john p. jarrell iii manager, regulatory assurance waterford 3inspection (isi) program for the...

10 CFR 50.55a W3F1-2017-0082 December 4, 2017 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Subject: Submittal of the Inservice Inspection Plan and Containment Inservice Inspection

Plan for the Fourth 10-Year Interval Waterford Steam Electric Station, Unit 3 (Waterford 3) Docket No. 50-382 License No. NPF-38

Dear Sir or Madam: As required by paragraph IWA-1400(c) of Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Entergy Operations, Inc. (Entergy) hereby submits the approved Inservice Inspection Plan and Containment Inservice Inspection Plan for the Fourth 10-year interval at Waterford 3. Entergy is providing these plans for information only. Entergy is not requesting NRC approval of the plans. The plans contain no new commitments. If you have any questions or require additional information, please contact the Regulatory Assurance Manager, John P. Jarrell, at (504) 739-6685. Sincerely, JPJ/MMZ Attachments: 1. Waterford 3 Fourth 10-Year Interval Inservice Inspection Plan 2. Waterford 3 Fourth 10-Year Interval Containment Inservice Inspection Plan

Entergy Operations, Inc. 17265 River Road Killona, LA 70057-3093 Tel 504-739-6685 [email protected]

John P. Jarrell IIIManager, Regulatory Assurance Waterford 3

W3F1-2017-0082 Page 2 cc: Mr. Kriss Kennedy, Regional Administrator

U.S. NRC, Region IV [email protected] U.S. NRC Project Manager for Waterford 3 [email protected] U.S. NRC Senior Resident Inspector for Waterford 3 [email protected] [email protected] Louisiana Department of Environmental Quality Office of Environmental Compliance Surveillance Division [email protected]

Attachment 1

to

W3F1-2017-0082

Waterford 3 Fourth 10-Year Interval Inservice Inspection Plan

(196 pages)

Program Section No.: SEP-ISI-104Revision No.: 7Page No.: Page 1 of 91

PROGRAM SECTIONFOR

ASME SECTION XI, DIVISION 1WF3 INSERVICE INSPECTION PROGRAM

ENTERGY NUCLEAR ENGINEERING PROGRAMS

APPLICABLE SITES

ALL SITES:

SpecificSites:

AN1 CNS GGNS IP3 PAL PNP VTY

AN2 HQN IP2 JAF PLP RBS WF3

Safety Related: Yes No

___

Program Section No.: SEPISMO4

Page No.: Page 2 ot 91

REVIEW AND CONCURRENCE SHEET

Program Section Title: ASME SECTION XI, DIVISION 1, WF3 INSERVICEINSPECTION PROGRAM

Prepared By:

______________________________

Date:

__________

Checked By:

____________________________

Date:

_________

ANII: Date: 7 /_Reviewed By (or NA)

Concurred: Date: tY-ResponsibupeMsor

/


REVISION STATUS SHEET

REVISION SUMMARY

REVISION DESCRIPTION

0 Initial Revision Issued For Use. Based on CEP-ISI-104 and an update of the last revision with thefollowing changes made.

1 Updated program to complete replacement ofMRP-139 Augmented inspection program withthe N-770-1 requirements as allowed by 10 CFR50.55a.

Updated Figures WTR-1-4100, WTR-1-4101,WTR-1-4200 and WTR-1-4201 to reflect ColdLeg RTD weld Component IDs that require N-722-1 examination. This was previously capturedin A600 Program.

2 Updated W3-R&R-006 Augmented Inspectiondiscussion to show a 9 year examinationfrequency (Ref. CR-WF3-2011-6576. AddedMRP-146 Augmented Inspection Program, addedW3-ISI-020, W3-ISI-021 and W3-ISI-023 to Table3.4.1, incorporated SEP-ISI-104-PCN-2, SEP-ISI-104-PCN-3, SEP-ISI-104-PCN-4, insertedreference to 77FR3073 to Section 2.1B andupdated Section 2.2 to not refer to Alloy 600Iddeal database.

3 Updated WTR-1-1300 per SEP-ISI-104 PCN-5.Updated Figure WTR-1-4205 to reflect addition ofwelds IDs 22-031X2, 22-033X2, and 22-064.

4 Update Code Case N-532-4 to N-532-5 on page32. Add Reference to CEP-RR-001 on Page 38.


REVISION STATUS SHEET

REVISION SUMMARY

REVISION DESCRIPTION

5 Deleted Code Case N-664 from pg. 39(reference: CR-HQN-2015-01353 CA-008)

6 Revised wording in Code Case N-648-1 to thelatest revision of the Code Case on pg. 39.

7 Updated SEP-ISI-104 to incorporate ASME Boilerand Pressure Vessel Code Section XI 2007Edition, 2008 Addenda for Fourth Ten YearInterval and reformatted for consistency withEntergy Inservice Inspection Programs preparedby Iddeal Concepts, Inc. This is a completerevision of the document therefore revision barswere not used.


Table of Contents

Section Description Page NumberNA Cover Page 1

NA Revision and Concurrence Sheet 2

NA Revision Status Sheet 3

NA Table of Contents 5

1.0 ASME Section XI Inservice Inspection Program 8

1.1 Purpose 8

1.2 General 11

1.3 Inspection Intervals 11

1.4 ASME Section XI Code of Record for the Fourth InserviceInspection Interval

12

1.5 ASME Section XI Inservice Inspection ProgramDescription

14

1.6 Records, Reports, and Submittals 16

1.7 Administrative Controls 18

2.0 ASME Code Case Applicability 19

2.1 Adoption of Code Cases 19

2.2 Regulatory Guide 1.147, Revision 17 Approved CodeCases

21

2.3 Code Cases Adopted Via NRC Approved Requests 23

2.4 Code Cases Required by 10 CFR 50.55a 23

3.0 Relief Requests 24

3.1 Request for Alternatives 24


Table of Contents

Section Description Page Number3.2 Relief Request Required due to Impracticality or Limited

Examinations24

3.3 Requests to use Later Edition and Addenda of ASMESection XI

25

4.0 Developmental References 27

5.0 Augmented Examination Programs 27

5.1 Augmented Examinations for External Commitments 28

5.2 Owner Elected Examinations for Internal Commitments 33

5.3 License Renewal Examinations for Aging ManagementCommitments

33

6.0 ASME Systems & Examination Boundaries 33

6.1 ASME Class 1, 2 and 3 33

6.2 Calibration Standards 35

7.0 Application Criteria and Code Compliance 36

7.1 ASME Section XI 36

7.2 Augmented Programs 45

8.0 Inservice Inspection Data Management Software 71

9.0 Examination Evaluation Criteria 73

9.1 Successive Inspections 73

9.2 Additional Examinations 75

10.0 Risk-Informed ISI Program 80

TABLES

Table1.3-1

WF3 ISI Component Scheduling 11

Table2.2-1

Code Cases Adopted from Regulatory Guide 1.147 21

Table2.3-1

Code Cases Adopted Via NRC Approved Requests 23


Table of Contents

Section Description Page NumberTable2.4-1

Code Cases Required by 10 CFR 50.55a 23

Table3.0-1

Waterford Unit No.3 Fourth Interval Relief Requests 26

Table 7.1 Waterford Unit No.3 Code Category Summary 47

FIGURES

Figure 1 WF3 Program Plan 10

Figure 2 WF3 4th ISI Interval Schedule 12

APPENDIX

AppendixA

Waterford Unit No.3 ASME Code Class SystemsISI Boundary Diagrams

86

AppendixB

Waterford Unit No.3 Class 1, Class 2 and Class 3 ISIIsometrics and Equipment Drawings

88


1.0 ASME Section XI Inservice Inspection Program

1.1 Purpose

Implementation of an Inservice Inspection Program in accordance with the requirementsof ASME Section XI, Division 1, is mandated by the United States Code of FederalRegulations, Title 10, Part 50, Section 55a (10 CFR 50.55a).This Program Section contains the details of the ASME Section XI, Division 1, InserviceInspection (ISI) Program for the Waterford 3 Steam Electric Station (WF3).This Inservice Inspection Program is for the fourth 120-month Inservice InspectionInterval. The coordination of refueling outages and periods within the current InserviceInspection interval for WF3 is shown in Figure 2 WF3 4th ISI Interval Schedule.The scope of this Program Section includes the inspection of Class 1, 2, and 3 pressureretaining components and their supports. This Program Section also includes augmentedinservice examinations that require NDE inspections and are maintained andimplemented by the ISI Program. Other augmented examinations are maintained andimplemented in independent programs due to their complexity, subject matter, orbecause the examinations are not related to the ISI Program.Changes to the contents of this Program Section shall be performed in accordance withNuclear Management Manual Procedure EN-DC-174.This inservice inspection plan is controlled by 10 CFR 50.55a. The original and anychanges that meet 10 CFR 50.55a do not require a Process Applicability Determinationper EN-LI-100.

This plan’s objective is to provide a traceable link between the governing coderequirements and the implementing procedures in order to ensure that Regulatory rulesand ASME Section XI Code requirements for the inservice inspection of safety relatedsystems, components and structures are being fulfilled.These instructions provide the necessary guidance for the Corporate & StationEngineering Programs personnel at Entergy’s Waterford 3 Steam Electric Station (WF3)to ensure the following:1) Conformance to Title 10, Section 50.55a of the Code of Federal Regulations (10

CFR 50.55a).2) Conformance to the 2007 Edition 2008 Addenda of Section XI of the American

Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code.3) Conformance to Entergy Corporation and Station policies, practices and procedures.4) The necessary technical content included in WF3 Inservice Inspection Program and

implementing procedures.


5) The proper ASME Section XI Code required examinations, tests and administrativeprocedures are implemented.

