View source for ET 06-0049, Response to Request for Additional Information Relating to Pre-Weld Overlay Examination of Pressurizer Nozzle to Safe-End Dissimilar Metal Welds

{{Adams
| number = ML063380456
| issue date = 11/29/2006
| title = Response to Request for Additional Information Relating to Pre-Weld Overlay Examination of Pressurizer Nozzle to Safe-End Dissimilar Metal Welds
| author name = Garrett T
| author affiliation = Wolf Creek Nuclear Operating Corp
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000482
| license number = 
| contact person = 
| case reference number = ET 06-0049, LTR-MRCDA-06-198-NP, Rev. 2
| document type = Letter type:ET, Report, Miscellaneous
| page count = 58
| project = 
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:WLF CREEK  NUCLEAR OPERATING CORPORATION Terry J. Garrett                                                          November 29, 2006 Vice President, Engineering ET 06-0049 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

==Reference:==
Letter ET 06-0031, dated August 4, 2006, from T. J. Garrett, WCNOC, to USNRC

==Subject:==
Docket No. 50-482:                    Response to Request for Additional Information Relating to Pre-Weld Overlay Examination of Pressurizer Nozzle to Safe-End Dissimilar Metal Welds Gentlemen:
Wolf Creek Nuclear Operating Corporation (WCNOC) performed pre-weld overlay examinations of the nozzle to safe-end dissimilar metal (DM) butt welds and safe-end to pipe stainless steel butt welds on the safety, relief, spray, and surge line connections to the pressurizer during Refueling Outage 15 in October 2006. The examinations for the DM and stainless steel butt welds used Performance Demonstration Initiative (PDI) qualified procedures. The examinations were performed in preparation for the installation and examination of full structural weld overlays for repairing/mitigating pressurizer nozzle to safe-end DM butt welds as described in the Reference. The examinations identified circumferential flaw indications in three of the nozzle DM welds. WCNOC's resolution for these circumferential flaw indications was to install previously planned full structural weld overlays. On October 16, 2006, the Nuclear Regulatory Commission (NRC) provided a request for additional information (RAI) by electronic mail in preparation for a teleconference on October 17, 2006. A teleconference was held on October 17, 2006 between WCNOC, Nuclear Reactor Regulation (NRR) and Region IV personnel in which the information requested in the October 16, 2006 RAI was provided verbally concerning the results of the examinations. On October 23, 2006, a teleconference was held to clarify some of the information provided during the October 17 teleconference. Subsequent to the October 23, 2006 teleconference, the NRC requested, by electronic mail, that WCNOC confirm certain information and provide additional information for the NRC staff to perform a flaw evaluation. Additional requests for information were transmitted to WCNOC from the NRC by electronic mail on October 26, October 30, November 1 (two requests), and November 13, 2006. The Attachment identifies the information to be confirmed and the additional information requested by the NRC staff. Some of the additional information requested is information proprietary to Westinghouse Electric Company LLC, and is provided in a separate Enclosure.
P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET A -0 7

ET 06-0049 Page 2 of 2 Enclosure I, LTR-MRCDA-06-198, Rev. 2, "Wolf Creek Information on Pressurizer Nozzles Requested by the NRC," provides additional information requested by the NRC staff for their performance of a flaw evaluation. Enclosure I contains information proprietary to Westinghouse Electric Company LLC, and is supported by an affidavit (Enclosure Ill) signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of section 2.390 of the Commission's regulations.
Accordingly, it is respectfully requested that the information that is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations. Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW 2217 (Enclosure Ill) and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania, 15230-0355. Enclosure II, LTR-MRCDA-06-198-NP, Rev. 2, provides a non-proprietary version of LTR-MRCDA-06-198, Rev. 2.
Enclosure IV contains the Non-Destructive Examination (NDE) Reports for the Pre-Weld Overlay Examinations of the Relief nozzle DM Weld, the "C" Safety nozzle DM Weld, and the Surge nozzle DM Weld.
Enclosure V contains Radiograph Repair Maps for the Surge nozzle DM Weld, the "C" Safety nozzle DM Weld and the Relief nozzle DM Weld.
This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4084, or Mr. Kevin Moles at (620) 364-4126.
Very truly yours, Terry J. Garrett TJG/rlt Attachment Enclosures cc:   J. N. Donohew (NRC), w/a, w/e B. S. Mallett (NRC), w/a, w/e G. B. Miller (NRC), w/a, w/e Senior Resident Inspector (NRC), w/a, w/e

Attachment to ET 06-0049 Page 1 of 13 INFORMATION COMFIRMATION/REQUESTED INFORMATION Wolf Creek Nuclear Operating Corporation (WCNOC) performed pre-weld overlay examinations of the nozzle to safe-end dissimilar metal (DM) butt welds and safe-end to pipe stainless steel butt welds on the safety, relief, spray, and surge line connections to the pressurizer during Refueling Outage 15 in October 2006. The examinations for the DM and stainless steel butt welds used Performance Demonstration Initiative (PDI) qualified procedures. The examinations were performed in preparation for the installation and examination of full structural weld overlays for repairing/mitigating pressurizer nozzle to safe-end DM butt welds as described in the Reference. The examinations identified circumferential flaw indications in three of the nozzle DM welds. WCNOC's resolution for these circumferential flaw indications was to install previously planned full structural weld overlays. On October 16, 2006, the Nuclear Regulatory Commission (NRC) provided a request for additional information (RAI) by electronic mail in preparation for a teleconference on October 17, 2006. A teleconference was held on October 17, 2006 between WCNOC, Nuclear Reactor Regulation (NRR) and Region IV personnel in which the information requested in the October 16, 2006 RAI was provided verbally concerning the results of the examinations. On October 23, 2006, a teleconference was held to clarify some of the information provided during the October 17 teleconference. Subsequent to the October 23, 2006 teleconference, the NRC requested, by electronic mail, that WCNOC confirm certain information and provide additional information for the NRC staff to perform a flaw evaluation. Additional requests for information were transmitted to WCNOC from the NRC by electronic mail on October 26, October 30, November 1 (two requests), and November 13, 2006. Each of the NRC requests (italicized) and the WCNOC responses are provided on the following pages.
NRC REQUEST (October 16, 2006 electronic mail)
: 1. List the nozzles inspected this outage and the size and orientation of the cracking found.
Include a profile of each crack. Indicate whether any of the cracked welds are within the scope of NRC approved leak-before-break systems.

===Response===
Relief Nozzle: TBB03-4-W The Relief nozzle DM weld was reported to contain a circumferentially oriented planar flaw indication that appeared to originate at or near the inside surface. The ultrasonic responses from this reflector are consistent with branched and faceted indications. Informational sizing showed the flaw indication to be approximately 11.5 inches long (length as projected on the outside diameter) with a maximum through-wall extent of approximately 26% of the component thickness. No indications were reported in the adjacent stainless steel butt weld. A detailed plot constructed from data collected during the examination is shown below, although the location of the butter to safe-end weld interface is a pictorial approximation. The red line represents the nominal ultrasonic beam path in the material. However, some degree of beam deviation is possible due to the weld metal. The position of the transducer is indicated by where the red line terminates at the outside surface. The angle of the red line indicates the ultrasonic beam angle within the material. The flaw indication location is indicated by where the red line terminates at the inside surface. The total weld length on the outside diameter is documented as 25.0 inches. Refer to Enclosure IV for the Non-Destructive Examination (NDE) Report for the Relief nozzle DM weld.

Attachment to ET 06-0049 Page 2 of 13 TBB03-4-W Indication #1 Start: 16.5" Clockwise (CW); Max.: 1.0" CW; End: 3.0" CW; Total Length: 11.5"; Through-Wall Extent: ;26%
1.50 in Safety Nozzle: TBB03-3-C-W The "C" Safety nozzle DM weld was reported to contain a circumferentially oriented planar flaw indication that appeared to originate at or near the inside surface. The ultrasonic responses from this reflector are consistent with branched and faceted indications. Informational sizing showed the flaw indication to be approximately 3.75 inches long (length as projected on the outside diameter) with a maximum through-wall extent of approximately 23% of the component thickness. No indications were reported in the adjacent stainless steel butt weld. A detailed plot constructed from data collected during the examination is shown below, although the location of the butter to safe-end weld interface is a pictorial approximation. The plot depicts the reported cross sectional positions of the flaw indications. The total weld length on the outside diameter is documented as 25.0 inches. Refer to Enclosure IV for the NDE Report for the "C" Safety nozzle DM weld.
TBB03-3-C-W Indication #1 Start: 23.75" CW; Max.: 1.0" CW; End: 2.5" CW; Total Length: 3.75"; Through-Wall Extent: ;23%

Attachment to ET 06-0049 Page 3 of 13 Surqe Nozzle: TBB03-1-W The Surge nozzle DM weld was reported to contain three circumferentially oriented planar flaw indications that appeared to originate at or near the inside surface. Informational sizing performed estimated that flaw indication number one was approximately 1.0 inch long with a maximum through-wall extent of less than 10% of the component thickness; the second flaw indication was estimated to be approximately 2.75 inches long with a maximum through-wall extent of approximately 25% of the component thickness; and the third flaw indication was estimated to be approximately 5 inches long and with a maximum through wall extent of approximately 31% of the component thickness. All flaw indication lengths are as projected on the outside diameter. No indications were reported in the adjacent stainless steel butt welds.
The ultrasonic characteristics of these reflectors were consistent with branched flaws with multiple facets. However, these characteristics were much more evident on the larger reported flaw indication (indication #3). The cross-sectional plots shown below are based on physical measurements and available design drawings, although the location of the butter to safe-end weld interface is a pictorial approximation. The plots depict the reported cross sectional positions of the flaw indications. The total weld length on the outside diameter (OD) is documented as 47.0 inches. Refer to Enclosure IV for the NDE Report for the Surge nozzle DM weld.
TBB03-1-W Indication #1 Start: 43.0" CW; Max.: 43.5" CW; End: 44.0" CW; Total Length: 1.0"; Through-Wall Extent: <10%

Attachment to ET 06-0049 Page 4 of 13 TBB03-1-W Indication #2 Start: 28.75" CW; Max.: 30.0" CW; End: 31.5" CW; Total Length: 2.75"; Through-Wall Extent: -25%
TBBO3-1-W Indication
                                                               #3 Start: 20.5" CW; Max.: 21.0" CW; End: 25.5" CW; Total Length: 5.0"; Through-Wall Extent: z31%
140* " D IA piping welds or                piping lines has None of the Pressurizer nozzle to                        connected                          utilized leak-hpfore-break analysis.
: 2. Summarize the type and qualification of each inspection types and angles of probes used,                               performed; please specify the the scanning directions, automatic
             .n
              . a..c ,.l~r n, *nnlicable limitations to the PDI qualification.            and/or manual inspection, and lht a,, Y ,,
eluilzd....nacoda Response: The examination procedure (UT-103) and                                                        c personnel utilized were in accordance with ASME Section XI, Appendix VIII Supplement content of examination                                  10 and PDI requirements. The technical examination procedure procedure         UT-103 is the same as PDI-UT-10, UT-103 is qualified for the detection                  Revision C. The circumferentially oriented flaws   and the detection of axially oriented flawsand length sizing of located in the base or

