3F0507-03, Relief Request 07-003-RR, Revision 0

Relief Request #07-003-RR, Revision 0

ML071410449
Person / Time
Site:	Crystal River
Issue date:	05/15/2007
From:	Annacone M Progress Energy Co, Progress Energy Florida
To:	Document Control Desk, NRC/NRR/ADRO
References
07-003-RR, Rev 0, 3F0507-03
Download: ML071410449 (42)

Text

2Progress Energy Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 Ref: 10 CFR 50.55a May 15, 2007 3F0507-03 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 - Relief Request #07-003-RR, Revision 0

Reference:

ASME Code Case N-740-1 Tracking No. BC06-1651 2-7-07 editing and review Final, "Dissimilar Metal Weld Overlay for Repair of Class 1, 2 and 3 ItemsSection XI, Division 1," Draft February 2007

Dear Sir:

Pursuant to 10 CFR50.55a(a)(3)(i), Florida Power Corporation (FPC), doing business as Progress Energy Florida, Inc., requests approval to use the American Society of Mechanical Engineers (ASME)Section XI Code Case N-740-1 Draft February 2007 to apply dissimilar metal weld overlays for repair/replacement activities. A copy of the Draft Code Case is included in . This request contains alternative requirements for the Inservice Inspection (ISI) program for scheduled preemptive full structural weld overlays (SWOLs) that are planned to mitigate the potential for Primary Water Stress Corrosion Cracking (PWSCC) susceptibility at Crystal River Unit 3 (CR3). Attachment 1 contains the proposed alternative, Relief Request #07-003-RR, Revision 0. Attachment 2 shows the comparison of the Performance Demonstration Initiative (PDI) Program modifications to ASME Code Section XI Appendix VIII Supplement

11. provides a discussion on the use of a "barrier layer" in cases where the SWOLs will be deposited on stainless steel base material with high sulfur content.

FPC requests the review and approval of this proposal by October 1, 2007, to support the CR3 15th Refueling Outage in the fall of 2007. Similar alternatives have been submitted to the NRC for review and approval and these are referenced in the attached request.

No regulatory commitments are being made in this submittal.

Progress Energy Florida, Inc.

Crystal River Nuclear Plant 15760 W. Powerline Street Crystal River, FL 34428

U. S. Nuclear Regulatory Commission Page 2 of 2 3F0507-03 If you have any questions regarding this submittal, please contact Paul Infanger, Supervisor, Licensing and Regulatory Programs at (352) 563-4796.

Sincerely, Engineering Manager Attachments: 1. Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)

2. PDI Program Modifications to Appendix VIII Supplement 11

3. ASME Section XI Code Case N-740-1 Tracking No. BC06-1651 2-7-07 Editing and Review Final, "Dissimilar Metal Weld Overlay for Repair of Class 1, 2, and 3 ItemsSection XI, Division 1," Draft February 2007

4. Barrier Layer to Prevent Hot Cracking in High Sulfur Stainless Steel xc: NRR Project Manager Regional Administrator, Region II Senior Resident Inspector

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 ATTACHMENT 1 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

U. S. Nuclear Regulatory Commission Attachment 1 3F0507-03 Page 1 of 12 USE OF WELD OVERLAYS AS AN ALTERNATIVE REPAIR TECHNIQUE

--Alternative Provides Acceptable Level of Quality and Safety--

INSERVICE INSPECTION RELIEF REQUEST #07-003-RR, REVISION 0 THIRD TEN YEAR INTERVAL REFERENCE CODE: The American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME),Section XI, 1989 Edition with no Addenda.

1.0 ASME Code Components Affected

ASME Code components associated with this request are high safety significant (HSS) Class 1 dissimilar metal welds (DMWs) with Alloy 82/182 weld metal and Alloy 600 base material that are believed to be susceptible to Primary Water Stress Corrosion Cracking (PWSCC). There are seven (7) DMWs and the pressurizer spray nozzle safe end that are scheduled to have preemptive full structural weld overlays (SWOLs) applied. These items are scheduled to have SWOLs applied during the upcoming Crystal River Unit 3 (CR3) 15th Refueling Outage scheduled to start on November 3, 2007.

1.1 Category and System Details:

Code Class: Class 1 System Welds: Reactor Coolant System Examination Categories: R-A*

• Welds are included in the Risk Informed Inservice Inspection Program 1.2 Component Descriptions:

This alternative is to apply SWOLs on the pressurizer surge nozzle safe end-to-nozzle weld, three (3) relief nozzle flange-to-nozzle welds, spray nozzle safe end-to-nozzle weld, spray pipe-to-spray nozzle safe-end weld, spray nozzle safe end and "A" hot leg surge pipe-to-surge nozzle weld. The applicable items and their identifications are as follows:

1. Pressurizer Weld No. B4.1.9 Surge Nozzle Buttering and B4.1.10 Safe End-to-Surge Nozzle Weld

2. Pressurizer Weld No. B4.1.3 Relief Nozzle #1 Buttering and B4.1.4 Flange-to-Relief Nozzle #1 Weld

3. Pressurizer Weld No. B4.1.5 Relief Nozzle #2 Buttering and B4.1.6 Flange-to-Relief Nozzle #2 Weld

4. Pressurizer Weld No. B4.1.7 Relief Nozzle #3 Buttering and B4.1.8 Flange-to-Relief Nozzle #3 Weld

5. Pressurizer Weld No. B4.1.1 Safe End-to-Spray Nozzle-Weld

6. Pressurizer Spray Nozzle Safe End Mk No. 45

U. S. Nuclear Regulatory Commission Attachment 1 3F0507-03 Page 2 of 12

7. Spray Pipe-to-pressurizer Spray Nozzle Safe End Weld No. B4.5.52

8. "A" Hot Leg Pipe Weld No. B4.1.11 Surge Nozzle Buttering and B4.1.12 Surge Pipe-to-Surge Nozzle Weld 1.3 Component Materials:

1. Pressurizer nozzles are carbon steel A 508 Class 1 (P-No. 12A Sub 1)

2. "A" Hot Leg pipe surge nozzle is carbon steel A 105 Grade II (P-No. 1)

3. Pressurizer surge nozzle safe end is A 336 Class F8M (P-No.8)

4. Relief nozzle flanges are SA-182 Grade F316 (P-No. 8)

5. Welds are Alloy 82/182 (F-No. 43)

6. Pressurizer spray nozzle safe end is NiCrFe SB-166 Alloy 600 (P-No. 43)

7. Elbow attached to the pressurizer surge nozzle safe end is A 403 WP316 (P-No. 8)

8. Piping attached to the "A" hot leg surge nozzle buttering and to the pressurizer spray nozzle safe end is wrought seamless austenitic stainless steel A 376 TP 316 (P-No. 8) 2.0 Applicable Code Edition and Addenda CR3 is currently in the third 10-year Inservice Inspection (ISI) interval. The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) of record for the current 10-year ISI interval isSection XI, 1989 Edition, no Addenda (Reference 1). This is also the version used for the Repair/Replacement Program.