6) The proper ASME Section XI Code request for alternatives and relief requests aresubmitted to and approved by the regulatory authority.

7) Component repair and replacement activities are performed in accordance withASME Section XI Code requirements.

8) The proper examination, test and repair and replacement records and reports aremaintained and submitted.

Figure 1 WF3 Program Plan illustrates how this program plan effectively functions as acentral source to help ensure all regulatory rules and Entergy requirements areincorporated into the Inservice Inspection Program. This program plan provides a usefulaid in program self-assessments, procedure preparation and/or revision, managementquick reference, and program familiarization.

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1.2 General

The Waterford 3 Steam Electric Station nuclear steam supply system is a CombustionEngineering two loop Pressurized Water Reactor design. Entergy obtained aConstruction Permit to build WF3 on November 14, 1974. After satisfactory plantconstruction and pre-operational testing was completed, a full power operating license,NPF-38, was granted on March 16, 1985. WF3 subsequently commenced commercialoperation on September 24, 1985. The NRC Docket Number assigned to WF3 is 050-00382.

1.3 Inspection Intervals

The initial 120-month ISI Program commenced with commercial operation on September24, 1985. However, by authorization from the Director of the Office of Nuclear Regulation(Reference ILN 94-0177 and GNRI 96-00244) the first 120-month interval was extendeduntil June 30, 1997. The second 120-month interval began on July 1, 1997 and continuedthrough June 30, 2007, but was extended 11 months to May 31, 2008, as allowed byASME Section XI, IWA-2430(c)(1). The third 120-month interval began on May 31, 2008and continued to November 30, 2017 thus reclaiming 6 months of the 11 monthextension that occurred in the 2nd interval.The Fourth Inspection Interval is divided into inspection periods consistent with ASMESection XI Table IWB-2411-1 (Reference Table 1.3-1). The inspection periods arescheduled as follows:1st Period: From December 1, 2017 through November 30, 2020 (3 Years)2nd Period: From December 1, 2020 through November 30, 2024 (4 Years)3rd Period: From December 1, 2024 through November 30, 2027 (3 Years)

In accordance with ASME Section XI, IWA-2430(c)(3), that portion of an inspectioninterval described as an inspection period may be reduced or extended by as much as 1year. This adjustment shall not alter the requirements for scheduling inspection intervals.Outages during the 4th inservice inspection interval are scheduled in Figure 2 WF3 4th ISIInterval Schedule:

TABLE 1.3-1WF3 ISI Component Scheduling

INSPECTIONINTERVAL

INSPECTION PERIODCALENDAR YEARS OF

PLANT SERVICE WITHINTHE INTERVAL

MINIMUMEXAMINATIONSCOMPLETED, %

MAXIMUMEXAMINATIONSCREDITED, %

4th 3 16 50

4th 7 501 75

4th 10 100 100


1If the first period completion percentage for any examination category exceeds 34%, at least 16% of therequired examinations shall be performed in the second period.

Figure 2

WF3 4th ISI Interval Schedule

1.4 ASME Section XI Code of Record for the Fourth Inservice Inspection Interval

Entergy is required to update the ASME Section XI, ISI Program for WF3 once every tenyears. The regulations in 10 CFR 50.55a(g)(4) establish the effective ASME Code editionand addenda to be used by licensees for performing inservice inspections of components(including supports). Paragraph 50.55a(g)(4)(ii) requires the use of the latest edition andaddenda that has been incorporated by 10 CFR 50.55a(a), 12 months before the start ofthe 120-month inspection interval. This is considered the Code of Record.CFR82FR32934 was published in July 2017 requiring the implementation of Code CasesN-729 and N-770 to N-729-4 and N-770-2 respectively. This Final Rule became effectiveAugust 17, 2017.Based on 10 CFR 50.55a(a)(1)(ii)(C), the WF3 Fourth Ten-Year Interval ISI ProgramPlan is required to meet the 2007 Edition of the American Society of MechanicalEngineers (ASME) Boiler and Pressure Vessel Code Section XI with the 2008 Addendawith the associated conditions contained in 10 CFR 50.55a(b)(2) as defined below. 10CFR 50.55a conditions applicable to the System Pressure Testing, Containment

1/2017

1RF24S 2022

1RF26S 2025

1RF27F 2026

2nd Period48 Months

3rd Period36 Months

12/01/2017Start 4TH ISIInterval

11/30/2027End 4TH ISIInterval

1RF23F 2020

1RF25F 2023

1/2018 1/2019 1/2020 1/2021 1/2022 1/2023 1/2024 1/2026

12/01/2020 12/01/2024

1st Period36 Months

1RF22S 2019

1/2025 1/2027 1/2028


Inservice Inspection and Repair/Replacement Activities are address in their applicableProgram Sections.10 CFR 50.55a(b)(2)(x), WF3 will apply the station 10 CFR 50 Appendix B QualityAssurance Program to ASME Section XI activities.10 CFR 50.55a(b)(2)(xviii)(A), the Level I and II nondestructive examination personnelmust be recertified on a 3-year interval in lieu of the 5 year interval in IWA-2314(a) andIWA-2314(b).10 CFR 50.55a(b)(2)(xix), the provisions for substituting alternative examination methods,a combination of methods, or newly developed techniques in the 1997 Addenda of IWA-2240 must be applied. The provisions in IWA-4520(b)(2) and IWA-4521 of the 2008Addenda through the latest edition and addenda incorporated by reference in paragraph(a)(1)(ii) of this section, allowing the substitution of ultrasonic examination forradiographic examination specified in the Construction Code, are not approved for use.10 CFR 50.55a(b)(2)(xxi)(A), the provisions of Table IWB-2500-1, Examination CategoryB-D, Full Penetration Welded Nozzles in Vessels, Items B3.120 and B3.140 of the 1998Edition must be applied when using the 1999 Addenda through the latest edition andaddenda incorporated by reference in paragraph (a)(1)(ii) of this section. A visualexamination with magnification that has a resolution sensitivity to detect a 1-mil widthwire or crack, utilizing the allowable flaw length criteria in Table IWB-3512-1, 1997Addenda through the latest edition and addenda incorporated by reference inparagraph(a)(1)(ii) of this section, with a limiting assumption on the flaw aspect ratio (i.e.,a/l=0.5), may be performed instead of an ultrasonic examination.10 CFR 50.55a(b)(2)(xxii), The use of the provision in IWA-2220, “Surface Examination”,of Section XI, 2001 Edition through the latest edition and addenda incorporated byreference in paragraph (a)(1)(ii) of this section, that allows use of an ultrasonicexamination is prohibited.10 CFR 50.55a(b)(2)(xxviii), Analysis of flaws, Licensees using ASME BPV Code,Section XI, Appendix A must use the following conditions when implementing Equation(2) in A-4300(b)(1): For R < 0, KI depends on the crack depth (a), and the flow stress

f). The flow stress is defined by f = 1 2( ys + ult), where ys is the yield strength andult is the ultimate tensile strength in units ksi (MPa) and a is in units in. (mm). For –2 R 0 and Kmax – Kmin 0.8 × 1.12 f a), S = 1 and KI = Kmax. For R < –2 and Kmax –

Kmin 0.8 × 1.12 f a), S = 1 and KI = (1 – R) Kmax/3. For R < 0 and Kmax – Kmin > 0.8× 1.12 f a), S = 1 and KI = Kmax – Kmin.ASME Code Cases N-729-4, N-722-1 and N-770-2 with the applicable conditions asidentified in 10 CFR 50.55a(g)(6)(ii)(D),(E) and (F).

1.5 ASME Section XI Inservice Inspection Program Description

The ASME Section XI Inservice Inspection Program for the Fourth Inspection Interval iscomprised of the following individual programs:


ASME Section XI and Augmented ISI Program for pressure retaining componentsand their supports

ASME Section XI System Pressure Test Program

ASME Section XI Containment Inservice Inspection Program

ASME Section XI Repair and Replacement ProgramThese programs are separate documents or procedures, each bearing the title of theprogram. The ISI Programs are administered through EN-DC-174, “Engineering ProgramSections”.For the purpose of clarification, the following definitions for terms used in the ASMESection XI Inservice Inspection program are:PROGRAM The term “program” is used to provide the structure and methods for

accomplishment of the object and is to be considered synonymous with theterm “plan” as used in ASME Section XI, 2007 Edition, 2008 Addenda,Article IWA-2400.

SCHEDULE The term “schedule” is used to define the detailed scheme of performing therequired inspections over the ten-year interval.

1.5.1 Ten-Year Inservice Inspection (ISI) Program Description

The Ten-Year Inservice Inspection Program details WF3 compliance with ASME Code,Section XI 2007 Edition, 2008 Addenda, Articles IWA, IWB, IWC, IWD, and IWF forexamination of Class 1, 2, and 3 pressure retaining items and their supports. Thisdocument defines the Class 1, 2, and 3, components and the Code requiredexaminations for each ASME Section XI examination category, and the augmentedinspection scope.The purpose of the Ten-Year ISI Program is to periodically perform nondestructiveexamination of ASME Class 1, 2, or 3 safety related components and supports in order toidentify the presence of service related degradation.The administrative procedures and Inspection Schedule described in the Ten-Year ISIProgram, combined with applicable WF3, Entergy, and approved vendor procedures,constitute the ISI portion of the Ten-Year ISI Program required by FSAR Sections 5.2.4and 6.6.For convenience, the Ten-Year ISI Program also contains augmented examinations thatare outside the scope of 10 CFR 50.55a. These examinations may result from activitiesincluding, but not limited to, commitments made to the NRC outside the scope of 10 CFR50.55a, internal commitments, License Renewal commitments, or industry initiatives.These examinations may use ASME Section XI techniques and procedures as defined inthe commitment, however, the requirements of ASME Section XI, including reporting, do


not apply. These augmented examinations are not required by the ASME Code and arenot included in the summary totals for the specific examination category.The Ten-Year ISI Program schedule is contained in the IDDEAL Software Suite®computer database. This information is retained at the plant site and is available forreview.

