W3F1-2018-0065, Request for Relief from ASME Section XI Volumetric Examination Requirements - Third 10-Year Interval, W3-ISI-032

Request for Relief from ASME Section XI Volumetric Examination Requirements - Third 10-Year Interval, W3-ISI-032

ML18334A219
Person / Time
Site:	Waterford
Issue date:	11/30/2018
From:	Halter M Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3-ISI-032, W3F1-2018-0065
Download: ML18334A219 (97)

Text

Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5573 Mandy K. Halter Director, Nuclear Licensing 10 CFR 50.55a W3F1-2018-0065 November 30, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Request for Relief from ASME Section XI Volumetric Examination Requirements - Third 10-Year Interval, W3-ISI-032 Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382 Facility Operating License No. NPF-38

Reference:

U. S. Nuclear Regulatory Commission (NRC) letter to Entergy Operations, Inc.

(EOI) "Waterford Steam Electric Station, Unit 3 - Request for Relief Nos.

WF3-ISI-007, WF3-ISI-008, WF3-ISI-009, WF3-ISI-010, WF3-ISI-011, WF3-ISI-012, WF3-ISI-013, and WF3-ISI-014 from ASME Code, Section XI, Examination Requirements for Second 10-year Inservice Inspection Interval (TAC Nos. ME1426, ME1427, ME1428, ME1429, ME1430, ME1431, ME1432, AND ME1433)," dated June 30, 2010 (ADAMS Accession Number ML101590574)

Pursuant to 10 CFR 50.55a, "Codes and Standards," paragraph (g)(6)(i), Entergy Operations, Inc. (EOI) requests U.S. Nuclear Regulatory Commission (NRC) approval of the attached relief request associated with the Third Inservice Inspection (ISI) interval of the Waterford Steam Electric Station, Unit 3 (Waterford 3) ISI program.

In accordance with 10 CFR 50.55a(g)(5)(iii), the basis for the determination of impracticality is being submitted to the NRC within 12 months after the expiration of the 120-month ISI interval. The third 10-year ISI interval ended on November 30, 2017, and complied with the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPVC), Section XI, 2001 Edition through the 2003 Addenda.

By this submittal, EOI is requesting relief from the requirements of the American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel (B&PV) Code, Section XI pertaining to volumetric examinations at Waterford 3. In several locations, the required

W3F1-2018-0065 Page 2 of 2 coverage cannot be obtained due to interference or geometry. The Enclosure and associated Attachments provide EOl's request for relief.

By letter and Safety Evaluation (SE) dated June 30, 2010 (Reference 1 ), relief was previously granted for limited volumetric examinations for pressure-retaining welds for the for the Second ISi interval of the Waterford 3 ISi program.

EOI requests approval by November 30, 2019.

This submittal contains no new regulatory commitments.

If you have any questions or require additional information, please contact the Acting Regulatory Assurance Manager, John V. Signorelli, at (504) 739-6032.

Respectfully, I

. Y/t:Z/J'7c?i,<:-.: C2 ,>._

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Ci Mandy K. Halter MKH/mmz

Enclosure:

10 CFR 50.55a Request Number W3-ISl-032, Relief Request in Accordance with 10 CFR 50.55a(g)(6)(i) : Component Identification : Exam Details cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - Waterford Steam Electric Station, Unit 3 NRR Project Manager

ENCLOSURE W3F1-2018-0065 Entergy Operations, Inc.

10 CFR 50.55a Request Number W3-ISI-032 Relief Request in Accordance with 10 CFR 50.55a(g)(6)(i)

Inservice Inspection Impracticality Attachment 1: Component Identification Attachment 2: Exam Details

W3F1-2018-0065 Enclosure Page 1 of 8 Entergy Operations, Inc.

10 CFR 50.55a Request Number W3-ISI-032 Relief Request in Accordance with 10 CFR 50.55a(g)(6)(i)

Inservice Inspection Impracticality

1. PLANT/UNIT Waterford Steam Electric Station, Unit 3 (Waterford 3).

2. INTERVAL Third Interval beginning May 31, 2008, and ending November 30, 2017.

3. ASME CODE COMPONENTS AFFECTED The Waterford 3 Class 1 and 2 welds with limited Inservice Inspection (ISI) examinations and Preservice Inspection (PSI) performed for Repair/Replacement Activities are included in this relief request and are listed in Attachments 1 and 2. The content of this relief request includes the insights gained from guidance provided in Reference 1, and the following Code Classes, Examination Categories, and Item Numbers apply.

Code Classes: Code Classes 1 and 2 Examination Categories: B-D, C-A, and R-A Item Numbers: B3.90, B3.110, B3.120, C1.10, R1.11, R1.11/16, and R1.20

4. APPLICABLE CODE EDITION AND ADDENDA The applicable ASME Boiler and Pressure Vessel Code of Record (hereafter referred to as the "Code") edition and addenda is ASME Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, 2001 Edition through 2003 Addenda (Reference 2), which was used for the Third 10-Year ISI Interval (May 31, 2008 to November 30, 2017) at Waterford 3, as modified by 10 CFR 50.55a, and as conditioned by 10 CFR 50.55a(b)(2)(xxi)(A), where the 1998 Edition (Reference 3) is required for use. The Appendix VIII requirements and use of the Performance Demonstration Initiative (PDI) requirements at Waterford 3 are in accordance with the 2001 Edition of Section XI (Reference 4), as conditioned by 10 CFR 50.55a(b)(2)(xv) and 10 CFR 50.55a(b)(2)(xxiv).

As an alternative to the requirements above for ASME Section XI Examination Category B-F, B-J, C-F-1 and C-F-2 welds, on April 28, 2008, Entergy received NRC authorization for Waterford 3 to use a Risk-Informed Safety Based Inservice Inspection (RIS_B) program (Reference 5). The duration of this alternative to Section XI is for the remainder of the Third 10-Year ISI Interval. This RIS_B program is based in part on using ASME Code Case N-716 (Reference 6) as guidance, and, from its authorization date forward, Examination

W3F1-2018-0065 Enclosure Page 2 of 8 Category B-F, B-J, C-F-1, and C-F-2 welds were all included under Examination Category R-A of the new RIS_B program.

5. APPLICABLE CODE REQUIREMENTS As previously defined in 10 CFR 50.55a(g)(6)(ii)(A)(2) (now removed) and ASME Code Case N-460 (Reference 7), as approved in Regulatory Guide 1.147, the Code Case states that "essentially 100%" means more than 90% of the examination volume or required surface area of each weld, where the reduction in coverage is due to interference by another component or part geometry. These requirements have been applied to Waterford 3 for all welds contained in this relief request. Below are the descriptions of the applicable code requirements used to conduct examinations associated with the thirty (30) welds and items that have demonstrated examination limitations.

Class 1 Welds Examined for ISI Table IWB-2500-1, Examination Category B-D, "Full Penetration Welded Nozzles in Vessels -

Inspection Program B," Item No. B3.90 requires the examination volume for the Reactor Vessel Nozzle-to-Vessel Welds chosen to meet the Third 10-Year ISI Interval requirements at Waterford 3 to be as defined by the applicable figures shown in Figures IWB-2500-7(a) through (d) (ref. footnote 4); however, limited examinations have been determined to exist based on the demonstrated limitations experienced when attempting to comply with the code requirements (as documented in Attachment 1) when performing examination of two (2) of these welds.

Table IWB-2500-1, Examination Category B-D, "Full Penetration Welded Nozzles in Vessels -

Inspection Program B," Item No. B3.110 requires the examination volume for the Pressurizer Nozzle-to-Vessel Welds chosen to meet the Third 10-Year ISI Interval requirements at Waterford 3 to be as defined by the applicable figures shown in Figures IWB-2500-7(a) through (d) (ref. footnote 4); however, limited examinations have been determined to exist based on the demonstrated limitations experienced when attempting to comply with the code requirements (as documented in Attachment 1) when performing examination of five (5) of these welds.

Table IWB-2500-1, Examination Category B-D, "Full Penetration Welded Nozzles in Vessels -

Inspection Program B," Item No. B3.120 of the 1998 Edition of Section XI, as conditioned in 10 CFR 50.55a(b)(2)(xxi)(A), was used for the selection of the Nozzle Inside Radius Sections (IRS) of the Pressurizer. Ultrasonic examination was performed on five (5) Nozzle Inside Radius Sections of the Pressurizer to meet the Third 10-Year ISI Interval requirements at Waterford 3, as defined by the applicable figures shown in Figures IWB-2500-7(a) through (d)

(ref. footnote 4); however, limited examinations have been determined to exist based on the demonstrated limitations experienced when attempting to comply with the code requirements (as documented in Attachment 1) when performing examination of five (5) of these IRS.