3.0 Applicable Code Requirement The applicable Code requirement for which the relief is requested is ASME Code Section XI, 1989 Edition, no Addenda (Reference 1), IWA-4120(a), IWA-4340(a) and Section XI, 1995 Edition, including Addenda through 1996, Appendix VIII, Supplement 11 (Reference 2).

IWA-4120(a) states in part the following:

"Repairs shall be performed in accordance with the Owner's Design Specification and the original Construction Code of the component or system. Later Editions and Addenda of the Construction Code or of Section III, either in their entirety or portions thereof, and Code Cases may be used. ... If repair welding cannot be performed in accordance with these requirements, the applicable requirements of IWA-4500 and the following may be used:

(1) IWB-4000 for Class 1 components.."

IWA-4340(a) states in part the following:

"After final grinding, the affected surfaces of cavities prepared for welding, shall be examined by the magnetic particle or liquid penetrant method to ensure that the indication has been reduced to an acceptable limit in accordance with IWA-3000. The original defect shall be removed: ... (2) when repair welding is required in accordance with IWA-4520 or IWA-4530, and the defect penetrates the base material."

U. S. Nuclear Regulatory Commission Attachment 1 3F0507-03 Page 3 of 12 Appendix VnI provides requirements for performance demonstration for ultrasonic examination systems. Supplement 11 provides qualification requirements for full structural overlay wrought austenitic piping welds.

4.0 Reason for Reqluest DMWs, primarily consisting of Alloy 82/182 weld metal, are frequently used in pressurized water reactor (PWR) construction to connect stainless steel pipe and safe ends to vessel and pipe nozzles, generally constructed of carbon or low alloy ferritic steel. These welds have shown a propensity for PWSCC degradation, especially in components subjected to higher operating temperatures, such as the pressurizer and the hot leg pipe. See EPRI MRP-169, "Technical Basis for Preemptive Weld Overlays for Alloy 82/182 Butt Welds in PWRs," October 2005 (Reference 3). Alloy 600 base material is also susceptible to PWSCC.

For the upcoming CR3 15th Refueling Outage, SWOLs are scheduled to be applied to DMWs on pressurizer nozzles, the pressurizer spray nozzle safe end, the spray pipe-to-spray nozzle safe end DMW and the "A" hot leg surge pipe-to-nozzle DMW. Repair/replacement activities associated with SWOL repairs are required to address the materials, welding parameters, ALARA concerns, operational constraints, examination techniques and procedure requirements for repairs.

ASME Code Section XI, 1989 Edition, no Addenda (Reference 1), IWA-4120(a) and IWA-4340(a), does not address all the needed requirements for this type of repair since potential existing defects will not be removed or reduced in size, and weld overlay of potential existing flaws in DMWs or associated Alloy 600 base material will be performed. Also comprehensive and generic NRC approved criteria are not currently available for application of SWOL repairs to DMWs constructed of Alloy 82/182 weld material or associated Alloy 600 base material for mitigation of potential PWSCC.

In addition, ASME Code Section XI, 1995 Edition including Addenda through 1996, Appendix Vll Supplement 11 (Reference 2) cannot be implemented as written for ultrasonic examination of a structural weld overlay repair. Attachment 2 includes a discussion of the Performance Demonstration Initiative (PDI) Program alternatives and their bases with respect to Appendix VIII Supplement 11 requirements.

The alternative described in Section 5.0 is proposed to permit the implementation of SWOLs at CR3 as an alternative for the repair/replacement requirements of the ASME Code Section XI, 1989 Edition, no Addenda (Reference 1), IWA-4120(a), IWA-4340(a) and ASME Code Section XI, 1995 Edition, including Addenda through 1996, Appendix VIII, Supplement 11 (Reference 2).

5.0 Proposed Alternative and Basis for Use The ASME Subcommittee XI has recently approved ASME Section XI Code Case N-740-1, Draft February 2007, "Dissimilar Metal Weld Overlay for Repair of Class 1, 2, and 3 Items" shown in Attachment 3. This Draft Code Case is the result of the industry's experience with weld overlay repairs for flaws suspected or confirmed to be from PWSCC and for the first time

U. S. Nuclear Regulatory Commission Attachment 1 3F0507-03 Page 4 of 12 directly applies to the Alloy 52M weld material that is primarily being used for these overlay repairs.

This proposal requests the use of the ASME Section XI Code Case N-740-1, Draft February 2007 (Attachment 3) for implementing the SWOLs for potentially PWSCC susceptible items.

This request applies to each of the DMWs and the pressurizer spray nozzle safe end base material listed in Section 1.2, which are generically depicted in Figures 1 through 4. The proposed alternative is scheduled to be performed during the CR3 15th Refueling Outage.

The ultrasonic examination of the completed SWOLs will be accomplished with personnel and procedures qualified in accordance with ASMIE Code Section XI, 1995 Edition including Addenda through 1996 (Reference 2) Appendix VIII, Supplement 11 as specified in ASME Section XI Code Case N-740-1, Draft February 2007 (Attachment 3) Section 3 therein, with the alternatives used for complying with the PDI Program. See Attachment 2 for the PDI Program changes to Appendix VIII Supplement 11.

5.1 SWOL Design The SWOLs satisfy all the structural design requirements of the pipe assuming no strength contributed by the original DMWs or the pressurizer spray nozzle safe end, as if they were removed. As shown in Figures 1 through 4, the SWOLs will completely cover the existing DMWs, will extend onto the ferritic nozzle and austenitic stainless steel material on each end of the weld and completely cover the pressurizer spray nozzle safe end. The SWOLs extend around the entire circumference of the nozzle. Alloy 52M and 52 filler metals are compatible with all the wrought base materials and the DMWs and similar metal welds that will be covered by the SWOL.

