2CAN031203, Requests for Relief from American Society of Mechanical Engineers (ASME) Section XI Volumetric and Surface Examination Requirements - Third 10-Year Interval
ML12086A293 | |
Person / Time | |
---|---|
Site: | Arkansas Nuclear ![]() |
Issue date: | 03/26/2012 |
From: | Pyle S Entergy Operations |
To: | Office of Nuclear Reactor Regulation, Document Control Desk |
References | |
2CAN031203 | |
Download: ML12086A293 (71) | |
Text
March 26, 2012
U.S. Nuclear Regulatory Commission
Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Requests for Relief from American Society of Mechanical Engineers (ASME)Section XI Volumetric and Surface Examination Requirements -
Third 10-Year Interval Arkansas Nuclear One, Unit 2
Docket No. 50-368 License No. NPF-6
Dear Sir or Madam:
Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operat ions, Inc. (Entergy) requests relief from the requirements of the ASME, Boiler and Pressure Vessel Code,Section XI pertaining to volumetric and surface examinations at Arkansas Nuclear One, Unit 2 (ANO-2). In several locations, the required coverage cannot be obtained due to interference or geometry.
Individual relief requests are provided in the attachments, divided by examination category.
These reliefs are for the third 10-year Inservice Inspection (ISI) interval.
There are no new regulatory commitments made in this submittal.
If you have any questions or require additional information, please contact me.
Sincerely, Original signed by Stephenie L. Pyle SLP/rwc
Attachments:
- 1. Request for Relief - ANO2-ISI-008
- 2. Request for Relief - ANO2-ISI-009
- 3. Request for Relief - ANO2-ISI-010 4. Request for Relief - ANO2-ISI-011 5. Request for Relief - ANO2-ISI-012
- 6. Request for Relief - ANO2-ISI-013
- 7. Request for Relief - ANO2-ISI-014 Entergy Operations, Inc. 1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4704 Stephenie L. Pyle Manager, Licensing Arkansas Nuclear One 2CAN031203 Page 2 of 2
cc: Mr. Elmo E. Collins Regional Administrator U. S. Nuclear Regulatory Commission, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 NRC Senior Resident Inspector Arkansas Nuclear One P. O. Box 310
London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Kaly Kalyanam MS O-8B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852
Attachment 1 to 2CAN031203 Request for Relief ANO2-ISI-008 to 2CAN031203
Page 1 of 11 REQUEST FOR RELIEF ANO2-ISI-008 Components /
Numbers: See Table 1 Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1
References:
ASME Section XI 1995 Edition with 1996 Addenda, for Ultrasonic Testing (UT) Examination ASME Section XI 2001 Edition with 2003 Addenda, Table IWB-2500-1 ASME Code Case N-593 Examination Category:
B-D Item Number(s)
B3.130; B3.140
==
Description:==
Full Penetration Welded Nozzles in Vessels - Inspection Program B Unit / Inspection Interval Applicability: Arkansas Nuclear One, Unit 2 (ANO-2) / Third (3rd) 10-Year Interval I. CODE REQUIREMENTS ASME Section XI, Table IWB-2500-1, Examination Category B-D, "Full Penetration Welded Nozzles in Vessels - Inspection Program B":
- 1) Item B3.130 requires a volumetric examination of the Steam Generator (SG) Nozzle-to-Vessel Weld volume, as depicted in Figures IWB-2500-7 (a) through (d).
- 2) Item B3.140 requires a volumetric examination of the SG Nozzle-to-Vessel Inner Radii, as depicted in Figures IWB-2500-7 (a) through (d).
II. RELIEF REQUEST Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Op erations, Inc. (Entergy) requests relief from achieving the Code-required coverage when performing volumetric examinations of the components identified in Table 1 below.
III. BASIS FOR RELIEF During ultrasonic examination of the nozzle-to-vessel welds and inner radii listed in Table 1 below, 100% coverage of the required examination volume could not be
obtained.
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Page 2 of 11 Due to the geometric configuration of the components and the close proximity of other structures which limited scan paths, the use of approved beam angles in the axial and circumferential direction were not able to achieve greater than 90% code required volume. See Table 1 below for additional information.
Radiography is not practical on these types of nozzle-to-vessel weld configurations, which prevent placement of the film and exposure source. To effectively perform any significant additional Code allowable ultrasonic examinations, modification and/or
replacement of the component would be required. The examinations performed on the subject items in addition to the examination of other vessel welds contained in the Inservice Inspection Program would detect generic degradation, if it existed, demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS No alternative testing is proposed at this time. Entergy has examined these welds to the extent practical and will continue to perform pressure testing on the subject components as required by the Code.
V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Entergy believes that it is impractical to obtain greater examination coverage on these welds. To effectively obtain significant additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject welds, in addition to the examination of similar welds contained in the program, would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. Entergy requests the proposed relief be authorized pursuant to
10 CFR 50.55a(g)(6)(i). to 2CAN031203
Page 3 of 11 Table 1 Limited B-D Examinations Component Description Additional Information Item Number Comp. ID Item Description Estimated % Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Examination Exam Results B3.130 04-005 Steam Generator (SG)
"B" Primary Outlet Nozzle-to-Extension
Pipe Circumferential Weld 61.5 Component was scanned from both sides; however, scanning was limited
from the nozzle side due to the component configuration. See the attached sketch (Figure 1) derived from UT examination report ISI-UT-06-045 on file at ANO.
Manual UT A detailed sketch (Figure 1) of the limitation is included with the
scan plan Wave modalities are longitudinal and shear.
Insonification angles included 0°, 45°, and 60°. None required.
No indications were recorded.
B3.130 04-006 SG "B" Primary Outlet Nozzle-to-Extension
Pipe Circumferential Weld 61.5 Component was scanned from both sides; however, scanning was limited
from the nozzle side due to the
component configuration. See the attached sketch (Figure 2) derived from UT examination report ISI-UT-06-046 on file at ANO.
Manual UT A detailed sketch (Figure 2) of the limitation is included with the scan plan. Wave modalities are longitudinal and shear.
Insonification angles included 0°, 45°, and 60°. None required.
No indications were recorded.
B3.130 04-007 Extension Pipe-to-SG "B" Primary Inlet Nozzle Circumferential Weld 54.69 Component was scanned from both sides; however, scanning was limited from the nozzle side due to the component configuration. See the attached sketch (Figure 3) derived from UT examination report ISI-UT-06-049 on file at ANO.
Manual UT A detailed sketch (Figure 3) of the limitation is included with the
scan plan. Wave modalities are longitudinal and shear.
Insonification angles included 0°, 45°, and
60°. None required.
No indications were recorded.
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Page 4 of 11 Table 1 (cont') Limited B-D Examinations Component Description Additional Information Item Number Comp. ID Item Description Estimated % Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Examination Exam Results B3.140 03-005IR SG "A" Primary Outlet Nozzle Inner Radii 88 Scanning was performed from the vessel side only due to component
configuration. See the attached sketch (Figure 4) derived from UT examination reports ISI-UT 059 and ISI-UT-06-060 and UT procedure CEP-NDE-0485 on file at ANO. Manual UT Four integral attachments, each 4.25" x 3.75" in size, located on the SG lower head, reduced examination coverage by 12% Wave modality and insonification angles
included 25
û shear at 90û skew angle; 35
û shear at +120
û and -120û skew angles; 55
û shear at +22
û and -22û skew angles and 70
û shear at +81
û and -81û skew angles.
None required.
No indications were recorded.
B3.140 03-006IR SG "A" Primary Outlet Nozzle Inner Radii 88 Scanning was performed from the vessel side only due to component configuration. See the attached sketch (Figure 4) derived from UT
examination reports ISI-UT-06-061 and ISI-UT 062 and UT procedure CEP-NDE-0485 on file at ANO. Manual UT Four integral attachments, each 4.25" x 3.75" in size, located on the SG lower head, reduced examination coverage by 12% Wave modality and insonification angles included 25
û shear at 90û skew angle; 35
û shear at +120
û and -120û skew angles; 55
û shear at +22
û and -22û skew angles and 70
û shear at +81
û and -81û skew angles.
None required.
No indications were recorded.
B3.140 03-007IR SG "A" Primary Inlet Nozzle Inner Radii 90 Scanning was performed from the vessel side only due to component configuration. See the attached sketch (Figure 4) derived from UT
examination reports ISI-UT-06-063 and ISI-UT 064 and UT procedure CEP-NDE-0485 on file at ANO. Manual UT Four integral attachments, each 4.25" x 3.75" in size, located on the SG lower head, reduced examination coverage by 10% Wave modality and insonification angles included 25
û shear at 90û skew angle; 35
û shear at +120
û and -120û skew angles; 55
û shear at +22
û and -22û skew angles and 70
û shear at +81
û and -81û skew angles.