ASME Code Case N-716, Table 1, Examination Category R-A, Item No. R1.11, "Elements subject to Thermal Fatigue," requires selected welds to have a volumetric examination performed in accordance with the volume required in Figures IWB-2500-8(c),

IWB-2500-9, -10, and -11, as applicable. Additionally, Table 1 Note (1) is also required to be applied to cover an increased volume of the base metal thickness or counterbore transition for the welds included in this relief request under this item number. Thus, limited examinations

W3F1-2018-0065 Enclosure Page 3 of 8 have been determined to exist as documented in Attachment 1 when performing examination of eight (8) of these welds.

ASME Code Case N-716, Table 1, Examination Category R-A, Item No. R1.20, "Elements Not Subject to a Degradation Mechanism," requires selected welds to have a volumetric examination performed in accordance with the volume required in Figures IWB-2500-8(c),

IWB-2500-9, -10, and -11, as applicable; however, limited examinations have been determined to exist based on the demonstrated limitations experienced when attempting to comply with the code requirements (as documented in Attachment 1) when performing the examination of four (4) of these welds.

Class 1 Welds Examined for Preservice Examination (PSI)

ASME Code Case N-716, Table 1, Examination Category R-A, Item No. R1.11 and R1.11/16, "Elements subject to Thermal Fatigue," requires selected welds to have a volumetric examination performed in accordance with the volume required in Figures IWB-2500-8(c),

IWB-2500-9, -10, and -11, as applicable. Additionally, Table 1 Note (1) is also required to be applied to cover an increased volume of the base metal thickness or counterbore transition for the welds included in this relief request under this item number. For PSI, all of these High Safety Significant (HSS) welds were required to be examined per the RIS_B program. Limited examinations have been determined to exist based on the demonstrated limitations experienced when attempting to comply with the code requirements during PSI of two (2) of these welds (as documented in Attachment 1).

ASME Code Case N-716, Table 1, Examination Category R-A, Item No. R1.20, "Elements Not Subject to a Degradation Mechanism," requires selected welds to have a volumetric examination performed in accordance with the volume required in Figures IWB-2500-8(c),

IWB 2500-9, -10, and -11, as applicable; however, limited examinations have been determined to exist based on the demonstrated limitations experienced when attempting to comply with the code requirements (as documented in Attachment 1) when performing the examination of two (2) of these welds.

Class 2 Welds Examined for ISI Table-IWC-2500-1, Examination Category C-A, "Pressure Retaining Welds in Pressure Vessels," Item No. C1.10 requires the examination volume for the Shell Circumferential Welds to be as defined by Figure IWC-2500-1. The Shell-to-Flange Weld of the Shutdown Cooling Heat Exchanger (SDCHX) B is the weld that was examined per this category and Item number to meet the Third 10-Year ISI Interval requirements at Waterford 3; however, a limited examination has been determined to exist based on the demonstrated limitations experienced when attempting to comply with the code requirements (as documented in Attachment 1) when performing the examination of this weld.

Table-IWC-2500-1, Examination Category C-A, "Pressure Retaining Welds in Pressure Vessels," Item No. C1.30 requires the examination volume for the Shell Circumferential Welds to be as defined by Figure IWC-2500-1. The Shell-to-Tube Sheet Weld of the SDCHX B is the weld that was examined per this category and Item number to meet the Third 10-Year ISI Interval requirements at Waterford 3; however, a limited examination has been determined to exist based on the demonstrated limitations experienced when attempting to comply with the code requirements (as documented in Attachment 1) when performing the examination of this weld.

W3F1-2018-0065 Enclosure Page 4 of 8 Table 1: Exam Categories and Item Numbers applicable to Relief Request W3-ISI-032 Exam Item ISI Examination Requirements Category No.

B3.90 Essentially 100% examination of the Reactor Pressure vessel and B-D B3.110 Pressurizer Nozzle-to-Vessel Welds and Nozzle Inside radius B3.120 Sections. [Seven (7) Welds & Five (5) IRS]

Essentially 100% examination of the selected welds per the R1.11 R-A requirements of ASME Code Case N-716-1, Table 1. [Sixteen (16)

R1.20 Welds]

C1.10 Essentially 100% examination of the weld length for Shell [Two (2)

C-A C1.30 Welds]

6. REASON FOR REQUEST Impracticality of Compliance 10 CFR 50.55a(g)(6) Actions by the Commission for evaluating impractical and augmented ISI Code requirements - (i) Impractical ISI requirements: Granting of relief, 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 are authorized by law, will not endanger life or property or the common defense and security, and are 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.

10 CFR 50.55a(g)(5) Requirements for updating ISI programs - (iii) ISI program update:

Notification of impractical ISI Code requirements, states: If the licensee has determined that conformance with a Code requirement is impractical for its facility the licensee must notify the NRC and submit, as specified in §50.4, information to support the determinations.

Determinations of impracticality in accordance with this section must be based on the demonstrated limitations experienced when attempting to comply with the Code requirements during the inservice inspection interval for which the request is being submitted. Requests for relief made in accordance with this section must be submitted to the NRC no later than twelve (12) months after the expiration of the initial or subsequent 120-month inspection interval for which relief is sought.

Pursuant to 10 CFR 50.55a(g)(5)(iii) described above, the required submittal of this relief request is due on or before November 30, 2018 for Waterford 3, because Entergy has determined that compliance with the code requirements of achieving essentially 100%

coverage of the welds listed in this relief request is impractical for Waterford 3 to achieve.

This relief request is based on actual demonstrated limitations experienced when attempting to comply with the code requirements in the performance of the examinations listed in this relief request.

The construction permit for Waterford 3 was issued on November 14, 1974 and it falls under the provisions of 10 CFR 50.55a(g)(3), which were applied to provide design and access to

W3F1-2018-0065 Enclosure Page 5 of 8 perform preservice and inservice examinations of Class 1, 2 and 3 components and their supports using the preservice requirements of Section III Editions and Addenda or preservice and inservice examination requirements of Section XI Editions or Addenda applicable at that time in conjunction with those national standards referenced by these codes. Therefore, although the design of the plant has provided access for examinations, component design configurations with conditions resulting in examination limitations such as geometric configurations of welds may not allow full required examination volume coverage and thus this relief request addresses those conditions. A typical example of such a condition is a valve-to-pipe weld where essentially 100% of the code required volume cannot be examined from the valve side of the weld and where a plant modification would be needed to provide this coverage. Details for all examination restrictions and reductions in required examination coverage are provided in Attachments 1 and 2.

When examined, the welds listed in Attachment 1 did not receive the required code volume coverage due to their component design configurations. These conditions resulted in scanning limitations that prohibited obtaining essentially 100% examination coverage of the required examination volume; however, when this situation occurred, 100% of the accessible volume of the welds and items were covered.

Burden Caused by Compliance To comply with the code required examination volumes for obtaining essentially 100%

coverage for the welds listed in this relief request, the welds and their associated components would have to be physically modified and/or disassembled beyond their current design.

Overall, components and fittings associated with the welds listed in this relief request are constructed of standard design items meeting typical national standards that specify required configurations and dimensions. To replace these items with items of alternate configurations to enhance examination coverage would require unique redesign and fabrication. Because these items are in the Class 1 and 2 boundaries, and, for the Class 1 items, form a part of the reactor coolant pressure boundary, their redesign and fabrication would be an extensive effort based on the limitations that exist.

Specifically, for the Class 1 Category B-D Nozzle-to-Vessel Welds of the Reactor Pressure Vessel and Pressurizer, the design configurations of these welds and associated nozzles do not allow the required examination coverage to be obtained without a design modification of the components.

For the Class 1 and 2 Category R-A HSS Piping Welds listed in this relief request they are also typically limited by their design configurations. The configurations of these welds, such as Pipe-to-Valve, Pipe-to-Tee, or Elbow-to-Tee Welds, only allow ultrasonic examination coverage from one side of the weld or limited coverage from a specific area or areas of one side of the weld. Therefore, they would also require a design modification to obtain the required examination coverage.

