Text

Requests for Relief from American Society of Mechanical Engineers (ASME) Section XI Volumetric Examination Requirements Fourth 10-Year Interval, Second and Third Period
	ML18115A102
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/23/2018
From:	Pyle S; Entergy Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	1CAN041801
	Download: ML18115A102 (46)
	v • d • e

~ Entergy Entergy Operation s, Inc.

1448 S.R. 333 Ru ssellvill e, AR 72802 Tel 479-858-4704 Stephenie L. Pyle Manager, Regulatory Assurance Arkansas Nuclear On e 1CAN041801 April 23, 2018 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 Examination Requirements Fourth 10-Year Interval, Second and Third Period Arkansas Nuclear One , Unit 1 Docket No. 50-313 License No. DPR-51

REFERENCES:

(1) Entergy letter to NRC, "Request for Relief from American Society of Mechanical Engineers (ASME) Section XI Volumetric Examination Requirements Fourth 10-Year Interval, First Period ," dated July 25, 2012 (1CAN071202} (ML12207A594)

(2) NRC letter to Entergy, "Arkansas Nuclear One, Unit 1 - Request for Relief AN01-1Sl-022 From ASME Code , Section XI Volumetric Examination Requirements for the Fourth 10-year lnservice Inspection Interval, First Period ," dated July 24, 2013 (1 CNA071304}

(ML13179A116)

Dear Sir or Madam:

Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from the requirements of the ASME, Boiler and Pressure Vessel Code, Section XI pertaining to volumetric examinations at Arkansas Nuclear One, Unit 1 (AN0-1) . In several locations it was determined that the examinations were impractical due to interference or geometry. Individual relief requests are provided in the attachments, sorted by examination category.

10 CFR 50.55a(g)(5)(iii) requires that the basis for the determination of impracticality be submitted to the NRC for review and approval within 12 months after the expiration of the 120-month inspection interval. These requests are for the fourth AN0-1 10-year lnservice Inspection interval , second and third period. The second period started on May 31 , 2011. The third period and the fourth 10-year interval ended May 30, 2017. ,4 b i.f 1

1CAN041801 Page 2 of 2 Reference 1 provides the relief request for the first period of the fourth 10-year interval. The NRC's Safety Evaluation for that request is provided in Reference 2.

There are no new regulatory commitments made in this submittal.

If you have any questions or require additional information, please contact me.

Sin~(;,)

SLP/rwc Attachments:

1. Request for Relief - AN01-ISl-027

2. Request for Relief - AN01-ISl-028

3. Request for Relief - AN01-ISl-029

4. Request for Relief - AN01-ISl-030

5. Request for Relief-AN01-ISl-031 cc: Mr. Kriss Kennedy 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. Thomas Wengert MS 0-08B1A One White Flint North 11555 Rockville Pike Rockville, MD 20852

Attachment 1 to 1CAN041801 Request for Relief AN01-IS1-027 to 1CAN041801 Page 1 of 11 REQUEST FOR RELIEF AN01-1Sl-027 Components I Lower shell to transition piece circumferential weld/ ISi #01 -005 Numbers:

Transition piece to bottom head circumferential weld/ ISi #01-006 Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1

References:

ASME Section XI 2001 Edition w/ 2003 Addenda, Table IWB-2500-1 Code Case N-460 Examination Category: B-A Item Number(s) B1.11 andB1 .21

==

Description:==

Pressure Retaining Welds in Reactor Vessel - Inspection Program B Unit/ Inspection Arkansas Nuclear One, Unit 1 (AN0-1) / Fourth (4th) 10-Year Interval Applicability: Interval , Third (3rd) Inspection Period I. CODE REQUIREMENTS ASME Section XI, Table IWB-2500-1, Examination Category B-A, "Pressure Retaining Welds in Reaotor Vessels":

Item B1 .11, Lower Shell to Transition Piece weld, requires a volumetric examination of the circumferential weld as depicted in Figure IWB-2500-1.

Item B1 .21 , Transition Piece to Lower Head weld , requires a volumetric examination of Reactor Vessel Head Circumferential Weld volume, as depicted in Figure IWB-2500-3.

II. RELIEF REQUEST Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving the code required coverage when performing volumetric examinations of the components identified in Table 1.

Ill. BASIS FOR RELIEF During the AN0-1 twenty-sixth refueling outage (1 R26) Fall 2016, the reactor pressure vessel welds were examined in compliance with the requirements of the ASME Code Section XI Table IWB-2500-1 Examination Category B-A. Greater than 90% coverage of the required examination volumes could not be obtained.

to 1CAN041801 Page 2 of 11 The ultrasonic examination procedures utilized were qualified in accordance with Mandatory Appendix VIII , Supplements 4 & 6 through the performance demonstration initiative (POI) process conducted at the Electric Power Research Institute (EPRI).