None required.
No indications were recorded. to 2CAN031203
Page 5 of 11 Table 1 (cont') Limited B-D Examinations Component Description Additional Information Item Number Comp. ID Item Description Estimated % Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Examination Exam Results B3.140 04-005IR SG "B" Primary Outlet Nozzle Inner Radii 88 Scanning was performed from the vessel side only due to component configuration. See the attached sketch (Figure 4) derived from UT examination reports ISI-UT-06-050 and ISI-UT-06-051 and UT
procedure CEP-NDE-0485 on file at ANO. Manual UT Four integral attachments, each 4.25" x
3.75" in size, located on the SG lower head, reduced examination coverage by
12% Wave modality and insonification angles included 25
û shear at 90û skew angle; 35
û shear at +120
û and -120û skew angles; 55
û shear at +22
û and -22û skew angles and 70
û shear at +81
û and -81û skew angles.
None required.
No indications were recorded.
B3.140 04-006IR SG "B" Primary Outlet Nozzle Inner Radii 88 Scanning was performed from the vessel side only due to component configuration. See the attached sketch (Figure 4) derived from UT examination reports ISI-UT-06-052 and ISI-UT-06-053 and UT
procedure CEP-NDE-0485 on file at ANO. Manual UT Four integral attachments, each 4.25" x
3.75" in size, located on the SG lower head, reduced examination coverage by
12% Wave modality and insonification angles included 25
û shear at 90û skew angle; 35
û shear at +120
û and -120û skew angles; 55
û shear at +22
û and -22û skew angles and 70
û shear at +81
û and -81û skew angles.
None required.
No indications were recorded.
B3.140 04-007IR SG "B" Primary Inlet Nozzle Inner Radii 90 Scanning was performed from the vessel side only due to component
configuration. See the attached sketch (Figure 4) derived from UT examination reports ISI-UT 054 and ISI-UT-06-055 and UT procedure CEP-NDE-0485 on file at ANO. Manual UT Four integral attachments, each 4.25" x 3.75" in size, located on the SG lower head, reduced examination coverage by 10% Wave modality and insonification angles
included 25
û shear at 90û skew angle; 35
û shear at +120
û and -120û skew angles; 55
û shear at +22
û and -22û skew angles and 70
û shear at +81
û and -81û skew angles.
None required.
No indications were recorded.
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Page 6 of 11 Table 1 (cont') Limited B-D Examinations Component Description Additional Information Item Number Comp. ID Item Description Estimated % Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Examination Exam Results B3.130 03-005 SG "A" Primary Outlet Nozzle-to-Extension Pipe Circumferential Weld 50 Component was scanned from extension pipe side only. See the attached sketch (Figure 5) derived from UT examination report 203ISIUT011 and 203ISIUT012 on file at ANO.
Manual UT A detailed sketch (Figure 5) of the limitation is included with the scan plan Wave modalities are longitudinal and shear.
Insonification angles included 0°, 45°, 60°,
and 70°. None required.
No Relevant indications were recorded.
B3.130 03-006 SG "A" Primary Outlet Nozzle-to-Extension Pipe Circumferential Weld 50 Component was scanned from extension pipe side only. See the attached sketch (Figure 6) derived from UT examination report 203ISIUT013 on file at ANO.
Manual UT A detailed sketch (Figure 6) of the limitation is included with the
scan plan. Wave modalities are longitudinal and shear.
Insonification angles included 0°, 45°, 60°, and 70°. None required.
No indications were recorded.
B3.130 03-007 Extension Pipe -to- SG "A" Primary Inlet Nozzle Circumferential Weld 50 Component was scanned from extension pipe side only. See the attached sketch (Figure 7) derived from UT examination report 203ISIUT015 on file at ANO.
Manual UT A detailed sketch (Figure 7) of the limitation is included with the scan plan. Wave modalities are longitudinal and shear.
Insonification angles included 0°, 45, 60°,
and 70°. None required.
No indications were recorded.
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Page 7 of 11 Figure 1 Scan Plan and Coverage for ISI Component 04-005 Not to Scale
Figure 2 Scan Plan and Coverage for ISI Component 04-006 Not to Scale
45° 60° 45° 60° Ext. Piece Nozzle 45° 60° 45° 60° Ext. Piece Nozzle to 2CAN031203
Page 8 of 11 Figure 3 Scan Plan and Coverage for ISI Component 04-007 Not to Scale
45° 60° 45° 60° Ext. Piece Nozzle to 2CAN031203
Page 9 of 11 Figure 4 Scan Plan and Coverage for ISI Components 03-005IR; 03-006IR; 03-007IR; 04-005IR; 04-006IR AND 04-007IR Not to Scale
120 118 116 114 112 110 108 4 6 8 10 12 14 16 18 R Z 70/19bd 120 118 116 114 112 110 108 4 6 8 10 12 14 16 18 R Z 55/22bd 120 118 116 114 112 110 108 4 6 8 10 12 14 16 18 R Z 25/90bd 120 118 116 114 112 110 108 4 6 8 10 12 14 16 18 R Z 35/120bd to 2CAN031203
Page 10 of 11 Figure 5 Scan Plan and Coverage for ISI Component 03-005 Not to Scale
Figure 6 Scan Plan and Coverage for ISI Component 03-006 Not to Scale
45° 60° 45° 60° Ext. Piece Nozzle 45° 60° 45° 60° Ext. Piece Nozzle to 2CAN031203
Page 11 of 11 Figure 7 Scan Plan and Coverage for ISI Component 03-007 Not to Scale
45° 60° 45° 60° Ext. Piece Nozzle Attachment 2 to 2CAN031203 Request for Relief ANO2-ISI-009 to 2CAN031203
Page 1 of 2 REQUEST FOR RELIEF ANO2-ISI-009 Components /
Numbers: See Table 1 Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1
References:
ASME Section XI 1992 Edition, Table IWB-2500-1 Examination Category:
B-H Item Number(s)
B8.30
Description:
Integral Attachments for Vessels Unit / Inspection Interval Applicability: Arkansas Nuclear One, Unit 2 (ANO-2) / Third (3rd) 10-Year Interval I. CODE REQUIREMENTS ASME Section XI, Table IWB-2500-1, "Examination Category B-H, Integral Attachments for Vessels", Item B8.30 requires a surface examination, as applicable, of integrally
welded attachments.
II. RELIEF REQUEST Due to the geometric configuration of the integrally welded attachment and associated welded insulation bracket, the code examination area, as depicted in ASME Section XI, cannot be examined to the extent of obtaining full code coverage. Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests permission to perform surface examination within the limitations described in Table 1 of this relief
request. Table 1 Limited B-H Examination Item # Item ID Description Coverage (%) Reason for Limitation B8.30 04-008 Integrally Welded Attachment - Key
Bracket 62 Structural interference at the lower weld of Key Bracket due to welded insulation support. B8.30 04-009 Integrally Welded Attachment - Key Bracket 62 Structural interference at the lower weld of Key Bracket due to welded insulation support.
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Page 2 of 2 III. BASIS FOR RELIEF During surface examination of the vessel integral attachment weld, 100% coverage of the required examination area could not be obtained.
The configuration of the subject component is a metal key bracket with dimensions approximately twenty-two inches by eight inches welded on four sides. The bracket is integrally welded to the steam generate shell. The angle iron insulation support below the bracket is welded in place and restricts access to the lower portion of the weld. Code examination of this type of integral attachment weld requires a surface examination technique, such as a Liquid Dye Penetrate or Magnetic Particle Testing, of the weld crown surface and 1/2 inch of base material on either side of the weld toes.
However, due to the configuration of this integral attachment and associated welded insulation support, access to the lower weld and surrounding base material for examination purposes is limited.
In order to perform additional or alternative Code examinations, modification and/or replacement of the insulation support would be required. The examination performed on the available surface area of the subject item would detect generic degradation, if it existed, demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS No alternative testing is proposed at this time. Entergy has examined the subject item to the extent practical.
V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on
the facility.
Entergy believes that it is impractical to obtain greater examination coverage on these areas. To obtain additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject areas, in addition to the examination of similar welds contained in the program would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. Therefore, Entergy requests the proposed relief be authorized pursuant to 10 CFR 50.55a(g)(6)(i).
