overlay grading units, and base metal grading units, five flawed overlay fabrication grading units, and ten unflawed overlay grading units. For each type of grading unit,  ten unflawed overlay fabrication grading units. For each type of grading the set shall contain at least twice as many unflawed as flawed     unit, the set shall contain at least twice as many unflawed as flawed grading grading units.                                                      units. For initial procedure qualification, detection sets shall include the equivalent of three personnel qualification sets. To qualify new values of essential variables, at least one personnel qualification set is required.
Basis: This paragraph states that overlay fabrication grading units designed to be unflawed shall be separated by unflawed overlay material and unflawed base metal-to-overlay interface for at least 1 inch at both ends, rather than around its entire perimeter.
(f Sizing Specimen (1) The minimum number of flaws shall be ten. At least 30% of the   (1) The minimum number of flaws shall be ten. At least 30% of the flaws flaws shall be overlay fabrication flaws. At least 40% of the flaws  shall be overlay fabrication flaws. At least 40% of the flaws shall be open to shall be cracks open to the inside surface.                         the inside surface. Sizing sets shall contain a distribution of flaw dimensions to assess sizing capabilities. For initial procedure qualification, sizing sets shall include the equivalent of three personnel qualification sets.
To qualify new values of essential variables, at least one personnel qualification set is required.
(3) Base metal cracking used for length sizing demonstrations shall (3) Base metal flaws used for length sizing demonstrations shall be be oriented circumferentially.                                      oriented circumferentially.
(4) Depth sizing specimen sets shall include at least two distinct  (4) Depth sizing specimen sets shall include at least two distinct locations locations where cracking in the base metal extends into the overlay where a base metal flaw extends into the overlay material by at least material by at least 0.1 in. in the through-wall direction.         0.1 inch in the through-wall direction.
58 of 61 to W3-R&R-006 Appendix VIII Supplement 11: Qualification Requirements for                                           PDI Program:
Full Structural Overlaid Wrought Austenitic Piping Welds                :The Proposed Alternative to Supplement 11 Requirements 2.0      CONDUCT OF PERFORMANCE DEMONSTRATION The specimen inside surface and identification shall be concealed     The specimen inside surface and identification shall be concealed from the from the candidate. All examinations shall be completed prior to      candidate. All examinations shall be completed prior to grading the results grading the results and presenting the results to the candidate.      and presenting the results to the candidate. Divulgence of particular Divulgence of particular specimen results or candidate viewing of     specimen results or candidate viewing of unmasked specimens after the unmasked specimens after the performance demonstration is             performance demonstration is prohibited. The overlay fabrication flaw test prohibited.                                                           and the base metal flaw test may be performed separately.
Basis: The PDI Program revised paragraph 2.0 allowing the overlay fabrication and base metal flaw tests to be performed separately.
2.1 Detection Test.
Flawed and unflawed grading units shall be randomly mixed.            Flawed and unflawed grading units shall be randomly mixed. Although the Although the boundaries of specific grading units shall not be        boundaries of specific grading units shall not be revealed to the candidate, revealed to the candidate, the candidate shall be made aware of       the candidate shall be made aware of the type or types of grading units the type or types of grading units (base or overlay) that are present (base metal or overlay fabrication) that are present for each specimen.
for each specimen.
2.2 Length Sizing Test (d) For flaws in base grading units, the candidateshall estimate the  (d) For flaws in base metal grading units, the candidate shall estimate the length of that part of the flaw that is in the outer 25% of the base   length of that part of the flaw that is in the outer 25% of the base metal wall wall thickness.                                                        thickness.
59 of 61 to W3-R&R-006 Appendix VIII Supplement 11: Qualification Requirements for.                                            PDI Program:
Full Structural Overlaid Wrought Austenitic Piping Welds                  The Proposed Alternative to Supplement 11 Requirements 2.3 Depth Sizing Test.
For the depth sizing test, 80% of the flaws shall be sized at a       (a) The depth sizing test may be conducted separately or in conjunction specific location on the surface of the specimen identified to the    with the detection test.
candidate. For the remaining flaws, the regions of each specimen containing a flaw to be sized shall be identified to the candidate.   (b) When the depth sizing test is conducted in conjunction with the The candidate shall determine the maximum depth of the flaw in        detection test and the detected flaws do not satisfy the requirements of each region.                                                          1.1(f), additional specimens shall be provided to the candidate. The regions containing a flaw to be sized shall be identified to the candidate.
The candidate shall determine the maximum depth of the flaw in each region.
(c) For a separate depth sizing test, the regions of each specimen containing a flaw to be sized shall be identified to the candidate. The candidate shall determine the maximum depth of the flaw in each region.
3.0      ACCEPTANCE CRITERIA 3.1 Detection Acceptance Criteria.
Examination procedures, equipment, and personnel are qualified        (a) Examination procedures are qualified for detection when; for detection when the results of the performance demonstration          (1) All flaws within the scope of the procedure are detected and the satisfy the acceptance criteria of Table ViII-S2-1 for both detection    results of the performance demonstration satisfy the acceptance criteria and false calls. The criteria shall be satisfied separately by the       of Table VIII-$2-1 for false calls.
demonstration results for base grading units and for overlay grading units.                                                                   (2) At least one successful personnel demonstration has been performed meeting the acceptance criteria defined in (3b).
(3) Examination equipment and personnel are qualified for detection when the results of the performance demonstration satisfy the acceptance criteria of Table VIII-S2-1 for both detection and false calls.
(4) The criteria in (2), (3) shall be satisfied separately by the demonstration results for base metal grading units and for overlay fabrication grading units.