Examination of ISi #01-005 was limited due to the core support lugs and flow diverters on the bottom head of the RPV. The perpendicular and parallel coverage scans were limited due to geometrical interference of the lugs and flow diverters. A combination of 45° shear, 45° longitudinal, and 45° dual longitudinal search units were employed in the clockwise (CW) , counter clock wise (CCW) , Up and down (Own) directions on all accessible scan surfaces.

Examination of the required weld volume of ISi #01-006 was limited due to twelve {12) flow diverters and the Bottom Mounted Instrumentation (BMI) tubes located on the bottom head of the RPV. The perpendicular and parallel coverage scans were limited due to geometrical interference of the flow diverters and BMI tubes. A combination of 45° shear, 45° longitudinal, and 45° dual longitudinal search units were employed in the CW, CCW , Up and Own directions on all accessible scan surfaces.

Radiographic examination as an alternative to ultrasonic examination is not practical.

The geometry of the components prevent proper placement of the film and exposure source as well as the existing high radiation field in which these components are located preclude radiography as an alternative to ultrasonic examination. To perform the code required examination would require modifying and/or replacing the flow diverters. The examinations performed on the subject items, in addition to the examination of the other reactor vessel welds, would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. '

Entergy filed a similar relief request (AN01-ISl-015) for the limited weld examinations during the third ISi interval of these two welds. The NRC approved that relief request in letter dated May 5, 2010. (ML101170119).

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 ASME Section XI 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.

to 1CAN041801 Page 3 of 11 Entergy believes that it is impractical to obtain greater examination coverage on these welds. To effectively obtain sign ificant additional coverage would necessitate modification and/or replacement of the component. The examinations performed on th e 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 1CAN041801 Page 4 of 11 Table 1 Limited B-A Examinations Component Description Additional Information Estimated%

Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume 81 .11 01*005 Reactor Vessel 71.12 Examination of the required volume as See the attached Automated UT Wave modalities None No Lower Shell to depicted in Fig. IWB-2500*1 was sketch (Fi gure 2) Scan path are longitudinal and required . indications Lower Head weld limited due to the component derived from limitation due to shear. were configuration. ultrasonic testing the configuration lnsonification observed or (UT) examination of th e angles include 45°. recorded .

reports 1*ISi-VE* component. (See Acceptable 16-015 on file at Figure 1 and ANO. Figure 3) 81 .21 01*006 Reactor Vessel 68.90 Examination of the required volume as See the attached Automated UT Wave modalities None Two Bottom Head depicted in Fig. IWB-2500* 1 was sketch (Figure 5) Scan path are longitudinal and required . Indications weld limited due to the component derived from limitation due to shear. were configuration. ultrasonic testing observed

. (UT) examination the configuration of the lnsonification angles incl ude 45°. and reports 1*ISl*VE* component. (See recorded.

16*016 on file at Figure 4 and Acceptable ANO. Figure 6) per IWB*

3510*1 (See Figure 7) to 1CAN041801 Page 5 of 11 Figure 1 Reactor Vessel Rollout for Component 01-005 Not to Scale

\I I

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(0 1-015>

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<01-0IOM

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11 9 (01 -010) (01 -009 CORC SUPPORT LUtiS

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115 (01 - 006)

..J.I...-...JU..--U......,..LU...-,.-U...-.-:J..'""!-.11..""""i~ .i...-~.u..-~....,- ~+-:JOBJe ARKANSAS NUCLEAR ONE UNIT 1 - CBARKD 2016 EXAM ! AT !ON PROGRAM PLA VESS EL RD LL OUT j 1./ESDYNE 1:.::-:.::::: 11 OF 22 I to 1CAN041801 Page 6 of 11 Figure 2 Scan Plan for Component 01-005 Not to Scale Note,

1. Per*'f'Or"M scans bet ween tugs f irst then expand scons below lugs to noxil""liZe coverage.

8.4 4 2 . Sl ed roto. tions will vo.ry between *Re ver se* o.ncl

s to.nclnrd*

.19 roto.t ion a.round the lugs . Vef' if y with the robot operator who. t roto. tion the sled is o t f'or ea.ch sco.n.