Attachment 3 to 2CAN021203 Request for Relief ANO2-ISI-010 to 2CAN031203
Page 1 of 28 REQUEST FOR RELIEF ANO2-ISI-010 Components /
Numbers: See Table 1 Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1
References:
ASME Section XI 1986 Edition, Table IWB-2500-1 ASME Section XI 1992 Edition with 2003 Addenda, Table IWB-2500-1 ASME Section XI 1995 Edition with 1996 Addenda, for Ultrasonic Testing (UT) Examination ASME Section XI 2001 Edition with 2003 Addenda, Table IWB-2500-1 ASME Code Case N-460 Examination Category:
B-J Item Number(s)
B9.11; B9.21; R1.11 and R1.20
==
Description:==
Pressure Retaining Welds in Piping - Inspection Program B Unit / Inspection Interval Applicability: Arkansas Nuclear One, Unit 2 (ANO-2) / Third (3rd) 10-Year Interval I. CODE REQUIREMENTS ASME Section XI, Table IWB-2500-1, Examination Category B-J, "Pressure Retaining Welds in Piping - Inspection Program B":
- 1) Item B9.11, as allowed by the risk informed (RI) process, requires a volumetric examination of circumferential piping welds Nominal Pipe Size (NPS) 4 or larger, as depicted in Figures IWB-2500-8 and Risk-Informed Inservice Inspection Evaluation Procedure, Electric Power Research Institute (EPRI) Report No. TR-106706, Interim Report, June 1996.
- 2) Item B9.21 requires a volumetric examination of circumferential piping welds less than NPS 4, as depicted in Figures IWB-2500-8 and Risk-Informed Inservice Inspection Evaluation Procedure, EPRI Report No. TR-106706, Interim Report, June 1996. ASME Code Case N-460 allows a reduction in coverage due to interference or geometry as long as the overall coverage is greater than 90%.
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Page 2 of 28 II. RELIEF REQUEST Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Op erations, Inc. (Entergy) requests relief from achieving the Code-required coverage when performing volumetric examinations of the components identified in Table 1 below.
III. BASIS FOR RELIEF
During ultrasonic examination of the piping welds listed in Table 1 above, greater than 90% coverage of the required examination volume could not be obtained.
Class 1 piping and components are often designed with welded joints such as nozzle-to-pipe, pipe-to-valve and pipe-to-pump which can physically obstruct a large portion of the required examination volume. For examinations performed after the 10 CFR 50.55a mandatory implementation date for Appendix VIII of Section XI, and Code coverage percentages reflect what is currently allowed by qualified Appendix VIII techniques.
Appendix VIII qualified Performance Demonstration Initiative (PDI) procedures have demonstrated that sound beams may potentially be attenuated and distorted when required to pass through austenitic weld metal. Still, the PDI qualified methods employ the best available technology for maximizing examination coverage of these types of welds. Examination was extended to the far side of the weld to the extent permitted by geometry, but this portion of the examination is not included in the reported coverage for welds examined under PDI and Appendix VIII rules.
These ultrasonic examinations have been performed over the course of the interval to varying code requirements and procedures. Entergy has used the best available and EPRI approved techniques to examine the subject piping welds. To improve upon these examination coverage percentages, modification and/or replacement of the component would be required. Consistent with the ASME Section XI sampling approach, examination of the subject welds, when combined with examinations that have been performed on other welds within the same Examination Category, is adequate to detect generic degradation, if it existed, demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS No alternative testing is proposed at this time. Entergy has examined the subject items to the extent practical and will continue to perform pressure testing on the subject areas as required by the Code.
V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is to 2CAN031203
Page 3 of 28 otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Entergy believes that it is impractical to obtain greater examination coverage on these areas. To obtain additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject areas, in addition to the examination of similar welds contained in the program would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. Therefore, Entergy requests the proposed relief be authorized pursuant to 10 CFR 50.55a(g)(6)(i). to 2CAN031203
Page 4 of 28 Table 1 Limited B-J Examinations Component Description Additional Information Item Number Comp. ID Item Description Estimated % Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Examination Exam Results B9.11 02-T-082 Reactor Vessel Closure Head (RVCH) Instrument Nozzle Tube-to-Flange #82 80 Component was scanned from both sides; however, scanning of the required code volume was limited from the flange side due to the component configuration. See the attached sketch (Figure 1) derived from UT examination report ISI-UT-08-063 on file at ANO.
Manual UT Figure 1 depicts the component configuration. Wave modality is shear.
Insonification angles included 45° shear (S)
and 70°S.
A 60°S supplemental exam was also performed.
Although not required by
the Risk Informed (RI) process, a
surface examination was performed and documented
on examination report ISI-PT-08-013
on file at ANO. No indications were recorded.
B9.11 02-T-083 RVCH Instrument Nozzle Tube-to-Flange #83 80 Component was scanned from both sides; however, scanning of the required code volume was limited from the flange side due to the component configuration. See the attached sketch (Figure 2) derived from UT examination report ISI-UT-08-064 on file at ANO.
Manual UT Figure 2 depicts the component
configuration. Wave modality is shear.
Insonification angles included 45°S and 70°S.
A 60°S supplemental exam was also performed.
Although not required by the RI process, a surface examination was performed and documented on examination report ISI-PT-08-014 on file at ANO. No indications were recorded.
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Page 5 of 28 Table 1 (cont') Limited B-J Examinations Component Description Additional Information Item Number Comp. ID Item Description Estimated % Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Examination Exam Results B9.11 21-001 Safety Injection Loop 1A Safe End-to-Nozzle Circumferential Weld 82.5 Component was scanned from both sides; however, scanning was limited
from the nozzle side due to the component configuration and weld geometry (lift off). See the attached sketch (Figure 3) derived from UT examination report 200ISIUT033 on file at ANO.
Manual UT Figure 3 depicts the component configuration and weld profile. Wave modality was longitudinal.
Insonification angles included 45°RL and
60°RL. Although not required by
the RI process, a surface examination was performed
and documented on examination
report 200ISIPT018 on file at ANO. Two geometric
reflectors were recorded.
No surface indications were recorded.
R1.11 21-007 Safety Injection Loop 1A Elbow-to-Valve Circumferential Weld 50 Component was scanned from the elbow side only due to the component configuration. See the attached sketch (Figure 4) derived from UT examination report ISI-UT-09-004 on file at ANO.
Manual UT Figure 4 depicts the component configuration and weld profile at the intrados and extrados of the elbow. Wave modality used included shear and longitudinal.
Insonification angles
included 45°S, 60°S and 60°RL.
None required.
No indications were recorded.
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Page 6 of 28 Table 1 (cont') Limited B-J Examinations Component Description Additional Information Item Number Comp. ID Item Description Estimated % Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Examination Exam Results B9.11 22-001 Safety Injection Loop 1B Safe End to Nozzle Circumferential Weld 70 Component was scanned from both sides; however scanning was limited from the nozzle side due to the component configuration and weld geometry (lift off). See the attached sketch (Figure 5) derived from UT examination report 200ISIUT040 and 200ISIUT041 on file at ANO.
Manual UT Figure 5 depicts the component configuration and weld profile. Wave modality was longitudinal.
Insonification angles included 45°RL and 60°RL. Although not required by the RI process, a
surface examination was performed and documented
on examination report 200ISIPT025 on file at ANO. No indications were recorded.
R1.11 22-004 Safety Injection Loop 1B Valve-to-Pipe Circumferential Weld 50 Component was scanned from the pipe side only due to the component
configuration.
An examination, from the pipe side, was also performed through the weld for flaw detection on the valve side of the weld utilizing a 70°RL. See the attached sketch (Figure 6) derived from UT examination report ISI-UT-05-023 on file at ANO.
Manual UT Figure 6 depicts the component configuration and weld profile. Wave modality used included shear and
longitudinal.
Insonification angles included 45°S, 60°S and 70°RL.
None required.
No indications were recorded.
R1.11 22-005 Safety Injection Loop 1B Pipe-to-Valve Circumferential Weld 50 Component was scanned from the pipe side only due to the component configuration.
An examination, from the pipe side, was also performed through the weld for flaw detection on the valve side of the weld utilizing a 70°RL. See the attached sketch (Figure 7) derived from UT examination report ISI-UT-05-024 on file at ANO.
Manual UT Figure 7 depicts the component
configuration and weld profile. Wave modality used included shear and longitudinal.
Insonification angles included 45°S, 60°S and 70°RL.
None required.
No indications were recorded. to 2CAN031203
Page 7 of 28 Table 1 (cont') Limited B-J Examinations Component Description Additional Information Item Number Comp. ID Item Description Estimated % Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Examination Exam Results B9.11 23-001 Safety Injection Loop 2A Safe End-to-Nozzle Circumferential Weld 70 Component was scanned from both sides; however scanning was limited from the safe end side due to the component configuration and weld geometry (lift off). See the attached sketch (Figure 8) derived from UT examination report 200ISIUT042 and 200ISIUT043 on file at ANO.