Attachment to ET 06-0049 Page 5 of 13 weld metal. The procedure is not qualified for depth sizing flaws of either circumferential or axial orientation. Examination personnel qualifications were for detection only. Informational sizing was performed to provide an approximation of indication length and depth. The examination techniques applied to estimate the through-wall extent of the indications were capable of detecting the presence of flaw indications through-out the examination volume, but have not been qualified for depth sizing.
PDI-UT-10 and UT-103 are manual examination procedures. Manual examinations of these nozzle to safe-end welds were performed with a Panametrics EPOCH 4 ultrasonic instrument.
The search units used during the examinations complied with the requirements of the procedure and are listed on the PDI Table 1 document for PDI-UT-10. The welds were scanned with the required search units (see Table 1 and 2) for flaw detection in both the axial and circumferential directions.
Table 1 WCGS Pressurizer Surge Nozzle MANUFACTURER             MODEL         ANGLE/MODE          FREQ        SCAN DIRECTION (MHz)
RTD                  TRLA        450 Longitudinal     2.0              AX (1)
RTD                  TRLA        600 Longitudinal     2.0              AX (1)
RTD                  TRLA        450 Longitudinal      1.0            CIRC (2)
KBA               COMP-G            450 Shear          1.5        AX/CIRC (FLAT)
(1)Contoured for axial scanning (2) Contoured for circumferential scanning Table 2 WCGS Pressurizer Safety and Relief Nozzles MANUFACTURER             MODEL         ANGLE/MODE          FREQ        SCAN DIRECTION (MHz)
RTD                  TRLA        450 Longitudinal     2.0              AX (1)
RTD                  TRLA        600 Longitudinal     2.0              AX (1)
RTD                  TRLA        360  Longitudinal     1.0            CIRC (2)
KBA               COMP-G            450 Shear          1.5          AX (FLAT)
KBA               COMP-G             380 Shear         1.5            CIRC (2)
(1) Contoured for axial scanning (2) Contoured for circumferential scanning
: 3. Summarize actions taken to characterizethe nature of the cracking found (e.g., PWSCC).
For example: Indicate (1) whether previous UT data has been reviewed and, if so, what was determined from this review, and (2) whether the construction radiographs were retrieved, digitized, enhanced and/or reviewed and, if so, what was determined from this review.
Response: A review of the historical ultrasonic (UT) examination data revealed no recordable indications. However, the previous UT examinations were performed in 1993 and in 2000 prior to the current improved ASME Section Xl Appendix VIII and PDI requirements. The previous examination techniques do not meet current procedure requirements. Based on industry experience, the previously applied examination techniques may have been incapable of detecting the currently identified flaw indications.

Attachment to ET 06-0049 Page 6 of 13 The final acceptance construction radiographs were retrieved, digitized, and enhanced. A complete review of the digitized construction radiographs and reader sheets was performed to determine if fabrication flaws were present in the areas of the reported indications and to determine if there was evidence of any weld repairs that could have been performed in these areas. The results of this review revealed that the Surge and Relief nozzle welds had gone through significant repair evolutions. However, the post repair, final acceptance radiographs show no relevant indications present. Also, the results of this review revealed that the "C" Safety nozzle had no rejectable indications or repair history and the final acceptance radiographs show no relevant indications present.
Enclosure V provides the radiograph repair maps for the Surge nozzle DM weld, the "C" Safety nozzle DM weld and the Relief nozzle DM weld. Enclosure V shows that shop fabrication repairs were made in the same location as a portion of the Refueling Outage 15 identified flaw indication for the Relief DM weld. However, for the Surge nozzle DM weld, the reference point for shop radiograph locations could not be determined. Therefore, no direct correlation can be determined between the Surge nozzle DM weld shop repairs and Refueling Outage 15 identified flaw indications. Shop radiograph records for the "C" Safety nozzle DM weld show no rejectable flaws requiring repair, but the reported Refueling Outage 15 flaw indications did exhibit characteristics similar to the flaw indications reported for the Relief nozzle DM weld.
Although the "C" Safety nozzle DM weld radiographs do not show evidence of repairs, shop radiographs may not provide a true indication of the extent of shop repairs because in-process weld repairs performed before the weld was presented for radiographic examination are not documented in the radiography reports.
: 4. Provide any applicable information regarding third party review of the UT data gathered during this outage. For example, were any representatives from the EPRI NDE Center involved in reviewing the data? Summarize the conclusion of any third party reviewers.
Response: The Electric Power Research Institute (EPRI) Non-Destructive Examination (NDE)
Center was contacted to provide an independent evaluation concerning the results of the examinations. An EPRI NDE Center representative arrived at Wolf Creek Generating Station (WCGS) on October 11, 2006. The EPRI evaluation included review of the techniques utilized during the examination and characterization of the flaw indication responses. The EPRI review included a "hands on" evaluation of the reported flaw indications using the same qualified techniques as used during the initial examination. The EPRI review concurred with the observation made by the original examiner that the reflector responses were consistent with the presence of flaws. The results reported in the response to RAI #1 above include the EPRI evaluation.
: 5. Provide any information regarding review of fabrication records of the welds inspected.
Identify the weld metal used in the dissimilarmetal welds. Indicate whether repairs were noted on the respective records and whether the indicationsare in the vicinity of the repair areas. Identify the butter material applied to the nozzle and whether the entire nozzle/butter assembly was stress relieved.
Response: Most shop fabrication records were not provided to WCNOC. For details on the review of shop fabrication radiographic records provided to WCNOC, see the response provided to RAI #3 above. As identified in the WCNOC Relief Request 13R-05 (WCNOC letter ET 06-0031 dated August 4, 2006), each of the welds between the safe-end and butter weld

Attachment to ET 06-0049 Page 7 of 13 were made with Alloy 82/182 filler material and the butter welds were made with Alloy 182 filler material. Fabrication techniques used to comply with ASME Section III Code requirements installed the butter weld prior to post weld heat treatment of the Pressurizer. Subsequent to the post weld heat treatment, the safe-end to butter dissimilar metal weld was made.
: 6. Provide your conclusions regardingthe nature of the cracking found and provide the basis for any conclusions regardingthe nature of the cracking.

===Response===
Cause of the flaw indications:
The mechanism of formation of the indications found on the pressurizer nozzle to safe-end welds cannot be determined with complete certainty without destructive laboratory examination of a sample containing a flaw. Because of the inside diameter (ID) origin, depth, and locations of the indications, obtaining a sample for laboratory analysis was impractical. Based on the preponderance of evidence discussed below, it is concluded that the most probable mechanism for formation of the indications in the Relief, "C" Safety, and Surge nozzle DM welds is Primary Water Stress Corrosion Cracking (PWSCC).
The basis for this conclusion is as follows:
The possible mechanisms of formation of the indications found by the Refuel 15 UT inspections are:
: 1. PWSCC
: 2. Fatigue
: 3. Fabrication defects Of these mechanisms, PWSCC is considered the most probable.             Observations that support PWSCC as the mechanism include the following:
: 1. All indications were found in the susceptible Alloy 82/182 weld material.
: 2. The indications are all near the ID or clearly ID connected.
: 3. The UT reflectors (indications) were characterized as "branched with multiple facets".
Of the possible defect mechanisms, only PWSCC is specific to the Alloy 82/182 nozzle to safe-end welds. The other possible mechanisms are equally likely to produce defects in the stainless steel safe-end to pipe welds as to produce defects in the nozzle to safe-end welds.
PWSCC degradation only occurs in contact with the primary coolant so defects must initiate from the ID of the pipe and grow outward through the pipe wall. Of the possible mechanisms, only PWSCC produces cracks that can be characterized as branched with multiple facets.
Fatigue cracking would be more likely to occur in the safe-end to pipe welds because they are smaller in diameter than the corresponding nozzle to safe-end welds and experience higher stresses from pipe loads. Stresses from thermal transients should be nearly the same for both welds. Because stress amplitude is the dominant factor that determines fatigue life, fatigue cracks are more likely to initiate in the safe-end to pipe welds than in the nozzle to safe-end welds. In addition, the relief and safety valve lines do not experience significant fatigue loading.
Those lines are at the top of the pressurizer in a saturated steam-saturated water environment.

Attachment to ET 06-0049 Page 8 of 13 There is no flow through the safety valve lines and no significant thermal transients.      Finally, fatigue initiated cracks would not be branched or multi faceted.
Fabrication defects should be at least as likely to be found in the safe-end to pipe welds as in the nozzle to safe-end welds. The Alloy 82/182 welds were shop welds while the safe-end to pipe welds were field welds. Shop welds are typically made under more favorable conditions than field welds. Welders are generally provided with good access to components to make the safe-end to nozzle welds. Welder access is not restricted by an attached pipe. There is also better access to the shop welds for inspection. These factors generally mean that undetected weld defects in shop welds are rare. In contrast, the safe-end to pipe welds are made in the field during plant construction. Field access for making the welds and inspecting the finished welds is generally not as favorable as for shop welds. Therefore, if the indications were from fabrication defects it is expected that some of them would have been found in the safe-end to pipe welds.
Fatigue stresses from pipe loads are highest on the outside diameter (OD) of the pipe so fatigue from such loads usually initiate on the OD surface of the pipe. ID fatigue cracks can be initiated by thermal transients because these occur from temperature changes in the fluid contained by the pipe. However, the relief and safety valve lines are stagnant and experience no thermal cycles other than heatup and cooldown. The surge line does experience ID thermal cycles, but the indications in the surge line weld appear to be very similar to those in the safety valve and relief line welds.
Fabrication defects are consistent with the ID location of the indications. The welds were made from the pipe OD so ID defects would be associated with the root pass, which is usually the most difficult weld pass to perform. ID defects are also the most likely to be missed by inspections of the finished welds. However, for these shop welds, the ID of the pipe was accessible for inspection and repair, and the final inspections of the welds was by radiography, which should detect fabrication defects at any location in the welds. The final inspection radiographs for the welds with indications have been carefully reviewed using a digitization and enhancement methodology. No features have been found on the radiographs that could be associated with the indications identified by the Refueling Outage 15 UT inspections.
Neither fatigue cracks nor fabrication defects would produce UT reflectors that would be characterized as "branched with multiple facets."
The most significant characteristic of the UT indications in the pressurizer nozzle to safe-end welds that does not strongly support PWSCC as the mechanism is the orientation of the cracks.
Past industry experience with PWSCC at pipe butt welds has been that the cracks are mostly axial in orientation. This experience is supported by computer simulations of the butt weld fabrication process that show high circumferential (hoop) residual tensile stresses but low compressive residual axial stresses (MRP-106). (Axial tensile stresses produce circumferential cracks and hoop tensile stresses produce axial cracks.) Tensile axial total stresses at the welds are only expected when tensile bending stresses from pipe loads exceed the compressive residual stresses from welding. The safety valve and relief lines are designed to have very low pipe bending moments at the pressurizer nozzles, and calculations for the surge nozzle show pipe loads to be moderate. Thus, it is considered unusual that all of the indications found at WCGS are circumferential if PWSCC is the mechanism that formed the defects.
One possible reason for the welds to have high axial stresses is that repairs were made to the welds. Repairs of defects in the butt welds are made by grinding out the defect and filling the