,____ 85.5 R to clod

3. Scans below the 1... gs, Perp Un its , +/- 3.1' froM 1.,g l Paroll el liMits, + / - 5.0' froM ll.<g l 303.1 8 308 .38 (7 9 .12' ) - - - ---l-t--\/llll~ :::-

312.02 ~ ~ - - - - 311. 15 <77.25") Top Perpendiculo.r ond Po.ro.lle l Below L ugs

- - - - - - 313 .77 ( 75.48') Bot toM Perpendiculo.r ond Po.ro.l l e l

- - -- 3 19.50 <71.55") BottoM Per pendicul ar Below Lugs WORKING POINT SUPREEM SCAN INCREMENT 29 1.9 4" PERP. AND PAR . SCANS = 0.5' SURF AC E INDEX PARAGON SCAN INCREMENT PERP. AND PAR. SCANS BELO\./ LUGS = - 0.329"

<US JNG HEAD RADIUS OF 87 .06' )

V PERP. SCANS BET\./EEN LUGS = 0.335" ARKANSAS NUC LEAR ONE

<USING VESSEL RADIUS OF 85 .5')

PAR. SCANS BE T\./EEN LUGS = 0.5' UNIT 1 - <BAR KD C.ll.Cll.A TUJN [f'"

BOTTOM OM TCP POSITl°'S 2016 EXAMINA TION PROGRAM PLAN LOVER SHELL TO TRANSITION P!ECE VELD Po.rc ll

t Sco.n Lr.its 1, /- 5.o* Elthf'!"' Sicl* or Co,-* GI.lid* LtJQS ID* 01-005 <V4)

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Guide Lvgs locc.tl!'d at o* .30 *,60 *,90* ,120*.1so*.te0°.2I0* ,2"0*270*,300*,c.nd 330* I \./E SDYNE 1:.:-:.:: 121 OF 221 to 1CAN041801 Page 7 of 11 Figure 3 Coverage Calculation for Component 01-005 Not to Scale Arkansas Nuclear One Unit 1 DIRECTION/ ORIENTATION RPV COVERAGE ESTIMATE BREAKDOWNS PARALLEL SCANS CCW/CW PERP. SCANS UP/ON WELD WELD NO. Lower Shell to Transition Piece Weld 01-005 (W4) DESCRIPTION BEAM ANGLES 45° Dual 45° Single 45° Shear Total BEAM DIRECTION EXAM VOLUME EXAM VOLUME EXAM VOLUME CCW/CW 26.85 9.98 29.32 66.15 UP/ON 24.32 13.24 38.54 76.10 UT COVERAGE = 71.12 % Combination of dual sided and single sided coverage. Coverages weighted to reflect relative coverage area of each type of probe. See exam volume EPP sketch sheet 21 of 22 Limitations: Core Support Lugs and Flow Diverters to 1CAN041801 Page 8 of 11 Figure 4 Reactor Vessel Rollout for Component 01-006 Not to Scale 1.'I (01- 001) <<:11-r. )) ,.oo (0 1-002> '."r....==d.:~~/fo==1---97.00 lolN)O \INIS0 l.'N90 WN270 (01 - 012) (01 - 011) <01 - 01 8 > {01-016) <0 1-015) 1J3 (01--003) 1,19 \,I ] (01- 008 (01-007) <01 -0IOA> .. 'w'eld Re p o. l,. lol6 (01-00<> ~-- --------....IL...-------- ---------.....--r----i-e*JS.19 l,IJ Q 1,19 (01 - 010) <Ol-009 CORE SUPPORT LUG S Cot-OOS> F"L OIJ DIV[ RTE RS ARKANSA S NUCLE AR ONE UNIT 1 - <BAR K!) 201 6 EX AM INAT ION PROGRA M PLA V ESS EL RDLLOU T I \./E SDYNE 1::.:::.:::::: 11 OF 2 2) to 1CAN041801 Page 9 of 11 Figure 5 Scan Plan for Component 01-006 Not to Scale 291.94 \JORKING POINT / / Caution : Vis1.,1ally COl"lf irM sa.tety / nargin with obstruct iof"ls o. t / upper anci l ower sco.n boundr ie s To MaxiMize sc o.n coverage t:he s l ed nay be rota tecl. See robot scan plan for aff'ecteci 58.78" scans. PERPENDICULAR 51.49 " BOTTOM PARALLEL 51.22" BOTTOM PERPEND ICULAR 55.00' \Jelci C L( ?l.3 15 SUPREEM SCAN lNCR*MENT Perp and paralle l SCOr"IS .: 0.5* Surf'a.ce index. PARAGON SCAN INCREMENT Parallel scans = -0.329" <using botton heo.ci raciil.lS of 87.06' . Perp scans = 0.401" (C1S ing radius at wel cl cen,er line of' 71.315' . ARKANSAS NUCLEAR ONE UNIT 1 - <BARKD 20 16 EXAMINATION PROGRAM PLAN TRANSITION PI ECE TO LO\J ER HEAD \JELD JD, 01 - 006 (\J5) I w'ESDYNE 1::.:-:::.:::122 OF 28 to 1CAN041801 Page 1O of 11 Figure 6 Coverage Calculation f or Component 01-006 Not to Scale Arkansas Nuclear One Unit 1 DIRECTION I ORIENTATION RPV COVERAGE ESTIMATE BREAKDOWNS PARALLEL SCANS CCW/CW PERP. SCANS UP/ON WELD WELD NO. Transition Piece to Lower Head Weld 01-006 (W5) DESCRIPTION BEAM ANGLES 45° Dual 45° Single 45° Shear Total BEAM DIRECTION EXAM VOLUME EXAM VOLUME EXAM VOLUME CCW/CW 29.87 7..93 29.70 67.50 UP/ON 33 .34 6.35 30.62 70.31 UT COVERAGE = 68.90 % Combination of dual sided and single sided coverage . Coverages weighted to reflect relative coverage area of each type of probe. See exam volume EPP sketch sheet 22 of 22 limitations: Flow Diverters and Bottom Mounted Instruments to 1CAN04 1801 Page 11 of 11 Figure 7 Indication Assessment for Component 01-006 Not to Scale PLANT ANO UNIT 1 ............ Yllii PROCEDURE PDI-ISl-254 REV. 7 INDICATION ASSESSMENT ANALYST ~ ---:?;/- LEVEL Ill DATE 10/14/16