Manual UT Figure 8 depicts the component configuration and weld profile. Wave modality was longitudinal.
Insonification angles included 45°RL and
60°RL. Although not required by the RI process, a
surface examination was performed and documented
on examination report 200ISIPT023 on file at ANO. No indications were recorded.
B9.11 23-006 Safety Injection Loop 2A Valve-to-Pipe Circumferential Weld 50 Component was scanned from the pipe side only due to the component
configuration. An examination from the pipe side was also performed through the weld for flaw detection utilizing the 60°RL. See the attached sketch (Figure 9) derived from UT examination report 202ISIUT032 on file at ANO.
Manual UT Figure 9 depicts the component configuration and weld profile. Wave modality used included shear and
longitudinal.
Insonification angles included 45°S and
60°RL. None required.
One geometric
reflector was recorded.
B9.11 23-007 Safety Injection Loop 2A Pipe-to-Valve Circumferential Weld 50 Component was scanned from the pipe side only due to the component
configuration. An examination from the pipe side was also performed through the weld for flaw detection utilizing the 60°RL. See the attached sketch (Figure 10) derived from UT examination report 202ISIUT033 on file at ANO.
Manual UT Figure 10 depicts the component configuration and weld profile. Wave modality used included shear and
longitudinal.
Insonification angles included 45°S and
60°RL. None required.
One geometric
reflector was recorded.
to 2CAN031203
Page 8 of 28 Table 1 Limited B-J Examinations Component Description Additional Information Item Number Comp. ID Item Description Estimated % Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Examination Exam Results B9.11 24-001 Safety Injection Loop 2B Safe End-to-Nozzle Circumferential Weld 66.5 Component was scanned from both sides; however, scanning was limited from the safe end side due to the component configuration and weld geometry (lift off). See the attached sketch (Figure 11) derived from UT examination report 200ISIUT044 and 200ISIUT045 on file at ANO.
Manual UT Figure 11 depicts the component configuration and weld profile. Wave modality was longitudinal.
Insonification angles included 45°RL and 60°RL. Although not required by
the RI process, a surface examination was performed and documented on examination
report 200ISIPT024 on file at ANO. No indications were recorded.
R1.11 24-006 Safety Injection Loop 2B Pipe-to-Valve Circumferential Weld 50 Component was scanned from the pipe side only due to the component configuration. An examination from the pipe side was also performed through the weld for flaw detection utilizing the 70°RL. See the attached sketch (Figure 12) derived from UT examination report ISI-UT-06-009 on file at ANO.
Manual UT Figure 12 depicts the component
configuration and weld profile. Wave modalities used included shear and longitudinal.
Insonification angles included 45°S, 60°S and 70°RL.
None required.
No indications were recorded.
B9.11 25-024 Shutdown Cooling Pipe-to-Weld-o-let
Circumferential Weld 68.75 Component was scanned from the pipe side only due to the component configuration. See the attached sketch (Figure 13) derived from UT examination report 202ISIUT005 on file at ANO.
Manual UT Figure 13 depicts the
component configuration and weld profile. Wave modality used included shear.
Insonification angles included 45°S and 70S°. None required.
No indications were recorded. to 2CAN031203
Page 9 of 28 Table 1 Limited B-J Examinations Component Description Additional Information Item Number Comp. ID Item Description Estimated % Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Examination Exam Results B9.21 27-001 Pressurizer Spray Loop 1B Safe End-to-Nozzle Circumferential Weld 83 Component was scanned from both sides; however, scanning was limited from the nozzle side due to the component configuration and weld geometry (lift off). See the attached sketch (Figure 14) derived from UT examination report 200ISIUT046, 200ISIUT047, and 200ISIUT048 on file at ANO.
Manual UT Figure 14 depicts the component
configuration and weld profile. Wave modality used included longitudinal.
Insonification angles included 32°RL, 45°RL and 60°RL.
Although not required by the RI process, a
surface examination was performed and documented
on examination report 200ISIPT021 on file at ANO. One geometric reflector was recorded.
R1.20 27-002 Pressurizer Spray Piping Loop 1B Safe End-to-Elbow Circumferential Weld 83 Component was scanned from both sides; however scanning was limited from the downstream side of the weld at the intrados of the elbow due to the component configuration. See the attached sketch (Figure 15) derived from UT examination report ISI-UT-06-023 on file at ANO.
Manual UT Figure 15 depicts the component configuration and weld profile. Wave modality used included shear.
Insonification angles included 45°S and 70°S. None required.
No indications were recorded.
R1.20 27-003 Pressurizer Spray Piping Loop 1B Elbow-to-Pipe Circumferential Weld 83 Component was scanned from both sides; however, scanning was limited from the upstream side of the weld at the intrados of the elbow due to the component configuration. See the attached sketch (Figure 16) derived from UT examination report ISI-UT-06-024 on file at ANO.
Manual UT Figure 16 depicts the component configuration and weld profile. Wave modality used included shear.
Insonification angles included 45°S and 70°S. None required.
No indications were recorded.
to 2CAN031203
Page 10 of 28 Table 1 Limited B-J Examinations Component Description Additional Information Item Number Comp. ID Item Description Estimated % Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Examination Exam Results R1.20 27-065 Pressurizer Spray Piping Loop 1B Valve-to-Pipe Circumferential Weld 50 Component was scanned from the pipe side only due to the component configuration. An examination from the pipe side was also performed through the weld for flaw detection utilizing the 60°RL. A supplemental examination from the pipe side was also performed with a 45° shear wave transducer. See the attached sketch (Figure 17) derived from UT examination report ISI-UT-05-036 on file at ANO.
Manual UT Figure 17 depicts the component configuration and weld profile. Wave modality used included shear and
longitudinal.
Insonification angles included 45°S, 60°S, 70°S and 60°RL.
None required.
No indications were recorded.
R1.20 27-066 Pressurizer Spray Piping Loop 1B Pipe-to-Tee Circumferential Weld 73 Component was scanned from both sides to the extent practical. An examination from the pipe side was also performed through the weld for flaw detection utilizing the 60°RL. A supplemental examination from the pipe side was also performed with a 45° shear wave transducer. See the attached sketch (Figure 18) derived from UT examination report ISI-UT-05-037 on file at ANO.
Manual UT Figure 18 depicts the component configuration and weld profile. Wave modality used included shear and
longitudinal.
Insonification angles included 45°S, 60°S, 70°S and 60°RL.
None required.
No indications were recorded.
B9.21 40-005 Charging Piping Loop 1A Valve-to-Pipe Circumferential Weld 59.6 Component was scanned from the pipe side only due to the component
configuration. See the attached sketch (Figure 19) derived from UT examination report 202ISIUT030 on file at ANO.
Manual UT Figure 19 depicts the component configuration and weld profile. Wave modality used included shear.
Insonification angles included 45°S and 70°S. None required.
No indications were recorded.
B9.21 40-008 Charging Piping Loop 1A Pipe-to-Elbow Circumferential Weld 74 Component was scanned from both sides; however, scanning was limited at the elbow intrados due to the component configuration and 360
û due to weld crown configuration. See the attached sketch (Figure 20) derived from UT examination report 202ISIUT007 on file at ANO.
Manual UT Figure 20 depicts the component
configuration and weld profile. Wave modality used included shear.
Insonification angles included 45°S and
70°S. None required No indications were recorded.
to 2CAN031203
Page 11 of 28 Table 1 Limited B-J Examinations Component Description Additional Information Item Number Comp. ID Item Description Estimated % Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Examination Exam Results R1.11 40-025 Charging Piping Loop 1A Elbow-to-Safe End Circumferential Weld 85 Component was scanned from both sides; however, scanning was limited at the intrados of the elbow due to the component configuration. See the attached sketch (Figure 21) derived from UT examination report ISI-UT-09-006 on file at ANO.
Manual UT Figure 21 depicts the component configuration and weld profile. Wave modality used included shear.
Insonification angles included 45°S, 60°S and 70°S.
None required.
No indications were recorded.
B9.21 41-003 Charging Piping Loop 2A Valve-to-Pipe Circumferential Weld 60 Component was scanned from the pipe side only due to the component configuration. See the attached sketch (Figure 22) derived from UT examination report 202ISIUT039 and 202ISIUT040 on file at ANO.
Manual UT Figure 22 depicts the component
configuration and weld profile. Wave modality used included shear.
Insonification angles included 45°S and
70°S. None required.