The SWOLs will be designed as full structural overlays (assumed worst case flaw) in accordance with ASME Section XI Code Case N-740-1, Draft February 2007 (Attachment 3), Section 2 therein. Note that the details surrounding the design analysis for the SWOLs are being developed to support the CR3 15th Refueling Outage and the vendor will supply this analysis to Florida Power Corporation (FPC). The analysis will be available at CR3 for NRC review at the beginning of the CR3 15th Refueling Outage.

5.2 Welding The welding will be performed in accordance with ASME Section XI Code Case N-740-1, Draft February 2007 (Attachment 3) using a remote machine gas tungsten-arc welding (GTAW) process and using the ambient temperature temper bead method with ERNiCrFe-7A (Alloy 52M) weld metal. Manual GTAW, using ERNiCrFe-7 (Alloy 52) or Alloy 52M will be used if local repairs of weld defects are necessary or additional weld metal is required locally to form the final SWOL contour in locations at least 3/16 inch away from the carbon steel nozzles.

U. S. Nuclear Regulatory Commission Attachment 1 3F0507-03 Page 5 of 12 5.3 Examination For the portions of the ferritic carbon steel nozzle base material beneath the SWOLs, where their thicknesses are 1-1/2 inches and less, Paragraph 1(c)(1) of ASME Section XI Code Case N-740-1 Draft February 2007 applies thereto, and temper bead welding would not be required. The pressurizer spray nozzle ferritic steel base material thickness is less than 1-1/2 inches thick beneath the SWOL. The relief nozzles ferritic carbon steel base material, with the possible exception of a small portion of the nozzle transition taper beneath the SWOLs, is less than 1-1/2 inches thick and is a function of the final SWOL thickness. The "A" hot leg surge nozzle and pressurizer surge nozzle ferritic carbon steel base material, with the exception of a portion of the nozzle transition taper beneath the SWOLs, is less than 1-1/2 inches thick. The final SWOL ultrasonic and surface examination may be performed after welding completion since the temper bead technique would not be required, even though it will be used, on the nozzles ferritic carbon steel base materials, on the spray nozzle and applicable portions of the other nozzles. The clarifications in this paragraph are conservative with respect to the intent of the Construction Code post weld heat treatment (PWHT) exemption requirements [Table NB-4622.7(b)-l, ASME Code Section III, 1989 Edition, no Addenda] since all weld overlays are deposited on the surfaces of the ferritic carbon steel nozzles instead of partial or complete through thickness welds applicable for the cases described in the Construction Code.

Since temper bead welding is required, ultrasonic and surface examinations will be performed on the temper bead welded portion of the SWOLs on the applicable portions of the nozzle transition tapers beneath the SWOLs greater than 1-1/2 inches thick for the pressurizer relief nozzles, if applicable, and the "A" hot leg surge nozzle and the pressurizer surge nozzle no sooner than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after completion of the third temper bead layer, instead of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after the weld has returned to ambient temperature, as currently specified in ASME Section XI Code Case N-740-1 Draft February 2007, Paragraph 3(a)(2).

The 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> delay provides time for delayed hydrogen cracking occurrence. ASME Section XI Code Case N-740-1 Draft February 2007, Appendix 1 requires the machine or automatic GTAW process to be used for temper bead welding thereby eliminating the use of welding processes requiring flux for arc shielding.

The machine GTAW temper bead process uses a welding process that is inherently free of hydrogen. The GTAW process relies on bare welding electrodes and bare wire filler metal with no flux to absorb moisture. An inert gas blanket provides shielding for the weld and surrounding metal, which protects the region during welding from the atmosphere and the moisture it may contain and typically produces porosity free welds. In accordance with the weld procedure qualification, welding grade argon is used for the inert gas blanket. To further reduce the likelihood of any hydrogen effects, specific controls will be used to ensure the welding electrodes, filler metal and weld region are free of all sources of hydrogen.

In addition, the use of the machine GTAW temper bead process provides precise control of heat input, bead placement, bead size and contour. The very precise control over these factors afforded by the machine GTAW process provides effective tempering of the nozzle ferritic steel HAZ resulting in achievement of lower hardness and tempered martensite. This further reduces

U. S. Nuclear Regulatory Commission Attachment 1 3F0507-03 Page 6 of 12 susceptibility to hydrogen induced cracking.

EPRI Report 1013558, "Temperbead Welding Applications, 48 Hour Hold Requirements for Ambient Temperature Temperbead Welding, Technical Update," December 2006 (Reference 4),

provides justification for reducing the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> hold time on P-No. 3 Group No. 3 ferritic steel base material to start after completion of the third temper bead layer instead of the currently specified hold time in ASME Section XI Code Case N-740-1 Draft February 2007. Report 1013558 addresses microstructural issues, hydrogen sources, tensile stress and temperature, and diffusivity and solubility of hydrogen in steels.

The base materials studied in the EPRI report are primarily P-No. 3. The pressurizer nozzles and "A" hot leg surge nozzle ferritic steel base materials are P-No. 1 and P-12A Sub 1. The concerns associated with hydrogen assisted cracking are generally more significant for P-No. 3 than P-No. 1 and P-12A Sub 1 base materials due to P-No. 3 base materials increased hardenability.

Also, post weld heat treat exemptions shown in ASME Section III, Table NB-4622.7(b)-1 are provided for P-No. 1 Group No. 2 materials (this P-No. and Group Number is the current base material classification in ASME Code Section IX for the applicable nozzle base materials where the SWOLs will be applied at CR3 which were formerly classified as P-No. 1 and P-No. 12A Sub 1), including temper bead welding, whereas no post weld heat treat exemptions, other than temper bead welding, are permitted for P-No. 3 Group No. 3 materials.

Furthermore past industry experience with the use of the machine or automatic GTAW process has resulted in no detection of hydrogen induced cracking after the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> hold Non-Destructive Examination (NDE) or subsequent in-service inspections.

There is currently an ASME XI Subcommittee action to incorporate the revised NDE hold requirement into ASME Section XI Code Case N-740-1 Draft February 2007. ASME Section XI Code Case N-638-3, "Similar and Dissimilar Metal Welding Using Ambient Temperature Machine GTAW Temper Bead Technique Section XI Division 1," has been revised with the Main Committee and Board of Nuclear Codes and Standards approval to specify NDE 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after completion of the third temper bead layer.