Where the Class 2 Category C-A Shell Circumferential Weld requirements apply to the SDCHX B welds listed in this relief request, they can only be examined from one side due to their configuration and nozzle weld interference. The heat exchanger welds are not accessible without cutting additional welds or nozzles of the heat exchanger and would require a design modification to gain access to the welds to obtain the required examination coverage.

W3F1-2018-0065 Enclosure Page 6 of 8 Overall it is not possible to obtain ultrasonic interrogation of greater than 90% of the required code examination volume for the welds in this relief request without extensive weld or area design modifications. Examinations have been performed to the maximum extent possible and radiography is impractical due to the amount of work being performed in the areas on a 24-hour basis when the welds are available for examination. This would result in numerous work-related stoppages and increased exposure due to the shutdown and startup of other work in the areas. The water must be drained from systems or components where radiography is performed, which increases the radiation dose rates over a much broader area than the weld being examined. Therefore, there is significant impracticality associated with the performance of weld or area modifications or the use of radiography in order to increase the examination coverage.

The ultrasonic examination techniques used for each weld in this relief request were reviewed to determine if additional coverage could be achieved by improving those techniques. None could be identified. The examinations have been performed to the maximum extent possible.

Therefore, Waterford 3 has determined that obtaining essentially 100% coverage is not feasible and is impractical without adding additional burden consisting of significant redesign work, increased radiation exposure, and/or potential damage to the plant or the component itself.

7. PROPOSED ALTERNATIVE AND BASIS Proposed Alternative

1) Periodic system pressure tests and VT-2 visual examinations will continue to be performed in accordance with ASME Section Xl, Examination Category B-P, for Class 1 pressure retaining welds and items each refueling outage and Examination Category C-H for Class 2 pressure retaining welds and items each inspection period in accordance with Table IWB-2500-1 and Table IWC-2500-1, respectively.

2) Ultrasonic examinations will be conducted to the maximum extent possible when required by ASME Section XI or the RIS_B Program.

Basis for Use Waterford 3 has performed ISI examinations of selected welds in accordance with the requirements of 10 CFR 50.55a, plant technical specifications, and the 2001 Edition through the 2003 Addenda, of the ASME Boiler and Pressure Vessel Code, Section XI including Appendix VIII requirements in accordance with the 2001 Edition of Section XI and applicable PDI requirements along with the requirements of the RIS_B Program. When a component is found to have condition(s), which limited the required examination volume or surface area, Waterford 3 is required to submit this information to the enforcement and regulatory authorities having jurisdiction at the plant site. This relief request has been written to address areas where these types of conditions exist and where the required amount of coverage was reduced below the minimum acceptable.

10 CFR 50.55a(g)(4) recognizes that throughout the service life of a nuclear power facility, components which are classified as ASME Code Class 1, Class 2 and Class 3 must meet the requirements set forth in the ASME Code to the extent practical within the limitations of

W3F1-2018-0065 Enclosure Page 7 of 8 design, geometry and materials of construction of the welds and items as those described in .

Waterford 3 performed the weld examinations listed in this relief request to the maximum extent possible for each of the welds identified with limitations in Attachment 1. Plant-specific, or industry operating experience regarding potential degradation specific to welds in this relief request has been taken into account with the identification of potential degradation mechanisms within the scope of the applied RIS_B Program. The welds in this relief request were ultrasonically examined with manual and automated techniques.

All the Class 1 Examination Category B-D and R-A welds with limited examinations included in Attachment 1 of this relief request are located inside the containment at Waterford 3. The following RCS leakage detection equipment and requirements help to ensure the early identification of any leakage of these welds during Reactor Coolant System (RCS) operation.

Even though the limitations associated with the examinations identified in this relief request did not meet the essentially 100% code required volume coverage requirement, there is instrumentation in place to assure that early detection of any RCS pressure boundary leakage is identified. This is accomplished by the leakage monitoring instruments inside the containment at Waterford 3 where the RCS leakage detection instrumentation is required to be operable. The instrumentation consists of one containment sump monitor and one containment atmosphere particulate radioactivity monitor. These instruments are used to quantify any unidentified leakage from the RCS and to comply with Waterford 3 Technical Specifications 3/4.4.5 associated with RCS Leakage (Limiting Condition for Operation (LCO) 3.4.5.1, Leakage Detection Instrumentation, and LCO 3.4.5.2, Operational Leakage).

TS Surveillance Requirement (SR) 4.4.5.1 ensures that the leakage detection instrumentation is operable and SRs 4.4.5.2.1 and 4.4.5.2.2 (in part), ensure that the operational leakage requirements of LCO 3.4.5.2 are met. LCO 3.4.5.2 states that RCS operational leakage shall be limited to: a. No pressure boundary leakage; b. 1 gallon per minute (gpm) unidentified leakage; c. 75 gallons per day primary to secondary leakage through any one steam generator; d. 10 gpm identified leakage; and e. 1 gpm leakage at a Reactor Coolant System pressure of 2250 +/- 20 psia from any Reactor Coolant System pressure isolation valve specified in Table 3.4-1.

Based upon the extent of the ultrasonic examination volume achieved for each of the welds within this relief request and any alternate scans performed, coupled with applicable leakage monitoring and required system pressure tests with VT-2 visual examinations, no further action can be taken by Entergy at this time to improve these examinations without applying impractical options. Therefore, the proposed alternatives in this relief request will provide assurance of an acceptable level of quality and safety by providing reasonable assurance of structural integrity.

8. DURATION This relief request covers the limited examinations that have been identified for the entire Third 10-Year ISI Interval that started on May 31, 2008 and ended on November 30, 2017.

W3F1-2018-0065 Enclosure Page 8 of 8

9. PRECEDENTS Note: Industry requests for relief due to impracticality associated with limited examinations are common and are typically filed by all licensees. Some of the more recent NRC approvals of requested relief that are aligned with Reference 1 are provided below.

1. Dresden Nuclear Power Station, Units 2 and 3 - Request 14R-17 Relief from the Requirements of the ASME Code (TAC Nos. MF3352 and MF3353), dated October 30, 2015, (ADAMS Accession No. ML15265A164).

2. Salem Nuclear Generating Station, Unit 2 - Relief from the Requirements of the ASME Code (TAC No. MF4591), dated July 28, 2015, (ADAMS Accession No. ML15195A495).

3. St. Lucie Plant, Unit No. 2 - Relief Request No. 17 - Request for Relief from Performing Inservice Inspection Volumetric Examinations of ASME Category B-A Welds (TAC No. MF4339), dated April 17, 2015, (ADAMS Accession No. ML15029A583).

10. REFERENCES

1. NRC presentation "Coverage Relief Requests," Industry/NRC NDE Technical Information Exchange Public Meeting January 13-15, 2015, (ADAMS Accession No. ML15013A266).

2. ASME Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, 2001 Edition through 2003 Addenda.

3. ASME Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, 1998 Edition.

4. ASME Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, 2001 Edition, Appendix VIII, Performance Demonstration for Ultrasonic Examination Systems.

5. Waterford Steam Electric Station, Unit 3 - Request for Alternative W3-ISI-005, Request to Use ASME Code Case N-716 (TAC No. MD7061), dated April 28, 2008, (ADAMS Accession No. ML080980120).

6. ASME Code Case N-716, Alternative Piping Classification and Examination Requirements Section XI, Division 1.

7. ASME Code Case N-460, Alternative Examination Coverage for Class 1 and Class 2 Welds Section XI, Division 1.

ENCLOSURE, ATTACHMENT 1 W3F1-2018-0065 Component Information

W3F1-2018-0065 Enclosure, Attachment 1 Page 1 of 5 Attachment 1 Component Information This attachment contains tables and figures that are used to depict the limitations and calculations for obtained coverage, materials, and product forms, with ultrasonic examination angles and wave forms used, and the examination results for the welds and items associated with this relief request.

Material 1 Material 2 Examination Component Item and and Code Category Item No. Examination Limitations and Results ID Description Product Product Coverage Form Form Obtained B-D B3.90 01-021 R.V. Nozzle SA-533 SA-508 UT = 78.59% 01-021 is a Class 1, Reactor Vessel to Shell at 0° Carbon Carbon nozzle to vessel weld. Exam is limited Steel Shell Steel due to geometric nozzle design Nozzle configuration. Scanned from inside the vessel. The examination recorded Six (6) previously recorded indications which were determined to be acceptable per IWB-3512-1.