No indications were recorded.
B9.21 41-003C Charging Piping Loop 2A Tee-to-Pipe Circumferential Weld 60 Component was scanned from the pipe side only due to the component
configuration. See the attached sketch (Figure 23) derived from UT examination report 202ISIUT041 and 202ISIUT042 on file at ANO.
Manual UT Figure 23 depicts the component configuration and weld profile. Wave modality used included shear.
Insonification angles included 45°S and 70°S. None required.
No indications were recorded.
B9.11 43-022 Pressurizer LTOP Tee-to-Pipe Circumferential Weld 71.2 Component was scanned from both sides; however, scanning was limited from the Tee side due to the
component configuration. See the attached sketch (Figure 24) derived from UT examination report 203ISIUT021 and 203ISIUT023 on file at ANO.
Manual UT Figure 24 depicts the
component
configuration and weld profile. Wave modality used included shear and longitudinal.
Insonification angles included 45°S, 60°S, 70°S and 60°RL.
None required No indications were recorded.
R1.11 43-023 Pressurizer LTOP Tee-to-
Pipe Circumferential Weld 81 Component was scanned from both sides; however, scanning was limited from the Tee side due to the component configuration. See the attached sketch (Figure 25) derived from UT examination report ISI-UT-05-029 on file at ANO.
Manual UT Figure 25 depicts the component configuration and weld profile. Wave modality used included shear and
longitudinal.
Insonification angles included 45°S, 60°S, 70°S and 60°RL.
None required No indications were recorded. to 2CAN031203
Page 12 of 28 Table 1 Limited B-J Examinations Component Description Additional Information Item Number Comp. ID Item Description Estimated % Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Examination Exam Results B9.11 43-027 Pressurizer LTOP Pipe-to-Valve Circumferential Weld 67.6 Component was scanned from the pipe side and partially from the tee due to the component configuration. See the attached sketch (Figure 26) derived from UT examination report 202ISIUT011 on file at ANO.
Manual UT Figure 26 depicts the component configuration and weld profile. Wave modality used included shear.
Insonification angles included 45°S and 70°S. None required No indications were recorded.
B9.11 43-033 Pressurizer LTOP Tee-to-
Pipe Circumferential Weld 72.5 Component was scanned from the pipe side only due to the component
configuration. See the attached sketch (Figure 27) derived from UT examination report 202ISIUT012 on file at ANO.
Manual UT Figure 27 depicts the component configuration and weld profile. Wave modality used included shear.
Insonification angles included 45°S and 70°S. None required No indications were recorded.
R1.20 13-008 RCP 2P-32C Discharge Nozzle Safe End-to-Pipe
Circumferential Weld 60.1 Component was scanned from the pipe side only with Appendix VIII procedure qualified for single side access, which also interrogated the cast stainless steel side of the component. Coverage for the cast stainless steel side was not included in the code required coverage. The circumferential scan was limited due to the cast stainless and the component configuration (weld surface/taper).. See the attached sketch (Figure 28) derived from UT examination report ISI-VE-09-044 on file at ANO.
Manual UT Phased Array examination.
Figure 28 depicts the component configuration. Wave modalities are longitudinal and shear.
Insonification angles included 0°-80° flat L-wave; 25°-75° axial shear wave; and 0°-80° circumferential L-wave w/ +10° & -10° skew.
None required No indications were recorded.
R1.20 15-008 RCP 2P-32D Discharge Nozzle Safe End-to-Pipe
Circumferential Weld 62.8 Component was scanned from the pipe side only with Appendix VIII procedure qualified for single side access, which also interrogated the cast stainless steel side of the component. Coverage for the cast stainless steel side was not included in the code required coverage. The circumferential scan was limited due to the cast stainless steel and the component configuration (weld surface/taper). See the attached sketch (Figure 29) derived from UT examination report ISI-VE-09-046 on file at ANO.
Manual UT Phased Array examination.
Figure 29 depicts the component configuration. Wave modalities are longitudinal and shear.
Insonification angles included 0°-80° flat L-wave; 25°-75° axial shear wave; and 0°-80° circumferential L-wave w/ +10° & -10° skew.
None required No indications were recorded. to 2CAN031203
Page 13 of 28 Table 1 Limited B-J Examinations Component Description Additional Information Item Number Comp. ID Item Description Estimated % Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Examination Exam Results R1.11 29-056 Pressurizer Auxiliary Spray Pipe-to-Tee
Circumferential Weld 50 Component was scanned from the pipe side only due to the component configuration See the attached sketch (Figure 30) derived from UT examination report ISI-UT-08-060I on file at ANO.
Manual UT Figure 30 depicts the
component configuration. Wave modality used included shear.
Insonification angles included 45° S and 70° S. None required No indications were recorded.
to 2CAN031203
Page 14 of 28 Figure 1 Scan Plan and Coverage for ISI Component 02-T-082 Not to Scale
Figure 2 Scan Plan and Coverage for ISI Component 02-T-083 Not to Scale
Figure 3 Scan Plan and Coverage for ISI Component 21-001 Not to Scale
C L 45° 45° 45° 45° Shear/Lon g. Shear/Lon g.Shear/Lon g.Shear/Lon g. S.S. SAFE-END CAST S.S. PIPE 45° 70° 70° FLOW FLANGE INSTRUMENT NOZZLE TUBE C L 45° 45° 70° 70° C L FLOW FLANGE INSTRUMENT NOZZLE TUBE 45° to 2CAN031203
Page 15 of 28 Figure 4 Scan Plan and Coverage for ISI Component 21-007 Not to Scale
Figure 5 Scan Plan and Coverage for ISI Component 22-001 Not to Scale
64° 63° 63° 42° 45° SAFE END ELBOW TO SAFE END WELD NOZZLE C L 45° ELBOW SIDE C L 60° 45° 60° C L VALVE SIDE INTRADOS EXTRADOS to 2CAN031203
Page 16 of 28 Figure 6 Scan Plan and Coverage for ISI Component 22-004 Not to Scale
Figure 7 Scan Plan and Coverage for ISI Component 22-005 Not to Scale
Figure 8 Scan Plan and Coverage for ISI Component 23-001 Not to Scale
PIPE VALVE (2SI-15A)
FLOW 60° 70° C L 1.2 1.15 1.10 1.20 1.20 SHEAR RL VALVE (2SI-15A) FLOW PIPE 1.20 1.20 1.20 1.20 1.15 70° Shear RL 60° C L SAFE END C L 45° Nozzle 45° 45° 45° 45° Flow to 2CAN031203
Page 17 of 28 Figure 9 Scan Plan and Coverage for ISI Component 23-006 Not to Scale
Figure 10 Scan Plan and Coverage for ISI Component 23-007 Not to Scale
C L PIPE 45° FLOW VALVE 45° 60° RL 60° RL 60° RL C L 60° RL 45° 45° FLOW VALVE 2SI-15C to 2CAN031203
Page 18 of 28 Figure 11 Scan Plan and Coverage for ISI Component 24-001 Not to Scale
Figure 12 Scan Plan and Coverage for ISI Component 24-006 Not to Scale
Safe End C L 45° Flow Nozzle 45° 45° 45° 60° 60° 60° FLOW Pipe Valve 45° 60° 70° RL C L to 2CAN031203
Page 19 of 28 Figure 13 Scan Plan and Coverage for ISI Component 25-024 Not to Scale
Figure 14 Scan Plan and Coverage for ISI Component 27-001 Not to Scale
Flow Pipe Weld-O-Let C L 45° 70° FL FL Safe End C L 45°.60° Flow Nozzle 45°.60° 45°.60° 45°.60° TOE TOE to 2CAN031203
Page 20 of 28 Figure 15 Scan Plan and Coverage for ISI Component 27-002 Not to Scale
Figure 16 Scan Plan and Coverage for ISI Component 27-003 Not to Scale
Figure 17 Scan Plan and Coverage for ISI Component 27-065 Not to Scale
Flow Safe End Elbow 70° 70° 45° 45° C L 45°/70° 45°/70° PIPE ELBOW FLOW C L SCANNED ACROSS WELD VALVE C L Flow 45° 70° 60° RL PIPE 2CV-4655 to 2CAN031203
Page 21 of 28 Figure 18 Scan Plan and Coverage for ISI Component 27-066 Not to Scale
Figure 19 Scan Plan and Coverage for ISI Component 40-005 Not to Scale
Flow PIPE TEE 45° 70° 70° 45° C L C L 60° RL 60° RL 1.125" 4.225" 9.675" 6.675" 3" ID TDC Flow Pipe Valve C L 70° 45° 45° to 2CAN031203
Page 22 of 28 Figure 20 Scan Plan and Coverage for ISI Component 40-008 Not to Scale
Figure 21 Scan Plan and Coverage for ISI Component 40-025 Not to Scale
Flow Extradose ELBOW SAFE-END 70° 70° 60° 60° 45° 45° C L Flow Elbow C L 70 Pipe 70 70 70 to 2CAN031203
Page 23 of 28 Figure 22 Scan Plan and Coverage for ISI Component 41-003 Not to Scale
Figure 23 Scan Plan and Coverage for ISI Component 41-003C Not to Scale
45° 70°/45° C L Valve Pipe Flow TEE 70° C L 70° PIPE to 2CAN031203
Page 24 of 28 Figure 24 Scan Plan and Coverage for ISI Component 43-022 Not to Scale
PIPE TEE FLOW C L 70° 60° 45° 45°-60°-70° PROFILE SHOWS OBS. OF TEE AT T.D.C. AND BDC 5/5" OF SCAN OBS. IN BOTH AREAS FOR TOTAL OF 11.00" FLOW 45° COVERAGE IS 65% IN OBS. AREA. PLUS 10% MORE PICKED UP WITH THE 60°. OBS. AREA IS 2" DIA.