All examinations will meet the requirements of the ASME Section XI Code Case N-740-1, Draft February 2007 (Attachment 3), excluding qualification of the ultrasonic examination for the completed SWOLs. The ultrasonic examination qualification will be in accordance with ASME Code Section XI, 1995 Edition including Addenda through 1996, Appendix VIII, Supplement 11 (Reference 2) with the alternatives that are used to comply with the PDI Program. See for the PDI Program changes to Appendix VIII Supplement 11.

The PDI Program allows closer spacing of flaws provided they don't interfere with detection or discrimination. The specimens used to date for qualification to the Tri-party (NRC/BWROG/EPRI) agreement have a flaw population density greater than allowed by current Code requirements. These samples have been used successfully for all previous qualifications under the Tri-party agreement program. To facilitate their use and provide continuity from the

U. S. Nuclear Regulatory Commission Attachment 1 3F0507-03 Page 7 of 12 Tri-party agreement program to Supplement 11, the PDI Program has merged the Tri-party test specimens into their structural weld overlay program.

Appendix VIII Supplement 10 ultrasonic examination will not be performed on the DMWs prior to the SWOLs being applied. Since the structural integrity at the DMW locations will be restored by the SWOLs, the ultrasonic examination of the DMWs is unnecessary and the increased personnel dose that would be incurred performing the examinations is also undesirable and not consistent with good ALARA practice. The additional dose received due to performing these examinations would result in a hardship without a compensating increase in the level of quality and safety.

5.4 Conclusion Similar NRC approved requests have been used to produce acceptable weld overlays when applied to DMWs. The proposed alternative uses ASME Section XI Code Case N-740-1, Draft February 2007 (Attachment 3) that has been developed to cover the most recent operating experience and NRC approved criteria that are associated with similar SWOL applications.

Therefore FPC considers that this draft Code Case, and the alternatives thereto described herein and the PDI Program ultrasonic examination qualification alternative to ASME Section XI, 1995 Edition, 1996 Addenda, Appendix VIII, Supplement 11, provide an acceptable level of quality and safety, consistent with provisions of 10 CFR 50.55a(a)(3)(i)).

6.0 Precedents Similar requests have been submitted to address the issues that are contained in this request.

These include requests from the Indiana Michigan Power Company's D. C. Cook Unit 2. NRC verbal approval was received on March 23, 2006, for their request, which included the application of full SWOLs applied to their pressurizer nozzle DMWs.

Recently, Virginia Electric and Power Company (Dominion) submitted a similar request on March 13, 2007, for North Anna 1 and 2, CMP-022R1 and CMP-023R1, Serial No. 06-1007A, Docket Nos. 50-338/339, "Supplemental Information to Support Use of Weld Overlays as an Alternative Repair Technique" (ADAMS Accession No. M1L070730563). Verbal NRC approval was granted to Dominion on March 29, 2007.

Union Electric Company's Callaway Plant submitted a similar request on August 14, 2006, (ADAMS Accession ML062360200) for weld overlays to pressurizer nozzle welds to be performed during their Refuel 15 outage in the Spring 2007.

Additionally, the following requests associated with weld overlay repairs have been approved by the NRC: AmerGen Energy Company, Three Mile Island Nuclear Station, Unit 1, on July 21, 2004 (Reference 5); Constellation Energy's Calvert Cliffs Nuclear Power Plant, Unit 2, on July 20, 2005 (Reference 6); Millstone Unit 3, on January 20, 2006 (Reference 7); and Indiana Michigan Power Company, Donald C. Cook Unit 1, on February 10, 2006 (Reference 8).

U. S. Nuclear Regulatory Commission Attachment 1 3F0507-03 Page 8 of 12 7.0 Duration of Proposed Alternative The alternative requirements of this request will be applied for the duration of up to and including the last outage of the current third 10-year ISI interval which includes inservice examination requirements of ASME Section XI Code Case N-740-1, Draft February 2007 (Attachment 3) for any applied weld overlays. The use of ASME Section XI Code Case N-740-1, Draft February 2007 (Attachment 3) is requested until the NRC publishes the ASME Section XI Code Case as a future revision of Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1." Future inservice examinations of weld overlays at CR3 beyond this inspection interval will be as required by the NRC in the regulations.

8.0 References

1. ASME Code,Section XI, 1989 Edition, no Addenda.

2. ASME Code,Section XI, 1995 Edition, including Addenda through 1996, Appendix VIII, Supplement 11.

3. EPRI MRP-169, "Technical basis for Preemptive Weld Overlays for Alloy 82/182 Butt Welds in PWRs," October 2005.

4. EPRI Report 1013558, "Temperbead Welding Applications, 48 Hour Hold Requirements for Ambient Temperature Temperbead Welding, Technical Update,"

December 2006.

5. NRC letter, "Safety Evaluation of Request for Relief from Flaw Removal, Heat Treatment and Nondestructive Examination (NDE) Requirements for the Third 10-Year Inservice Inspection Interval," Three Mile Island Nuclear Station, Unit 1 (TMI-1),

Docket No. 50-289, (TAC No. MC1201), dated: July 21, 2004, (ADAMS Accession No. ML041670510).

6. NRC letter, "Safety Evaluation for Calvert Cliffs Nuclear Power Plant, Unit No. 2, Docket No. 550-318, Relief Request for Use Weld Overlay and Associated Alternative Inspection Techniques (TAC Nos. MC6219 and MC6220)," dated July 20, 2005, (ADAMS Accession No. ML051930316).

7. NRC letter, "Safety Evaluation of Relief Request IR-2-39 Pertaining to the Repair and Inspection of Nozzle to Safe End Weld, Weld No. 03-X-5641-E-T at Millstone Power Station Unit No. 3 (MPS3) Docket No. 50-423, (TAC No. MC8609)," dated January 20, 2006, (ADAMS Accession No. ML053260012).

8. NRC letter, "Safety Evaluation of Alternative Regarding Repair of Safe-End-To-Elbow Weld 1-RC-9-01F at the Donald C. Cook Nuclear Plant Unit 1, Docket No. 50-315, (TAC No. MC8807)," dated February 10, 2006, (ADAMS Accession No. ML060240355).