1.5.2 Repair and Replacement Program Description

ASME Section XI requirements for Class 1, 2 and 3 and MC pressure retainingcomponents and supports repairs and replacements are not contained in this plan. CEP-RR- 001, ASME Section XI Repair/Replacement Program is the implementing procedurewhich describes the implementation process for the repair and replacement provisions ofASME Code, Section XI Article IWA-4000.

1.5.3 Snubber Program Description

The Snubber Program requirements are not contained in this plan. Snubbers (pin-to-pinportion) will be examined and tested in accordance with plant Snubber Programcontained in, SEP-WF3-IST-002. Snubber support hardware such as lugs, bolting, pinsand clamps between the snubber pins and component (or the snubber pin and thebuilding structure) will be examined in accordance with Section XI, Subsection IWF, perthis Program Section.

1.5.4 Pressure Test Program Description

ASME Section XI requirements for Class 1, 2 and 3 pressure testing are not contained inthis plan. CEP-PT-001, ASME Section XI Pressure Testing Program and SEP-PT-WF3-001, Inservice Inspection Pressure Testing (PT) Program Section, satisfies therequirements established in ASME, Section XI, Articles IWA-5000, IWB-5000, IWC-5000,and IWD-5000.

1.5.5 Containment Inspection Program Description

ASME Section XI requirements for MC components and component supports are notcontained in this plan. SEP-CISI-104, Containment Inservice Inspection Programimplements the requirements of the ASME Code, Section XI Articles IWE (Class MCcomponents).

1.5.6 Pump and Valve Program DescriptionThe Inservice Testing (IST) Program requirements are not contained in this plan. TheWF3 Inservice Testing Program implements the requirements of the ASME OM Code.


1.5.7 Steam Generator Tube Surveillance Program Description

In accordance with ASME Section XI 2007 Edition, 2008 Addenda IWB-2500-1Examination Category B-Q, the Steam Generator Tube Inspection Program is inaccordance with Technical Specification 6.5.9 in lieu of ASME Section XI.

1.6 Records, Reports, and Submittals

The requirements of Code Case N-532-5 shall be met in lieu of the requirements of IWA-6210(c), (d), (e), and (f), IWA-6220, IWA-6230(b), (c), and (d), and IWA-6240(b). All otherrequirements of IWA-6000 and the other requirements of Section XI applicable to recordsand reporting shall be met as described below.

1.6.1 RecordsRecords of examinations, tests, and repair replacement activities shall be prepared inaccordance with the governing procedure or program document.Records and reports required by Section XI and this program are safety related and shallbe maintained as a permanent plant record. They shall be filed in a manner to ensureaccessibility by the Authorized Nuclear Inservice Inspector (ANII). The storage andmaintenance of these records are under the auspices of the Quality Assurance Program.Records and reports shall be either the original or a reproduced legible copy.Alternatively, they may be maintained in an electronic format provided the requirementsof IWA-6320(a) are met. Radiographs may be microfilmed or digitally reproduced. Digitalreproduction shall be in accordance with IWA-6320(b).Inservice Inspection Records, as a minimum shall include: Record Index Preservice and inservice inspection plans and schedules Preservice and inservice inspection reports Records and reports of repair/replacement activities Records of flaw acceptance by analytical evaluation Records of regions in ferritic Class 1 components with modified acceptance criteria Nondestructive examination procedures Nondestructive examination records Pressure test procedures Pressure test records


1.6.2 Reports and Submittals

Reports and submittals comprise those documents or records that are required to besubmitted to the NRC either on a recurring basis or as a result of activities described bySection XI. Reports shall be as described below. Reports and submittals are provided to theNRC for “Information Only” to meet a specific Section XI requirement. NRC approval isnot required.

In accordance with IWA-1400(c), the initial ISI Program shall be provided to the NRC.Program Change Notices (PCN) is not required to be submitted.

The Summary Reports required by ASME Section XI, 2007 Edition, 2008 Addenda IWA-6000 are replaced by the Owner’s Activity Report described by Code Case N-532-5. FormOAR-1 will be prepared, maintained, and submitted in accordance with the applicableProgram Section. The Owner’s Activity Report shall be prepared to meet the requirementsof the Code Case and submitted to the NRC within 90 calendar days of completing eachrefueling outage. The report shall include all applicable activities of the operating cycle notincluded in the previous report.

Analytical evaluations that accept items for continued service in accordance with IWB-3132.3, IWB-3142.4, IWC-3122.3, IWC-3132.3, and IWD-3600 shall be submitted to theNRC. If the evaluation is performed during a refueling outage, the submittal may beincluded with the Owner’s Activity Report provided the cover letter makes specificreference to the contained analytical evaluation. Evaluations performed during theoperating cycle between refueling outages shall be submitted independent of the Owner’sActivity Report. As a guide, these submittals should be timely and within 30 calendardays of completing the analytical evaluation.

Evaluation procedures used in analytical evaluations of flaws in austenitic and ferriticpiping shall be provided to the NRC in accordance with IWB-3640, IWC-3640, and IWD-3640. A onetime submittal is acceptable provided subsequent revisions are provided andthe scope and application of the procedure does not change. The cover letter shouldindicate that the procedure is only submitted once (not for each use) and what criteria willbe used to determine when additional submittals will be made.

When acceptance standards have been modified as a result of using smaller flaw sizes indeveloping the Pressure/Temperature Limit Curves in accordance with IWB-3410.2, themodified acceptance standards shall be filed with the NRC.

1.6.3 Incomplete or Missing ExaminationsResolution and tracking of incomplete or missed examinations shall be in accordancewith the Program Change Notice (PCN) and Condition Report process as describedbelow and EN-DC-174, Engineering Program Sections:

1.6.3.1 PCN Requirements


A PCN to the program shall be developed in a timely manner. The PCN shouldcontain the following:a) The affected component.b) The examination requirement that has not been, or will not be, met.c) The reason for incomplete or missed examination.d) Alternate examinations performed or recommended, (i.e. best effort vs. VT-1,

etc.) to include reasons why this is acceptable.e) For partial examinations, the extent of coverage the component received or will

receive using approved methods.1.6.3.2 Request for Relief

If a Request for Relief is required for an incomplete or missing examination, thefollowing steps shall be completed:a) The site should develop and submit the necessary documentation to the

NRC1.b) If the Request for Relief is approved by the NRC, the approval should be

incorporated into the program plan by a PCN.c) If the Request for Relief is disapproved, the site should initiate a Condition

Report.1.6.3.3 Missed Examinations Which Cannot Be Made Up

If it is discovered that a required examination has been missed and cannot beperformed before the end of the inspection period in accordance with theProgram Plan, a Condition Report should be initiated.

NOTE:The period includes any extensions made within the ASME Section XI and 10 CFR 50.55aprovisions. The end of the period does not occur until any applicable extensions arecompleted.

1.7 Administrative Controls

This program is written and implemented as a Program Section meeting the requirementsof EN-DC-174, “Program Sections”. This Program Section will be maintained throughrevisions and Program Change Notices in accordance with EN-DC-174.

1 For information on what the NRC expects to see in Coverage Relief Request refer to the presentation made by StephenCumblidge to the Industry/NRC NDE technical Information Exchange Public Meeting on January 13-15, 2015 (ML15013A266)


This program will be maintained current to reflect applicable changes to plantconfiguration through the review process defined by EN-DC-115, Engineering ChangeProcess”.Additions of items to the program resulting from changes to the plant configuration will beincorporated and scheduled for inspection or examination in accordance withIWB/IWC/IWD-2411 and IWF-2410.Organizational and divisions of responsibilities for the management and implementationof the ISI Program are defined in EN-DC-351 “Inservice Inspection Program Duties andResponsibilities” and CEP-ISI-100 “ASME Section XI, Division 1 Fleet AdministrativeControls for Inservice Inspection Program”.Several elements required by Section XI to be contained in the ISI Program aremaintained in the Iddeal Concepts Software Suite®. This software and its contents arepart of the formal ISI program and are controlled in accordance with Program SectionCEP-COS-0100, “Control and Use of Iddeal Concepts Software”.The initial ISI Program Plan, revisions, and PCNs are subject to review by the AuthorizedNuclear Inservice Inspector (ANII).

2.0 ASME Code Case Applicability

This section contains ASME Section XI Code Cases applicable to the WF3 Fourth TenYear Inspection Interval. ASME Section XI Code Cases applicable to System PressureTesting, Containment Inservice Inspection, Repair/Replacement Activities, and NDE areaddressed in their associated Program Sections; CEP-PT-001, SEP-CISI-104, CEP-RR-001, and CEP-NDE-100, respectively.

2.1 Adoption of Code Cases

ASME Section XI Code Cases adopted for ISI and related NDE activities for the FourthInterval are listed in Tables 2.2-1, 2.3-1, and 2.4-1. The use of Code Cases is inaccordance with ASME Section XI, IWA-2440, 10 CFR 50.55a, and Regulatory Guide1.147. As permitted by ASME Section XI and Regulatory Guide 1.147 or 10 CFR 50.55a,ASME Section XI Code Cases may be adopted and used as described below:

2.1.1 Adoption of Code Cases Listed for Generic Use in Regulatory Guide 1.147

Code Cases that are listed for generic use in the latest revision of Regulatory Guide1.147 may be included in the ISI program provided any additional conditions specified inthe Regulatory Guide are also incorporated. Table 2.2-1 identifies the Code Casesapproved for generic use and adopted for the fourth interval.