Attachment to ET 06-0049 Page 9 of 13 resulting cavity with new weld metal. The repair welds have different restraint than the original fabrication butt weld. Depending on the size, shape, and location of the repairs tensile axial residual stresses on weld ID over a portion of the circumference may be produced. It should be noted that for the dissimilar metal shop welds the ID of the pipe was accessible. The radiography history for the surge line and relief line nozzle to safe-end welds shows that they were extensively repaired. No history of repairs to the safety valve line nozzle to safe-end weld is found from the radiographs. This does not definitively show that repairs were not made.
Welders always have the option of grinding out portions of the deposited weld metal and re-welding as an in-process activity before the weld is submitted for the final acceptance radiograph. In process repairs can be to any layer of the butt weld deposit. Such in-process repairs are frequently not specifically documented because they are considered part of the specified welding activity. No other factors that can account for high axial tensile stresses on the ID of the "C" Safety nozzle have been identified.
: 7. Given the significanceof the inspection findings, provide your plans for expanding the inspection scope this outage to other dissimilarmetal welds in the reactorcoolant system.
If no additionalinspections are planned provide your basis for concluding that there is no additionalsignificant cracking in other welds in the RCS.
Response: This item was previously addressed in the WCNOC response to NRC RAI #2 included in WCNOC letter ET 06-0031, dated August 4, 2006. The applicable portion of that response is provided below.
"All six of the Alloy 82/182 dissimilar metal (DM) butt welds on the Pressurizer are being examined in the upcoming Refuel 15 (RF15) refueling outage. These DM welds are classified as WCNOC augmented examinations in the WCNOC Inservice Inspection (ISI) Program, based on industry experience with Alloy 82/182 welds at higher temperature locations in the reactor coolant system. The six adjacent safe-end to piping stainless steel (SS) butt welds are also being examined in RF15 due to the installation of weld overlays on the DM welds. One of these SS welds (BB02-F008) is scheduled for examination per the ISI Program.
If unacceptable flaws are found during the examination of the Alloy 82/182 DM butt welds, no expansion of examination for the DM welds is necessary. This is due to the fact that 100% of the reactor coolant system Alloy 82/182 DM piping butt welds at Wolf Creek Generating Station (WCGS) would have been examined within 18 months. The other Alloy 82/182 DM piping butt welds are on the reactor vessel nozzles and were examined with acceptable results in the previous RF14 refueling outage."
NRC REQUEST (from electronic mail dated October 23, 2006):
For the staff to perform a flaw evaluation on the pressurizer nozzle cracking, some basic information is needed. Please confirm, or correct, the information given below, and provide the information identified as needed:
Information from 10/23/06 call to be confirmed:
: 1. Material data:
82/182 weld (Sm or ultimate and yield strength, Young's modulus, etc)

Attachment to ET 06-0049 Page 10 of 13 Response: See Enclosure I, Request 5 and Response and its reference to Table 1.
: 2. Inspection history:
1993 on surge line - no reportableindication 2000 on safety and relief lines - no reportableindication Response: The information requested to be confirmed is correct.
: 3. Crack description:
Surge Nozzle (15" nozzle to 14" line)
Extensive Repair
: 1. 1" + no depth measurement! 43-44" clockwise
: 2. 2.75" + 25% thru-wall/ 28.75-31.5" clockwise
: 3. 5.0" + 31% thru-wall/ 20.5-25.5" clockwise Relief Nozzle (8" nozzle to 6" line)
Extensive Repair?
: 1. 11.5" + 26% thru-wall/ at 12 o'clock 16.5-3" clockwise Safety Nozzle (8" nozzle to 6" line)
No repairrecord
: 1. 3.75" + 23% thru-wall/ at 12 o'clock Response: The information requested to be confirmed has been revised as follows:
Surge Nozzle (15" nozzle to 14" line)
Extensive Shop Repairs
: 1. 1", <10% through-wall, i.e., essentially no depth measurement.
Starting at nozzle 00 (3150 from site north): 43 "- 44" Clockwise (CW)
: 2. 2.75", approx. 25% thru-wall.
Starting at nozzle 00: 28.75" - 31.5" CW
: 3. 5", approx. 31% thru-wall.
Starting at nozzle 00: 20.5" - 25.5" CW Relief Nozzle (8" nozzle to 6" line)
Extensive Shop Repairs
: 1. 11.5", approx. 26% thru-wall.
Starting at nozzle 00 (top dead center): 16.5" - 3" CW Safety Nozzle (8" nozzle to 6" line)
No identified shop repairs
: 1. 3.75", approx. 23% thru-wall.
Starting at nozzle 00 (top dead center): 23.75" - 2.5" CW
: 4. Additional Information needed:
A. Nozzle geometry and operatingloading?
Looking for a schematic showing all dimensions and operating membrane and bending loads for: Surge Nozzle, Relief Nozzle, and Safety Nozzle Response: See Enclosure I, Request 6 and Response, Figures 1 and 2, and Tables 2 and 3.

Attachment to ET 06-0049 Page 11 of 13 B. Is there a LBB application from Wolf Creek for its surge line?
Response: None of the pressurizer nozzle to piping welds or connected piping lines has utilized leak-before-break analysis.
C. Operating Temperature for pressurizernozzles?
Response: Operating temperature and pressure for pressurizer nozzles:
Nozzle         Normal pressure (psig)     Normal temperature (OF)
Surge                 2235                        644 Safety A, B & C            2235                        650 Relief                2235                        650 NRC REQUEST (from electronic mail dated October 26, 2006):
In addition to the email sent on 10/23/2006, add the following as information being requested:
: 1. Ultimate strength, yield strength, and Young's modulus for the 182 weld.
Response: See the response to "Material data" question in NRC's October 23, 2006 email request.
: 2. Confirm whether the stainless steel material is cast or wrought.
Response: As previously provided in Table 1 of Reference 1; connecting piping is SA-312 Type 304S and SA-376 Type 316S (wrought); safe-ends are SA-182 Grade F-316L (forging).
: 3. The residualstress distributionthat you (the licensee) plan to use.
Response: WCNOC does not have a residual stress distribution to provide. There is no requirement for WCNOC to use or develop a residual stress distribution that would be appropriate for the NRC to use in performing a flaw evaluation. The original Construction Code (Section III) does not require consideration of residual stresses and the residual stress profile developed for the weld overlay design is not appropriate for use in a flaw evaluation. However, the Materials Reliability Program (MRP) has residual stress distribution information that would be appropriate for the NRC to use and the MRP has indicated to WCNOC that, if the NRC requests this information, they would provide it to the NRC.
NRC REQUEST (from electronic mail dated October 30, 2006):
The branch would also like to take a look at [the surge nozzle] repairhistory so that it could use a reasonableresidual stress distributionin its analysis.
Response: See the response to question 3 from the NRC's October 16, 2006 email and its reference to Enclosure V for the repair history for the Surge nozzle DM weld.

Attachment to ET 06-0049 Page 12 of 13 NRC REQUEST (from electronic mail dated November 1, 2006):
/ have been asked to confirm/request about draft letter:
: 1. To confirm that the pressurizer safety nozzle and the relief nozzle have the identical geometry and loading as indicated in the draft submittal.
Response: See Enclosure 1, Request 3 and Response.
: 2. To confirm that the geometry and loading for spray line is only for information. There is no detected flaw in the spray line nozzle weld.
Response: Neither the Spray nozzle DM weld nor SS weld had any flaws detected in the pre-weld overlay examinations. The Spray nozzle information was inadvertently provided in the draft letter and has been removed from the formal submittal of letter ET 06-0049.
: 3. Request the SSE load instead of the OBE load because NRC is going to calculate the criticalflaw size consistent with the LBB approach.
Response: See Enclosure I, Request 4 and Response and Table 3 for the requested loadings, which now includes safe shutdown earthquake (SSE) loads.
NRC REQUEST (from electronic mail dated November 1, 2006):
Another PZR Nozzle Weld cracking Data Question:
The thermal loads provided in the draft letter appear to be the normal operating load. Would you also provide startup transientthermal load and the load due to thermal stratification?
Response: See Enclosure I, Request 2 and Response and Table 3 for the requested loading.
NRC REQUEST (from electronic mail dated November 13, 2006):
The clarifications that NRC needs on previously provided information are items (1) and (2) below.
: 1. Please confirm whether the thermal loads reported in draft ET 06-0049 include thermal stratification loads. If they do not, please provide the thermal stratification loads during normal operation (excluding heatup and cooldown).
Response: See Enclosure 1, Request 1 and Response and Table 3 for the requested loading.

Attachment to ET 06-0049 Page 13 of 13
: 2. MRP communicated with us that the flaw lengths reported in draft ET 06-0049 are the projected lengths of the flaws on the nozzle outer surfaces, not the actual flaw lengths on the nozzle innersurfaces. Please confirm that MRP's interpretationis correct.
Response: WCNOC has reviewed the examination summary report (which was provided for information to the NRC by e-mail dated 11/8/06) and the draft WCNOC letter ET 06-0049 (provided by e-mail dated 10/31/06) and confirms that the projected flaw lengths are on the outside surface. Therefore, the interpretation that the MRP communicated is correct as described in item 2.

==References:==
: 1. WCNOC letter ET 06-0031, "Wolf Creek Nuclear Operating Corporation's Response to Request for Additional Information Regarding 10 CFR 50.55a Request 13R-05 and Submittal of Revision 1 to 10 CFR 50.55a Request 13R-05," August 4, 2006.

Enclosure II to ET 06-0049 LTR-MRCDA-06-198-NP, Rev. 2, "Wolf Creek Information on Pressurizer Nozzles Requested by the NRC" NON- PROPRIETARY

e&Westinghouse Westinghouse Non-Proprietary Class 3 To:   Ed Ray                                                                        Date: November 17, 2006 cc: John Ghergurovich From:   Reddy Ganta                                                         Your ref:
Ext: 860-731-6425                                                         Our ref:        LTR-MRCDA-06-198-NP, Rev. 2 Fax: 860-731-6709

==Subject:==
Wolf Creek Information on Pressurizer Nozzles Requested by the NRC This letter serves as documentation satisfying the NRC request for information on the Wolf Creek Nuclear Operating Company (WCNOC) pressurizer surge, safety, and relief nozzles. The data was requested by a Wolf Creek letter [1].
Request 1: "Please confirm whether the thermal loads reported in draft letter (Westinghouse letter LTR-MRCDA-06-198) include thermal stratification loads? If they do not, please provide the thermal stratification loads during the normal operation (excluding heatup and cooldown)."
Response: Thermal stratification loads excluding heatup and cooldown for surge line are provided as a separate case in Table 3.
Request 2: "The thermal loads provided in the draft letter (Westinghouse letter LTR-MRCDA-06-198) appear to be the normal operating load. Would you also provide startup transient thermal load and the load due to thermal stratification?"
Response: Table 3 provides operating thermal loads. Table 3 also provides startup transient thermal stratification loads for surge line. These loads are enveloped from all the thermal transients.
Request 3: "To confirm that the pressurizer safety and the relief nozzle have the identical geometry and loading."
Response: Pressurizer safety and relief nozzles have identical geometry. These are designed for the same set of loading, as shown in Table 3.
Request 4: "Request the SSE loads instead of the OBE loads because NRC is going to calculate the critical flaw size consistent with the LBB approach (in Westinghouse letter LTR-MRCDA-06-198)."
Response: SSE loads have been added to Table 3.
* Electronically approved records are authenticated in the Electronic Document Management System.