B-D B3.90 01-024 R.V. Nozzle SA-533 SA-508 UT = 78.59% 01-024 is a Class 1, Reactor Vessel to Shell at Carbon Carbon nozzle to vessel weld. Exam is limited 180° Steel Shell Steel due to geometric nozzle design Nozzle configuration. Scanned from inside the vessel. No recordable indications.

B-D B3.110 05-009 PZR Surge SA-533 SA-508 UT = 79.57% 05-009 is a Class 1, Pressurizer nozzle Nozzle to Carbon Carbon to vessel weld. Exam is limited due to Bottom Steel Head Steel geometric nozzle design configuration.

Head Weld Nozzle Scanned from outside the vessel on bottom head. No recordable indications.

B-D B3.110 05-010 PZR Spray SA-533 SA-508 UT = 79.62% 05-010 is a Class 1, Pressurizer nozzle Nozzle to Carbon Carbon to vessel weld. Exam is limited due to Top Head Steel head Steel geometric nozzle design configuration.

Weld Nozzle Scanned from outside the vessel on top head. The 60° circumferential flaw scan recorded one spot indication with no measurable through wall dimension that was determined to be fabrication type flaw.

B-D B3.110 05-011 PZR Safety SA-533 SA-508 UT = 82.61% 05-011 is a Class 1, Pressurizer nozzle Nozzle to Carbon Carbon to vessel weld. Exam is limited due to Top Head Steel Head Steel geometric nozzle design configuration.

Weld @ 45° Nozzle Scanned from outside the vessel on top head. The 60° circumferential flaw scan recorded one indication with no measurable through wall dimension that was determined to be fabrication type flaw.

B-D B3.110 05-012 PZR Safety SA-533 SA-508 UT = 80.97% 05-012 is a Class 1, Pressurizer nozzle Nozzle to Carbon Carbon to vessel weld. Exam is limited due to Top Head Steel Head Steel geometric nozzle design configuration.

Weld Nozzle Scanned from outside the vessel on top

@ 135° head. The 60° circumferential flaw scan recorded one indication with no measurable through wall dimension that was determined to be fabrication type flaw.

W3F1-2018-0065 Enclosure, Attachment 1 Page 2 of 5 Material 1 Material 2 Examination Component Item and and Code Category Item No. Examination Limitations and Results ID Description Product Product Coverage Form Form Obtained B-D B3.110 05-013 PZR Safety SA-533 SA-508 UT = 80.84% 05-013 is a Class 1, Pressurizer nozzle Nozzle to Carbon Carbon to vessel weld. Exam is limited due to Top Head Steel Head Steel geometric nozzle design configuration.

Weld Nozzle Scanned from outside the vessel on top

@ 225° head. No recordable indications.

B-D B3.120 05-014 PZR Surge SA-508 Not UT = 42.95% 05-014 is a Class 1, Pressurizer nozzle Nozzle Inner Carbon Applicable inside radius section. Exam is limited Radius Nozzle due to geometric nozzle design configuration. Scanned from outside the vessel on bottom head. No recordable indications.

B-D B3.120 05-015 PZR Spray SA-508 Not UT = 55% 05-015 is a Class 1, Pressurizer nozzle Nozzle Inner Carbon Applicable inside radius section. Exam is limited Radius Steel due to geometric nozzle design Nozzle configuration. Scanned from outside the vessel on top head. No recordable indications.

B-D B3.120 05-016 PZR Safety SA-508 Not UT = 70.38% 05-016 is a Class 1, Pressurizer nozzle Nozzle Inner Carbon Applicable inside radius section. Exam is limited Radius Steel due to geometric nozzle design

@ 45° Nozzle configuration. Scanned from outside the vessel on top head. No recordable indications.

B-D B3.120 05-017 PZR Safety SA-508 Not UT = 70.27% 05-017 is a Class 1, Pressurizer nozzle Nozzle Inner Carbon Applicable inside radius section. Exam is limited Radius Steel due to geometric nozzle design

@ 135° Nozzle configuration. Scanned from outside the vessel on top head. No recordable indications.

B-D B3.120 05-018 PZR Safety SA-508 Not UT = 66.67% 05-018 is a Class 1, Pressurizer nozzle Nozzle Inner Carbon Applicable inside radius section. Exam is limited Radius Steel due to geometric nozzle design

@ 225° Nozzle configuration. Scanned from outside the vessel on top head. No recordable indications.

C-A C1.10 54-074 SDCHX B SA-533 SA-533 UT = 87.55% 54-074 is a Class 2, Shut Down Cooling Shell to Carbon Carbon Heat Exchanger shell circumferential Flange Weld Steel Steel Shell weld. Exam is limited due to geometric Flange design configuration. Scanned from shell side and limited in area of nozzles.

No recordable indications.

C-A C1.30 54-075 SDCHX B SA-533 Not UT = 84.84% 54-075 is a Class 2, Shut Down Cooling Shell to Carbon Specified Heat Exchanger shell circumferential Tube Sheet Steel Shell weld. Exam is limited due to geometric Weld design configuration. Scanned from shell side and limited in area of nozzles.

No recordable indications.

W3F1-2018-0065 Enclosure, Attachment 1 Page 3 of 5 Material 1 Material 2 Examination Component Item and and Code Category Item No. Examination Limitations and Results ID Description Product Product Coverage Form Form Obtained R-A R1.11 08-009 12 SI SA-182 SA-351 UT = 86.4% 08-009 is a Class 1, Dissimilar weld in Nozzle to Forged Safe-End the Reactor Coolant system connecting Safe-End Nozzle a Carbon Steel nozzle to a Cast (CASS) Austenitic Stainless Steel safe end. The Weld weld is identified by the N-716-1 risk informed program as High Safety Significant (HSS) with a degradation mechanism of thermal transients (TT).

The examination is limited due to no qualified exam technique to scan from CASS side. Best effort scan was performed from CASS side but not included in the achieved coverage calculation. The examination recorded Two (2) indications which were determined to be acceptable per IWB-3512-2.

R-A R1.11 14-006 12 SI SA-182 SA-351 UT = 86.2% 14-006 is a Class 1, Dissimilar weld in Nozzle (CS) Forged Safe-End the Reactor Coolant system connecting to Safe-End Nozzle a Carbon Steel nozzle to a Cast (CASS) Austenitic Stainless Steel safe end. The Weld weld is identified by the N-716-1 risk informed program as High Safety Significant (HSS) with a degradation mechanism of thermal transients (TT).

The examination is limited due to no qualified exam technique to scan from CASS side. Best effort scan was performed from CASS side but not included in the achieved coverage calculation. No recordable indications.

R-A R1.11 17-033 Pipe to 12 x SA-376 SA-376 UT = 80.1% 17-033 is a Class 1, Circumferential pipe 8 Reducer Stainless Stainless weld. The weld is identified by the Weld Steel Steel N-716-1 risk informed program as High Safety Significant (HSS) with a degradation mechanism of thermal transients (TT). The examination is limited due to geometric reducer design configuration. No recordable indications.

R-A R1.11 21-004 Elbow to 14 SA-376 SA-376 UT = 75% 21-004 is a Class 1, Circumferential pipe Elbow Weld Stainless Stainless weld. The weld is identified by the Steel Steel N-716-1 risk informed program as High Safety Significant (HSS) with a degradation mechanism of thermal stratification, cycling and striping (TASCS). The examination is limited due to geometric design configuration permanent support on the downstream side of the weld. No recordable indications.

R-A R1.11 32-002 2 Pipe to SA-376 SA-376 UT = 84.97% 32-002 is a Class 1, Circumferential pipe Elbow Weld Stainless Stainless weld. The weld is identified by the Steel Steel N-716-1 risk informed program as High Safety Significant (HSS) with a degradation mechanism of thermal stratification, cycling and striping (TASCS). The examination is limited due to geometric design configuration at the inside radius of the elbow. No recordable indications.

W3F1-2018-0065 Enclosure, Attachment 1 Page 4 of 5 Material 1 Material 2 Examination Component Item and and Code Category Item No. Examination Limitations and Results ID Description Product Product Coverage Form Form Obtained R-A R1.11 32-003 2 Elbow to SA-376 SA-376 UT = 84.97% 32-003 is a Class 1, Circumferential pipe Pipe Weld Stainless Stainless weld. The weld is identified by the Steel Steel N-716-1 risk informed program as High Safety Significant (HSS) with a degradation mechanism of thermal stratification, cycling and striping (TASCS). The examination is limited due to geometric design configuration at the inside radius of the elbow. No recordable indications.