2.1.2 Adoption of Code Cases Not Approved in Regulatory Guide 1.147

Certain Code Cases that have been approved by the ASME Board of Nuclear Codes andStandards may not have been reviewed and approved by the NRC Staff for generic useand listed in Regulatory Guide 1.147. Use of such Code Cases may be requested in theform of a “Request for Alternative” in accordance with 10 CFR 50.55a(a)(z). Onceapproved, these Requests for Alternatives will be available for use until such time that theCode Cases are adopted into Regulatory Guide 1.147, at which time compliance with theprovisions contained in the Regulatory Guide is required.Table 2.3-1 identifies those Code Cases that have been requested through Requests forAlternatives. For convenience to the user of this ISI Program, the appropriate internalcorrespondence number is provided to assist in their retrieval from Document Control. Allother Requests for Alternatives and Relief Requests (those not associated with NRCapproval of Code Cases) are addressed in Section 3.0.

2.1.3 Adoption of Code Cases Mandated by 10 CFR 50.55a

Code Cases required by rule in 10 CFR 50.55a are incorporated into the ISI Program andimplemented at the specified schedule. Code Cases currently required by 10 CFR 50.55aare identified in Table 2.4-1.

2.1.4 Use of Annulled Code Cases

As permitted by Regulatory Guide 1.147(B), Code Cases that have been adopted for usein the current inspection interval that are subsequently annulled by ASME may be usedfor the remainder of the interval.

2.1.5 Code Case Revisions

Initial adoption of a Code Case requires use of the latest revision of that Code Case listedin Regulatory Guide 1.147. However, if an adopted Code Case is later revised andapproved by the NRC, then either the earlier or later revision may be used as permittedby Regulatory Guide 1.147(B). An exception to this provision would be the inclusion ofany conditions on the later revision necessary to enhance safety. In this situation, theconditions imposed on the later revision must be incorporated into the program.

2.1.6 Adoption of Code Cases Issued Subsequent to Filing the Inservice Inspection Plan

Code Cases issued by ASME subsequent to filing the Inservice Inspection Plan with theNRC may be incorporated within the provisions of paragraphs 2.1.1 or 2.1.2 by revisionto the ISI Plan. Any subsequent Code Cases shall be incorporated into the program andidentified in either Table 2.2-1 or 2.3-1, as applicable, prior to their use.


2.1.7 Non Inservice Inspection Code Cases

Only Code Cases applicable to ISI and related nondestructive examinationrequirements for Class 1, 2, and 3 components and component supports are includedin Table 2.2-1, 2.3-1 and 2.4-1. Code Cases applicable to System Pressure Testing,Containment Inservice Inspection, Repair/Replacement Activities, and NDE areaddressed in their associated Program Sections; CEP-PT-001, SEP-CISI-104, CEP-RR-001, and CEP-NDE-100, respectively.

2.1.8 Code Cases not approved for use by the NRC

Code Cases that have been approved by the ASME Board of Nuclear Codes andStandards may not be approved by the NRC Staff for generic use. These Code Cases arelisted in Regulatory Guide 1.193, ASME Code Cases Not Approved for Use. However, theNRC may approve their use in specific cases. Code Cases listed in Regulatory Guide 1.193will not be used at WF3 without an approved Request for Alternative in accordance with 10CFR 50.55a(a)(z).

2.2 Regulatory Guide 1.147, Revision 17 Approved Code Cases

Table 2.2-1 - Code Cases Adopted from Regulatory Guide 1.147Code CaseNumber Title NRC Conditions

N-526 Alternative Requirements for SuccessiveInspections of Class 1 and 2 Vessels

None

N-532-5 Repair/Replacement ActivityDocumentation Requirements andInservice Inspection Summary ReportPreparation and Submission

None

N-586-1 Alternative Additional ExaminationRequirements for Classes 1, 2, and 3Piping, Components, and Supports

None

N-613-1 Ultrasonic Examination of PenetrationNozzles in Vessels, Examination CategoryB-D, Item Nos. B3.10 and B3.90, ReactorNozzle-to-Vessel Welds, Figs. IWB-2500-7(a), (b), and (c).

None


Table 2.2-1 - Code Cases Adopted from Regulatory Guide 1.147Code CaseNumber Title NRC Conditions

N-639 Alternative Calibration Block Material Chemical ranges of thecalibration block may varyfrom the materialsspecification if (1) it iswithin the chemical rangeof the componentspecification to beinspected, and (2) thephase and grain shapeare maintained in thesame ranges produced bythe thermal processrequired by the materialspecification.

N-648-1 Alternative Requirements for Inner RadiusExamination of Class 1 Reactor VesselNozzles

In lieu of a UTexamination, licenseesmay perform a VT-1examination inaccordance with the codeof record for the InserviceInspection Programutilizing the allowable flawlength criteria of TableIWB-3512-1 with limitingassumptions on the flawaspect ratio.

N-716-1 Alternative Classification and ExaminationRequirements

None

N-735 Successive Inspection of Class 1 and 2Piping Welds

None

N-765 Alternatives to Inspection IntervalScheduling Requirements of IWA-2430

None

N-773 Alternative Qualification Criteria for EddyCurrent Examinations of Piping InsideSurfaces

None


2.3 Code Cases Adopted Via NRC Approved Requests

The following ASME Code Cases are not contained in Regulatory Guide 1.147, Revision17 and require a request for alternative prior to implementation. Refer to Section 3.0 ofthis plan for the applicable requests.

Table 2.3-1 - Code Cases Adopted Via NRC Approved RequestsCode Case

Number TitleRequest for

Alternative No.NA NA NA

2.4 Code Cases Required by 10 CFR 50.55a

The following ASME Code Cases are not contained in Regulatory Guide 1.147, Revision17, but are mandated in 10 CFR 50.55a.

Table 2.4-1 - Code Cases Required by 10 CFR 50.55aCode Case

Number Title NotesN-722-1 Additional Examinations for PWR Pressure

Retaining Welds in Class 1 ComponentsFabricated With Alloy 600/82/182 Materials

Conditions specifiedin paragraphs(g)(6)(ii)(E)(2)through (4) of 10CFR 50.55a.

N-729-4 Alternative Examination Requirements for PWRReactor Vessel Upper Heads With NozzlesHaving Pressure-Retaining Partial-PenetrationWelds

Conditions specifiedin paragraphs(g)(6)(ii)(D)(2)through (4) of 10CFR 50.55a.

N-770-2 Alternative Examination Requirements andAcceptance Standards for Class 1 PWR Pipingand Vessel Nozzle Butt Welds Fabricated WithUNS N06082 or UNS W86182 Weld FillerMaterial With or Without Application of ListedMitigation Activities

Conditions specifiedin paragraphs(g)(6)(ii)(F)(2)through (13) of 10CFR 50.55a.


3.0 Relief Requests

Throughout this program, the term “relief request” is used interchangeably referring tosubmittals to the NRC requesting permission to deviate from either an ASME Section XIrequirement, a 10 CFR 50.55a rule, or to use provisions from Editions or Addenda ofSection XI not approved by the NRC as referenced in 10 CFR 50.55a(b). However, whencommunicating with the NRC and in written requests to deviate, the terms as definedbelow must be used for clarity and to satisfy 10 CFR 50.55a. Submittals to the NRC mustclearly identify which of the below rules are being used to request the deviation.Table 3.0-1 contains an index of Relief Requests written in accordance with 10 CFR50.55a(a)(g)(5)(iii) and 10 CFR 50.55a(z). The applicable Entergy submittal and NRCSafety Evaluation Report (SER) correspondence numbers are also included for eachrequest.Only relief requests associated with the ISI program and the supporting nondestructiveexamination requirements are listed in Table 3.0-1. Relief Requests applicable to SystemPressure Testing, Containment Inservice Inspection, Repair/Replacement Activities, andNDE are addressed in their associated Program Sections; CEP-PT-001 or SEP-PT-WF3-001, SEP-CISI-104, CEP-RR-001, and CEP-NDE-100, respectively.

3.1 Request for Alternatives

When seeking an alternative to the rules contained in 10 CFR 50.55a(b) through (h) therequest is submitted under the provision of 10 CFR 50.55a(z). Once approved by theDirector, Office of Nuclear Reactor Regulation, the alternative may be incorporated intothe ISI program. These types of requests are typically used to request use of CodeCases, Code Edition, or Addenda not yet approved by the NRC. Request for Alternativesmust be approved by the NRC prior to their implementation or use. Within the provisionsof 10 CFR 50.55a(z) there are two specific methods of submittal:10 CFR 50.55a(z)(1) Acceptable level of quality and safety. The proposed alternativewould provide an acceptable level of quality and safety.10 CFR 50.55a(z)(2) Hardship without a compensating increase in quality and safety.Compliance with the specified requirements of this section would result in hardship orunusual difficulty without a compensating increase in the level of quality and safety.

3.2 Relief Request Required due to Impracticality or Limited Examinations

10 CFR 50.55(a)(g)(5)(iii) and (iv) allows relief to be requested in instances when a Coderequirement is deemed impractical with (iv) being specific to examination requirementsthat are determined to be impractical. The provisions of these two paragraphs aretypically used to address impracticalities like limited examination coverage. Under 10CFR 50.55(a)(g)(5)(iv), relief requests for impracticality determinations must be submitted


for NRC review and approval not later than 12 months after the expiration of the initial orsubsequent 120-month inspection interval for which relief is sought.In cases where conformance with an ASME Section XI requirement for inserviceinspection is considered impractical, Entergy will notify the NRC and submit informationto support the determination, as required by 10 CFR 50.55a(g)(5). The submittal of thisinformation will be referred to as a Request for Relief.In the event that the entire examination volume or surface (as defined in the ASME Code)cannot be examined due to interference by another component or part geometry, then inaccordance with ASME Section XI IWA-2200(c) a request for relief will be submitted.ASME Section XI IWA-2200(c) does not apply to the bare metal visual examinationrequired by Code Case N-729-4. When performing visual examinations to meet N-729-4,the requirements of N-729-4 shall be used for determining allowance for partialexamination of the required surface.