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NOTES (1) Allowable Per ASME XI 2001 Edition through the 2003 Addenda: IWB-35 10-1 Calibration Data Sheet No. LS1 -LS8 & LS5A-7A (2) Reported during 1R21 outage as lndicaiton # 1 Acquisition Log Sheet No. W5 -1

Procedure defa ult throughwall size used Ana lysis Log Sheet No. WS-1

Attachment 2 to 1CAN041801 Request for Relief AN01-1Sl-028 to 1CAN041801 Page 1 of 6 REQUEST FOR RELIEF AN01-ISl-028 Components I Steam Generator E-24A Lower Head to Lower Ring Head Weld/ 03-Numbers: 102 Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1

References:

ASME Section XI 2001 Edition w/ 2003 Addenda, Table IWB-2500-1 Code Case N-460 Examination Category: B-B Item Number(s) B2.31

==

Description:==

Pressure Retaining Welds in Vessels other than Reactor Vessels -

Inspection Program B Unit/ Inspection Arkansas Nuclear One, Unit 1 (AN0-1) / Fourth (4th) 10-Year Interval Applicability: Interval , Second (2nd) Inspection Period I. CODE REQUIREMENTS ASME Section XI , Table IWB-2500-1 , Examination Category B-B, "Pressure Retaining Welds in Vessels other than Reactor Vessels":

Item B2.310 requires a volumetric examination of steam generator circumferential head weld volume, as depicted in Figure IWB-2500-3.

II. RELIEF REQUEST Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving the Code-required coverage when performing volumetric examinations of the components identified in Table 1.

Ill. BASIS FOR RELIEF During ultrasonic examination of the non-Appendix VIII Steam Generator Circumferential weld listed in Table 1, greater than 90% coverage of the required examination volume could not be obtained. Examinations were performed utilizing Entergy approved procedures specific to ferritic vessels greater than 2 inches in thickness.

Due to the geometric configuration of the components, effective volumetric examination could only be performed from the shell side of the weld. The use of o*, 35°, and 45*

beam angles in the axial and circumferential direction were not able to achieve greater than 90% code required volume as required by Code Case N-460. See Table 1 for additional information.

to 1CAN041801 Page 2 of 6 Radiography is not practical on this type of head circumferential weld configuration, 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 lnservice Inspection program would detect generic degradation, if it existed, therefore 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 .

The limitations on this weld on the "A" steam generator would be the same as on the weld in this category on the "B" steam genertor. Based on this there are no alternative welds to examine.

V. CONCLUSION 10 CFR 50.55a(g)(6)(i) ~tates:

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 1CAN041801 Page 3 of 6 Table 1 Limited B-B Examinations Component Description Additional Information Estimated%

Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume B2.31 03-102 Steam Generator 73.7 This is essentially a single sided exam See the attached Manual UT Wave modalities None No E*24A Lower from the vessel shell surface due to sketch (Figure 1) Scan path are longitudinal and required. indications head to lower the component configuration. derived from limitation due to shear. we re ring weld Examination of the required volume as ultrasonic testing the configuration Insonification obseNed or depicted in Fig. IWB-2500-3 was (UT) examination of the angles included 0°, recorded .

limited due to the component reports HSI-UT- component. (See 35°, and 45°. Acceptable configuration . Both the lower ring and 11-012 and 1-ISI- Figures 1,2,3) head are carbon steel with stainless UT-11-013 on file steel cladding on the inside surface. at ANO.