60 of 61 to W3-R&R-006 AppendixVill Supplement 11: Qualification Requirements for                                            PDI Program:'
Full Structural Overlaid Wrought Austenitic Piping Welds-                -The Proposed Alternative to Supplement 11- Requirements Basis: The PDI Program allows procedure qualification to be performed separately from personnel and equipment qualification. Historical data indicate that, if ultrasonic detection or sizing procedures are thoroughly tested, personnel and equipment using those procedures have a higher probability of successfully passing a qualification test. In an effort to increase the passing rate, PDI has elected to perform procedure qualifications separately in order to assess and modify essential variables that may affect overall system capabilities. For a procedure to be qualified, the PDI program requires three times as many flaws to be detected (or sized) as shown in Supplement 11 for the entire ultrasonic system. The personnel and equipment arestill required to meet Supplement 11.
i 3.2 Sizing Acceptance Criteria.
(a) The RMS error of the flaw length measurements, as compared        (a) The RMS error of the flaw length measurements, as compared to the to the true flaw lengths, is less than or equal to 0.75 inch. The     true flaw lengths, is less than or equal to 0.75 inch. The length of base length of base metal cracking is measured at the 75% through-         metal flaws is measured at the 75% through-base-metal position.
base-metal position.
(b) All extensions of base metal cracking into the overlay material   This requirement is omitted.
by at least 0.1 inch. are reported as being intrusions into the       Basis: The requirement for reporting all extensions of cracking into the overlay material.                                                     overlay is omitted from the PDI Program because it is redundant to the RMS calculations performed in paragraph 3.2(c), and its presence adds confusion and ambiguity to depth sizing as required by paragraph 3.2(c).
This also makes the weld overlay program consistent with the Supplement 2 depth sizing criteria.
(c) The RMS error of the flaw depth measurements, as compared       (b) The RMS error of the flaw depth measurements, as compared to the to the true flaw depths, is less than or equal to 0.125 inch.       true flaw depths, is less than or equal to 0.125 inch.
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ENCLOSURE 4 W3FI-2008-0010 LICENSEE-IDENTIFIED COMMITMENTS

Enclosure 4 to W3F1-2008-0010 Page 1 of 2 LICENSEE-IDENTIFIED COMMITMENTS TYPE (Check one)         SCHEDULED ONE-TIME      CONTINUING   ,COMPLETION COMMITMENT                           ACTION      COMPLIANCE         DATE Entergy will submit the following information to       /                     Within fourteen the NRC within fourteen (14) days from                                       (14) days from completing the final ultrasonic examinations of                              completing the the completed weld overlays:                                                 final ultrasonic examinations of
* Weld overlay examination results                                       the completed including a listing of indications detected.                          weld overlays
* Disposition of all indications using the standards of ASME Section XI, IWB-3514-2 and/or IWB-3514-3 criteria and, if possible, the type and nature of the indications
     "    A discussion.of any repairs to the weld overlay material and/or base metal and the reason for the repairs.
: 2. Entergy will submit to the NRC a stress                                      Prior to entry into analysis summary demonstrating that the                                      Mode 4 start-up subject nozzles will perform their intended                                  from RF15 design functions after the weld overlay installation. The stress analysis report will include results showing that the requirements of NB-3200 and NB-3600 of the ASME Code, Section III are satisfied. The stress analysis will also include results showing that the requirements of IWB-3000 of the ASME Code, Section XI, are satisfied. The results will show that the postulated crack including its growth in the nozzles will not adversely affect the integrity of the overlaid welds. This information will be submitted to the NRC.prior to entry into Mode 4 start-up from W3's fifteenth refueling outage (RF15).
: 3. Unless PDI procedures are qualified in time to           "                   Following support the preservice examinations required                                 installation of the by Attachment 2, Entergy will perform a "best                                weld overlays effort" preservice examination of the cast                                   during RF15.
stainless steel region.

Enclosure 4 to W3F1-2008-0010 Page 2 of 2 TYPE (Check one)        SCHEDULED ONE-TIME      CONTINUING   COMPLETION COMMITMENT                          ACTION      COMPLIANCE        DATE
: 4. Until PD1 procedures are qualified to examine                         ,/   During scheduled the upper 25% of the cast stainless steel,                                 inservice Entergy will perform "best effort" inservice                               inspections at the inspections of the region shown in Figure 2 of                             frequencies Attachment 2. Once qualified, Entergy will                                 specified in implement these PDI procedures at the next                                 Attachment 2, scheduled inservice inspection as required by                              paragraph 3.0(c).
paragraph 3.0(c) of Attachment 2. Note that inservice inspection of weld overlays for stainless steel welds is performed at the frequencies required by the Waterford 3 ISI Program as stipulated in Section V.A.3.j.
: 5. Inservice inspection of the DMW weld overlays                              During scheduled with cast stainless steel safe ends will be                                inservice performed at a higher frequency than those                                 inspections at the without cast stainless steel safe ends. First,                             frequencies the initial UT inspection of the DMW weld                                  specified in overlays will be performed during the first or                             Attachment 2, second refueling outage after installation.                                paragraph 3.0(c).
Then, instead of being inspected on a twenty-five percent sample basis, these weld overlays will be UT examined once every ten years from the date of installation until such time when a technique is. qualified to examine cast stainless steel in accordance with the PDI Program.
Once the subject DMW overlays are UT examined by a qualified PDI technique (for cast stainless steel) and no planar flaws are detected, then the DMW overlays will be placed into a population in which 25% of that population is examined once every 10 years.
Until such time, the UT inspections of the subject DMW overlays (with cast stainless steel safe ends) will not be credited to satisfy the 25% sample inspection requirement. Note that inservice inspection of weld overlays for stainless steel welds is performed at the frequencies required by the WF3 ISI Program as stipulated in Section V.A.3.j.}}