3.3 Requests to use Later Edition and Addenda of ASME Section XI

On July 28, 2004, the NRC published Regulatory Issue Summary (RIS) 2004-12,“Clarification on Use of Later Editions and Addenda to ASME OM Code and Section XI”.This RIS clarifies the NRC position on using Editions and Addenda of Section XI, in wholeor in part, later than those specified in the ISI program. If the desired Edition or Addenda arereferenced in 10 CFR 50.55a(b)(2), the request is submitted following the guidance of theRIS. These types of request are not required to demonstrate hardship, difficulty, or provideevidence of quality and safety. They do need to ensure that all related requirements arealso used. Requests to use edition and/or addenda of ASME Section XI that are referencedin 10 CFR 50.55a(b)(2) that are later than the initial Code of Record established for the ISIprogram shall be submitted under the provisions of 10 CFR 50.55a(g)(4)(iv).

The guidance of RIS 2004-12 does not apply to the use of later Edition/Addenda of ASMESection XI, Appendix I and VIII. In accordance with the provisions of 10 CFR50.55a(g)(4)(ii), Appendix I and VIII from the latest Edition/Addenda of ASME Section XIlisted in 10 CFR 50.55a(a) may be adopted anytime within the interval without additionalNRC approval.

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4.0 Developmental References

4.1 Title 10, Code of Federal Regulations, Part 504.2 American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel

Code Section XI, 2007 Edition, 2008 Addenda4.3 Regulatory Guide 1.14, Reactor Coolant Pump Flywheel Integrity4.4 Regulatory Guide 1.147 Revision 17, Code Case Applicability4.5 Regulatory Guide 1.26, Quality Group Classifications4.6 Waterford Unit 3 Technical Specifications4.7 Waterford Unit 3 Final Safety Analysis Report (FSAR)4.8 CEP-COS-100, Control and Use of Iddeal Concepts Software4.9 CEP-COS-0110, Control and Use of the of ScheduleWorks® Module of IDDEAL

Software4.10 EN-DC-174, Engineering Program Sections4.11 CEP-PT-001, ASME Section XI Pressure Testing Program4.12 CEP-RR-001, ASME Section XI Repair/Replacement Program4.13 SEP-PT-WF3-001, WF3 Period Pressure Testing Program4.14 EN-DC-351 “Inservice Inspection Program Duties and Responsibilities”4.15 CEP-ISI-100 “ASME Section XI, Division 1 Fleet Administrative Controls for

Inservice Inspection Program”

5.0 Augmented Examination Programs

The Ten-Year ISI Program contains augmented examination plans and schedules thatmay be inside or outside the scope of 10 CFR 50.55a. These examinations may resultfrom activities including, but not limited to, commitments made to the NRC per 10 CFR50.55a, commitments made outside of 10 CFR 50.55a and made based on otherdocument requirements, internal commitments, license renewal commitments, or industryinitiatives. These examinations may use ASME Section XI techniques and procedures asdefined in the commitment, however, the requirements of ASME Section XI, includingreporting, do not apply when these examinations are required outside of 10 CFR 50.55a.Augmented examinations that are not required by 10 CFR 50.55a and ASME Coderequirements, such as Section XI and its Code Cases, are not required to be included inthe summary totals for a specific examination category. Changes to these examinationrequirements and schedules are outside of 10 CFR 50.55a and are required to beevaluated using the 10 CFR 50.59 screening/review process unless otherwise specified.


Augmented examinations are considered in one of the following three categories:“Augmented Examinations for External Commitments;” “Owner Elected Examinations forInternal Commitments;” and “License Renewal Examinations for Aging ManagementCommitments.” These three types of augmented examinations are described in Sections5.1, 5.2 and 5.3 below. In addition, each section includes a table in Section 7.0 which liststhe applicable augmented programs that are described in detail within each section.

5.1 Augmented Examinations for External Commitments

This type of augmented examination is conducted to meet a commitment made to asource outside the utility. Typically these are commitments made to the NRC in responseto regulatory documents such as Generic Letters, Bulletins and NUREGs. Theaugmented examinations for external commitments covered in this program are asfollows:

5.1.1 RI-BER: Standard Review Plan for the Review of Safety Analysis Reports forNuclear Power Plants - Determination of Rupture Locations and DynamicEffects Associated with the Postulated Rupture of Piping (Examination of HighEnergy Line Break Piping)

Source Document: USNRC Branch Technical Position, MEB 3-1 dated November1975 and NUREG-0800, Section 3.6.2.

Commitment No.: P-4845.

Associated Document: Engineering Reports ENTP-19Q-302, WF3-ME-07-00001,WF3-SA-07-00001 and WF3-SA-07-00002.

Purpose: The purpose of this augmented program is to perform examinations onpiping subject to High Energy Line Break (HELB) analysis criteria. During previousintervals examinations were required on 100% of the subject welds per NUREG-0800, Section 3.6.2, Branch Technical Position MEB 3-1, Paragraph B.1.b(7). Forthis interval the examinations will be maintained and performed under the risk-informed break exclusion region (RI-BER) application.

Scope: For Main Steam and Feedwater piping, all of the circumferential andlongitudinal welds from both Steam Generators to the first rigid restraint past the outercontainment isolation valve.

For Moderate Energy Safety Injection piping, the augmented ISI requirements will beimposed on the two 14-inch shutdown cooling lines and the four 8-inch LPSI linespenetrating containment.This was defined by Revisions 0-2 of the first interval ISI Plan. The lines wereidentified by line number and the welds were identified as requiring augmented


examination. This was approved in NRC SER dated January 29, 1987. On May 11,2001, the NRC completed an inspection at Waterford Steam Electric Station, Unit 3.The design basis for the high energy line break exclusion area on the main steam andmain feedwater systems as documented in the FSAR and the NRC’s SER of July1981 was reviewed. The purpose of the review was to determine whether the designbases of the systems were met by the installed and tested configurations. InspectionReport IR-2001-03 (ILN 01-0097, dated 6/01/01) documented that no findings ofsignificance were identified.Method: Ultrasonic examinations will be performed per the RI-BER application, exceptas restricted by part geometry or access.

Industry Code or Standards: ASME Code Section XI, 2007 Edition, 2008 Addenda.

Frequency: Ultrasonic examinations will be performed once per 10 year interval perthe RI-BER application.

Acceptance Criteria or Standard: Flaws detected during examination shall beevaluated by comparing the examination results to the acceptance standardsestablished in ASME Section XI, IWB-3514.

Regulatory Basis: The examination criteria of NUREG-0800, Section 3.6.2 aresuperseded by the RI-BER application.

5.1.2 RG 1.14 RCP FLYWHEEL: Reactor Coolant Pump Flywheel Integrity

Source Document: NRC Regulatory Guide 1.14.

Commitment No.: P-9944.

Associated Document: Technical Specification 6.5.7.

Purpose: The reactor coolant pump (RCP) motor flywheels are examined due to aconcern about high-energy missiles inside containment that could potentially damageand cause the simultaneous failure of multiple trains of multiple safety-related systems.

Scope: The scope includes the examination of all four RCP flywheels.

Method: Surface and volumetric examinations of all four RCP flywheels shall beconducted in accordance with WF3 Technical Specification 6.5.7. These examinationsare to be performed to the extent possible through the access ports in the motorhousings without disassembly of the motors.

Industry Code or Standards: ASME Code Section XI, 2007 Edition, 2008 Addenda.

Frequency: All 4 RCP flywheels shall be inspected once every ISI 10-Year Interval.


Acceptance Criteria or Standard: Any flaws detected during examination shall beforwarded to Entergy Engineering for resolution.

Regulatory Basis: The regulatory basis for this augmented examination program isNRC Regulatory Guide 1.14.

5.1.3 W3-R&R-006: Volumetric Examinations of Weld Overlay Including Upper 25%of Original Weld

Source Document: W3-R&R-006 (TAC NO. MD5388) 08-0069.

Commitment No.: A-27070 & A-27148.

Associated Document: W3F1-2013-0062, CR-WF3-2011-6576, CR-WF3-2009-2572,EC 15163.

Purpose: Ensure cracking does not propagate into the upper 25% of the original basemetal of dissimilar metal welds that contain alloy that have been mitigated by fullstructural weld overlays. The weld overlay examination shall be ultrasonicallyexamined during the first or second refueling outage following application. Weldsmitigated in RF15.

Scope: Pressurizer Nozzle to Surge Line, Pressurizer Nozzle to Relief Valve (2locations), Pressurizer Spare Nozzle (capped), Pressurizer Nozzle to Spray Line, HotLeg Loop 1 Nozzle to Surge Line, Hot Leg Loop 1 Nozzle to Drain Line, Hot Leg Loop1 Nozzle to Shut Down Cooling (SDC) Line and Hot Leg Loop 2 Nozzle to SDC Line.