U. S. Nuclear Regulatory Commission Attachment 1 3F0507-03 Page 9 of 12 Figure 1 - PZR Surge Nozzle SWOL Configuration

U. S. Nuclear Regulatory Commission Attachment 1 3F0507-03 Page 10 of 12 Figure 2 - PZR Relief Nozzle SWOL Configuration

U. S. Nuclear Regulatory Commission Attachment 1 3F0507-03 Page 11 of 12 (A,376

-Pipe/SE Weld (821182)

.Weld (82/182)

.SWOL

-Carbon Steel Nozzle (A 508 Class 1)

Figure 3 - PZR Spray Nozzle SWOL Configuration

U. S. Nuclear Regulatory Commission Attachment 1 3F0507-03 Page 12 of 12 SS Pipe (A 376 TP311 Pipe/Nozzle Weld (821182)

-Carbon Steel Nozzle (A 105 Grade 11)

Figure 4 - HL Pipe Surge Nozzle SWOL Configuration

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 ATTACHMENT 2 PDI PROGRAM MODIFICATIONS TO ASME CODE SECTION XI, APPENDIX VIII, SUPPLEMENT 11

U. S. Nuclear Regulatory Commission Attachment 2 3F0507-03 Page 1 of 6 PDI Program Modifications to ASME Code Section XI, Appendix VIII, Supplement 11 Appendix VIII, Supplement 11 PDI Modification 1.0 SPECIMEN REQUIREMENTS 1.1 General (b) The specimen set shall consist of at least Modification: (b) The specimen set shall consist of at three specimens having different nominal pipe least three specimens having different nominal pipe diameters and overlay thicknesses. They shall diameters and overlay thicknesses. They shall include include the minimum and maximum nominal the minimum and maximum nominal pipe diameters for pipe diameters for which the examination which the examination procedure is applicable. Pipe procedure is applicable. Pipe diameters within a diameters within a range of 0.9 to 1.5 times a nominal range of 0.9 to 1.5 times a nominal diameter diameter shall be considered equivalent. If the procedure shall be considered equivalent. If the procedure is applicable to pipe diameters of 24 inches or larger, the is applicable to pipe diameters of 24 inches or specimen set must include at least one specimen 24 larger, the specimen set must include at least inches or larger but need not include the maximum one specimen 24 inches or larger but need not diameter.

include the maximum diameter. The specimen The specimen set shall include specimens with overlays set must include at least one specimen with not thicker than 0.1 inches more than the minimum overlay thickness within -0.1 inches to +0.25 thickness, nor thinner than 0.25 inches of the maximum inches of the maximum nominal overlay nominal overlay thickness for which the examination thickness for which the procedure is applicable, procedure is applicable.

Basis: To avoid confusion, the overlay thickness tolerance contained in the last sentence was reworded and the phrase "and the remainder shall be alternative flaws" was added to the next to last sentence in paragraph 1.1 (d) (1).

(d) Flaw Conditions (1) Base metal flaws. All flaws must be cracks Modification: (1) Base metal flaws. All flaws must be in or near the butt weld heat-affected zone, open in or near the butt weld heat-affected zone, open to the to the inside surface, and extending at least 75% inside surface, and extending at least 75% through the through the base metal wall. Flaws may extend base metal wall. Intentional overlay fabrication flaws 100% through the base metal and into the shall not interfere with ultrasonic detection or overlay material; in this case, intentional characterization of the base metal flaws. Specimens overlay fabrication flaws shall not interfere with containing IGSCC shall be used when available. At least ultrasonic detection or characterization of the 70% of the flaws in the detection and sizing tests shall be cracking. Specimens containing IGSCC shall cracks and the remainder shall be alternative flaws.

be used when available. Alternative flaw mechanisms, if used, shall provide crack-like reflective characteristics and shall be limited by the following:

(a) The use of alternative flaws shall be limited to when the implantation of cracks produces spurious reflectors that are uncharacteristic of actual flaws.

(b) Flaws shall be semi elliptical with a tip width of less than or equal to 0.002 inches.

Basis: This paragraph requires that all base metal flaws be cracks. Implanting a crack requires excavation of the base material on at least one side of the flaw. While this

U. S. Nuclear Regulatory Commission Attachment 2 3F0507-03 Page 2 of 6 Appendix VIII, Supplement 11 PDI Modification may be satisfactory for ferritic materials, it does not produce a useable axial flaw in austenitic materials because the sound beam, which normally passes only through base material, must now travel through weld material on at least one side, producing an unrealistic flaw response. To resolve this issue, the PDI program revised this paragraph to allow use of alternative flaw mechanisms under controlled conditions. For example, alternative flaws shall be limited to when implantation of cracks precludes obtaining an effective ultrasonic response, flaws shall be semi elliptical with a tip width of less than or equal to 0.002 inches, and at least 70% of the flaws in the detection and sizing test shall be cracks and the remainder shall be alternative flaws. To avoid confusion, the overlay thickness tolerance contained in paragraph 1.1(b) last sentence, was reworded and the phrase "and the remainder shall be alternative flaws" was added to the next to last sentence. Paragraph 1.1(d)(1) includes the statement that intentional overlay fabrication flaws shall not interfere with ultrasonic detection or characterization of the base metal flaws.

(e) Detection Specimens (1) At least 20% but less than 40% of the flaws Modification: (1) At least 20% but less than 40% of the shall be oriented within +20 degrees of the pipe base metal flaws shall be oriented within +/-20 degrees of axial direction. The remainder shall be oriented the pipe axial direction. The remainder shall be oriented circumferentially. Flaws shall not be open to circumferentially. Flaws shall not be open to any surface any surface to which the candidate has physical to which the candidate has physical or visual access.

or visual access. The rules of IWA-3300 shall Basis: The requirement for axially oriented overlay be used to determine whether closely spaced fabrication flaws was excluded from the PDI Program as flaws should be treated as single or multiple an improbable scenario. Weld overlays are typically flaws. applied using automated GTAW techniques with the filler metal applied in a circumferential direction.

Because resultant fabrication induced discontinuities would also be expected to have major dimensions oriented in the circumferential direction axial overlay fabrication flaws are unrealistic. The requirement for using IWA-3300 for proximity flaw evaluation was excluded, instead indications will be sized based on their individual merits.

(2) Specimens shall be divided into base and Modification: (2) Specimens shall be divided into base overlay grading units. Each specimen shall metal and overlay fabrication grading units. Each contain one or both types of grading units. specimen shall contain one or both types of grading units. Flaws shall not interfere with ultrasonic detection or characterization of other flaws.