R-A R1.11 32-004 2 Pipe to SA-376 SA-376 UT = 84.97% 32-004 is a Class 1, Circumferential pipe Elbow Weld Stainless Stainless weld. The weld is identified by the Steel Steel N-716-1 risk informed program as High Safety Significant (HSS) with a degradation mechanism of thermal stratification, cycling and striping (TASCS). The examination is limited due to geometric design configuration at the inside radius of the elbow. No recordable indications.

R-A R1.11 32-005 2 Elbow to SA-376 SA-376 UT = 84.97% 32-005 is a Class 1, Circumferential pipe Pipe Weld Stainless Stainless weld. The weld is identified by the Steel Steel N-716-1 risk informed program as High Safety Significant (HSS) with a degradation mechanism of thermal stratification, cycling and striping (TASCS). The examination is limited due to geometric design configuration at the inside radius of the elbow. No recordable indications.

R-A R1.20 06-007 42 Elbow to SA-516 SA-516 UT = 87.82% 06-007 is a Class 1, Circumferential pipe Pipe Weld Carbon Carbon weld. The weld is identified by the Steel Steel Pipe N-716-1 risk informed program as High Elbow Safety Significant (HSS) with no degradation mechanism. The examination is limited due to geometric design configuration of a permanent pipe support on the downstream side of the weld and a nozzle on the upstream side of the weld. No recordable indications.

R-A R1.20 09-005 30 Elbow to SA-516 SA-516 UT = 85.35% 09-005 is a Class 1, Circumferential pipe Elbow Weld Carbon Carbon weld. The weld is identified by the Steel Steel N-716-1 risk informed program as High Elbow Elbow Safety Significant (HSS) with no degradation mechanism. The examination is limited due to geometric design configuration of a permanent pipe support. No recordable indications.

R-A R1.20 09-008 30 Elbow to SA-516 SA-516 UT = 85.78% 09-008 is a Class 1, Circumferential pipe Pipe Weld Carbon Carbon weld. The weld is identified by the Steel Steel Pipe N-716-1 risk informed program as High Elbow Safety Significant (HSS) with no degradation mechanism. The examination is limited due to geometric design configuration of a permanent pipe support and close proximity to wall.

No recordable indications.

W3F1-2018-0065 Enclosure, Attachment 1 Page 5 of 5 Material 1 Material 2 Examination Component Item and and Code Category Item No. Examination Limitations and Results ID Description Product Product Coverage Form Form Obtained R-A R1.20 15-011 42 Pipe to SA-516 SA-516 UT = 86.71% 15-011 is a Class 1, Circumferential pipe Elbow Weld Carbon Carbon weld. The weld is identified by the Steel Steel Pipe N-716-1 risk informed program as High Elbow Safety Significant (HSS) with no degradation mechanism. The examination is limited due to geometric design configuration of a permanent pipe support on the upstream side and nozzles on the downstream side. No recordable indications.

R-A R1.11/16 19-008-X1 12Pipe to SA-351 SA-351 UT=50% 19-008-X1 is a Class 1, Circumferential Valve Weld Stainless Stainless pipe weld The weld is identified by the Steel Steel N-716-1 risk informed program as High Product Safety Significant (HSS) with a Form cast degradation mechanism of thermal stratification, cycling and striping (TASCS). The examination is limited due to the pipe to valve geometric design configuration. There was no scan on the valve side of the weld. No recordable indications.

R-A R1.11 19-006-X1 12 Valve to SA-351 SA-376 UT=50% 19-006-X1 is a Class 1, Circumferential Pipe Weld Stainless Stainless pipe weld The weld is identified by the Steel Steel N-716-1 risk informed program as High Product Safety Significant (HSS) with a Form cast degradation mechanism of thermal stratification, cycling and striping (TASCS). The examination is limited due to the pipe to valve geometric design configuration. There was no scan on the valve side of the weld. No recordable indications.

R-A R1.20 22-031-X2 3Pipe to SA-376 SA-351 UT=50% 22-031-X2 is a Class 1, Circumferential Valve Weld Stainless Stainless pipe weld The weld is identified by the Steel Steel N-716-1 risk informed program as High Product Safety Significant (HSS) with a Form cast degradation mechanism of thermal stratification, cycling and striping (TASCS). The examination is limited due to the pipe to valve geometric design configuration. There was no scan on the valve side of the weld. No recordable indications.

R-A R1.20 22-033-X2 Valve to 3 SA-351 SA-376 UT=50% 22-033-X2 is a Class 1, Circumferential Pipe Weld Stainless Stainless pipe weld The weld is identified by the Steel Steel N-716-1 risk informed program as High Product Safety Significant (HSS) with a Form cast degradation mechanism of thermal stratification, cycling and striping (TASCS). The examination is limited due to the pipe to valve geometric design configuration. There was no scan on the valve side of the weld. No recordable indications.

ENCLOSURE, ATTACHMENT 2 W3F1-2018-0065 Exam Details

Enclosure Attachment 2 to W3F1-2018-0065 Page 1 of 79 Attachment 2, Exam Details Exam Cat. B-D Item B3.90 Reactor Vessel Outlet Nozzles

Enclosure Attachment 2 to W3F1-2018-0065 Page 2 of 79 Exam Cat. B-D Item B3.90 Component ID: 01-021 & 01-024 Coverage Plot Figure A

Enclosure Attachment 2 to W3F1-2018-0065 Page 3 of 79 Component ID: 01-021 & 01-024 Coverage Calculation

Enclosure Attachment 2 to W3F1-2018-0065 Page 4 of 79 Exam Cat. B-D Item B3.90 Component ID: 01-021 & 01-024 Coverage Plot Figure B

Enclosure Attachment 2 to W3F1-2018-0065 Page 5 of 79 Component ID: 01-021 & 01-024 Coverage Calculation

Enclosure Attachment 2 to W3F1-2018-0065 Page 6 of 79 Exam Cat. B-D Item B3.90 Component ID: 01-021 & 01-024 Coverage Plot Figure C

Enclosure Attachment 2 to W3F1-2018-0065 Page 7 of 79 Exam Cat. B-D Item B3.110 and B3.120 Pressurizer Vessel-Top Head Pressurizer Spray & Safety Head Nozzle Welds and Inside Radius Sections Pressurizer Vessel-Bottom Head Pressurizer Surge Nozzle Weld & Inside Radius Section

Enclosure Attachment 2 to W3F1-2018-0065 Page 8 of 79 Exam Cat. C-A Item C1.10 Shutdown Cooling Heat Exchanger B Shell to Flange Weld and Shell to Tubesheet Weld

Enclosure Attachment 2 to W3F1-2018-0065 Page 9 of 79 Exam Cat. B-D Item B3.110 Weld 05-009, Coverage Diagram Scan Towards Nozzle (Down Stream)

Zerocoverageobtainedscanningindownstreamdirection45°/60°

Zerocoverageobtainedscanningindownstreamdirection45°

Additionalarearequiredbycodewhichnocoveragewasobtained.

Enclosure Attachment 2 to W3F1-2018-0065 Page 10 of 79 ID#05009:Upstreamexamareahas100%coverageforallscansperformed.

DownStreamTotalVolume:

x 3.8x4.6x50.75=887.11Plusextraareanotincludedinexamdrawing61.91=949.02 45°Down-Stream:

x 2.76x2.94/2=4.05x50.75=205.53+61.91=267.44 x 267.44/949.02=28.18%wasmissed x 100-28.18=71.82%coverageachieved.

60°DownStream:

x 2.94x1.9/2=2.79x50.75=141.59+61.91=203.5 x 203.5/949.02=21.44%wasmissed x 100-21.44=78.56%coverageachieved.

DownStreamCirc.:

x (2.7x4.6=12.42)x50.75=630.31+61.91=692.22 x 692.22/949.02=72.94%wasmissed x 100-72.94=27.06%coverageachieved.

ExamTotalCoverage:

x 45°UpStream=100%45°DownStream=71.82%

x 60°UpStream=100%60°DownStream=78.56%

x UpStreamCirc.=100%DownStreamCirc.=27.06%

x Total:477.44/6=79.57%CRVAchieved

Enclosure Attachment 2 to W3F1-2018-0065 Page 11 of 79 Exam Cat. B-D Item B3.110 Weld 05-010, Coverage Diagram Areanotcoveredby60°/45°withAxscan

Areanotcoveredby45°withAxscan

Areanotcoveredby60°/45°withCirc.scan

Additionalarearequiredbycodewhichnocoveragewasobtained.