Method: Perform Ultrasonic Examinations of the proposed preemptive full structuralweld overlays. The examination volume A-B-C-D of Figure 2 for each weld overlay willbe examined using ultrasonic examination procedures and personnel qualified inaccordance with ASME Section XI, Appendix VIII (as implemented through PDI).However, as of the submittal date of this request, PDI-qualified procedures toexamine the upper 25% of the cast austenitic stainless steel are not available.Therefore, until such procedures are qualified, Entergy will perform “best effort”inservice inspections of this region. Once qualified, Entergy will implement these PDIprocedures at the next scheduled inservice inspection as required by Attachment 2,paragraph 3.0(c) of W3-R&R-006.

Industry Code or Standards: ASME Code Section XI, 2007 Edition, 2008 Addendamay be used for guidance.

Frequency: ISI of the DMW overlays with cast stainless steel safe ends will beperformed at a higher frequency than those without cast stainless steel safe ends.


First, the initial UT inspection of the DMW weld overlays will be performed during thefirst or second refueling outage after installation. Then, instead of being inspected ona twenty-five percent sample basis, these weld overlays, with the exception of thePressurizer Safety/Relief Valves’ weld overlays, will be UT examined once every tenyears from the date of installation until such time when a technique is qualified toexamine cast stainless steel in accordance with the PDI Program. Then also, insteadof being inspected on a twenty-five percent sample basis, the PressurizerSafety/Relief Valves’ weld overlays will be UT examined once every nine years fromthe date of installation until such time when a technique is qualified to examine caststainless steel in accordance with the PDI Program. Once the subject DMW overlaysare UT examined by a qualified PDI technique (for cast stainless steel) and no planarflaws are detected, then the DMW overlays will be placed into a population in which25% of that population is examined once every 10 years. Until such time, the UTinspections of the subject DMW overlays (with cast stainless steel safe ends) will notbe credited to satisfy the 25% sample inspection requirement. Note the updating ofthe commitment and communication of this change to the NRC is being tracked withinCR-WF3-2011-6576.

Acceptance Criteria or Standard: The acceptance standards for the ultrasonicexamination of the weld overlay are specified in Table IWB-3514-2. However, if theweld overlay fails to meet the acceptance standards of Table IWB-3514-2, it can beaccepted based on an analytical evaluation meeting the requirements and acceptancecriteria of IWB-3600. However, flaws identified as primary water stress corrosioncracking (PWSCC) cannot be accepted by an IWB-3600 analytical evaluation. Cracksin the outer 25% of the base metal shall meet the design analysis requirements of 2.0in Attachment 2 to W3-R&R-006.

Regulatory Basis: W3-R&R-006.

5.1.4 NUREG-0612 HEAVY LOADS: Control of Heavy Loads at Nuclear Power Plants

Source Document: NUREG-0612.

Commitment No.: P8577, P8583, P8584, P8589, P8590, P8591, P8592, & P8594.

Associated Documents: NOECP-256, Non Destructive Examination of ReactorVessel Head, Upper Guide Structure, and Core Support Barrel Lifting RigAssemblies.

Purpose: The purpose of this augmented examination is to perform surfaceexaminations of load bearing welds on special lifting devices in accordance withNUREG-0612. Visual examinations of the components shall be performed perNOECP-256 and are not included in the WF3 ISI program.


Scope: As defined in NOECP-256, the special lifting devices addressed by thisaugmented examination are the RVH Lift Rig, Upper Guide Structure Lift Rig, and CoreSupport Barrel Lift Rig.

Method: Load bearing welds on the subject components shall be subject to a surfaceexamination.

Industry Code or Standards: ANSI N14.6-1978 and ANSI B30.9-1971 were used todevelop this program.

Frequency: The surface examination shall be performed once every ten years.

Acceptance Criteria or Standard: Acceptance criteria are stated in N14.6-1978,Section 5.5.

Regulatory Basis: The regulatory basis for this augmented examination program isNRC NUREG-0612.

5.1.5 MRP-146: Management of Thermal Fatigue in Normally Stagnant Non-IsolableReactor Coolant System Branch Lines

Source Document: MRP-146 Rev 1, EC-48006.

Commitment No.: N/A.

Associated Documents: LO-HQNLO-2007-68, WSES-18Q-301, SEP-ISI-104-PDCN-003.

Purpose: The purpose of this augmented examination is to perform ultrasonicexaminations of portions of piping that were assessed to possibly be susceptible tothermal fatigue in normally stagnant, non-isolable RCS branch lines. This is perguidance developed in MRP-146 Rev 0, MRP-146 Rev 1 and MRP-146S, Rev 0.

Scope: Assessment of WF3 piping was performed and documented in WSES-18Q-301 and EC-48006. There were three lines identified as applicable and requiringinspection per MRP-146 Rev 1, Section 2.4 (1RC2-46RL1A, 1RC2-48RL2A, 1RC2-47RL1B).

Method: Perform volumetric examination on the subject line applicable welds.

Industry Code or Standards: MRP-146 and MRP-170.

Frequency: The volumetric examination shall be performed once every other outage(MRP-146 Rev 1, Section 2.1.5.5).


Acceptance Criteria or Standard: MRP-146 Rev 1, Section 2.4.

Regulatory Basis: The regulatory basis for this augmented examination program isNeeded Requirement of an NEI 03-08 issue program.

5.2 Owner Elected Examinations for Internal Commitments

This type of augmented examination is conducted to meet a commitment made internallyat the plant. These typically involve examinations resulting from Condition Reports orsimilar documents that identify conditions in the plant that warrant monitoring, but areoutside the scope of ASME Section XI.

5.2.1 There are no Owner Elected Examinations for Internal Commitments for WF3 at thistime.

5.3 License Renewal Examinations for Aging Management Commitments

This type of augmented examination is conducted to ensure the integrity of componentsduring the license extension period. These typically involve components or criteria that arebeyond those of ASME Section XI, but in some cases may supplement existing Code orregulatory requirements.

5.3.1 There are no License Renewal Examinations for Aging Management Commitments forWF3 at this time.

6.0 ASME Systems & Examination Boundaries

6.1 ASME Class 1, 2 and 3This section defines those systems that are designated as ASME Class 1, 2, or 3 andprovides justification for their inclusion or exclusion within the Fourth Ten-Year InspectionInterval NDE Program. Several of WF3 systems or portions of systems are excluded fromsystem and component NDE as allowed by Articles IWB-1200, IWC-1200, and IWD-1200.However, these portions of systems are not excluded from the pressure testingrequirements of ASME Code, Section XI, except as allowed by Articles IWA-5000, IWB-5000, IWC-5000, and IWD-5000. System information for the NDE Program is provided inAppendix A, Waterford 3 ASME Code Class Systems ISI Boundary Diagrams. The 2007Edition, 2008 Addenda of the ASME Code, Section XI defines the inspection requirementsfor each of the ASME Code Classes within the fourth inspection interval, which started onDecember 1, 2017.Per IWA-1400(a) of the 2007 Edition, 2008 Addenda of Section XI, it is the owner'sresponsibility to determine the appropriate Code Classes for each component and toidentify the system boundaries subject to inspection. IWA-1400(a), footnote 1, states thatclassification criteria are specified in 10 CFR 50. This reference is to footnote 7 of 10CFR 50.55a which references Regulatory Guide 1.26 and Section 3.2.2 of NUREG-0800.


The component classifications of the ASME Code (Class 1, 2, or 3) determine the rulesand requirements for inspection and define the Section XI examination boundaries.Because early vintage nuclear plants were designed and constructed before Section III ofthe ASME Boiler and Pressure Vessel Code was incorporated into 10 CFR 50.55a, theASME Section XI Code classifications for ISI may differ from the original designclassifications. Therefore, while the ASME Code classifications determine the rules forrepairs and replacements and the component inspection requirements, repairs andreplacements are generally performed to meet the specifications of the original designcode.In order to avoid confusion between ASME Code Class for design (typically ASME SectionIII) and ASME Code Class for inservice inspection (ASME Section XI), Entergy is utilizingISI Class 1, 2, and 3 terminology for the application of ASME Section XI inservice inspectionrequirements.Components considered to be optionally classified as ASME Code Class may be excludedfrom the Section XI ISI Program per IWA-1320(e).Determination of the ASME Code Class (or equivalent to ASME Code Class forcomponents not designed in accordance with ASME Section III requirements) for WF3was performed as follows:The ASME Code Class of components was established in accordance with the safetyclassification criteria of ANSI N18.2, "Nuclear Safety Criteria for the Design of StationaryPressurized Water Reactor Plants", 1973, and ANSI N18.2a, "Revision and Addendum toNuclear Safety Criteria for the Design of Stationary Pressurized Water Reactor Plants",1975 as discussed in FSAR Section 3.2.2.ISI Boundary Diagrams, ISI Isometrics and ISI Equipment Drawings were developed toidentify the ASME Code Class 1, 2, and 3 components (welds, bolting, etc.) andcomponent supports which are subject to examination per ASME Section XI. The ISIBoundary Diagrams, ISI Isometrics and ISI Equipment Drawings were developed tosupport the ISI Program and are not to be used for design information.

The systems and components included in the Inservice Inspection Program areidentified in the W3 ISI Boundary Diagrams. A listing of these ISI Boundary Diagrams isincluded on drawing P-100 Sheet 1. These systems and components are referred to as“ISI Class 1”, “ISI Class 2” or “ISI Class 3” and are subject to the requirements of ASMESection XI, Subsections IWB, IWC, IWD and IWF.Typically, systems and components at WF3, which is designed in accordance withASME Section III, Class 1, 2, and 3 requirements are included in the InserviceInspection Program. Some of these systems and components are excluded orexempted from Section XI requirements because they are optionally upgraded to CodeClass as discussed in IWA-1320(e) or because they do not perform the functions listedin IWD-1210(a) to (f). Explanation of the implementation of Section XI requirements(including exemptions and exclusions) are referenced on the Piping Line CodingLegends and Exemption and Exclusion Flag Legends P-100 Sheet 1.