PROFILE SHOWS COVERAGE IN OBS. AREA OBS. 2BCH-16-3/4" FROM 4.2" TO 6.2" SW PIPE TEE C L C L 45°-60° 45°-60° 70° 70° 70° 70° 60° 60° 60° 60° 45° 45° 45° 45° SCAN COVERAGE ON TEE & PIPE AREA. ABLE TO SCAN 10" TOTAL FROM TEE SIDE. FROM 2.75" CW TO 7.5" CW ALSO FROM 13.25" CW TO 18.5" CW to 2CAN031203
Page 25 of 28 Figure 25 Scan Plan and Coverage for ISI Component 43-023 Not to Scale
TEE C L 70° PIPE 70° 45° 45° 60° RL 60° RL C L FLOW 17.6" 3.2" 7.2" 13.6" TDC 6" ID to 2CAN031203
Page 26 of 28 Figure 26 Scan Plan and Coverage for ISI Component 43-027 Not to Scale
Figure 27 Scan Plan and Coverage for ISI Component 43-033 Not to Scale
70° 45° Valve Pipe C L Flow 70° 45° Tee Pipe C L Flow 45° to 2CAN031203
Page 27 of 28 Figure 28 Scan Plan and Coverage for ISI Component 13-008 Not to Scale
Figure 29 Scan Plan and Coverage for ISI Component 15-008 Not to Scale
25° 80° C/S PIPE CAST SS SAFE C/S PIPE CAST SS SAFE 25° 80° to 2CAN031203
Page 28 of 28 Figure 30 Scan Plan and Coverage for ISI Component 29-056 Not to Scale
FLOW TEE PIPE 70° 70° C L Attachment 4 to 2CAN031203 Request for Relief ANO2-ISI-011 to 2CAN031203
Page 1 of 2 REQUEST FOR RELIEF ANO2-ISI-011 Components /
Numbers: See Table 1 Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1
References:
ASME Section XI 1992 Edition, Table IWB-2500-1 Examination Category:
B-K-1 Item Number(s)
B10.20
Description:
Integral Attachments for Piping, Pumps and Valves Unit / Inspection Interval Applicability: Arkansas Nuclear One, Unit 2 (ANO-2) / Third (3rd) 10-Year Interval I. CODE REQUIREMENTS ASME Section XI, Table IWB-2500-1, "Examination Category B-K, Integral Attachments for Piping, Pumps, and Valves", Item B10.20 requires a volumetric or surface examination, as applicable, of integrally welded attachments.
II. RELIEF REQUEST Due to the geometric configuration of the integrally welded attachment and associated pipe support, the code examination area, as depicted in ASME Section XI, cannot be examined to the extent of obtaining full code coverage. Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests permission to perform surface examination within the limitations described in Table 1 of this relief request. Table 1 Limited B-K-1 Examination Item # Item ID Description Coverage (%) Reason for Limitation B10.20 22-071W Integrally Welded Attachment Way Vertical Restraint 88 Structural interference at the end of lugs where they contact the support.
to 2CAN031203
Page 2 of 2 III. BASIS FOR RELIEF During surface examination of the pipe support integral attachment weld, 100% coverage of the required examination area could not be obtained.
The configuration of the subject component is four 5/8" x 1" x 1" lugs, placed 4 1/16" apart end-to-end in pairs at 0° and 180° on the vertical pipe. The lugs are integrally welded to the pipe with full penetration welds. The two piece four-inch wide hanger strap is positioned and bolted between the end to end lugs, contacting the upper lugs which support the vertical pipe. Code examination of this type of integral attachment weld requires a surface examination technique, such as Liquid Dye Penetrate or Magnetic Particle Testing, of the weld crown surface and 1/2 inch of base material on either side of the weld toes. However, due to the configuration of this integral attachment and associated hanger strap, access to the weld ends and surrounding base material for examination purposes is limited.
In order to perform additional or alternative Code examinations, modification and/or replacement of the component would be required. The examination performed on the available surface area of the subject item would detect generic degradation, if it existed, demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS No alternative testing is proposed at this time. Entergy has examined the subject item to the extent practical.
V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on
the facility.
Entergy believes that it is impractical to obtain greater examination coverage on these areas. To obtain additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject areas, in addition to the examination of similar welds contained in the program would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. Therefore, Entergy requests the proposed relief be authorized pursuant to 10 CFR 50.55a(g)(6)(i).
Attachment 5 to 2CAN031203 Request for Relief ANO2-ISI-012 to 2CAN031203
Page 1 of 6 REQUEST FOR RELIEF ANO2-ISI-012 Components /
Numbers: See Table 1 Code Classes: American Society of Mechanical Engineers (ASME) Code Class 2
References:
ASME Section XI 1986 Edition, Table IWC-2500-1 ASME Section XI 1995 Edition with 1996 Addenda for Ultrasonic Examinations Examination Category:
C-A Item Number(s)
C1.10; C1.30
==
Description:==
Pressure Retaining Welds in Pressure Vessels - Inspection Program B Unit / Inspection Interval Applicability: Arkansas Nuclear One, Unit 2 (ANO-2) / Third (3rd) 10-Year Interval I. CODE REQUIREMENTS ASME Section XI, Table IWC-2500-1, Examination Category C-A, "Pressure Retaining Welds in Pressure Vessels - Inspection Program B":
- 1) Item C1.10 requires a volumetric examination of the Shell Circumferential Weld volume, as depicted in Figure IWC-2500-1.
- 2) Item C1.30 requires a volumetric examination of the Tubesheet-to-Shell Weld, as depicted in Figure IWC-2500-1.
II. RELIEF REQUEST Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Op erations, Inc. (Entergy) requests relief from achieving the Code-required coverage when performing volumetric examinations of the components identified in Table 1 below.
III. BASIS FOR RELIEF During ultrasonic examination of the Letdown Heat Exchanger Flange-to-Channel Circumferential Weld and the Shutdown Cooling Heat Exchanger Flange-to-Channel Cylinder and Channel Cylinder-to-Tubesheet Welds listed in Table 1 below, 100% coverage of the required examination volumes could not be obtained.
Due to the geometric configuration of the components and the close proximity of other structures which limited scan paths, the use of approved beam angles in the axial and to 2CAN031203
Page 2 of 6 circumferential direction were not able to achieve greater than 90% code required volume. See Table 1 below for additional information.
Radiography is not practical on these types of nozzle-to-vessel weld configurations which prevent placement of the film and exposure source. To effectively perform any significant additional Code allowable ultrasonic examinations, modification and/or
replacement of the component would be required. The examinations performed on the subject items in addition to the examination of other vessel welds contained in the Inservice Inspection (ISI) program would detect generic degradation, if it existed, demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS No alternative testing is proposed at this time. Entergy has examined these welds to the extent practical and will continue to perform pressure testing on the subject components as required by the Code.
V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on
the facility.
Entergy believes that it is impractical to obtain greater examination coverage on these welds. To effectively obtain significant additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject welds, in addition to the examination of similar welds contained in the program, would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. Entergy requests the proposed relief be authorized pursuant to 10 CFR 50.55a(g)(6)(i). to 2CAN031203
Page 3 of 6 Table 1 Limited C-A Examinations Component Description Additional Information Item Number Comp. ID Item Description Estimated % Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Examination Exam Results C1.10 45-001 Letdown Heat Exchanger Flange-to-Channel Circumferential Weld 45.7 This was a single-sided exam due to the configuration and close proximity of the channel head flange. Additionally, scan paths from the shell side were limited due to the inlet and
outlet piping configurations attached to the shell. See the attached sketch (Figure 1)
derived from ultrasonic test (UT) examination report ISI-UT-08-065 on file at ANO.