Westinghouse Non-Proprietary Class 3 Page 2 of 11 Our ref: LTR-MRCDA-06-198-NP, Rev. 2 Date: November 17, 2006 Request 5: "Material data: 82/182 weld material (Sm or ultimate and yield strength, Young's modulus, etc)."
Response: Allowable strength Sm, yield and ultimate strengths, and modulus of elasticity properties of the materials used in the pressurizer surge, safety, and relief nozzles are taken from Westinghouse data [4]. These properties are provided at the temperature of 650'F in Table 1.
Request 6: "Nozzle geometry and operating loading? Looking for a schematic showing all dimensions and operating membrane and bending loads for Surge Nozzle, Relief Nozzle, and Safety Nozzle."

===Response===
a) Figures 1 and 2 are schematics showing all dimensions [3]. Table 2 provides a summary of the dimensions derived from the drawings.
b) Table 3 provides design piping membrane and bending loads used in the evaluation [2].
Operating pressure is 2,235 psig [3].
Request 7: "Is there a LBB application from Wolf Creek for its surge line?"
Response: Westinghouse did not perform LBB analysis for Wolf Creek surge line.
Request 8: "Operating temperature for pressurizer nozzles?"
Response: Operating temperatures for the pressurizer nozzles may be determined by Wolf Creek.
Author:         Reddy Ganta            (ElectronicallyApproved*)
Major Reactor Component Design and Analysis Verifier:       C. R. Schmidt           (ElectronicallyApproved*)
Major Reactor Component Design and Analysis Approved by: Joel Stevens              (ElectronicallyApproved*)
(Acting Product Manager for John Ghergurovich)
Major Reactor Component Design and Analysis

Westinghouse Non-Proprietary Class 3 Page 3 of 11 Our ref: LTR-MRCDA-06-198-NP, Rev. 2 Date: November 17, 2006 LEGAL NOTICE This reporrTws prapaed a-- an accoimt of worki pefarnme by I.esiiughouse Electric Compan) LLC.
Ketwer WXestkih&Lse Eiectric CDmpWay I-,I                  mr any person ac*ing o, ift behallf A. Makes any warTnmty or representa--* ui ep&Trem. or implied incidrig the.z.fies of iute s; for a p-aticls purpose. or merctanbit wihrespec to                       oe-auicy complet:meness or iseftiness of the infonnation contained-in this repom or tat the use of any iarma*ot* appwraiL s, method: or process disdoed in d.is repoit may not in                 e privateky o             _d,ts.; or B_     Assumes aysbiidesiwi*t respect to theeeofr for dama*es reyudting from*                     de 5eof, any' inhrmaiion, apparutos. niethxoct or prrcess disriosed in thiis,report COPYRIC4T NOTICE, This report has been prprdb                  e~~os          krcCompaay LLC and bemr a WUestingouise Blrectsi Company copyii&#xfd;gt notice. IEformat'frnin this, report is the pmpely of amd contin copy&#xfd;Tigh- inaeeial owued bjy Viusan!Le Eaecni Company-L!ZCandbor its sbtac~ors -and sappkiers. It, is      masnitted to you im.comfdence. amd ousl, azd you. saree to treat-this domtment and the materia -c uani ned tbhereih in m~cc accordanmce wirh. the ternms and cokditons of die. a~sleinen under whicditwas.T-zpded to yoi As a,pxrrdizaang member of This ts.you are pennirted. to make the nmbiher of copies of the in. armatcio contained in ttis Tepoit dir are Lec es 1-arv for ;ou inzernia. use in. ccnnectinawith yow1 imp Lamentation of
*he re z- resu&#xfd;t for            p.Lt) :invyoi     =norl r       condut oaf buiss. Shauld implementa U.of this report. imnl1e a third parry,.yu are uperittedlto make the number of copies of the inam.nation conta.ied in Ts report tht a:e ne essary for the2 thir par's rue in supporting yoar impIementatioa at y.our PIan (s) b in or, oma ,3r =         dIroo lct ofbunes        if, aohvwe ce Sd the pjor wrMtena ,     ccnae Mtof Westing~bouse E.'ec tric Comupany LLC to 3, naswirt thi- inft =Iaion to a th ird pazrty or"pa~t'es. ALI Copies made by yonmust include the. c op~r        -          nTien a!2:tne       n heporeayntiei h ~
was5 ide adfled as projxietor3%v (1)

Westinghouse Non-Proprietary Class 3 Page 4 of 11 Our ref: LTR-MRCDA-06-198-NP, Rev. 2 Date: November 17, 2006 Proprietary Information Note that there are several locations in this report where proprietary information has been identified and bracketed. For each of the bracketed locations, the reason for the proprietary classification is given, using
-a standardized system. The proprietary brackets-are labeled with three different letters, to provide this information, and the explanation for each letter is given below:
: a.      The. information reveals the distinguishing aspects of a process or component, structure, tool, method, etc., and the prevention of its use by Westinghouse's competitors, without license from Westinghouse, gives Westinghouse a competitive economic advantage.
: c.      The information, if used by a competitor, would reduce the competitor's expenditure of resources or improve the competitor&#xfd;s advantage in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product..
: e.      The information reveals aspects of past, present, or future Westinghouse- or customer-funded development plans and programs of potential commercial value to Westinghouse.

==References:==
: 1) WCNOC Letter, ES-06-0023, "Request Information regarding NRC Questions",
November 15, 2006, (see Attachment 1).
: 2) Westinghouse Letter, LTR-MRCDA-06-56, Rev. 2, "Wolf Creek Design Information -
Pressurizer Nozzles Structural Weld Overlay (SWOL) Program", August 2, 2006.
: 3) Westinghouse Electric Report, WNET-138 (SAP)V1, Rev. 0, "Model F Series 84 Pressurizer Stress Report for Standardized Nuclear Unit Power Plant Systems (SNUPPS) Wolf Creek Nuclear Power Station Unit No. 1", August 17, 1981.
: 4) Westinghouse Calculation Note, CN-RCDA-04-46, Rev. 1, "Weld Overlay - Material Properties", June 19, 2006.

Westinghouse Non-Proprietary Class 3 Page 5 of 11 Our ref: LTR-MRCDA-06-198-NP, Rev. 2 Date: November 17, 2006 a,c,e Figure 1: Wolf Creek Pressurizer.Surge Nozzle Configuration (all units are in inches)

Westinghouse Non-Proprietary Class 3 Page 6 of 11 Our ref: LTR-MRCDA-06-198-NP, Rev. 2 Date: November 17, 2006 a,c,e r
Figure 2: Wolf Creek Pressurizer Safety and Relief Nozzle Configuration (all units are in inches)

Westinghouse Non-Proprietary Class 3 Page 7 of 11 Our ref: LTR-MRCDA-06-198-NP, Rev. 2 Date: November 17, 2006 Table 1: Material Properties Stainless Steel Alloy 182 Weld  Alloy 52 Weld   Sai8es Steel (ksi)(ksi)          SA 182, F316L (ksi)          (ksi)            (ksi)
Allowable Stress (Sm)            23.3          23.3              16.2 Yield Stress (SY)              29.7          27.5               18 Ultimate Stress (Sn)             80            80               63.4 Modulus of Elasticity (E)          28.5          27.9              25.1 Table 2: Pressurizer Nozzle Geometry for Weld Overlay Design Calculations a,c,e
_'I

Westinghouse Non-Proprietary Class 3 Page 8 of 11 Our ref: LTR-MRCDA-06-198-NP, Rev. 2 Date: November 17, 2006 Table 3: Enveloping Nozzle Loads a,c,e Notes:
OBE:   Operating Basis Earthquake SSE:   Safe Shutdown Earthquake HU:    Heatup CD:    Cooldown

Westinghouse Non-Proprietary Class 3 Page 9 of 11 Our ref: LTR-MRCDA-06-198-NP, Rev. 2 Date: November 17, 2006 Attachment 1: Request Letter from Wolf Creek W.4LF CREEK  4 'NUCLAR OPERATING CORPORATION 11115t2006 ES 06-0023 Ed Ray Westinghouse Electric Company P.O, Box 355 Pittsburg, PA 15230-0355

==SUBJECT:==
Request information regarding NRC questions

==Dear Mr. Ray:==

As per our telecom on 1 114/2006, attached Is a list of questions or additional information the NRC has requested from WCNOC. However, most of the information requested may be Westinghouse proprietary or not avilabe to WCNOC.
Please review and submit a formal letter to WCNOC responding to the additional information requested below. Recognizing some of the information may be proprietary, also include the necessary from(s)/documents required so WCNOC may distribute to the NRC.
Regards, Dave Meredith Engineeing DM/dm

Westinghouse Non-Proprietary Class 3 Page 10 of 11 Our ref: LTR-MRCDA-06-198-NP, Rev. 2 Date: November 17, 2006 The clarifications requested by the NRC (excepts from e-mails dated 11/14, 11/1 and 10/23):
(1) Please confirm whether the thermal loads reported in draft letter (Westinghouse letter LTR-MRCDA-06-198) include thermal stratification loads. if they do not, please provide the thermal stratification loads during normal operation (excluding heatup and cooldown).
(2) The thermal loads provided in the draft letter (Westinghouse letter LTR-MRCDA-06-198) appear to be the normal operating load. Would you also provide startup transient thermal toad and the load due to thermal stratification?
(3) To confirm that the pressurizer safety nozzle and the relief nozzle have the identical geometry and loading.
(4) Request the SSE loads instead of the OBE loads because NRC is going to calculate the critical flaw size consistent with the LBB approach (in Westinghouse letter LTR-MRCDA-06-198).
(5) Material data: 821182 weld material (Sm or ultimate and yield strength, Young's modulus, etc)
(6) Nozzle geometry and operating loading? Looking for a schematic showing all dimensions and operating membrane and bending loads for Surge Nozzle, Relief Nozzle, and Safety Nozzle (7) Is there a LBB application from Wolf Creek for its surge line?
(8) Operating Temperature for pressurizer nozzles?

Westinghouse Non-Proprietary Class 3 Page 11 of 11 Our ref: LTR-MRCDA-06-198-NP, Rev. 2 Date: November 17, 2006 DESIGN DOCUMENTATION VERIFIER CHECKLIST (Completed by the Verifier)
No.                                     Review Topic                                   Yes    No     N/A 1  Are the results/conclusions correct and appropriate for their intended use?         X 2  Are all limitations on the results/conclusions documented?                          X 3  Is the documentation legible, reproducible and in a form suitable for               X archiving as a Quality Record?
4  Is the document identified by title, document number and date?                      X 5  Are all the pages sequentially numbered with the total number of pages              X indicated and is the document number and revision number listed on each page?
6  Is the subject and/or purpose of the document clearly stated?                       X 7  Were adequate efforts made to determine the current or proposed                      x condition/configuration of the plant/equipment that is being evaluated?
8  Has the potential impact of the design activity on other plants been                              X assessed, and if applicable, been acknowledged and documented?
9  Are the assumptions clearly identified and justified?                                             X 10  Are the methods clearly identified?                                                  X 11  Are any open items properly identified?                                                           X 12  Are all design inputs and their sources provided and determined to be               X appropriate?
13  Are references as direct as possible to the original source?                        X 14  Do the references contain sufficient information to clearly identify the source     X and facilitate its retrieval, including documents not maintained as quality records by Westinghouse?
15  Is the verification status of design inputs appropriate and documented?             x 16  Is the verification status of the document indicated?                               X 17  Is the proprietary classification associated with the document appropriately         X identified?