to 1CAN041801 Page 4 of 6 Figure 1 Scan Plan and Coverage for Component 03-102 Not to Scale A External CL T T B Lower Head Lower Ring (vessel) 45° C Internal Diameter - 135" No Axial Scan Coverage Weld CL Thickness - 8.2" 50% Scan Coverage . Weld Width - 3" (T-T)

Circ Scan Coverage obtained - 61.6%

100% Scan Coverage Axial Scan Coverage -

45°8ase Metal& Weld:83.7% 35° Base Metal & Weld= 87.9%

Required Exam Volume Total Axial Coverage obtained= (83.7 + 87.9) / 2 = 85.8%

Total Code coverage obtained=

(61.6% Circ + 85.8% Ax)/ 2 = 73.7%

to 1CAN041801 Page 5 of 6 Figure 2 Photo for Component 03-102 Not to Scale to 1CAN041801 Page 6 of 6 Figure 3 Sketch for Component 03-102 Not fo Scale

~ 1 03-102

Attachment 3 to 1CAN041801 Request for Reli ef AN01-1Sl-029 to 1CAN041801 Page 1 of 8 REQUEST FOR RELIEF AN01-ISl-029 Components I Pressurizer Relief Nozzle Welds/ 05-014,05-015, and 05-021 Numbers:

Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1

References:

ASME Section XI 2001 Edition w/ 2003 Addenda, Table IWB-2500-1 Code Case N-460 Examination Category: B-D Item Number(s) B3.110

==

Description:==

Full Penetration Welded Nozzles in Vessels - Inspection Program B Unit/ Inspection Arkansas Nuclear One, Unit 1 (AN0-1) / Fourth (4th) 10-Year Interval Applicability: Interval, Second (2nd) and Third (3nd) Inspection Period I. CODE REQUIREMENTS ASME Section XI , Table IWB-2500-1 , Examination Category B-D, "Full Penetration Welded Nozzles in Vessels - lnspectio~ Program B":

Item B3.110 requires a volumetric examination of Pressurizer Nozzle-to-Vessel Weld volume , as depicted in Figures IWB-2500-?(a) through (d) , as applicable.

II. RELIEF REQUEST Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving the Code-required coverage when performing volumetric examinations of the components identified in Table 1.

Ill. BASIS FOR RELIEF During ultrasonic examination of the non-Appendix VIII Pressurizer and Steam Generator Nozzle-to-Vessel welds listed in Table 1, greater than 90% coverage of the required examination volume could not be obtained. Examinations were performed utilizing Entergy approved procedures specific to ferritic vessels greater than 2 inches in thickness.

Due to the geometric configuration welds05-014 and 05-015 , located in the intersection (crotch area) of the pressurizer head and relief nozzles, the use of o*, 45 ' , 60° and 70' shear transducers in the axial direction and 60° shear in the circumferential direction were not able to achieve greater than 90% of the code required volume as required by Code Case N-460. See Table 1 for additional information.

to 1CAN041801 Page 2 of 8 Due to the outside diameter geometric configuration of weld 05-021, which is located in the crotch area between the pressurizer vessel head and the nozzle, the multi-angle code required coverage is very limited. Scanning was performed from both the head and nozzle bore, where accessible, with 45°, 60°, and 70° shear transducers. No circumferential scan coverage was achievable due to the component configuration.

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 lnservice Inspection program would detect generic degradation, if it existed, therefore 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.

These three welds are the only welds in this category. There are no alternative welds to be examined.

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 1CAN041801 Page 3 of 8 Table 1 Limited B-D Examinations Component Description Additional Information Estimated%

Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume B3.110 05-014 Pressurizer 50.75 This is essentially a single sided exam See the attached Manual UT Wave modalities None No (PZR) Relief from the vessel surface due to the sketch (Figure 1) Effective are longitudinal and required . indications Nozzle between W-X axis component configuration however partial coverage was obtained from

. derived from ultrasonic testing volumetric examination shear.

lnsonification recorded .

Acceptable the nozzle side. Examination of the (UT) examination could be angles included 0°,

required volume as depicted in Fig. report 1-ISI-UT obtained from 45°, 60° and 70°.

IWB-2500-7 (a) was limited due to the 021 on file at ANO. both the component configuration and pressurizer head surrounding interferences on the head . and nozzle Both the nozzle and head are carbon surfaces (Figure steel with stainless steel cladding on 1, 2, and 3).

the inside surface.