(a)(1) A base grading unit shall include at least Modification: (a)(1) A base metal grading unit includes

U. S. Nuclear Regulatory Commission Attachment 2 3F0507-03 Page 3 of 6 Appendix VIII, Supplement 11 PDI Modification 3 inches of the length of the overlaid weld. The the overlay material and the outer 25% of the original base grading unit includes the outer 25% of the overlaid weld. The base metal grading unit shall extend overlaid weld and base metal on both sides. circumferentially for at least 1 inch and shall start at the The base grading unit shall not include the inner weld centerline and be wide enough in the axial direction 75% of the overlaid weld and base metal to encompass one half of the original weld crown and a overlay material, or base metal-to-overlay minimum of 0.50 inch of the adjacent base material.

interface. Basis: The phrase "and base metal on both sides," was inadvertently included in the description of a base metal grading unit, The PDI program intentionally excludes this requirement because some of the qualification samples include flaws on both sides of the weld. To avoid confusion several instances of the term "cracks" or "cracking" were changed to the term "flaws" because of the use of alternative flaw mechanisms. Modified to require that a base metal grading unit include at least 1 inch of the length of the overlaid weld, rather than 3 inches.

(a)(2) When base metal cracking penetrates into Modification: (a)(2) When base metal flaws penetrate the overlay material, the base grading unit shall into the overlay material, the base metal grading unit include the overlay metal within 1 inch of the shall not be used as part of any overlay fabrication crack location. This portion of the overlay grading unit.

material shall not be used as part of any overlay grading unit.

(a)(3) When a base grading unit is designed to Modification: (a)(3) Sufficient unflawed overlaid weld be unflawed, at least 1 inch of unflawed and base metal shall exist on all sides of the grading unit overlaid weld and base metal shall exist on to preclude interfering reflections from adjacent flaws.

either side of the base grading unit. The Basis: Modified to require sufficient unflawed overlaid segment of weld length used in one base weld and base metal to exist on all sides of the grading grading unit shall not be used in another base unit to preclude interfering reflections from adjacent grading unit. Base grading units need not be flaws, rather than the 1 inch requirement.

uniformly spaced around the specimen.

(b)(1) An overlay grading unit shall include the Modification: (b)(1) An overlay fabrication grading unit overlay material and the base metal-to-overlay shall include the overlay material and the base metal-to-interface of at least 6 square inches. The overlay interface for a length of at least 1 inch.

overlay grading unit shall be rectangular, with Basis: Modified to require sufficient unflawed overlaid minimum dimensions of 2 inches. weld and base metal to exist on all sides of the grading unit to preclude interfering reflections from adjacent flaws, rather than the 2 inch requirement.

(b)(2) An overlay grading unit designed to be Modification: (b)(2) Overlay fabrication grading units unflawed shall be surrounded by unflawed designed to be unflawed shall be separated by unflawed overlay material and unflawed base metal-to- overlay material and unflawed base metal-to-overlay overlay interface for at least 1 inch around its interface for at least 1 inch at both ends. Sufficient entire perimeter. The specific area used in one unflawed overlaid weld and base metal shall exist on overlay grading unit shall not be used in another both sides of the overlay fabrication grading unit to overlay grading unit. Overlay grading units preclude interfering reflections from adjacent flaws. The

U. S. Nuclear Regulatory Commission Attachment 2 3F0507-03 Page 4 of 6 Appendix VIII, Supplement 11 PDI Modification need not be spaced uniformly about the specific area used in one overlay fabrication grading unit specimen, shall not be used in another overlay fabrication grading unit. Overlay fabrication grading units need not be spaced uniformly about the specimen.

Basis: Paragraph 1.1 (e)(2)(b)(2) states that overlay fabrication grading units designed to be unflawed shall be separated by unflawed overlay material and unflawed base metal-to-overlay interface for at least 1 inch at both ends, rather than around its entire perimeter.

(b)(3) Detection sets shall be selected from Modification: (b)(3) Detection sets shall be selected Table VIII-S2-1. The minimum detection from Table VIII-S2-1. The minimum detection sample sample set is five flawed base grading units, ten set is five flawed base metal grading units, ten unflawed unflawed base grading units, five flawed base metal grading units, five flawed overlay fabrication overlay grading units, and ten unflawed overlay grading units, and ten unflawed overlay fabrication grading units. For each type of grading unit, the grading units. For each type of grading unit, the set shall set shall contain at least twice as many unflawed contain at least twice as many unflawed as flawed as flawed grading units. grading units. For initial procedure qualification, detection sets shall include the equivalent of three personnel qualification sets. To qualify new values of essential variables, at least one personnel qualification set is required.

(f) Sizing Specimen (1) The minimum number of flaws shall be ten. Modification: (1) The minimum number of flaws shall At least 30% of the flaws shall be overlay be ten. At least 30% of the flaws shall be overlay fabrication flaws. At least 40% of the flaws fabrication flaws. At least 40% of the flaws shall be shall be cracks open to the inside surface. open to the inside surface. Sizing sets shall contain a distribution of flaw dimensions to assess sizing capabilities. For initial procedure qualification, sizing sets shall include the equivalent of three personnel qualification sets. To qualify new values of essential variables, at least one personnel qualification set is required.

(3) Base metal cracking used for length sizing Modification: (3) Base metal flaws used for length demonstrations shall be oriented sizing demonstrations shall be oriented circumferentially.

circumferentially.

(4) Depth sizing specimen sets shall include at Modification: (4) Depth sizing specimen sets shall least two distinct locations where cracking in include at least two distinct locations where a base metal the base metal extends into the overlay material flaw extends into the overlay material by at least 0.1 inch by at least 0.1 inch in the through-wall in the through-wall direction.

direction.

2.0 CONDUCT OF PERFORMANCE DEMONSTRATION The specimen inside surface and identification Modification: The specimen inside surface and shall be concealed from the candidate. All identification shall be concealed from the candidate. All examinations shall be completed prior to examinations shall be completed prior to grading the

U. S. Nuclear Regulatory Commission Attachment 2 3F0507-03 Page 5 of 6 Appendix VIII, Supplement 11 PDI Modification grading the results and presenting the results to results and presenting the results to the candidate.

the candidate. Divulgence of particular Divulgence of particular specimen results or candidate specimen results or candidate viewing of viewing of unmasked specimens after the performance unmasked specimens after the performance demonstration is prohibited. The overlay fabrication demonstration is prohibited. flaw test and the base metal flaw test may be performed separately.