Enclosure III to, ET 06-0049 Westinghouse Electric Company LLC LTR CAW-06-2217, "Application for Withholding Proprietary Information from Public Disclosure"

Westinghouse                           '*
Westinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission                                Direct tel: (412) 374-4643 Document Control Desk                                             Direct fax: (412) 374-4011 Washington, DC 20555-0001                                            e-mail: greshaja@westinghouse.com Our ref: CAW-06-2217 November 20, 2006_
APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

==Subject:==
LTR-MRCDA-06-198, Rev. 2, "Wolf Creek Information on Pressurizer Nozzles Requested by the NRC" The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-06-2217 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by Wolf Creek Nuclear Operating Company.
Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-06-2217, and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.
Very truly yo rs,
                                                  /   A. Gresham, Manager Regulatory Compliance and Plant Licensing Enclosures cc: Jon Thompson (NRC)

CAW-06-2217 bcc: J. A. Gresham (ECE 4-7A) IL R. Bastien, IL (Nivelles, Belgium)
C. Brinkman, IL (Westinghouse Electric Co., 12300 Twinbrook Parkway, Suite 330, Rockville, MD 20852)
RCPL Administrative Aide (ECE 4-7A) IL, IA (letter and affidavit only)
E. Ray (ECE =260C) .........          ..     --..

CAW-06-2217 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared J. A. Gresham, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and. belief:
J. A. Gresham, Manager.
Regulatory Compliance and Plant Licensing Sworn to and subscribed before me this 20th day of November, 2006 Notary Public Notarial Seal Sharon L. Ron, Notary Public Monroeville Boro, Allegheny County My Commission Expires January 29,2007 Member, Pennsylvania A*1;: o. 3*     "

2                                      CAW-06-2217 (1) I am Manager, Regulatory Compliance and Plant Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the finction of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.
(2) I am making thisAffidavit in conformance with the provisions of 10 CFR Section 2.390 of tile Commission's regulations and in conjunction with the Westinghouse "Application for Withholding" accompanying this Affidavit.
(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.
(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.
(i)      The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.
(ii)    The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence.
The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.
Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:
(a)      The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

3                                       CAW-06-2217 (b)    It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.
(c)      Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
(d)      It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
(e)     It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.
(f)     It contains patentable ideas, for which patent protection may be desirable.
There are sound policy reasons behind the Westinghouse system which include the following:
(a)     The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.
(b)     It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.
(c)     Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.
(d)     Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary infornation, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

4                                     CAW-06-2217 (e)      Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.
(f)      The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.
(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.
(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in LTR-MRCDA-06-198, Rev. 2, "Wolf Creek Information on Pressurizer Nozzles Requested by the NRC" (Proprietary), dated November 13, 2006, for Wolf Creek, being transmitted by the Wolf Creek Nuclear Operating Company letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse for the Wolf Creek Nuclear Operating Company is expected to be applicable for other licensee submittals in response to certain NRC requirements forjustification of Information requested on Pressurizer nozzles.
This information is part of that which will enable Westinghouse to:
(a) Determine the specific dimensions of the pressurizer nozzles.
(b) Provide specific loading of the nozzles that can be used to develop methodology for determining weld overlay sizing.
Further this information has substantial commercial value as follows:

5                                     CAW-06-2217 (a)     Westinghouse plans to sell the use of similar information to its customers for purposes of meeting NRC requirements for licensing documentation.
(b)      Westinghouse can sell support and defense of the weld overlay analysis.
(c)      The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.
Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar weld overlay designs and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.
The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.
In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.
Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.
In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the infornation which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the infornation that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).
COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Enclosure IV to ET 06-0049 Non-Destructive Examination (NDE) Reports for the Pre-Weld Overlay Examinations of the Relief nozzle DM Weld, the "C" Safety nozzle DM Weld, and the Surge nozzle DM Weld

Plant / Unit                  WOLF CREEK                                                                                                                                       Page          1        of          9 Comp. / System           PZR SAFETYIRELIEF                             ULTRASONIC CALIBRATION I EXAMINATION DATA SHEET                                                         Data Sheet #            JLD-001 Procedure No.                     UT-103                                                                                                                            DAC CURVE Rev / Chng. No.                    3 / NA                        Cal. Checks           Time              Date                                       11DNOTCH                                         ID NOTCH        _
ID NOTCH Cal. Block No.                      170 Cal. Block Temp.                    1090                                                 946           10110106 Initial Surface Temp.                       1190                                                 948           10/10/06 Temp. Guage:               PTC 312F / 250911                                              NA                NA Intermediate Size            6"        Sch.             160                                            NA                NA NA                NA NA                NA Intermediate ED     Ferritic        r!J Austenitic                                                      NA                NA 1855           10110/06 Each Major CRT Div. :              0.389 10.376                                         1856           '101`10106 Search Unit #1                                    Search Unit #2 Cal. Dir.:       0*]Axial     QCirc. [Both                       Scan Dir.:             I        to weld               Manufacture:                   KBA                 Manufacture:                  RTD
                                                                                               -to        weld1            Serial No.:                 00PSW6                 Serial No.:                 06-1138 EXAM SURFACE: C)D                                                               No. of Elements:                     1             No. of Elements:                    2 Couplant Type:              Ultragel 11        Couplant Blatch No.:                             06225                  Size:       .375"       Shape:        ROUND        Size: 2(10 X 18) Shape:               RECT Freq.: 1.5 Mhz Style:              COMP G          Freq.: 2.0 Mhz Style:               TRLA Vertical Linearity:       Sional 2 shall eoual 50% of Signal 1. +/- 5% of Full Screen Height.                          Exam Angle:          45* Mode: SHEAR               Exam Angle:         45&deg; Mode:         LONG Signal1      100         90      80    1 70         60      1 50            40     30 1 20                 10      Measured Angle:                  44.3*             Measured Angle:                  42&deg; Sinal2           50      45      40    1 35         30           25         20      151 10                 5       Wedge Style:                MSWQC                  Wedge Style:              INTEGRAL Amplitude Control Linearity:
Sensitivity          SET      (-)6 dB     (-)12 dB         SET         (+)12 dB     SET          (+)6 dB                        Search Unit Cable                                 Search Unit Cable Actual Value           80         40           20              20           80        40              80         Type:                    RG 174                    Type:                   RG 174 Acceptable Range      I        32-48       116-24            1 -164 -96              J
* 164-96                     Length:          6'     No. of Con.:        0      Length:         6'    No. of Con.:        0 ISl               EXAMINATION              Access-             Exam              Indications Scan                Instrument Settings                               Instrument Settings NUMBER               AREA I WELD                                Volume           No     Yes         Geo       Sens.
22.0 Manufacture:             PANAMETRICS               Manufacture:            PANAMETRICS TBB03-4-W          PZR RELIEF NOZZLE             DUAL              >90%                    X                    42.0 Model:                      EPOCH 4                Model:                     EPOCH 4 22.0 Serial No.:                031499201               Serial No.:               031499201 TBBO3-3-C-W         PZR SAFETY NOZZLE             DUAL              >90%                    X                    42.0 Delay:         0.000       Range:      3.892       Delay:       0.000       Range:       3.751 M'tl Cal / Vel: .1233      Pulser: SQUARE          M't1 Cal I Vel: .2313    Pulser: SQUARE Damping:          400      Reject:         0%      Damping:         400     Reject          0%
Remarks / Comments:                                                                                                    Rep. Rate:          MAX    Freq:      2.0 Mhz      Rep. Rate:          MAX  Freq:       2.0 Mhz TRANSDUCER 06-1138 SA12' FS-40 8"OD AX                                                                                 Filter:        .8-3.0      Mode:         FW        Filter        .8-3.0      Mode:         FW Also performed 0&deg; lam I planar scan.
Reference Sensitivity                              Reference Sensitivity Examiners: JEFF DEVERS           R1                             III         Date              10110/06                Axial:          10.0       Circ:         NA        Axial:         36.0      Circ:          NA NA                                 Level            NA         Date                   NA                  SDH Sensitivity:           N/A                     SDH Sensitivity:          NA Reviewer:     "-(_.    ,u'*.L-_                       2                     Date       t          -/2:            . Further Evaluation Required?         *Yes      r'No&deg;-E          NCP t,            ,
I                                                       I 0/4/I UIILI                           V~               I~7tZ UTIUTY RE-EW ffit        rt-Aw           (If,6t",-
                                                            -to/it-

Plant / Unit                 WOLF CREEK                                                                                                                                Page           2         of         9 Comp. / System          PZR SAFETYIRELIEF                             ULTRASONIC CALIBRATION I EXAMINATION DATA SHEET                                                  Data Sheet #              JLD-001 Procedure No.                     UT-103                                                                                                                      DAC CUt EVE Rev / Chng. No.                    31 NA                                                                                                     ID NOTCH                                          ID NOTCH Cal. Checks           Time           Date Cal. Block No.                      170 Cal. Block Temp.                    1090                                                947        10/11lO0 Initial Surface Temp.                       1190                                                949        10/10106 Temp. Guage:              PTC 312F f 250911                                             NA            NA Intermediate Size            6"       Sch.               160                                         NA            NA Intermediate           NA            NA El Austenitic                                                      NA            NA M]    Ferritic Final            1857        10/10106 Each Major CRT Div. :              0.355 / 0.346                                       1858        10/110/06 Searchl Unit#l                                  search Unit #z Cal. Dir.:       [Axial r"Circ.                  Both          Scan Dir.:             I        to weld            Manufacture:                 KBA                 Manufacture:                   RTD cto           weldoE         Serial No.:                OtBTN4                Serial No.:                  06.225 EXAM SURFACE: OD                                                                         No. of Elements:                    1            No. of Elements:                    2 Couplant Type:             Ultragel II           Couplant Batch No.:                          06225               Size:       .375" Shape:             ROUND       Size: 2(15 X 25) Shape:               RECT Freq.:     1.5 Mhz Style:         COMP G         Freq.: 1.0 Mhz Style:               TRLA Vertical Linearity:      Signal 2 shall equal 500%. of Signal 1, +/- 5% of Full Screen Height.                    Exam Angle:         38&deg; Mode: SHEAR              Exam Angle:          360  Mode:       LONG Signal 1 Signal2 f100      90 45 80 40 70 35 60 I 50 30 1 25 1 20 40      30        20      10        Measured Angle:                 37.9&deg;            Measured Angle:                  360 150                                                                  15        10        5       Wedge Style:               MSWQC                 Wedge Style:               INTEGRAL Amplitude Control Linearity:
Sensitivity        SET        (-)6 dB       (-)12 dB       SET       (+)12 dB      SET       (+)6 dB                       Search Unit Cable                               Search Unit Cable Actual Value         80           40            20           20          80           40         80         Type: _                 RG 174                   Type:                    RG 174 Acceptable Range         **    32-48         116-24
* 164-96       1*--       64-96            Length:          6,   No. of Con.:         0     Length:         6,     No. of Con.:        0 ISl             EXAMINATION NUMBER ARA      / WELD              Access           Exam          -
Indications Scan                Instrument Settings                             Instrument Settings NUMBER              AREA IWELD                                 Volume         No       Yes      Geo      Sans.
22.0 Manufacture:            PANAMETRICS              Manufacture:             PANAMETRICS TBB03-4-W         PZR REMEF NOZZLE                DUAL            >90%          X                          45.0 Model:                     EPOCH 4               Model:                      EPOCH 4 22.0 Serial No.:               031499201              Serial No.:                031499201 TBB03-3-C-W        PZR SAFETY NOZZLE               DUAL            >90%          X                          45.0 Delay:         0.000      Range: .3.553          Delay:       0.000        Range:      3.461 M'tl Cal / Vel: .1233 Pulser: SQUARE             M'tl Cal / Vel: .2313     Pulser: SQUARE Damping:          400     Reject:        0%      Damping:         400       Reject:        0%
Remarks / Comments:                                                                                               Rep. Rate:          MAX Freq:        2.0 Mhz     Rep. Rate:          MAX    Freq:     1.0 Mhz Also performed 00 lam I planar scan.                                                                              Filter:        .8-3.0     Mode:         FW       Filter       .8-3.0        Mode:        FW TRANSDUCER S/N 06-225: FD-1.30", SA-91, OD8.0"CIRC.
Reference Sensitivity                            Reference Sensitivity Examiners: JEFF DEVERS                  .-----    e-vel         III        Date              10110106             Axial:           NA       Circ:        16.0      Axial:         NA          Circ:       39.0 Reviewer:
NA
             "-5-L. b     U""-aS Level          NA         Date Date
                                                                                         ,~o1,1oNA                SDH Sensitivity:          N/A Further Evaluation Required?       QYes       [*
SDH Sensitivity:           NA I
tQr CQui.-         JZD II     Lt N"RkJ .
ri~&                                      04_
yL7r Ib/I/~