Manual UT examination. Figure 1 depicts the component configuration and weld profile. Wave modality used included
shear. Insonification angles included 45° shear (S) and 70°S. None required.
No indications were recorded.
C1.10 49-001 Shutdown Cooling Heat Exchanger Flange-to-Channel Cylinder Circumferential Weld 69.5 This was a single-sided exam due to the configuration and close proximity of the channel head flange.
Additionally, scan paths from the shell side were limited due to the inlet and outlet piping configurations attached to the shell. See the attached sketch (Figure 2) derived from UT examination report 204ISIUT001 on file at ANO.
Manual UT examination. Figure 2 depicts the component
configuration and weld profile. Wave modality used included shear. Insonification angles included 45°S and 70°S.
None required.
One indication identified as
a plate segregate located outside the
code exam volume, ~0.50" from
the shell inside diameter, was recorded.
Evaluated as
acceptable by the Entergy Level III. to 2CAN031203
Page 4 of 6 Table 1 Limited C-A Examinations Component Description Additional Information Item Number Comp. ID Item Description Estimated % Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Examination Exam Results C1.30 49-002 Shutdown Cooling Heat Exchanger Channel Cylinder-to-Tubesheet Circumferential Weld 81.8 This was a single-sided exam due to the configuration and close proximity of the channel head flange. Additionally, scan paths from the shell side were limited due to the inlet and outlet piping configurations attached to the shell. See the attached sketch (Figure 3) derived from UT examination report 204ISIUT003 on file at ANO.
Manual UT examination. Figure 3 depicts the component
configuration and weld profile. Wave modality used included shear. Insonification angles included 45°S and 70°S.
None required.
Acceptable plate segregation and clad interface indications identified
during the 2 nd ISI Interval examination were confirmed.
No new indications recorded.
to 2CAN031203
Page 5 of 6 Figure 1 Scan Plan and Coverage for ISI Component 45-001 Not to Scale
Flange C L - Two Direction Coverage 45° 70° 70° Toe Toe Channel Head 3" Linear Obstruction 2" Linear Obstruction 3" Linear Obstruction 2" Linear Obstruction 45-001 45-002 Sketch of Obstructions to 2CAN031203
Page 6 of 6 Figure 2 Scan Plan and Coverage for ISI Component 49-001 Not to Scale
Figure 3 Scan Plan and Coverage for ISI Component 49-002 Not to Scale
FLANGE 45° 70° Bolts SHELL 45° 45° 70° 45° FLANGE 70° CHANNEL CYLINDER CLAD C L C L CLAD Attachment 6 to 2CAN031203 Request for Relief ANO2-ISI-013 to 2CAN031203
Page 1 of 4 REQUEST FOR RELIEF ANO2-ISI-013 Components /
Numbers: See Table 1 Code Classes: American Society of Mechanical Engineers (ASME) Code Class 2
References:
ASME Section XI 1992 Edition, Table IWC-2500-1 ASME Section XI 1995 Edition with 1996 Addenda for Ultrasonic Examinations Examination Category:
C-B Item Number(s)
C2.21
Description:
Pressure Retaining Nozzle Welds in Vessels - Inspection Program B Unit / Inspection Interval Applicability: Arkansas Nuclear One, Unit 2 (ANO-2) / Third (3rd) 10-Year Interval I. CODE REQUIREMENTS ASME Section XI, Table IWC-2500-1, Examination Category C-B, "Pressure Retaining Nozzle Welds in Vessels - Inspection Program B":
- 1) Item C2.21 requires a volumetric and surface examination of the Nozzle-to-Shell Weld volume, as depicted in Figure IWC-2500-4 (a) or (b).
II. RELIEF REQUEST Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Op erations, Inc. (Entergy) requests relief from achieving the Code-required coverage when performing volumetric examinations of the components identified in Table 1 below.
III. BASIS FOR RELIEF During ultrasonic examination of the Feedwater Nozzle-to-Shell Weld listed in Table 1 below, 100% coverage of the required examination volumes could not be obtained.
Due to the close proximity of one of the steam generator insulation brackets, located
around the circumference of the vessel and directly below the Feedwater nozzles, scan paths from below the nozzle were impeded and 100% examination of the code required volume was not achieved. See Table 1 below for additional information.
There are several insulation bracket rings located around the circumference of the steam generator. These brackets facilitate supporting the many insulation panels surrounding the circumference of the steam generator. Removal of the subject bracket requires to 2CAN031203
Page 2 of 4 removal of all insulation panels directly supported by that ring as well as removal or engineered rigging of all insulation rings and panels above the removed ring. The insulation rings are not bolted directly to the steam generator shell therefore each lower elevation ring helps support the above rings and insulation panels.
Radiography is not practical on these types of nozzle-to-vessel weld configurations, which prevent placement of the film and exposure source. To effectively perform any significant additional Code allowable ultrasonic examinations, modification and/or removal are replacement of the insulation ring would be required. The examinations performed on the subject items in addition to the examination of other vessel welds contained in the Inservice Inspection program would detect generic degradation, if it existed, demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS No alternative testing is proposed at this time. Entergy has examined these welds to the extent practical and will continue to perform pressure testing on the subject components as required by the Code.
V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Entergy believes that it is impractical to obtain greater examination coverage on these welds. To effectively obtain significant additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject welds, in addition to the examination of similar welds contained in the program, would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. Entergy requests the proposed relief be authorized pursuant to
10 CFR 50.55a(g)(6)(i). to 2CAN031203
Page 3 of 4 Table 1 Limited C-B Examinations Component Description Additional Information Item Number Comp. ID Item Description Estimated % Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Examination Exam Results C2.21 04-002 Steam Generator "B" Feedwater Nozzle-to-Shell Weld 71.6 This was a dual sided exam, limited by the configuration of the shell-to-nozzle blend area and the close proximity of an insulation bracket ring below the nozzle. See the attached sketch (Figure 1)
derived from ultrasonic test (UT) examination report ISI-UT-06-067 on file at ANO.
Manual UT A detailed sketch (Figure 1) of the limitation is included with the
scan plan. Wave modality used included shear.
Insonification angles included 45° shear (S) and 60°S.
A surface examination was performed and documented on examination report ISI-MT-06-039. 100% of the
required surface was examined.
No indications were recorded.
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Page 4 of 4 Figure 1 Scan Plan and Coverage for ISI Component 04-002 Not to Scale
Insulation Bracket Obstruction Not to Scale
45° NOZZLE C L 60° 45° 60° SHELL TDC 04-002 INSULATION BRACKET 100% 60° X 45° X 100% 100% 60° X 45° X 100%
Attachment 7 to 2CAN031203 Request for Relief ANO2-ISI-014 to 2CAN031203
Page 1 of 9 REQUEST FOR RELIEF ANO2-ISI-014 Components /
Numbers: See Table 1 Code Classes: American Society of Mechanical Engineers (ASME) Code Class 2
References:
ASME Section XI 1992 Edition, Table IWC-2500-1 ASME Section XI 1995 Edition with 1996 Addenda, for Ultrasonic Testing (UT) Examination ASME Code Case N-460 Examination Category:
C-F-1 Item Number(s)
C5.11; R1.20
==
Description:==
Pressure Retaining Welds in Austenitic Stainless Steel or High Alloy Piping - Inspection Program B Unit / Inspection Interval Applicability: Arkansas Nuclear One, Unit 2 (ANO-2) / Third (3rd) 10-Year Interval I. CODE REQUIREMENTS ASME Section XI, Table IWC-2500-1, Examination Category C-F-1, "Pressure Retaining Welds in Austenitic Stainless Steel or High Alloy Piping - Inspection Program B":
- 1) Item C5.11, as allowed by the Risk Informed process, requires a volumetric examination of circumferential piping welds Nominal Pipe Size (NPS) 4 or larger, as depicted in Figure IWC-2500-7 and Risk-Informed Inservice Inspection Evaluation Procedure, Electric Power Research Institute (EPRI) Report No.
TR-106706, Interim Report, June 1996.
- 2) Item R1.20 requires a volumetric examination of circumferential piping welds as depicted in Figure IWC-2500-7 and Risk-Informed Inservice Inspection Evaluation Procedure, EPRI Report No. TR-106706, Interim Report, June 1996.