2.1 Detection Test. Flawed and unflawed Modification: 2.1 Detection Test. Flawed and unflawed grading units shall be randomly mixed. grading units shall be randomly mixed. Although the Although the boundaries of specific grading boundaries of specific grading units shall not be revealed units shall not be revealed to the candidate, the to the candidate, the candidate shall be made aware of candidate shall be made aware of the type or the type or types of grading units (base metal or overlay types of grading units (base or overlay) that are fabrication) that are present for each specimen.

present for each specimen.

2.2 Length Sizing Test (d) For flaws in base grading units, the Modification: (d) For flaws in base metal grading units, candidate shall estimate the length of that part the candidate shall estimate the length of that part of the of the flaw that is in the outer 25% of the base flaw that is in the outer 25% of the base metal wall wall thickness. thickness.

2.3 Depth Sizing Test. For the depth sizing test, Modification: 2.3 Depth Sizing Test.

80% of the flaws shall be sized at a specific (a) The depth sizing test may be conducted separately or location on the surface of the specimen in conjunction with the detection test.

identified to the candidate. For the remaining (b) When the depth sizing test is conducted in flaws, the regions of each specimen containing a conjunction with the detection test and the detected flaws flaw to be sized shall be identified to the do not satisfy the requirements of 1.1 (f), additional candidate. The candidate shall determine the specimens shall be provided to the candidate. The maximum depth of the flaw in each region. regions containing a flaw to be sized shall be identified to the candidate. The candidate shall determine the maximum depth of the flaw in each region.

(c) For a separate depth sizing test, the regions of each specimen containing a flaw to be sized shall be identified to the candidate. The candidate shall determine the maximum depth of the flaw in each region.

U. S. Nuclear Regulatory Commission Attachment 2 3F0507-03 Page 6 of 6 Appendix VIII, Supplement 11 PDI Modification 3.0 ACCEPTANCE CRITERIA 3.1 Detection Acceptance Criteria. Examination Modification: 3.1 Detection Acceptance Criteria.

procedures, equipment, and personnel are Examination procedures are qualified for detection qualified for detection when the results of the when:

performance demonstration satisfy the (a) All flaws within the scope of the procedure are acceptance criteria of Table VIII-S2-1 for both detected and the results of the performance detection and false calls. The criteria shall be demonstration satisfy the acceptance criteria of Table satisfied separately by the demonstration results VIII-S2-1 for false calls.

for base grading units and for overlay grading (b) At least one successful personnel demonstration has units. been performed meeting the acceptance criteria defined in (c).

(c) Examination equipment and personnel are qualified for detection when the results of the performance demonstration satisfy the acceptance criteria of Table VIII-S2-1 for both detection and false calls.

(d) The criteria in (b) and (c) shall be satisfied separately by the demonstration results for base metal grading units and for overlay fabrication grading units.

3.2 Sizing Acceptance Criteria.

(a) The RMS error of the flaw length Modification: (a) The RMS error of the flaw length measurements, as compared to the true flaw measurements, as compared to the true flaw lengths, is lengths, is less than or equal to 0.75 inch. The less than or equal to 0.75 inch. The length of base metal length of base metal cracking is measured at the flaws is measured at the 75% through-base-metal 75% through-base-metal position. position.

(b) All extensions of base metal cracking into Modification: This requirement is omitted.

the overlay material by at least 0.1 inch are Basis: The requirement for reporting all extensions of reported as being intrusions into the overlay cracking into the overlay is omitted from the PDI material. Program because it is redundant to the RMS calculations performed in paragraph 3.2(c) and its presence adds confusion and ambiguity to depth sizing as required by paragraph 3.2(c). This also makes the weld overlay program consistent with the Supplement 2 depth sizing criteria.

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 ATTACHMENT 3 ASME Section XI Code Case N-740-1 Tracking No. BC06-1651 2-7-07 Editing and Review Final, "Dissimilar Metal Weld Overlay for Repair of Class 1, 2, and 3 ItemsSection XI, Division 1," Draft February 2007

U. S. Nuclear Regulatory Commission Attachment 3 3F0507-03 Page 1 of 14 BC06-1651 2-7-07 editing and review Final. Deleted: 1.-07 RRA Inserted: 1.31-07RRA¶ Case N-740-1 Formatted: Right: 1.2S", Bottom:

Dissimilar Metal Weld Overlay for Repair of Class 1, 2, and 3 Items d ft ee 0.5" Section X1, Division I lete: Bc0-,03 Inquiry: As an alternative to the provisions ofIWA-4410 and IWA-461 I for reducing a defect to an acceptable size in accordance with the provisions of the Construction Code or Section XI, is it permissible to reduce a defect to a flaw of acceptable size by increasing the wall thickness, or to apply a mitigation to a specitied location, by Deleted: 2005 deposition of weld overlay on the outside surface of the piping, component, or associated Deleted::

weld?

4 Formatted: Bullets and Numbering Reply: It is the opinion of the Committee that, in lieu of the requirements of IWA-4410 Formatted:

bullets or numrbering, Left:

Indent: Tabs:0.5',i.9",No ulstab and IWA-461 1, a defect in austenitic stainless steel or austenitic nickel alloy piping, components, or associated welds may be reduced to a flaw of acceptable size in Deleted: Alloyt21182 I accordance with IWB-3640 by addition of a re.air weld overlay. Alternatively if Formtted: Font: n pt mitigation accordancec iswith perfonned, it may also be developed bv treating a postulated IWB-3640 by apiplication of a mitigative weld overlay. Allflaw in XI Section ., oeiet:: atesiio references are to the 2004 Edition with they2006 Addenda. For the use of this Case with For'; tted Font: i other Editions and Addenda, refer to Table 1.The weld overlay shall be applied by ',

P-oeted! ,r 12C'estc2nhaorbelwen NoDe1eed 1Ad deposition of weld reinforcement (weld overlay) on the outside surface of the piping, component, or associated weld, including ferritic materials when necessary, provided the Deleted following requirements are met. d Font: pt Fonnt:tedp LGeneral Requirements - t:

(a) A full-structural weld overlay shall be applied by deposition of weld reinforcement K!L , Formte ..