The ISI Class 1, 2, and 3 components which are not exempt from examination perASME Section XI, IWB-1220, IWC-1220, IWD-1220, and IWF-1230 are identified on theISI Boundary Diagrams in accordance with the Pipe Line Codes on drawing P-100Sheet 1. Nonexempt components are not included within flags corresponding to SectionXI exemptions listed in the plant Exemption and Exclusion Flag Legend.The ISI Class 1, 2, and 3 components which are exempt from examination are thosewhich meet the criteria of ASME Section XI, IWB-1220, IWC-1220 and IWD-1220.Component supports which meet the criteria of IWF-1230 are also exempt fromexamination. Exempt components are identified on the ISI Boundary Diagrams inaccordance with the Exemption and Exclusion Flag Legends on drawing P-100 Sheet1. Exempt component supports are supports of components which are exempt fromexamination per IWB-1220, IWC-1220, and IWD-1220.ASME Section XI, IWC-1222(b) presents separate exemption criteria for Class 2auxiliary feedwater systems in pressurized water reactor plants. For WF3, there is aconflict with the nomenclature for this piping regarding the application of IWC-1222(b)requirements.At WF3, there are two systems that support this function, one designated as AuxiliaryFeedwater (AFW) and the other designated as Emergency Feedwater (EFW).Waterford Design Basis Document W3-DBD-20, “Main Feedwater”, indicates that theAFW system is non-safety related and Waterford Design Basis Document W3-DBD-3“Emergency Feedwater System” indicates that the EFW is safety related.Because only the safety related portions of the auxiliary feedwater systems (i.e.,Emergency Feedwater) have been classified as ISI Class 2, the components in thesesystems will be subject to the exemption criteria of ASME Section XI, IWC-1222(b) andsubsequent examination criteria of Table IWC-2500-1. The non-safety relatedcomponents performing the auxiliary feedwater function at WF3 (i.e., AFW system) arenot classified for ASME Section XI inservice inspections and are not subject to therequirements of IWC-1222(b).An index of ISI Boundary Diagrams, ISI Isometrics and ISI Equipment Drawings isincluded in Appendix A and Appendix B.

6.2 Calibration Standards6.2.1 Calibration standards are used to calibrate ultrasonic examination equipment. These

standards were used during preservice examinations and during the previous ISIintervals, and are maintained at WF3. Calibration standards are listed in the IDDEAL®database.Calibration block thickness is the same nominal thickness as the material beingexamined. Any calibration block thickness that is within + 25% of the material beingexamined may be considered to be the same nominal thickness.Alternative calibration blocks may be used if the referencing procedure allows the useof such blocks. Additions or changes to the calibration blocks listed in the IDDEAL®


database shall be requested with the use of a Program Database Change Notice(PDCN) in accordance with Program Section CEP-COS-0110.

7.0 Application Criteria and Code Compliance7.1 ASME Section XI

The following provides a summary of the application of ASME Code, Section XI, 2007Edition, 2008 Addenda to the Waterford Unit No.3 Ten-Year Program for the FourthInspection Interval. Class 1, 2 and 3 components and component supports were selectedfor examination per the requirements of ASME Section XI 2007 Edition, 2008 AddendaTables IWB-2500-1, IWC-2500-1, IWD-2500-1 and IWF-2500-1, respectively. Theapplication and distribution of examinations for this interval is based upon Articles IWB-2411, IWC-2411, IWD-2411 and IWF-2410 of Section XI. Augmented examinations willalign with the ASME Section XI interval unless stated otherwise in the document thatgoverns the specific criteria for the examinations. There may be instances whenaugmented examinations and ASME Section XI examinations coincide for the samecomponent. Examinations should be performed concurrently to optimize examinationresources to the extent practical.If there are less than three items or welds to be examined in an Examination Category,the items or welds may be examined in any two periods, or in any one period if there isonly one item or weld in lieu of the percentage requirements in IWB-2411-1, IWC-2411-1or IWD-2411.Administration and control of Section XI examination records and personnel qualificationrequirements are included in CEP-NDE-0100, “Administration and Control of NDE”.The results of this application are summarized by ASME Category and Item number andare contained within Table 7.1. Table 7.1 only contains those ASME Item numbers thatare relevant to WF3.

7.1.1 EXAMINATION CATEGORY B-A - PRESSURE RETAINING WELDS IN REACTORVESSELThe Reactor Vessel examinations are scheduled to be examined in the third interval to meetthe 2007 Edition, 2008 Addenda of the ASME Code, Section XI as required by 10 CFR50.55a. Once Request for Alternative W3-ISI-006 is approved for the Fourth Interval, theseexaminations can be removed from the schedule.

7.1.2 EXAMINATION CATEGORY B-B - PRESSURE RETAINING WELDS IN VESSELSOTHER THAN REACTOR VESSELS

The 2007 Edition, 2008 Addenda of the ASME Code Section XI, Examination CategoryB-B requires that pressurizer and primary side of steam generators be examined duringthe inspection interval. The examination may be limited to one vessel among the group ofvessels performing a similar function.


STEAM GENERATORS

There is one Class 1 Examination Category B-B, tube sheet to head weld on each steamgenerator (S/G). Table IWB-2500-1, Category B-B, Note (1) allows the examination belimited to one vessel among a group of vessels performing a similar function or 50%. Oneof the two tubesheet to head welds is selected for examination, thus meeting the onevessel among a group of vessels performing a similar function or 50% requirement.

PRESSURIZERSection XI requires examination of both shell to head welds and one foot of one intersectinglongitudinal weld per head. Both shell to head welds are selected meeting the 100%requirement. There are two longitudinal welds on each shell to head weld (total 4). One footof one longitudinal weld on each head requires examination per ASME Section XI. 1 footeach of two of the longitudinal welds is selected for examination or 50%.This meets the Examination Category B-B examination requirements in the 2007 Edition,2008 Addenda of Section XI.

7.1.3 EXAMINATION CATEGORY B-D - FULL PENETRATION WELDED NOZZLES INVESSELS

This category applies to the reactor vessel, pressurizer, and steam generators. ASMECode, Section XI does not allow the deferral of these examinations, except for nozzle toreactor vessel welds. Table IWB-2500-1, Category B-D, Note 3, allows partial deferral if thenozzle weld is examined by the straight beam ultrasonic method from inside the nozzlebore, the remaining examinations required from the shell inside diameter may be performedat or near the end of the interval.The RV Nozzle-to-Vessel and Nozzle Inner Radius Sections are scheduled for examinationduring the Third Period of the Fourth Interval meeting the requirements of ASME Section XI.Once NRC approval of Request for Alternative W3-ISI-006 is obtained for the FourthInterval, these examinations may be removed from the schedule.10 CFR 50.55a(b)(2)(xxi)(A) requires that the provisions of Table IWB–2500–1,Examination Category B–D, Full Penetration Welded Nozzles in Vessels, Code ItemsB3.120 and B3.140 of the 1998 Edition must be applied when using the 2007 Edition, 2008Addenda. A visual examination with magnification that has a resolution sensitivity to detecta 1-mil width wire or crack, utilizing the allowable flaw length criteria in Table IWB–3512–1,1997 Addenda through the latest edition and addenda incorporated by reference inparagraph (a)(1)(ii) of this section, with a limiting assumption on the flaw aspect ratio (i.e.,a/l=0.5), may be performed instead of an ultrasonic examination. All of the pressurizer andsteam generator nozzle to vessel welds and nozzle inner radii are selected for examinationmeeting the 100% examination requirement. Each Steam Generator has three integrallycast nozzles. Therefore, all six of the inner radii are scheduled for examination.This meets the Examination Category B-D examination requirements in the 2007 Edition,2008 Addenda of Section XI as modified by 10 CFR 50.55a(b)(2)(xxi)(A).


7.1.4 EXAMINATION CATEGORY B-F - PRESSURE RETAINING DISSIMILAR METALWELDS IN VESSEL NOZZLES

This category addresses Nozzle-to-Safe End Welds and Piping Welds. WF3 has developeda Code Case N-716-1 RI-ISI program. All Examination Category B-F Welds have been re-categorized as R-A welds in accordance with Code Case N-716-1. Therefore noexaminations will be performed per Examination Category B-F.

7.1.5 EXAMINATION CATEGORY B-G-1 - PRESSURE RETAINING BOLTING, GREATERTHAN 2 in. (50 mm) IN DIAMETER

The RV Studs, Nuts, Threads in Flange, Washers, and Bushings are scheduled. ForVolumetric examination of Pump Studs, one of four sets of reactor coolant pump studs isselected for volumetric examination. For the visual examination of pump bolting, one of thereactor coolant pumps will be examined, only if disassembled. This is the same requirementas for Examination Category B-L-2. All other B-G-1 components are scheduled forexamination.This meets the Examination Category B-G-1 examination requirements in the 2007Edition, 2008 Addenda of Section XI.

7.1.6 EXAMINATION CATEGORY B-G-2 - PRESSURE RETAINING BOLTING, 2 in. (50 mm)AND LESS IN DIAMETER

This category includes pressurizer manway, steam generator manway, reactor coolantpump heat exchanger, reactor coolant pump seal bolting, flange bolting and valve bolting.Examinations will be conducted as required in Table IWB-2500-1 in the 2007 Edition, 2008Addenda of Section XI. This bolting will only be examined if associated connections aredisassembled.For components other than piping, bolting examinations will be required only when thecomponent is examined under Examination Category B-B, B-L-2, or B-M-2. WF3 hasgrouped B-G-2 bolting in accordance with components examined under ExaminationCategory B-B, B-L-2, or B-M-2.This meets the Examination Category B-G-2 examination requirements in the 2007Edition, 2008 Addenda of Section XI.