Plant / Unit                    WOLF CREEK                                                                                                                                     Page         3       of       9 Comp. I System             PZR SAFETYIRELIEF                           ULTRASONIC CALIBRATION I EXAMINATION DATA SHEET                                                         Data Sheet #          JLD-00i Procedure No.                          UT-103                                                                                                                         DAC CURVE Rev / Chng, No.                        31 NA                                                                                                        ID NOTCH Cal. Checks             Time           Date Cal. Block No.                           170 Cal. Block Temp.                        109&deg;                                               945        10/10106 Initial Surface Temp.                           1190                                               NA             NA Temp. Guage:                 PTC 312F / 250911                    Intermediate             NA             NA Size              6"        Sch.                 160                                       NA             NA NA             NA Intermediate             NA              A Ferritic              Austenitic NA             NA Final Each Major CRT Div.                           0.517                                   1   1859        10/10/06                              I        I I I I Search Unit #1                                     Search Unit #2 Cal. Dir.:         r9Axial QCirc. QBoth                          Scan Dir.:               I       to weld             Manufacture:                    RTD cto      0 weldo              Serial No.:                   06-1139 EXAM SURFACE: OD                                                                               No. of Elements:                      2 Couplant Type:                Ultragel II            Couplant Blatch No.:                        06225                Size: 2(15 X 25) Shape:                  RECT Freq.:     2.0 Mhz Style:             TRLA Vertical Linearity:         Signal 2 shall equal 50% of Signal 1, +/- 5% of Full Screen Height.                       Exam Angle:          60* Mode:          LONG Signal 1        100 1 90            80 1 70 160                 501        40       30        20        101      Measured Angle:                   57.2*
Signal2      150 1      45     I 40 I 35 I 30 I 25                        20       15        10        5   I    Wedge Style:                INTEGRAL Amolitude Control Linearitv:
Sensitivity         SET         (-)6 dB       (-)12 dB    SET        (+)12 dB       SET       (+)6 dB                        Search Unit Cable Actual Value          80             40           20         20           80          40          80          Type: _                   RG 174 Acceptable Range          **      32 - 48      116-24      1--         64 -96            **     64 - 96          Length:          6-     No. of Con.:          0 Isl              EXAMINATION                  Access        Exam           -   Indications            Scan                 Instrument Settings NUMBER              AREA I WELD                               Volume           No       Yes      Geo      Sens.
X               43.5   Manufacture:              PANAMETRICS DUAL         >90%
TBB03-4-W           PZR RELIEF NOZZLE                                                                               Model:                       EPOCH 4 43.5   Serial No.:                 031499201 TBB03-3-C-W          PZR SAFETY NOZZLE                 DUAL         >90%             X                               Delay:         0.000        Range:       5.167       Delay:                Range:
M'tl Cal I Vel: .2313 Pulser: SQUARE                 M'tl Cal I Ve. _      Pulser:
Damping:          400       Reject:          0%      Damping:               Reject:_     _
Remarks / Comments:                                                                                                   Rep. Rate:          MAX     Freq:      2.0 Mhz       Rep. Ra :_Freq:
TRANSDUCER S/N 06-1139: FS-50, SA-160, 8.0"AX                                                                          Filter:       .8-3.0       Mode:         FW         Filter:                Mode:
Also performed 0&deg; lam I planar scan.
Reference Sensitivity                                Reference Sensitivity Examiners: JEFF DEVERS             1       -         LeVel       III         Date               10/10106              Axial:          37.5        Circ:          NA        Ax 1: .       _        Circ:
NA                                   Level       NA          Date                  NA                 SDH Sensitivity:            NA                       SH Sensitivity:
Reviewer:       "E"e.
                                    *1 E*
f 5J                              Date                                      Further Evaluation Required?       9]Yes           Nos'.E *
* O-O-R772_
m UTILJTYREVIE      "
                                                                          /M                                         r  0 P"EW:(W               ;(;ka            1j"441t,
       -      -~.
i9~'DS

Page      4       of      9 Indication Tabulation Sheet                                                 Data Sheet #,       JLD-O01 PLANT /UNIT                   WOLF CREEK /I                      EXAMINATION ANGLE                      SEE BELOW COMP / SYSTEM                      PZR SAFETY                    COMP THICKNESS                              1.32"                             DATE             10/10/2006 PROCEDURE NO                         UT-103                      WELD CROWN WIDTH                            1.95" REV / CHANGE NO                       3/NA                       WELD LENGTH                                 25.0"                      WELD NO / ID          TBB03-3-C-W EXAMINER / LEVEL              JEFF DEVERS / III                                                      EXAMINER / LEVEL                                        NIA INDICATION LENGTH       MIN. 20%        MIN. 60%               PEAK              MAX. 60%          MAX. 20%           BEAM INDICATION        FROM           TO    SWP. IN. TO  SWP. IN. TO   SWP. IN. TO +1.DAC SWP.      IN. TO   SWP. IN. TO   ANGLE   DIR.                   REMARKS NUMBER                                        REF.            REF. MP      REF. AMPL.             REF.              REF.
CORNER TRAP RESPONSE @ I.D. SURFACE 1        23.75" CW      2.5" CW                                    1.61"   1.25"   85%                                         45&deg;     DS            SUSPECT FLAW INDICATION TIP DIFFRACTION RESPONSE @ 1.02" DEPTH a          1.0"CW        *MAX                                    1.26"    0.80"   15%                                         45&deg;     DS            SUSPECT FLAW INDICATION UTUT REIE    DAT                 -
                                                                                         -      --              (  0    r         -AA       a06
                      -      f-    -              -6                                                      -                 -                                                             I--
Reviewer:     ITo.****                              DATE      /.o/I j /-2. Z>-                 Further Evaluation Required?       rIlYes     Q   No 5,-,    AJp_*RWR. 6&*-o.s-77ZZ_
           - -d*
                                                                                -frr,0/,#

Page       5        of         9 Indication Tabulation Sheet                                                    Data Sheet #           JLD-001 PLANT / UNIT                  WOLF CREEK /1                        EXAMI NATION ANGLE                    SEE BELOW COMP / SYSTEM                       PZR RELIEF                     COMP THICKNESS                           1.32"                                   DATE              10/10/2006 PROCEDURE NO                          UT-103                       WELD CROWN WIDTH                         1.95" REV / CHANGE NO                         31NA                       WELD LENGTH                              25.0"                         WELD NO / ID               TBB03-4-W EXAMINER / LEVEL              JEFF DEVERS / III                           _                           EXAMINER / LEVEL                                             NIA INDICATION LENGTH         MIN. 20%        MIN. 50%                PEAK          MAX. 50%            MAX. 20%             BEAM INDICATION        FROM           TO     SWP. IN. TO     SWP. IN.TO       SWP.      IN.TO +1-DAC SWP. IN.TO        SWP. IN. TO ANGLE DIR.                               REMARKS NUMBER                                          REF.           REF.      MP       REF. AMPL.           REF.               REF.
CORNER TRAP RESPONSE @ I.D. SURFACE I        16.50"CW       3.0" CW                                     1.73"     1.60" 100% I                                      45&deg;       DS              SUSPECT FLAW INDICATION TIP DIFFRACTION RESPONSE @ 1.07" DEPTH la           1.0"CW        *MAX                                      1A42"     1.35"  25%                                        450       DS              SUSPECT FLAW INDICATION TIP DIFFRACTION  RESPONSE @ 0.90" DEPTH lb           1.0"CW        *MAX                                      1.51"     1.50"  25%                                        60&deg;       DS              SUSPECT FLAW INDICATION
             -7k        -                -e-                     1,0  13                   -     -         -       -       -9W        - Ply   --                                        6r-UTUYRVE:          -&#xfd;&#xfd;           -,&#xfd;     -U                               -                      -    - -
REIE    D-                I -           -
                            -9   -                       -                   -W                  -a               C- -       -                    V-6 Reviewer: "..           ;/-                          DATE      t       fl13[ z,:4=               Further Evaluation Required?       rxles              No ._.*(          J       (-37Z-

Page       6    of      9 Data Sheet #    JLD-001 UT INDICATION PLOT/ PROFILE DATA PLANT                         WOLF CREEK                      UNIT    I       WELD #                  TBB03-4-W SYST./COMP.                             PZR RELIEF                            PROCEDURE              UT-I103 REV. 3 EXAMINER JEFF DEVERS /l1l                  DATE    10110/2006    EXAMINER               N/A              DATE      NIA INDICATION #1 START: 16.50" CW / MAX: 1.0" CW / END: 3.0" CW   TOTAL LENGTH: 11.50" I.5 ihl jREIWRy I
                   ~~E~tEWERIDATE
                         ~c2-               IrzREVIEWIDA%                        ((O2U(   ~AOJ      /&
DATE JTUM REIEW I   -
                                                                                        -=jug.&

Page       7    of       9 Data Sheet #     JLD-001 UT INDICATION PLOT/ PROFILE DATA PLANT                             WOLF CREEK                                   UNIT    1         WELD #                 TBBO3-3-C-W SYST./COMP.                                    PZR SAFETY                                         PROCEDURE              UT-103 REV. 3 EXAMINER JEFF DEVERS /III               "--2--DATE                  1011012006   EXAMINER                  NIA              DATE       N/A WOLF CREEK INDICATION #1 START: 23.75" CW / MAX: 1.0" CW / END: 2.5" CW                TOTAL LENGTH:  3.75" 0A) in 1.25 in REVIEWER I DATE    ~:i.L. e'J   s      lk;SL                   cs24mco           [ND REVEW I ATE           ~(
JTIUTY REVIEW 1 OA:    6 9         &#xfd;;r-    104 o_.(~eI q/