B3.110 05-015 Pressurizer 50.75 This is essentially a single sided exam See the attached Manual UT Wave modalities None Intermittent (PZR) Rel ief from the vessel surface due to the sketch (Figure 1) Effective are longitudinal and required . geometric Nozzle between component configuration however derived from UT volumetric shear. indications at Z-W axis partial coverage was obtained from examination report examination Insonification the nozzle the nozzle side. Examination of the 1-ISI-UT-11-022 on could be angles included 0°, bore were required volume as depicted in Fig. file at ANO. obtained from 45°,60° and 70°. observed IWB-2500-7 (a) was limited due to the both the and component configuration and pressurizer head recorded.

surrounding interferences on the head . and nozzle Acceptable Both the nozzle and head are carbon surfaces (Figure steel with stainless steel cladding on 1, 2, and 3).

the inside surface.

B3.110 05-021 Pressurizer 27.1 This is essentially a single sided exam See the attached Manual UT Wave modalities None No (PZR) Surge from the vessel surface due to the sketch (Figure 4) Effective are longitudinal and required . indications Nozzle to Head component configuration however derived from UT volumetric shear. recorded .

Weld partial coverage was obtained from examination report examination lnsonification Acceptable the nozzle side. Examination of the 1-ISI-UT-16-048 on could be angles included 0°,

required volume as depicted in Fig. file at ANO. obtained from 45°, and 60°.

IWB-2500-7 (a) was limited due to the . the pressurizer component configuration. head surface.

(Figure 4 and 5)

Attachme nt 3 to 1CAN041801 Page 4 of 8 Figure 1 Scan Plan and Coverage for Components05-014 & 05-015 Not to Scale 45°

~ 70° 0

45° fWJ No Scan Coverage

~ 50% Scan Coverage D 100% Scan Coverage Base Material 1(BM1)- 2 beam angles, 1 direction= 98,5% Achieved Base Material 2(BM2) - 2 beam angles, 1 direction = 18.26% Achieved Weld Material(W) - 2 beam angles, 2 directions = 35.5% Achieved Total Code required volume achieved= 98.5+18.26+35.5 =152.26 +3 = 50.75%

to 1CAN041801 Page 5 of 8 Figure 2 Sketch for Components05-014 & 05-015 Not to Scale 05-014 -0 05-015 to 1CAN041801 Page 6 of 8 Figure 3 Photo for Components05-014 & 05-015 Not to Scale to 1CAN041801 Pag e 7 of 8 Figure 4 Scan Plan and Coverage for Component 05-021 Not to Scale 45° D

BM

............. ;.*.*.*!*:**=*=**=******* ** ******* ******-*:**************

E No Scan Coverage 50% Scan Coverage [Base Metal = one angle/ Weld Metal =two angles one direction (no circ scan coverage)]

100% Scan Coverage Base Material (BM) - 2 beam angles, 1 direction = 39.9% Achieved Weld Material (W)- 2 beam angles, 2 directions = 14.26% Achieved Total Code required volume achieved= 39.9 + 14.26 -:-2 = 27.1%

to 1CAN04 1801 Page 8 of 8 Figure 5 Photo for Component 05-021 Not to Scale

Attachment 4 1CAN041801 Request for Relief AN01-1Sl-030 to 1CAN041801 Page 1 of 6 Request for Relief AN01-ISl-030 Components / Numbers: See Table 1 Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1

References:

ASME Section XI 2001 Edition w/ 2003 Addenda, Table IWB-2500-1 ASME Code Case N-460 Examination Category: B-G-1 Item Number(s) B6.40

==

Description:==

Pressure Retaining Bolting, Greater than 2 in . In Diameter Unit/ Inspection Interval Arkansas Nuclear One, Unit 1 (AN0-1) / Fourth (41h) 10-Year Applicability: Interval, Third (3rd) Inspection Period I. CODE REQUIREMENTS ASME Section XI, Table IWB-2500-1, Examination Category B-G-1, "Pressure Retaining Bolting, Greater Than 2 in. In Diameter", Item B6.40 requires a volumetric examination of the threads in the reactor vessel flange.

II. RELIEF REQUEST Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving the Code-required coverage when performing volumetric examinations of the components identified in Table 1 below.

Ill. BASIS FOR RELIEF The threads in the reactor vessel flange were examined to comply with the examination requirements of the ASME Section XI Code. During ultrasonic examination of the non-Appendix VIII RPV Threads in Flange listed in Table 1, greater than 90% coverage of the required examination volume could not be obtained. Examinations were performed utilizing Entergy approved procedures specific to the application.

Radiography is not practical due to the component configuration, which prevents effective placement of the film and exposure source. To perform any additional Code allowable ultrasonic examination, modification and/or replacement of the component would be required. The examination of 58.61 % of the required volume of the subject Items would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity.

to 1CAN041801 Page 2 of 6 Entergy filed a similar relief request (AN01-ISl-017) for the limited weld examinations during the third ISi interval of these two welds. The NRG approved that relief request in letter dated May 5, 201 O. (ML101170119).