ASME Code Case N-460 allows a reduction in coverage due to interference or geometry as long as the overall coverage is greater than 90%.
II. RELIEF REQUEST Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Op erations, Inc. (Entergy) requests relief from achieving the Code-required coverage when performing volumetric examinations of the components identified in Table 1 below.
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Page 2 of 9 III. BASIS FOR RELIEF During ultrasonic examination of the piping welds listed in Table 1 above, greater than 90% coverage of the required examination volume could not be obtained.
Class 2 piping and components are often designed with welded joints such as nozzle-to-pipe, pipe-to-valve and pipe-to-pump which can physically obstruct a large portion of the required examination volume. For examinations performed after the 10 CFR 50.55a mandatory implementation date for Appendix VIII of Section XI, and Code coverage percentages reflect what is currently allowed by qualified Appendix VIII techniques. Appendix VIII qualified Performance Demonstration Initiative (PDI) procedures have demonstrated that sound beams may potentially be attenuated and distorted when required to pass through austenitic weld metal. Still, the PDI qualified methods employ the best available technology for maximizing examination coverage of these types of welds. Examination was extended to the far side of the weld to the extent permitted by geometry, but this portion of the examination is not included in the reported coverage for welds examined under PDI and Appendix VIII rules.
These ultrasonic examinations have been performed over the course of the interval to varying code requirements and procedures. Entergy has used the best available and EPRI approved techniques to examine the subject piping welds. To improve upon these examination coverage percentages, modification and/or replacement of the component would be required. Consistent with the ASME Section XI sampling approach, examination of the subject welds, when combined with examinations that have been performed on other welds within the same Examination Category, is adequate to detect generic degradation, if it existed, demonstrating an acceptable level of integrity.
IV. PROPOSED ALTERNATIVE EXAMINATIONS No alternative testing is proposed at this time. Entergy has examined the subject items to the extent practical and will continue to perform pressure testing on the subject areas as required by the Code.
V. CONCLUSION 10 CFR 50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Entergy believes that it is impractical to obtain greater examination coverage on these areas. To obtain additional coverage would necessitate modification and/or replacement of the component. The examinations performed on the subject areas, in addition to the examination of similar welds contained in the program would detect generic degradation, to 2CAN031203
Page 3 of 9 if it existed, demonstrating an acceptable level of integrity. Therefore, Entergy requests the proposed relief be authorized pursuant to 10 CFR 50.55a(g)(6)(i). to 2CAN031203
Page 4 of 9 Table 1 Limited C-F-1 Examinations Component Description Additional Information Item Number Comp. ID Item Description Estimated % Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Examination Exam Results C5.11 61-025 Safety Injection Header Pipe-to-Valve Circumferential Weld 50 Single sided exam from the pipe side only due to the component configuration and geometry. See the attached sketch (Figure 1)
derived from ultrasonic test (UT) examination report 203ISIUT019 and 203ISIUT020 on file at ANO.
Manual UT A detailed sketch (Figure 1) of the limitation is included with the
scan plan Wave modality is shear and longitudinal.
Insonification angles included 45° Shear (S), 70°S and 60° Refracted Longitudinal (RL). None required.
Root geometry was recorded 360û. C5.11 66-014 Safety Injection Pipe-to-Flued
Head Penetration Circumferential Weld 50 Single sided exam from the pipe side only due to the component configuration and geometry. See the attached sketch (Figure 2) derived from UT examination report 203ISIUT017 and 203ISIUT018 on file at ANO.
Manual UT A detailed sketch (Figure 2) of the limitation is included with the scan plan. Wave modality is shear and longitudinal.
Insonification angles included 45°S, 70°S and 60°RL.
None required.
No indications were recorded.
R1.20 55-034A Safety Injection Weld-o-let-to-Pipe Circumferential Weld 50 Single sided exam from the pipe side only due to the component configuration and geometry. See the attached sketch (Figure 3) derived from UT examination report 203ISIUT005 and 203ISIUT006 on file at ANO.
Manual UT A detailed sketch (Figure 3) of the limitation is included with the scan plan. Wave modality is shear. Insonification angles included 45°S, 60°S
and 70°S.
None required.
Root geometry was recorded 360°. R1.20 55-043 Safety Injection Tee-to-Pipe
Circumferential Weld 50 Single sided exam from the pipe side only due to the component configuration and geometry. See the attached sketch (Figure 4) derived from UT examination report ISI-UT-06-031 on file at ANO.
Manual UT A detailed sketch (Figure 4) of the limitation is included with the
scan plan. Wave modality is shear. Insonification angles included 45°S, 60°S and 70°S.
None required.
No indications were recorded.
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Page 5 of 9 Table 1 (cont') Limited C-F-1 Examinations Component Description Additional Information Item Number Comp. ID Item Description Estimated % Coverage of Code Required Volume Examination Summary Scan Plan Exam Method and Limitations Search Units Surface Examination Exam Results R1.20 55-057 Safety Injection Pipe-to-Branch Connection Circumferential Weld 46 Single-sided exam from the pipe side only due to the component configuration. A unistrut contacting the pipe further limited the upstream scan. See the attached sketch (Figure 5) derived from UT examination report ISI-UT-06-030 on file at ANO.
Manual UT A detailed sketch (Figure 5) of the limitation is included with the
scan plan. Wave modality is shear. Insonification angles included 45°S and 70°S. None required.
No indications were recorded.
R1.20 61-002 Safety Injection Pipe-to-Valve Circumferential Weld 50 Single-sided exam from the pipe side only due to the component configuration
. See the attached sketch (Figure 6) derived from UT examination report ISI-UT-08-001 on file at ANO.
Manual UT A detailed sketch (Figure 6) of the limitation is included with the
scan plan. Wave modality is shear. Insonification angles included 45°S and
70°S. None required.
No indications were recorded.
R1.20 61-011 Safety Injection Pipe-to-Valve Circumferential Weld 50 Single-sided exam from the pipe side only due to the component configuration
. See the attached sketch (Figure 7) derived from UT examination report ISI-UT-08-027 on file at ANO.
Manual UT A detailed sketch (Figure 7) of the limitation is included with the scan plan. Wave modality is shear. Insonification angles included 45°S and
70°S. None required.
No indications were recorded.
R1.20 61-021 Safety Injection Pipe-to-Valve Circumferential Weld 79 Single-sided exam from the pipe side only due to the component configuration
. See the attached sketch (Figure 8) derived from UT examination report 200ISIUT014 on file at ANO.
Manual UT A detailed sketch (Figure 8) of the limitation is included with the scan plan. Wave modality is shear. Insonification angles included 45°S and 70°S. None required.
No indications were recorded.
R1.20 78-056 Containment Spray Elbow-to-
Pipe Circumferential Weld 84 Component was scanned from both sides; however scanning was limited due to lift off at the toes of the weld. See the attached sketch (Figure 9) derived from UT examination report 200ISIUT024 on file at ANO.
Manual UT A detailed sketch (Figure 9) of the limitation is included with the
scan plan. Wave modality is shear. Insonification angles included 45°S and 70°S. None required.
No indications were recorded.
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Page 6 of 9 Figure 1 Scan Plan and Coverage for ISI Component 61-025 Not to Scale
Figure 2 Scan Plan and Coverage for ISI Component 66-014 Not to Scale
45° 60° RL 70° Valve C L Pipe 45° 60° RL 70° Flow Flow Pipe Elbow 45° 60° RL 70° 45° 60° RL 70° C L to 2CAN031203
Page 7 of 9 Figure 3 Scan Plan and Coverage for ISI Component 55-034A Not to Scale
Figure 4 Scan Plan and Coverage for ISI Component 55-043 Not to Scale
PIPE C L 70°-60°-45° 70°-60°-45° FLOW WELD-O-LET PIPE FLOW TEE C L 45°/70° 45°/70° to 2CAN031203
Page 8 of 9 Figure 5 Scan Plan and Coverage for ISI Component 55-057 Not to Scale
Figure 6 Scan Plan and Coverage for ISI Component 61-002 Not to Scale
PIPE FLOW BRANCH CONNECTION C L 45/70 70° 45° 45/70 45° 70° PIPE FLOW 70° VALVE to 2CAN031203
Page 9 of 9 Figure 7 Scan Plan and Coverage for ISI Component 61-011 Not to Scale
Figure 8 Scan Plan and Coverage for ISI Component 61-021 Not to Scale
Figure 9 Scan Plan and Coverage for ISI Component 78-056 Not to Scale
PIPE FLOW 70° VALVE FLOW VALVE PIPE 70° 70° C L FLOW C L 70° 70° 70° 70° ELBOW PIPE