Enclosure Attachment 2 to W3F1-2018-0065 Page 12 of 79 ID#05010:Downstreamexamareahas100%coverageforallscansperformed.

UpStreamTotalVolume:

x 3.35x4.6x52=801.32Plusextraareanotincludedinexamdrawing71.24=872.56 45°Up-Stream:

x 2.85x2.75/2=3.91x52=203.77+71.24=275.01 x 275.01/872.56=31.51%wasmissed x 100-31.51=68.49%coverageachieved.

60°UpStream:

x 3x1.7/2=2.55x52=132.6+71.24=203.84 x 203.84/872.56=23.36%wasmissed x 100-23.36=76.64%coverageachieved.

UpStreamCirc.:

x (4.6x3=13.8)-(4.6x1.68/2=3.864)=9.936x52=516.67+71.24=587.91 x 587.91/872.56=67.37%wasmissed x 100-67.37=32.63%coverageachieved.

ExamTotalCoverage:

x 45°UpStream=68.49%45°DownStream=100%

x 60°UpStream=76.64%60°DownStream=100%

x UpStreamCirc.=32.63%DownStreamCirc.=100%

x Total:477.76/6=79.62%CRVAchieved

Enclosure Attachment 2 to W3F1-2018-0065 Page 13 of 79 Exam Cat. B-D Item B3.110 Weld 05-011, Coverage Diagram at Bottom Dead Center (BDC)

Areanotcoveredby60°/45°incircflawscan

Areanotcoveredby45°incircflawscan

Areanotcoveredby60°/45°inaxialflawscan

Additionalarearequiredbycodewhichnocoveragewasobtained.

Enclosure Attachment 2 to W3F1-2018-0065 Page 14 of 79 Exam Cat. B-D Item B3.110 Weld 05-011, Coverage Diagram at Top Dead Center (TDC)

Areanotcoveredby60°/45°withAxscan

Areanotcoveredby45°withAxscan

Areanotcoveredby60°/45°withCircscan

Additionalarearequiredbycodewhichnocoveragewasobtained.

Enclosure Attachment 2 to W3F1-2018-0065 Page 15 of 79 ID#05011:Upstreamexamareahas100%coverageforallscansperformed.

DownStreamTotalVolume:

x 3.2x4.25x52=707.2Plusextraareanotincludedinexamdrawing57.59=764.79 45°Down-Stream:

x 2.45x2.3/2=2.82x52=146.64+57.59=204.23 x 204.23/764.79=26.70%wasmissed x 100-26.70=73.3%coverageachieved.

60°DownStream:

x 2.55x1.45/2=1.848x52=96.135+57.59=153.72 x 153.72/764.79=20.09%wasmissed x 100-20.09=79.91%coverageachieved.

DownStreamCirc.:

x (4.25x2.55=10.837)-(4.25x1.64/2=3.485)=7.352x52=382.33+57.59=

439.92 x 439.92/764.79=57.52%wasmissed x 100-57.52=42.48%coverageachieved.

ExamTotalCoverage:

x 45°UpStream=100%45°DownStream=73.3%

x 60°UpStream=100%60°DownStream=79.91%

x UpStreamCirc.=100%DownStreamCirc.=42.48%

x Total:495.68/6=82.61%CRVAchieved

Enclosure Attachment 2 to W3F1-2018-0065 Page 16 of 79 Exam Cat. B-D Item B3.110 Weld 05-012, Coverage Diagram at Bottom Dead Center (BDC)

Areanotcoveredby60°/45°withAxscan

Areanotcoveredby45°withAxscan

Areanotcoveredby60°/45°withCirc.scan

Additionalarearequiredbycodewhichnocoveragewasobtained.

Enclosure Attachment 2 to W3F1-2018-0065 Page 17 of 79 Exam Cat. B-D Item B3.110 Weld 05-012, Coverage Diagram at Top Dead Center (TDC)

Areanotcoveredby60°/45°withAxscan

Areanotcoveredby45°withAxscan

Areanotcoveredby60°/45°withCirc.scan

Additionalarearequiredbycodewhichnocoveragewasobtained.

Enclosure Attachment 2 to W3F1-2018-0065 Page 18 of 79

/ h^ŽŽŽ

Ž^dŽsŽ

x 3.25x4.25x52=718.25Plusextraareanotincludedinexamdrawing57.59=775.

45°Down-Stream:

x 2.63x2.6/2=3.419x52=177.788+57.59=235.37 x 235.37/775.=30.34%wasmissed x 100-30.34=69.66%coverageachieved.

60°DownStream:

x 2.73x1.58/2=2.156x52=112.112+57.59=169.7 x 169.7/775.=21.8%wasmissed x 100-21.8=78.1%coverageachieved.

DownStreamCirc.:

x (4.25x2.74=11.645)-(4.25x1.65/2=3.506)=8.139x52=423.228+57.59=

480.81 x 480.81/775.=61.9%wasmissed x 100-61.9=38.0%coverageachieved.

ExamTotalCoverage:

x 45°UpStream=100% 45°DownStream=69.66%

x 60°UpStream=100% 60°DownStream=78.1%

x UpStreamCirc.=100% DownStreamCirc.=38.0%

x Total:485./6=80.9%CRVAchieved

Enclosure Attachment 2 to W3F1-2018-0065 Page 19 of 79 Exam Cat. B-D Item B3.110 Weld 05-013, Coverage Diagram at Bottom Dead Center (BDC)

Areanotcoveredby60°/45°withAxscan

Areanotcoveredby45°withAxscan

Areanotcoveredby60°/45°withCirc.scan

Additionalarearequiredbycodewhichnocoveragewasobtained.

Enclosure Attachment 2 to W3F1-2018-0065 Page 20 of 79 Exam Cat. B-D Item B3.110 Weld 05-013, Coverage Diagram at Top Dead Center (TDC)

Areanotcoveredby60°/45°withAxscan

Areanotcoveredby45°withAxscan

Areanotcoveredby60°/45°withCirc.scan

Additionalarearequiredbycodewhichnocoveragewasobtained.

Enclosure Attachment 2 to W3F1-2018-0065 Page 21 of 79

/ h^ŽŽŽ

Ž^dŽsŽ

x 3.13x4.13x52=672.19Plusextraareanotincludedinexamdrawing57.59=729.78 45°Down-Stream:

x 2.55x2.5/2=3.187x52=165.75+57.59=223.34 x 223.34/729.78=30.60%wasmissed x 100-30.60=69.4%coverageachieved.

60°DownStream:

x 2.65x1.5/2=1.9875x52=103.35+57.59=160.94 x 160.94/729.78=22.05%wasmissed x 100-22.05=77.95%coverageachieved.

DownStreamCirc.:

x (4.13x2.65=10.94)-(4.13x1.6/2=3.304)=7.636x52=397.07+57.59=

454.66 x 454.66/729.78=62.30%wasmissed x 100-62.30=3.7%coverageachieved.

ExamTotalCoverage:

x 45°UpStream=100%45°DownStream=69.4%

x 60°UpStream=100%60°DownStream=77.95%

x UpStreamCirc.=100% DownStreamCirc.=3.7%

x Total:48.05/6=8.%CRVAchieved

Enclosure Attachment 2 to W3F1-2018-0065 Page 22 of 79 Exam Cat. B-D Item B3.120 Weld 05-014, Coverage Diagram

Enclosure Attachment 2 to W3F1-2018-0065 Page 23 of 79 ID#05014:

TotalVolume:

ThisVolumeisbasedoffofthe2001ASMErequirementswhichincludethecladding.The

coverageshownontheexamdrawingdoesnotincludethecladarea.

x 4.82lengthx0.75widthx35.93circumference=129.88 70°ExamCoverage:

x (0.75x2.6=1.95)+(0.75x0.3/2=0.1125)=2.0625 x 2.0625x35.93=74.105 x 74.105/129.88=57.05%missed 100-57.05=42.95%CRVAchieved

Enclosure Attachment 2 to W3F1-2018-0065 Page 24 of 79 Exam Cat. B-D Item B3.120 Weld 05-015, Coverage Diagram

Enclosure Attachment 2 to W3F1-2018-0065 Page 25 of 79 ID#05015:

TotalVolume:

ThisVolumeisbasedoffofthe2001ASMErequirementswhichincludethecladding.The

coverageshownontheexamdrawingdoesnotincludethecladarea.