IV. PROPOSED ALTERNATIVE EXAMINATIONS 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 ASME Section XI code.

This is the only weld in this category; therefore there are no alternative examinations that could be performed.

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 components contained in the program would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity. Therefore, Entergy requests the proposed alternative be authorized pursuant to 10 CFR 50.55a(g)(6)(i).

to 1CAN041801 Page 3 of 6 Table 1 Limited B-G-1 Examinations Component Description Additional Information Estimated %

Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume B6.40 01-F-01 Threads in 58.61 % Examination of the required volume as See the attached Manual UT Wave modalities None No through Reactor Vessel depicted in Fig. IWB-2500-12 was sketch (Figure 2) Limited due to are longitudinal. required. indications 01-F-60 Flange limited due to the component derived from Seal Surface lnsonification were configuration. ultrasonic testing and hole plugs angles included a observed or (UT) examination (Figures 1, 2, 7.5°. recorded.

reports 1-ISI-VE- and 3) Acceptabl e 16-043, 1-ISI-VE-16-044, and 1-ISI-VE-16-045 on file at ANO.

to 1CAN041801 Page 4 of 6 Figure 1 Sketch for Component 01-F-01 through 01-F-60 Not to Scale Stainless Steel Surface

/ '------'

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1. 00 MANUA L THRc- ~.DS LA GE 1 HRU 60 Figure 2 to 1CAN041801 Page 5 of 6 Scan Plan for Component 01-F-01 through 01-F-60 Not to Scale Rx Vessel ID Sta inless Steel Surface See Figure 1

\\\

256.90" Stud Hole Plug

§ I

Rx Vessel Flange OD to 1CAN041801 Page 6 of 6 Figure 3 Scan Plan for Component 01-F-01 through 01-F-60 Not to Scale Arkansas Nuclear One Unit 1 DIRECTION / ORIENTATION RPV COVERAGE ESTIMATE BREAKDOWN Radial Scan CCW / CW WELD WELD NO.

DESCRIPTION Threads in Flange 01-F-01 thru 01-F-60 BEAM ANGLES 7.5° BEAM DIRECTION EXAM VOLUME EXAM VOLUME EXAM VOLUME EXAM VOLUME EXAM VOLUME CCW/CW 58.61 Limitation : 103.10° Radially around the circumference of the stud holes was limited due to the stainless steel seal surface configuration .

7.27 in2 of the total exam area (8.85 in2 ) was covered for 256.90° around the stud holes.

=

7.27 I 8.85 0.8214 (82.14%)

=

256.9 I 360 0.7136 (71 .36%)

=

0.8214

0.7136*100 58 .61%

Stud holes were scanned on the stainless steel seal surface while monitoring threads responses. No coverage credit is being claimed for the stainless steel seal surface examination.

UT COVERAGE= 58.61%

See exam volume EPP sltetcll 51-t 15 of 22

Attachment 5 to 1CAN041801 Request for Relief AN01-IS1-031 to 1CAN041801 Page 1 of 8 Request for Relief AN01-ISl-031 Components I See Table 1 Numbers:

Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1

References:

ASME Section XI 2001 Edition w/ 2003 Addenda ,

ASME Code Case N-716-1 ASME Code Case N-460 Examination Category: R-A Item Number(s} R1.11, R1 .20

==

Description:==

Risk Informed Piping Welds Unit/ Inspection Arkansas Nuclear One, Unit 1 (AN0-1) / Fourth (4th) 10-Year Interval Applicability: Interval, Second (2nd) Inspection Period I. CODE REQUIREMENTS ASME Section XI , Code Case N-716-1 , Examination Category R-A "Risk Informed Piping Welds":

Item R1 .11 (Elements Subject to Thermal Fatigue)

Item R1 .20 (Elements Not Subject to a Damage Mechanism) require a volumetric examination of risk informed piping weld volume.

II. RELIEF REQUEST Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving the Code-required coverage when performing volumetric examinations of the components identified in Table 1.

Ill. BASIS FOR RELIEF During ultrasonic examination of these Appendix VIII piping welds listed in Table 1, greater than 90% coverage of the required examination volume could not be obtained.

Examinations were performed utilizing EPRI qualified Appendix VIII, Supplement 2 procedures specific to wrought austenitic piping welds .