UMITATION TO EXAMINATION                      Page       I of       9 Data Sheet #  JLD.001 PLANT                      WOLF CREEK                         UNIT       1           WELD 0         TB03-3-C-W SYSTJCOMP.                            PZR SAFETY                                     PROCEDURE      UT-103 REV. 3 EXAMINER JEFF DEVERS I III    "        -    DATE     10/1012006         EXAMINER                N/A         DATE     N/A TBB03-3-C-W TYPICAL FOR ALL SAFETY NOZZLE CONFIGURATIONS AXIAL DU2OH*1RQUR       COVERAGE*     HIEVED: 91.79%
CRCUMFURElT!AL DIREcTInow RMQURED COVERAGE ACHIEVD: 100%
COMBNW REQtIRF.D COVERAGE ACHEVED. 95.35%
                                                                                  --    7-N  /\
                                -                      REQUIRED EXAMINATION AREA 1.03 sq. i.s LIMITED EXAMINATION ARBA 0.17 sq.i.
RE MERI AT               Ieb A            19;; &#xfd; IAMo/,           WI A

UMITATION TO EXAMINATION                            Page       9 of Data Sheet # JLD.OO1 WOLF CREEK                        UNIT     I          WELD#                  TBB03-4-W PZR REUEF                                   PROCEDURE              UT-103 REV. 3 JEFF DEVERS I III              DATE      1010/2006        EXAMINER                       N/A         DATE     N/A TBB03-4-W AXLAL OVmECTM) REqIAW COVUMAO        ACUIBVW0 9~.5.0/i CIRCUUMFENTIAL DItrEhUNREQUIRED (VBRAIACHIIVED:         to(W COMBNEDREQuIREDCOVBAOE ACHIBvm&#xfd; 97.s~i I
_                     /
REQUI.ED EXAMINATION AREA 1.03 sq in.
NINE=
LOMrTED EXAMIMATION AREA Adth"0.09            sq. in.

Plant / Unit                      WOLF CREEK                                                                                                                                          Page          1         Iof           7 COmp. / System                      PZR SURGE                              ULTRASONIC CALIBRATION I EXAMINATION DATA SHEET                                                            Data Sheet #             JLD-00ZO3 Procedure No.                           UT-103                                                                                                                            DACv CURVFE vv, Rev / Chng. No.                         31 NA                        Ca 1l.Checks         Time            Date Cal. Block No.                            171                                                                                                                 ID NOTCH                                            ID NOTCH-Cal. Block Temp.                          900                                                  820         1011/06 Initial Surface Temp.                             850                                                  821         10/11106 Temp. Guage:                   PTC 312F I 250911                                               NA             NA 14"         Sch.                  160                   termediate Size                                                                                           NA             NA NA             NA In termediate ID      Ferritic           ED    Austenitic                                                     NA             NA Final            1217          10111106 Each Major CRT Div. :                    0.433 1 0.390                                       1218          10/11106 Search unit #1                                       Search Unit #2 Cal. Dir.:           DAxial QCirc. [nBoth                            So an Dir.:             I        to weld               Manufacture:                    KBA                   Manufacture:                  RTD to weld              Serial No.:                  OOTD6V                   Serial No.:                 06.1141 EXAM SURFACE: OD                                                              No. of Elements:                     I                No. of Elements:                    2 Couplant Type:                  Ultragel II              Couplant Blatc h No.:                       06225                  Size:         .5"        Shape:        ROUND          Size: 2(15 X 25) Shape:               RECT Freq.: 1.5 Mhz Style:               COMP G            Freq.: 2.0 Mhz Style:               TRLA Vertical Linearity:           Signal 2 shall equal 50% of Signal 1, +/- 5% of Full Screen Height                            Exam Angle:          45&deg; Mode: SHEAR                  Exam Angle:         465 Mode:         LONG Signall 1           100      90        80          70        60 1 50            40    1 30          20       10         Measured Angle:                   450                 Measured Angle:                 42*
Signal2              50     45         40          35        30 1 25            20    1 15          10 1 5              Wedge Style:                 MSWQC                    Wedge Style:              INTEGRAL Amplitude Control Linearity:
Sensitivity           SET         (-)6 dB         (-)12 dB    SET        (+)12 dB       SET        (+)6dB                          Search Unit Cable                                    Search Unit Cable Actual Value              80            40              20        20            80          40          80            Type: _                   RG 174                     Type:                    RG 174 Acceptable Range              **     32 - 48          16 - 24         **164 - 96          1 -         64-96              Length:           6-     No. of Con.:        o        Length:         6' No. of Con.:             0 ISI                 EXAMINATION                   Access         Exam            -  Indications
                                                                                                     -                 Scan                   Instrument Settings                                  Instrument Settings NUMBER                   AREA I WELD                                Volume           No       Yes       Geo     Sens.
19.8 Manufacture:                 PANAMETRICS                 Manufacture:            PANAMETRICS TBB03-1-W              PZR SURGE NOZZLE                   DUAL         >90%                      X                39.5 Model:                          EPOCH 4                  Model:                     EPOCH 4 Serial No.:                 031499201                 Serial No.:               031499201 Delay:         0.000        Range:      4.334         Delay:        0.000      Range:        3.90 M'tl Cal I Vel: .1233 Pulser: SQUARE                  M'tI Cal / Vel: .2313 Pulser. SQUARE Damping:           400      Reject:         0%        Damping:         400      Reject:          0%
Remarks / Comments:                Also performed 0' lam I planar scan.                                                     Rep. Rate:           MAX Freq:         2.0 Mhz        Rep. Rate:         MAX Freq:         2.0 Mhz Filter:        .8-3.0       Mode:         FW          Filter        .84.0       Mode:         FW TRANSDUCER SIN 06-1141: FS-55, SA-14&deg;, 00 16.0"AX.
Reference Sensitivity                                 Reference Sensitivity Examin          JEFF DEVERS                              Level       III        Date                10/11106                Axial:           1.8        Circ:         1.8         Axial:         33.5       Circ:         NA eiew           ARLENJENSEN .                  ,.        Level        II         Date               10/`1/06                SDH Sensitivity:            NIA                       SDH Sensitivity:          NA Reviewer:          T-.*..-.Z                      _                             Date            Ioli/2X.             (o     Further*r1Yes Evaluation Required?                   [Q'No5 E          Ale,?     W    e_(.         ,
IAI J11UTY REVIEW:&#xfd;,
                                                                                 ,,         r/
          -     -r,  st"  -      -  my-  -,              -                                                                                         -   I P1-r

Plant I Unit                 WOLF CREEK                                                                                                                            Page            2         of          7 Comp. / System                 PZR SURGE                          ULTRASONIC CALIBRATION I EXAMINATION DATA SHE ET                                                 Data Sheet #               JLD-003 Procedure No.                     UT-103                                                                                                              DACv CUIRVE v*.
Rev / Chng. No.                   31 NA                                                                                                    ID NOTCH                                         ID NOTCH Cal. Checks          Time           Date                              *so Cal. Block No.                      171 Cal. Block Temp.                    900                                            823        10111106 Initial Surface Temp.                        850                                           825        10/11106 Temp. Guage:              PTC 312F I 250911                                        NA            NA Intermediate Size           14"       Sch.              160                                     NA            NA NA            NA M      Ferritic       0J     Austenitic                       Intermediate NA            NA Final           1221        10/11/06 Each Major C RT Div. :              0.4101 0.532                                  1220        10111106 Searcn unkrir                                       Searcn unit *2 Cal. Dir.:       [:]Axial    QCirc. r'Both                 Scan Dir             *-I       to weld El        Manufacture:                RTD                    Manufacture:                    RTO to weld           Serial No.:                06-751                 Serial No.:                   06-1142 EXAM SURFACE: OD                                                    No. of Elements:                  2                No. of Elements:                      2 Couplant Typ e:            Ultragel II         Couplant Batch No.:                       06225              Size: 2(15 X 25) Shape:             RECT           Size: 2(15 X 25) Shape:                 RECT Freq.: 1.0 Mhz Style:              TRL             Freq,: 2.0 Mhz Style:                TRLA Vertical Linearrity:      Signal 2 shall equal 50% of Signal 1, +/- 5% of Full Screen Height.               Exam Angle:        45&deg; Mode:        LONG           Exam Angle:           60&deg; Mode:         LONG I   Signal1       11001 90         1 80 1 70         1 60 1 50 1 40 1 30 1 20 1 10 1                         Measured Angle:                45&deg;                 Measured Angle:                   570 I Signal2         I 501 45 1 40 I 35 1 301 251 201 151 101 5                                                 Wedge Style:             INTEGRAL                 Wedge Style:                 INTEGRAL Amplitude Control Linearity:
Sensitivity         SET       (-)6 dB     (-)12 de    SET I (+)12 dB          SET       (+)6de                    Search Unit Cable                                    Search Unit Cable Actual Value          80          40           20        20          80         40         So         Type:                 RG 174                      Type:                      RG 174 Acceptable Range     I -       32 - 48       16 J      - 164-96               -     64-96          Length:        6, No. of Con.:           0         Length:         6'      No. of Con.:         0 ISl              EXAMINATION               Access         Exam        -
Indications          Scan              Instrument Settings                                 Instrument Settings NUMBER              AREA I WELD                            Volume         No      Yes      Geo     Sens.
42.0 Manufacture:          PANAMETRICS                  Manufacture:              PANAMETRICS TBB03-1-W          PZR SURGE NOZZLE              DUAL                                X               46.0 Model:                    EPOCH 4                  Model:                       EPOCH 4 Serial No.:              031499201                 Serial No.:                 031499201 Delay:       0.000      Range:      4.101          Delay:       0.000         Range:       5.324 MtI Cal I Vel: .2313 Pulser: SQUARE                M'tl Cal/ Vel: .2313       Pulser: SQUARE Damping:        400      Reject:        0%         Damping:         400        Reject:         0%
Remarks / Comments:           Also performed 0&deg; lam I planar scan.                                          Rep. Rate:        MAX Freq:        1.0 Mhz         Rep. Rate:            MAX   Freq:     2.0 Mhz TRANSDUCER SIN 06-751: FD-1.5, SA-3', 0O16.0"CIRC.                                                          Filter:      .8-3.0      Mode:       FW            Filter:       .8-3.0        Mode:        FW TRANSDUCER SIN 06-1142: FS-75, SA-8, OD16.0"AX.
Reference Sensitivity                                Reference Sensitivity Examiners: JEFF DE                                          IlI       Date              10111106            Axial:        N/A        Circ:       35.0          Axial:         40.0         Circ:        NA ARLEN.                                          II       Date              10/11/06            SDH Sensitivity:         NA                        SDH Sensitivity:            NA
_______Date                lc>#/            (,,. Further Evaluation Required?    EYes         []No          56,E AlJe        L   .    (, -O-7"7Z
                                                                                                                                                              .I                 ....
Y/,?I' 10610