x 5.5lengthx0.75widthx14.137circumference=58.31 60°ExamCoverage:

x (0.75x2.3=1.725)+(0.75x0.35/2=0.131)=1.856 x 1.856x14.137=26.24 x 26.24/58.31=45%missed 10045=55%CRVAchieved

Enclosure Attachment 2 to W3F1-2018-0065 Page 26 of 79 Exam Cat. B-D Item B3.120 Weld 05-016, Coverage Diagram

Enclosure Attachment 2 to W3F1-2018-0065 Page 27 of 79 ID#05016:

TotalVolume:

ThisVolumeisbasedoffofthe2001ASMErequirementswhichincludethecladding.The

coverageshownontheexamdrawingdoesnotincludethecladarea.

x 5.55lengthx0.75widthx18.28circumference=76.09 60°ExamCoverage:

x (0.75x1.47=1.102)+(0.75x0.35/2=0.131)=1.233 x 1.233x18.28=22.539 x 22.539/76.09=29.62%missed 100-29.62=70.38%CRVAchieved

Enclosure Attachment 2 to W3F1-2018-0065 Page 28 of 79 Exam Cat. B-D Item B3.120 Weld 05-017, Coverage Diagram

Enclosure Attachment 2 to W3F1-2018-0065 Page 29 of 79 ID#05017:

TotalVolume:

ThisVolumeisbasedoffofthe2001ASMErequirementswhichincludethecladding.The

coverageshownontheexamdrawingdoesnotincludethecladarea.

x 5.5lengthx0.75widthx18.28circumference=75.405 60°ExamCoverage:

x (0.75x1.46=1.095)+(0.75x0.35/2=0.131)=1.226 x 1.226x18.28=22.415 x 22.415/75.405=29.727%missed 100-29.727=70.27%CRVAchieved

Enclosure Attachment 2 to W3F1-2018-0065 Page 30 of 79 Exam Cat. B-D Item B3.120 Weld 05-018, Coverage Diagram

Enclosure Attachment 2 to W3F1-2018-0065 Page 31 of 79 ID#05018:

TotalVolume:

ThisVolumeisbasedoffofthe2001ASMErequirementswhichincludethecladding.The

coverageshownontheexamdrawingdoesnotincludethecladarea.

x 5.4lengthx0.75widthx18.28circumference=74.034 60°ExamCoverage:

x (0.75x1.45=1.0875)+(0.75x0.35/2=0.2625)=1.35 x 1.35x18.28=24.678 x 24.678/74.034=33.33%missed 100-33.33=66.67%CRVAchieved

Enclosure Attachment 2 to W3F1-2018-0065 Page 32 of 79 Exam Cat. C-A Item C1.10 Weld 54-074, Coverage Diagram Part 1

Enclosure Attachment 2 to W3F1-2018-0065 Page 33 of 79 Exam Cat. C-A Item C1.10 Weld 54-074, Coverage Diagram Part 2

Enclosure Attachment 2 to W3F1-2018-0065 Page 34 of 79 Exam Cat. C-A Item C1.10 Weld 54-074, Coverage Diagram Part 3

Enclosure Attachment 2 to W3F1-2018-0065 Page 35 of 79 ID#54074: Circumference=141.4 VolumetricExamArea:4.32x141.4=610.84totalCRV.

18LimitedAreaCalculation:

x Volumeforthisarea:4.32x18=77.76/610.84=12.73%oftotalvolume.

x NoCoverage:18.58/77.76=23.89%

x OneDirectionCoverage:33.96/77.76=43.67/2=21.84%

x TwoDirectionCoverage:25.22/77.76=32.43%

x 21.84+32.43=54.27%ofthisareaachieved x 54.27x12.73=6.91%oftotalCRVachievedforthisarea.

25.7LimitedAreaCalculation:

x Volumeforthisarea:4.32x25.7=111.02/610.84=18.17%oftotalvolume.

x NoCoverage:35.95/111.02=32.38%

x OneDirectionCoverage:69.05/111.02=62.196/2=31.09%

x TwoDirectionCoverage:7.02/111.02=6.32%

x 6.32+31.09=37.41%ofthisareaachieved x 37.41x18.17=6.79%oftotalCRVachievedforthisarea.

97.7RemainingAreaCalculation:

x Volumeforthisarea:4.32x97.7=422.06/610.84=69.09%oftotalvolume.

x NoCoverage:4.39/422.06=1.04%

x OneDirectionCoverage:93.99/422.06=22.26/2=11.13%

x TwoDirectionCoverage:328.07/422.06=77.73%

x 11.13+77.73=88.86%ofthisareaachieved x 88.86x69.09=61.39%oftotalCRVachievedforthisarea.

TotalCoverageachievedfortheAxScan(Circ.Flaw):

x 6.91%+6.79%+61.39%=75.1%coverage ExamTotal:

AxScan:75.1%+CircScan:100%=175.09/2=87.55%TotalCRVAchieved

Enclosure Attachment 2 to W3F1-2018-0065 Page 36 of 79 Exam Cat. C-A Item C1.10 Weld 54-075, Coverage Diagram Part 1

Enclosure Attachment 2 to W3F1-2018-0065 Page 37 of 79 Exam Cat. C-A Item C1.10 Weld 54-075, Coverage Diagram Part 2

Enclosure Attachment 2 to W3F1-2018-0065 Page 38 of 79 Exam Cat. C-A Item C1.10 Weld 54-075, Coverage Diagram Part 3

Enclosure Attachment 2 to W3F1-2018-0065 Page 39 of 79 ID# 54-075 : Circumference=141.4 VolumetricExamArea:4.32x141.4=610.84totalCRV.

18LimitedAreaCalculation:

x Volumeforthisarea:4.32x18=77.76/610.84=12.73%oftotalvolume.

x NoCoverage:28.62/77.76=36.805%

x OneDirectionCoverage:30.92/77.76=39.76/2=19.88%

x TwoDirectionCoverage:18.22/77.76=23.43%

x 19.88+23.43=43.31%ofthisareaachieved x 43.31x12.73=5.51%oftotalCRVachievedforthisarea.

25.7LimitedAreaCalculation:

x Volumeforthisarea:4.32x25.7=111.02/610.84=18.17%oftotalvolume.

x NoCoverage:94.14/111.02=84.795%

x OneDirectionCoverage:46.77/111.02=42.127/2=21.06%

x TwoDirectionCoverage:8.5/111.02=7.656%

x 21.06+7.66=28.72%ofthisareaachieved x 28.72x18.17=5.22%oftotalCRVachievedforthisarea.

97.7RemainingAreaCalculation:

x Volumeforthisarea:4.32x97.7=422.06/610.84=69.09%oftotalvolume.

x NoCoverage:5.28/422.06=1.25%

x OneDirectionCoverage:113.32/422.06=26.85/2=13.42%

x TwoDirectionCoverage:303.46/422.06=71.9%

x 13.42+71.9=85.32%ofthisareaachieved x 85.32x69.09=58.947%oftotalCRVachievedforthisarea.

TotalCoverageachievedfortheAxScan(Circ.Flaw):

x 5.51%+5.22%+58.95%=69.68%coverage ExamTotal:

AxScan:69.68%+CircScan:100%=169.68/2=84.84%TotalCRVAchieved

Enclosure Attachment 2 to W3F1-2018-0065 Page 40 of 79 Exam Cat. R-A Item R1.11 Weld 08-009, General Diagram

Enclosure Attachment 2 to W3F1-2018-0065 Page 41 of 79 Exam Cat. R-A Item R1.11 Weld 08-009, Scanning Diagram

Enclosure Attachment 2 to W3F1-2018-0065 Page 42 of 79 Exam Cat. R-A Item R1.11 Weld 08-009, Axial Scanning Diagram Weld 08-009, Circumferential Scanning Diagram

Enclosure Attachment 2 to W3F1-2018-0065 Page 43 of 79 Exam Cat. R-A Item R1.11 Weld 08-009, Coverage and Flaw Evaluation Summary

Enclosure Attachment 2 to W3F1-2018-0065 Page 44 of 79 Exam Cat. R-A Item R1.11 Weld 14-006, General Diagram

Enclosure Attachment 2 to W3F1-2018-0065 Page 45 of 79 Exam Cat. R-A Item R1.11 Weld 14-006, Scanning Diagram

Enclosure Attachment 2 to W3F1-2018-0065 Page 46 of 79 Exam Cat. R-A Item R1.11 Weld 14-006, Coverage Summary

Enclosure Attachment 2 to W3F1-2018-0065 Page 47 of 79 Exam Cat. R-A Item R1.11 Weld 17-033, Coverage Diagram

Enclosure Attachment 2 to W3F1-2018-0065 Page 48 of 79 ID#17033:

UpstreamAx&CircScansachieved100%coverage.