7.1.7 EXAMINATION CATEGORY B-J - PRESSURE RETAINING WELDS IN PIPING

This category addresses piping welds. WF3 has developed a Code Case N-716-1 RI-ISIprogram. All Examination Category B-J Welds have been re-categorized as R-A welds inaccordance with Code Case N-716-1. Therefore no examinations will be performed perExamination Category B-J.


7.1.8 EXAMINATION CATEGORY B-K – WELDED ATTACHMENTS FOR VESSELS, PIPING,PUMPS, AND VALVES

Examination Category B-K of the ASME Code Section XI, 2007 Edition, 2008 Addendarequires examination of Welded Attachments. For vessel welded attachments, Note 4allows for multiple vessels of similar design, function, and service, only one weldedattachment of only one of the multiple vessels shall be selected for examination. For singlevessels, only one welded attachment shall be selected for examination. WF3 has onewelded attachment on the Reactor Vessel, one welded attachment on the Pressurizer andone welded attachment on each Steam Generator. The Reactor Vessel welded attachment,the Pressurizer welded attachment and one of the two S/G welded attachments areselected for examination or 75% of all vessel welded attachments.For piping, pumps and valves, inspection of 10% of the total population of weldedattachments is required. 10% of all reactor coolant pump welded attachments are selectedfor examination. WF3 does not have any piping or valve welded attachments.This meets the Examination Category B-K examination requirements in the 2007 Edition,2008 Addenda of Section XI.

7.1.9 EXAMINATION CATEGORY B-L-2 - PUMP CASINGS

This category involves reactor coolant pumps and requires visual, VT-3 examination onpump internal surfaces when disassembled. The reactor coolant pumps are the only ASMECode Class 1 pumps.B-L-2 requires examination of one pump in each group of pumps performing similarfunctions in the system. However, this examination is only required when a pump isdissembled for maintenance, or repair. None of the four Reactor Coolant Pump internalsurfaces have been selected. This requirement will be met during disassembly formaintenance, or repair.This meets Examination Category B-L-2 examination requirements in the 2007 Edition,2008 Addenda of Section XI.

7.1.10 EXAMINATION CATEGORY B-M-2 - VALVE BODIES

Examinations will be conducted as required in Table IWB-2500-1. There are twenty twovalves in WF3 within this examination category. The twenty two valves are placed into sixgroups and are identified in the Program Type field in the IDDEAL Software Suite®,computer program.B-M-2 examinations are limited to at least one valve within each group of valves that are ofthe same size, constructural design, and manufacturing method, and that perform similarfunctions in the system. WF3 Class 1 valves have been separated into 6 valve groups.However, this examination is only required when a valve is dissembled for maintenance, orrepair. No valve body internal surfaces have been selected. This requirement will be metduring disassembly for maintenance, or repair.


This meets Examination Category B-M-2 examination requirements in the 2007 Edition,2008 Addenda of Section XI.

7.1.11 EXAMINATION CATEGORY B-N-1 - REACTOR VESSEL INTERIOR

These examinations will be conducted each inspection period.This meets the Examination Category B-N-1 examination requirements in the 2007 Edition,2008 Addenda of Section XI.

7.1.12 EXAMINATION CATEGORY B-N-2 - WELDED CORE SUPPORT STRUCTURES ANDINTERIOR ATTACHMENTS TO REACTOR VESSELS

Examination will be conducted during the third period to coincide with the 10 year inspectionof the reactor vessel.This meets the Examination Category B-N-2 examination requirements in the 2007 Edition,2008 Addenda of Section XI.

7.1.13 EXAMINATION CATEGORY B-N-3 - REMOVABLE CORE SUPPORT STRUCTURES

Examination will be conducted during the third period to coincide with the 10 year inspectionof the reactor vessel.This meets the Examination Category B-N-3 examination requirements in the 2007 Edition,2008 Addenda of Section XI.

7.1.14 EXAMINATION CATEGORY B-O - PRESSURE RETAINING WELDS IN CONTROLROD DRIVE AND INSTRUMENT NOZZLE HOUSINGS

The ASME Code, Section XI, 2007 Edition, 2008 Addenda, requires volumetric or surfaceexamination of 10% of peripheral control rod drive housings during the inspection interval.There are 28 peripheral Control Rod Drive Housings (CRDH) on the reactor vessel headwith 4 welds each Control Rod Drive Housing. There are 10 Incore Instrumentation (ICI)Nozzles on the reactor vessel head with 1 weld each per ICI. To meet the Coderequirements 3 of the CRDH Housings have been selected for examination, each with 4welds for a total of 12 welds requiring examination and 1 ICI Nozzle for a total of 1 weld.This meets the Examination Category B-O examination requirements in the 2007 Edition,2008 Addenda of Section XI.WF3 does not contain any instrument nozzle housings, welds in In-Core InstrumentationNozzle (ICI) Housings > NPS 2 (DN50).

7.1.15 EXAMINATION CATEGORY B-P - ALL PRESSURE RETAINING COMPONENTS

The pressure testing program at WF3 meets the requirements of ASME Code, Section XI,2007 Edition, 2008 Addenda for Class 1 systems. Details of the component listing arecontained in the Pressure Test Program Plan.


7.1.16 EXAMINATION CATEGORY B-Q - STEAM GENERATOR TUBING

The Steam Generator Tube inspection program at WF3 is governed by TechnicalSpecification 6.5.9.

7.1.17 EXAMINATION CATEGORY C-A - PRESSURE RETAINING WELDS IN PRESSUREVESSELS

This category applies to the steam generators and shutdown cooling heat exchangers. WF3has developed a Code Case N-716-1 RI-ISI program. The shutdown cooling heatexchangers were evaluated as Low Safety Significant (LSS) and therefore no examinationsare required. The steam generators were evaluated as High Safety Significant (HSS) andtherefore required examinations in accordance with Category C-A. The Extent ofExamination in Table IWC-2500-1, Examination Category C-A only requires examination ofCylindrical-shell-to-conical-shell-junction welds and shell (or head)-to-flange welds, Head toshell welds and Tubesheet-to-shell welds. Note (3) states: In the case of multiple vessels ofsimilar design, size, and service, the required examinations may be limited to one vessel ordistributed among the vessels or 50%.” There is one circumferential head weld on eachSteam Generator, therefore, 1 of 2 Steam Generator Head welds is selected for 50%. Thereis one tubesheet-to-shell weld on each Steam Generator. One tubesheet-to-shell weld onone Steam Generator is selected for examination for 50%.There are 6 welds on each Steam Generator that are not considered Cylindrical-shell-to-conical-shell-junction welds or shell (or head)-to-flange welds and thus are exempt fromexamination.This meets the Examination Category C-A examination requirements in the 2007 Edition,2008 Addenda of Section XI.

7.1.18 EXAMINATION CATEGORY C-B - PRESSURE RETAINING NOZZLE WELDS INVESSELS

This category applies to steam generators and shutdown cooling heat exchangers. WF3has developed a Code Case N-716-1 RI-ISI program. The shutdown cooling heatexchangers were evaluated as Low Safety Significant (LSS) and therefore no examinationsare required. The steam generators were evaluated as High Safety Significant (HSS) andtherefore required examinations in accordance with Category C-B. Note (1) in Table IWC-2500-1, Category C-B, excludes manways and handholes. Note (3) requires that nozzlesselected initially for examination shall be reexamined in the same sequence over the servicelife of the component, to the extent practical. Note (4) allows that in the case of multiplevessels of similar design, size, and service the required examinations may be limited to onevessel or distributed among the vessels. Two Feedwater nozzle to vessel welds (includinginner radius) on one Steam Generator are selected for examination for 50%.This meets the Examination Category C-B examination requirements in the 2007 Edition,2008 Addenda of Section XI.


7.1.19 EXAMINATION CATEGORY C-C - WELDED ATTACHMENTS FOR VESSELS, PIPING,PUMPS, AND VALVES

Examination Category C-C of the ASME Code Section XI, 2007 Edition, 2008 Addendarequires examination of Welded Attachments. For vessel welded attachments, Note 4allows for multiple vessels of similar design, function, and service, only one weldedattachment of only one of the multiple vessels shall be selected for examination. There aretwo steam generators with four welded attachment welds each. One of the steam generatorwelded attachment welds is selected for examination or 12.5% of all vessel weldedattachment welds.For piping, pumps and valves, inspection of 10% of the total population of weldedattachments is required. Percentage of all piping and pump welded attachments scheduledfor examination is based on IWF-2500-1 support selection.WF3 has no valve welded attachments.This meets the Examination Category C-C examination requirements in the 2007 Edition,2008 Addenda of Section XI.

7.1.20 EXAMINATION CATEGORY C-D - PRESSURE RETAINING BOLTING GREATERTHAN 2 IN. (50 MM) IN DIAMTERWF3 does not contain any Class 2 pressure retaining bolting greater than 2 in. (50 mm) indiameter.

7.1.21 EXAMINATION CATEGORY C-F-1- PRESSURE RETAINING WELDS IN AUSTENITICSTAINLESS STEEL OR HIGH ALLOY PIPING

This category addresses Class 2 piping welds. WF3 has developed a Code Case N-716-1RI-ISI program. Examination Category C-F-1 welds has been re-categorized as R-A weldsin accordance with Code Case N-716-1.Therefore no examinations will be performed perExamination Category C-F-1.

7.1.22 EXAMINATION CATEGORY C-F-2 - PRESSURE RETAINING WELDS IN CARBON ORLOW ALLOY STEEL PIPING