Page          3        of      7 Indication Tabulation Sheet                                          Data Sheet #             JLD-003 PLANT /UNIT                WOLF CREEK / 1                        EXAMINATION ANGLE                SEE BELOW COMP /SYSTEM                         PZR SURGE                   COMP THICKNESS                       1.45"                          DATE                   10111/2006 PROCEDURE NO                           UT-103                    WELD CROWN WIDTH                      2.0" REV / CHANGE NO                         3/NA                     WELD LENGTH                          47.0"                   WELD NO / ID                 TBB03-1-W EXAMINER / LEVEL              JEFF DEVERS /I III         C-                                    EXAMINER I LEVEL            ARLEN JENSEN I/ 1             0,1,4 (24-m INDICATION LENGTH         MIN. 20%       MIN. 50%           PEAK           MAX. 60%         MAX. 20%         BEAM INDICATION        FROM          TO       SWP. IN. TO SWP. IN. TO   SWP. IN.TO +1-DAC SWP. IN.TO    SWP. IN. TO ANGLE      DIR.                       REMARKS NUMBER                                          REF.           REF. MP    REF. AMPL            REF.             REF.
                      -         .1.0-3.0     -                                 10-    66                                            D CORNER TRAP RESPONSE @ I.D. SURFACE 1         43.0" CW   44.0" CW                                   1.90"  1.30"  60%h                                  45&deg;     DS                SUSPECT FLAW INDICATION CORNER TRAP RESPONSE @ I.D. SURFACE 2        28.75" CW   31.5" CW                                   1.63"  1.40" 100%                                   45*     DS                SUSPECT FLAW INDICATION TIP DIFFRACTION RESPONSE @ 1.15" DEPTH 2a         30.0" CW        MAX                                   1.52"  1.20"  25%                                   450     OS                SUSPECT FLAW INDICATION TIP DIFFRACTION RESPONSE @ 1.02" DEPTH 2b          30" CW      *MAX                                     2.06"  2.00"  25%                                   600     DS                SUSPECT FLAW INDICATION CORNER TRAP RESPONSE @ I.D. SURFACE 3         20.5" CW   25.5" CW                                   1.89"  1.40" 130%                                   450     DS                SUSPECT FLAW INDICATION TIP DIFFRACTION RESPONSE @ 1.0" DEPTH 3a         21.0" CW       MAX                                    1.31"  0.55"  60%                                   450     DS                SUSPECT FLAW INDICATION CORNER TRAP RESPONSE @ I.0. SURFACE 3b         20.5" CW   25.5" CW                                   2.73"  2.50"  25%                                   60&deg;     DS                SUSPECT FLAW INDICATION TIP DIFFRACTION RESPONSE @ 1.09" DEPTH 3c         21.0" CW     *MAX                                     2.03"  1.50"  25%                      -.           60      DS                SUSPECT FLAW INDICATION Reviewer:      3LDATE                                           Igo  3s/2oo00              Further Evaluation Required?  0    Yes        No UTIUTY REVIEW I DAENlREVE1-o
                         -.  ~~1b                           IoLf&#xfd;6  10,                                            Ej~
(4d~                 ____________
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Page       4      of       7 Data Sheet #       JLD-003 UT INDICATION PLOT/ PROFILE DATA PLANT                           WOLF CREEK                         UNIT     1        WELD #                   TBB03-1-W PZR SURGE SYST./COMP.                                PZR SURGE                                  PROCEDURE              UT-103   REV. 3 EXAMINER JEFF DEVERS /III           0    -     DATE     10/1112006    EXAMINER ARLEN JENSEN I II    4     4:::-- DATE   10/11/2006 INDICATION #1 START: 43.0" CW I MAX: 43.5" CW I END: 44.0" CW      TOTAL LENGTH: 1.0" SCALE: 90%
REIWRIDATE                                 i I71-71307Q J     Zo,                       DA JAN REIEW IV      Uf~Qf     ,Q'/b LJTIUTY REVIEW I DATE 7. z-

Page       5      of       7 Data Sheet #       JLD-003 UT INDICATION PLOT/ PROFILE DATA PLANT                          WOLF CREEK                         UNIT       1          WELD #                   TBB03-I-W SYST./COMP.                              PZR SURGE                                      PROCEDURE                UT-103   REV. 3 EXAMINER JEFF DEVERS /111        3DATE              10/11/2006         EXAMINER ARLEN JENSEN/Il       II            DATE    10/111/2006 INDICATION #2 START: 28.75"CW I MAX: 30.0"CW / END: 31.5" CW              TOTAL LENGTH: 2.75" 1~-1 lj xo SCALE: 90%
A R~EVIEWER I DATE      J      ~      -- p   ~     /p        ~         ~     1 N11REVIEW IDATE(-l~    !        16t UITILITY REVIEW IDATE       I

Page       6       of      7 Data Sheet #       JLD-003 UT INDICATION PLOT/ PROFILE DATA PLANT                           WOLF CREEK WOLF                                   UNIT    I       WELD #                      T8103-1 -W SYST./COMP.                                PZR SURGE                                   PROCEDURE                  UT-I103 REV. 3 EXAMINER JEFF DEVERS /111          3)C?-      DATE     10/1112006         EXAMINER ARLEN JENSEN L21
                                                                                                         .p" 2--      DATE    1011112006 INDICATION #3 START: 20.5" CW I MAX: 21.0" CW I END: 25.5" CW        TOTAL LENGTH:      5.0" 4
203l SCALE: 90%
10   &#xfd; RevommID10                                       2w                     i'K    W W,,/O 1,-    '6

UMITATION TO EXAMINATION                            pig.        7  of     7 Data Sheet #   JLD4 PLANT                   WOLF CREEK                               UNIT        I      WELD 8                  TBB03-1-W SYST./COMP.                        PZR SURGE                                        PROCEDURE               UT-103 REV. 3 EXAMINER JEFF DEVERS IM                     DATE        111/2006            EXAMINER ARLEN JENSEN                   DATE   1011/2006 TBB03-1-W AXIAL DIRCTON RMD         COVUAGI ACM1VM. 98h%
CHJRX(haUtNTIAL DIREClON JWMUED COVERAGE ACHEVED: 100%
COMRPIMD UJIQMXD COVURAGN ACWIVUD> "9.3%
                         /                                                     \*/
t~ow in. b.
LIMIrrED EXAM24AT1IM AREA o.0307 0. ia.
SCALE: 90%
REVIEWER''   *    .DTEt-7-M-                                        AMREVIEW i t           d,,  '-  ,

Enclosure V to ET 06-0049 Radiograph Repair Maps for the Surge nozzle Dissimilar Metal (DM) Weld, the "C" Safety nozzle DM Weld and the Relief nozzle DM Weld From the radiograph (RT) reader sheets provided as part of the original radiographic examination records, radiograph repair maps have been prepared that show some correlation between the location of shop fabrication rejected radiographs and the Refueling Outage 15 identified flaw indications. Wolf Creek Nuclear Operating Corporation (WCNOC) does not have records that show the exact location of shop repairs following radiographic examination. For the Relief nozzle DM weld, WCNOC does have RT reader sheets that show the location of specific radiograph film where a rejectable indication was located, i.e., the outside diameter circumference location of each film that had a rejectable indication is known, but we do not know where the indication and subsequent repair was in any particular film. Therefore, for the Relief nozzle DM weld, the radiograph repair maps show a general correlation of shop repairs to Refueling Outage 15 identified flaw indications. In-process repairs may have occurred prior to the welds being presented for radiograph, so lack of identified shop repairs on the RT reader sheets does not mean repairs were not performed.
The radiograph repair maps for the Surge nozzle DM weld, the "C" Safety nozzle DM weld, and the Relief nozzle DM weld are enclosed. These radiographic repair maps show that shop fabrication repairs were made in the same location as a portion of the Refueling Outage 15 identified flaw indication for the Relief DM weld. However, for the Surge nozzle DM weld, the reference point for shop radiograph locations could not be determined. Therefore, no direct correlation can be determined between the Surge nozzle DM weld shop repairs and the Refueling Outage 15 identified flaw indications. Shop radiograph records for the "C" Safety nozzle DM weld show no rejectable flaws requiring repair, but the reported Refueling Outage 15 flaw indications did exhibit characteristics similar to the flaw indications reported for the Relief nozzle DM weld. As noted above, although the "C" Safety nozzle DM weld radiographs don't show evidence of repairs, shop radiographs may not provide a true indication of the extent of shop repairs because in-process weld repairs performed before the weld was presented for radiographic examination are not documented in the radiography reports.

TBB03-1-W Surge Nozzle                                                   Nozzle to Safe End RF15 UT Indications LU~
IL         .                      12   14-     ITI<''                              I,      .   .-.-.-     r 8
                                                                                                                                                          .1411.4 Inch                 1~~~ 2            3            45                    '                                              ~'~~10'~
74 '~I
                                                                                      '44                                                                        t!4
: 4.            1 I., I
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                                                          ,I 81                     [2       0- 21             22                             25' 26 vI-J-{                                                                  id
                                                                                                 -III GIL F
J131              3               33                                                                 39        40      ,4 71 [I]
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           /L2 fi{                                             vh            1j   11111
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11 Ifl~l~l' f~4                                                                     I-,,                                    -4,.--
4--
15                        7 IUT "0" is located at the Extradose of the first Downstream Elbow.
1nch-43.4. 1 i . .. . . . .The Test Number (T05831) stamped into the Nozzle Forging could not be located to
                                                                           ]correlate these indications to the shop repairs.
1   C/L4.
* 74          T                *
                                                                      ![    ~~   [    ~i it[,
k*Z lTi If 1If

TBBO3-1-W                                                 Nozzle to Safe End "S" Surge Nozzle 11     t                                            .!li4 i J*Ltt*L4    I i* II - 11&#xfd;                        it             J      i 1~
1 i  -'
12 i
I               241 1.-1 Nt 252'2i1 2K2 11 I nch    '1 4   15  i 16  *j1                                        23 1771 C/L         I    1-1~I                                                        -    ,  +-     ~- 4   ,,  4 -.- , - , 4 i!i Station !                                        t           6i Inch      28                 3
                                !ItI-                                  7         38v                           i4K1       f 4, t*
                                                                                                                               ,&#xf7;
    .i!ii Final Radiographs were shot on a combination of Kodak AA and Kodak M film.
RT "0"is located at the Test Number (TO5831) stamped into the Nozzle Forging, based on the information taken from the reader sheets.

TBB03-3-C-W                                        Nozzle to Safe End "C" Safety Nozzle "C" m
                  -              ;~~~'      ~~         o ocuimented Utt er or e       eair Station       I~~2         ~~3/41                ~        i                     3
- In                                                                                   8    Il9     1 _   10 '''4              '   1 I   +
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           -IIT 11                 -7      1 !
L1,     1
                                                                      '-                                   ''4                                        4 t         I.
I           I-111 4:   +   -       -, 1 Final Radiographs were shot on Kodak AA film.

TBB03-4-W                                   Nozzle to Safe End "D" Relief Nozzle "D" il Statio 0                                                                   &#xfd;4I    I    4 4'
T11  III 1L1                         1                      '9   1'12
                                                                                                 ''',i  '13     _   1 Butreair 2X    u:   pruer evair          u er epair               j   uier evair7,'
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