DownStreamCircScanachieved100%coverage.

TotalDownStreamVolume:

x 1.34lengthx0.45heightx40.25circumference=24.27 DownStreamAxScanCoverage:

x (0.8x0.45=0.36)+(0.54x0.45/2=0.1215)=0.48 x 0.48x40.25=19.32 x 19.32/24.27=79.60%missed 100-79.60=20.4%AchievedforDownStreamAxScan.

ExamTotalCoverage:

x UpStreamAXScan=100%DownStreamAXScan=20.4%

x UpStreamCircScan=100%DownStreamCircScan=100%

x Total:320.4/4=80.1%CRVAchieved

Enclosure Attachment 2 to W3F1-2018-0065 Page 49 of 79 Exam Cat. R-A Item R1.11 Weld 21-004, Coverage Diagram Component is actually 90° Elbow to Pipe

Enclosure Attachment 2 to W3F1-2018-0065 Page 50 of 79 Exam Cat. R-A Item R1.11 Weld 32-002, Coverage Diagram Part 1

Enclosure Attachment 2 to W3F1-2018-0065 Page 51 of 79 Exam Cat. R-A Item R1.11 Weld 32-002, Coverage Diagram Part 2

Enclosure Attachment 2 to W3F1-2018-0065 Page 52 of 79 Exam Cat. R-A Item R1.11 Weld 32-003, Coverage Diagram Part 1

Enclosure Attachment 2 to W3F1-2018-0065 Page 53 of 79 Exam Cat. R-A Item R1.11 Weld 32-003, Coverage Diagram Part 2

Enclosure Attachment 2 to W3F1-2018-0065 Page 54 of 79 Exam Cat. R-A Item R1.11 Weld 32-004, Coverage Diagram Part 1

Enclosure Attachment 2 to W3F1-2018-0065 Page 55 of 79 Exam Cat. R-A Item R1.11 Weld 32-004, Coverage Diagram Part 2

Enclosure Attachment 2 to W3F1-2018-0065 Page 56 of 79 Exam Cat. R-A Item R1.11 Weld 32-005, Coverage Diagram Part 1

Enclosure Attachment 2 to W3F1-2018-0065 Page 57 of 79 Exam Cat. R-A Item R1.11 Weld 32-005, Coverage Diagram Part 2

Enclosure Attachment 2 to W3F1-2018-0065 Page 58 of 79 Exam Cat. R-A Item R1.20 Weld 06-007, Coverage Diagram Part 1

Enclosure Attachment 2 to W3F1-2018-0065 Page 59 of 79 ID#06007: DownstreamCircScanshave100%coverage. 1of2 DownStreamAXScanhasalimitationduetoanozzleconnection.23limitationwhile

scanningwiththe45°.Additionalcoveragewasachievedwitha60°for5.2oneachsideof

thenozzleforatotalof10.4additionalD.S.coveragewiththeAxScan.

UpStreamhasa30limitationDuetoPermanentSupport.(AllU.S.scansarelimited)

ExamArea:3.5TotalExamArea/2=1.75eachsideofCenterLine.

UPStreamexamareacalculation:

x 1.75x149Circumference=260.75 Up-Streamlimitation:

x 1.75x30=52.5 x 52.5/260.75=20.13%wasmissed x 100-20.13=79.87%coverageachieved.

x DownStreamexamareacalculation:

x 1.75X141=260.75

Enclosure Attachment 2 to W3F1-2018-0065 Page 60 of 79 2of2

DownStreamAxScan45°:

x 1.75x23totallimitation=40.25 x 40.25/260.75=15.43%wasmissed x 100-15.43=84.57%coverageachieved.

x DownStreamAxScanadditionalcoverage60°:

x (5.2x2=10.4extrascancoverage)x1.75=18.2 x 43.75/260.75=6.97%coverageachieved DownStreamAxScancombinedcoverage:

x 84.57%+6.97%=91.54%CoverageAchieved ExamTotalCoverage:

x UpStreamAX=79.87% DownStreamAX=91.54%

x UpStreamCirc.=79.87%DownStreamCirc.=100%

x Total:351.28/4=87.82%CRVAchieved

Enclosure Attachment 2 to W3F1-2018-0065 Page 61 of 79 Exam Cat. R-A Item R1.20 Weld 09-005, Coverage Diagram Part 1

Enclosure Attachment 2 to W3F1-2018-0065 Page 62 of 79 Exam Cat. R-A Item R1.20 Weld 09-005, Coverage Diagram Part 2

Enclosure Attachment 2 to W3F1-2018-0065 Page 63 of 79 Exam Cat. R-A Item R1.20 Weld 09-008, Coverage Diagram Part 1

Enclosure Attachment 2 to W3F1-2018-0065 Page 64 of 79 Exam Cat. R-A Item R1.20 Weld 09-008, Coverage Diagram Part 2

Enclosure Attachment 2 to W3F1-2018-0065 Page 65 of 79 Exam Cat. R-A Item R1.20 Weld 15-011, Coverage Diagram Part 1

Enclosure Attachment 2 to W3F1-2018-0065 Page 66 of 79 ID#15011:DownstreamCircScanshave100%coverage. 1of2

DownStreamAXScanhas(2)limitationsduetonozzleconnections.20limitationforeach

nozzlewhilescanningwiththe45°.Additionalcoveragewasachievedwitha60°for6.25on

eachsideofeachnozzleforatotalof25additionalD.S.coveragewiththeAxScan.

UpStreamhasa30limitationDuetoPermanentSupport.(AllU.S.scansarelimited)

ExamArea:3.5TotalExamArea/2=1.75eachsideofCenterLine.

UPStreamexamareacalculation:

x 1.75x141Circumference=246.75 Up-Streamlimitation:

x 1.75x30=52.5 x 52.5/246.75=21.27%wasmissed x 100-21.27=78.73%coverageachieved.

x

Enclosure Attachment 2 to W3F1-2018-0065 Page 67 of 79 DownStreamexamareacalculation: 2of2

x 1.75X141=246.75 DownStreamAxScan45°:

x 1.75x40totallimitation=70 x 70/246.75=28.36%wasmissed x 100-28.36=71.64%coverageachieved.

20Noz.

Limitation

ID

15011

20Noz.

Limitation

x DownStreamAxScanadditionalcoverage60°:

x (6.25x4=25extrascancoverage)x1.75=43.75 x 43.75/246.75=17.73%coverageachieved DownStreamAxScancombinedcoverage:

x 71.64%+17.73%=89.37%CoverageAchieved ExamTotalCoverage:

x UpStreamAX=78.73% DownStreamAX=89.37%

x UpStreamCirc.=78.73%DownStreamCirc.=100%

x Total:346.83/4=86.707%CRVAchieved

Enclosure Attachment 2 to W3F1-2018-0065 Page 68 of 79 ID#19008X1

Enclosure Attachment 2 to W3F1-2018-0065 Page 69 of 79 ID#19008X1

Enclosure Attachment 2 to W3F1-2018-0065 Page 70 of 79 ID#19006X1

Enclosure Attachment 2 to W3F1-2018-0065 Page 71 of 79 ID#19006X1

Enclosure Attachment 2 to W3F1-2018-0065 Page 72 of 79 ID#22031X2coveragecalculations

Enclosure Attachment 2 to W3F1-2018-0065 Page 73 of 79 ID#22031X245degreescans

Enclosure Attachment 2 to W3F1-2018-0065 Page 74 of 79 ID#22031X260degreescans

Enclosure Attachment 2 to W3F1-2018-0065 Page 75 of 79 ID#22031X270degreescans

Enclosure Attachment 2 to W3F1-2018-0065 Page 76 of 79 ID#22033X2CoverageCalculation

Enclosure Attachment 2 to W3F1-2018-0065 Page 77 of 79 ID#22033X245degreescans

Enclosure Attachment 2 to W3F1-2018-0065 Page 78 of 79 ID#22033X260degreescans

Enclosure Attachment 2 to W3F1-2018-0065 Page 79 of 79 ID#22033X270degreescans