Due to the geometric configuration and material type of the components, effective volumetric examination could only be performed as noted in the Table 1 for each weld.

to 1CAN041801 Page 2 of 8 Although lnsonification was extended to the far side of the welds to the extent practical, this portion of the examination is not included in the reported exam coverage per the POI and Appendix VIII rules . The use of 45 ' , 60° and 70' beam angles in the axial and circumferential direction were not able to achieve greater than 90% code required volume as required by Code Case N-460. See Table 1 for specfic information .

Entergy has used the best available and EPRI approved techniques to examine the subject piping welds. 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 piping welds contained in the lnservice Inspection program would detect generic degradation, if it existed, therefore 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) .

Attachment 5 to 1CAN041801 Page 3 of 8 Table 1 Limited R-A Examinations Component Description Additional Information Estimated%

Item Comp. Item Coverage of Exam Method Surface Exam Examination Summary Scan Plan Search Units Number ID Description Code Required and Limitations Examination Results Volume R1 .11 23-057 Elbow to Pipe 88.9 This is a dual sided exam with a single See the attached Manual UT Wave modalities None No Gire Seam sided limitation for approximately 2.8

sketch (Figure 1) Scan path are shear. required. indications inches along the length of the weld derived from limitation due to lnsonification recorded .

due to the adjacent weld-o-let. ultrasonic testing the configuration angles included 45° Acceptable Examination of the required volume as (UT) examination of adjacent weld- and 70° depicted in Fig. IWG-2500-8 (c) was report 1-ISI-UT o-let. (See limited due to the component 002 on file at ANO. Figure 1 and 3) .

configuration. Both the Elbow and Pipe are stainless steel.

R1 .1 1 23-059 Pipe to Elbow 88.9 This is a dual sided exam with a single See the attached Manual UT Wave modalities None No Gire Seam sided limitation for approximately 2.8 sketch (Figure 2) Scan path are shear. required. indications inches along the length of the weld derived from UT limitation due to lnsonification recorded.

due to the adjacent weld-o-let. examination report the configuration angles included 45° Acceptable Examination of the required volume as 1-ISI-UT-11-003 on of adjacent weld- and 70° depicted in Fig. IWG-2500-8 (c) was file at ANO. o-let. (See limited due to the component Figure 2 and 3).

configuration. Both the Elbow and Pipe are stainless steel.

R1 .20 12-001 Safe End to 50 This is essentially a single sided exam See the attached Manual UT Wave modalities None No Pump Gire Seam from the safe end side due to the sketch (Figure 4) Scan path are longitudinal and required. indications component configuration. derived from UT limitation due to shear. recorded.

Examination of the required volume as examination report the configuration lnsonification Acceptable depicted in Fig . IWB-2500-8 (c) was 1-ISI-UT-13-024 on of Pipe to Pump. angles included 45° limited due to the component file at ANO. (See Figure 4 and 60° configu ration . Both the safe end and and 5) .

pump are stainless steel.

to 1CAN041801 Page 4 of 8 Figure 1 Scan Plan and Coverage of limited area for Component 23-057 Not to Scale Weld-o-let Elbow 45° Pipe HI Hd I ,

Pipe I

2.8" Elbow l

~ No Scan Coverage Diameter= 2.5" Circumference = 9.25" Thickness = 0.375" Axial Scan Coverage Obtained= 84.89%

Circ Scan Coverage Obtained = 92.87%

Total CRV Achieved= 84.89 + 92.87 = 177.76/2 = 88.9%

Attachm ent 5 to 1CAN041801 Page 5 of 8 Figure 2 Scan Plan and Coverage of limited area for Component 23-059 Not to Scale Weld-a-le

~ . . . ,_ _.: C...

L --,,.~7.:.o --'""'!

0 ... 4~

50- - - -E-lb_o_w_

Pipe \ d ** /

~ 11--f D ftC /

Pipe r

2.8" Elbow 1

t I

I

No Scan Cove rage! Diameter = 2.5 " Circumference = 9.25" Thickness = 0.375" Axial Scan Coverage Obtained = 84.89%

Circ Scan Coverage Obtained = 92.87%

Total CRV Achieved= 84.89 + 92.87 = 177.76/2 = 88.9%

to 1CAN041801 Page 6 of 8 Figure 3 Photo of limited area for Component 23-057 and 23-059 Not to Scale

Attach ment 5 to 1CAN041801 Page 7 of 8 Figure 4 Scan Plan and Coverage for Component 12-001 Not to Scale Pu m p Pi pe

~

' : :l ---.--. 45°S 60°R L 45°S

/

,/'/

/

I t

I' I

I /

I No Scan Covera ge 100% Sca n Coverage Total CRV Achieved = 50%

to 1CAN041801 Page 8 of 8 Figure 5 Photo for Component 12-001 Not to Scale

~ Entergy Entergy Operation s, Inc.