(weld overlay) on the outside surface of the low alloy steel nozzles (P-No. 3) to thclaife saf Fo.naed: Font: Itpt end (P-No. For 43). inclusive of theNN06082 or W86182 weld thai inins the two items. Jj., Deleted: toPNo.43 ,tcril The desian of the overlay may be extended to include the adiacent stainless steel to . Formatted Font It pt sta inle ss st eel w eld s P-No . 8 to P-No. 8F . . . .. ."t w or tw (bLThis Case applies to dissimilar metal welds between P-No.8 or 43 and P-No 1o3Deleted: wlds btwo F..8 loP-1_ 3 N.. 8 or 12A, 12BI 2CC materials This-Case also ap.lies to dissimilar metal welds between P .

,_o._8andTýlp-o 43 materialsjoined withpaustgnitic N.43 filler-mctal, and to wehlds . - Fmatted: Font: ll pt between P-5jNo. 8_nd P-No 8 materials as described inparagraph I.(a) abov .Deleted: 43to F-(.).Weld overlay filler metal shall beaustenitic nickel alloy (28% Cr mit*e, ., F-orre-matted:

ERNiCrFe-7 or ERNiCrFe-7A) applied 360'deg. around the circumference of the V.\ Deleted: anFont: 11pt item, and shall be deposited using a Welding Procedure Specification (WPS) for For m-atted .. 3 groove welding, qualified in accordance with the Construction Code and Owner's (Deeted: ,,ieo Requirements and identified in the Repair/Replacement Plan. As an altemative to Deleted -. 0 T4"1 the post weld heat treatment tPHIrequirements of the Construction Code and , _o.-. Foo...I

• ,*' Forma'tted.= Font: 11 Pt Owner's requirements, the Low rovsns

.............7nay be applie.h l*{/... e-* m~i~as.... .. . lFormatted: Bulletsand Numberingl (l) For P-No. base materials the Construction Code PWHT exemptio ."...

permitted for circumferential butt welds may be applied to exempt the eted: low oazo(O.0355 -c.

weld overlav ftiom PWHT with the following clarification§. ', coi o ooo . .o

'_________._____ _. .....- .__ IFormatted: Indent Lf: 0.49" (a) The nominal weld thickness shall be defined as the maximum overlay -,', '

thickness applied over the lfrritic base material. ,Deleted Deleted::1 IFormatted

' P-Non. 12A, 12B, and 12C designations refer to specific material classifications originally identified in Section Ill and subsequently reclassified in a later Edition of Section IX. I

U. S. Nuclear Regulatory Commission Attachment 3 3F0507-03 Page 2 of 14 1BC06-1651 .. ( cule 3 2-7-07 editing and review Final ..... Deleed: 1-31-0 l~ormatted: Bullets and Numbering j (b) The base material thickness shall be as defined as the maximum thickness of the fierritic material where the overlay is applied

.(I./.ppendix I may be used for ambient-temperature temper bead welding. Formatted: Indent: Left: 0.73', No bullets or numbering (dQPrior to deposition of the weld overlay, the surface to be-weld overlaid shall Deleted:

be examined by the liquid penetrant method. Indications larger than 1/16 in. (I.5 Formatted: Indent: Left: 0.5',

mm) shall be removed, reduced in size, or corrected in accordance with the Space Before: 12 pt. NO butlets or numbering following requirements, Deleted: repaired D~eleted.

(L)_One or more layers of weld metal shall be applied to seal unacceptable SDeleted::

indications in the area to be repaired with or without excavation. The thickness of these layers shall not be used in meeting weld reinforcement Intserted:

design thickness requirements. Peening the unacceptable indication prior to Formatted: Indent: Left'. 0.74", No bullets or numbering welding is permitted.

2.lfrpair of indications identified in W is required, the area where the - (Deleted: .0 weld overlay is to be deposited, including any local repairs or initial weld Deleted: c overlay layer, shall be examined by the liquid penetrant method. The area shall contain no indications greater than 1/16 in. (1.5 mm) prior to the application of the structural layers of the weld overlay.

Deleted:

(*.)Weld overlay deposits shall meet the following requirements -----------

,The austenitic nickel alloy weld overlay shall consist of at least two weld Formatted: Indent: Left: 0.49"% No layers deposited from a filler material with a Cr content of at least 28%. The bullets or numbering first layer of weld metal deposited may not be credited toward the required

• Deleted: <#>The sustenitic stainleos

• steel weld reinforcemeotshall consist of thickness. Alternatively, for PWR applications, a diluted first layer may be at least two weld laysn having as-credited toward the required thickness, provided the portion of the layer over deposited delta ferrite content ofat least 7.5 FN. The first layer of weld octal with the austenitic base material, austenitic filler material weld and the associated delta ferrite content ofat least 7.5 FN dilution zone from an adjacent ferritic base material contains at least 24% Cr shall ¢onstijtc the first layer of the weld rcinforcoment that may be credited and ,he Cr content of the deposited weld metal is determined by chemical toward the required thickness analysis of the production weld or of a representative coupon taken from joa Alternatively, first layca of least 5 FN ase acceptable, provided the carbon mockup prepared in accordance with the WPS for the production weld. cantont ofthe deposited weld metal is Alternatively, for BWR applications, a diluted first layer may be credited S determined by chemical analysis to be lesn than O.52%.1 toward the required thickness, provided the portion of the layer over the austenitic base material, austenitic filler material weld and the associated Formatted: Indent: Left: 0.75", No bullets or numbering, Tabs: 0.75",

dilution zone from an adjacent ferritic base material contains at least 20% Cr and the Cr content of the deposited weld metal is determined by chemical Deleted:

analysis of the production weld or of a representative coupon taken froma. ~Deeed:~

mockup prepared in accordance with the WPS for the production weld. Deleted:

ffLThis Case is only for welding in applications predicted not to have exceeded -- ormatted: Indent: Left: 0.49", No 2 bullets or numbering thermal neutron fluence of I x 1017 (E< 0.5 eV) neutrons per cm prior to welding.

(g) -A new weld overlay shall not he installed over the top of an existine weld . Formatted: Bullets and Numbering overlay that has been in service.

FoDeaeted:I (Formatted: tndent: Left 049 2

U. S. Nuclear Regulatory Commission Attachment 3 3F0507-03 Page 3 of 14

,BC06-1651] -,,.(.Dletd'. - ,4-00

.2-7-07 -editing and review Final_- [-lete: .1- RR3 1 1-01 2 Crack G rowth and Design. Deleted: Consid-rali.o

- aL F"rmatted: Bullets and Numbering Crack Growthl, Deeted: Flu. aaa-ctcatio. nnd evaluation requiienmcnitsshall be based on thsfound fluw. H--von. the The size of all flaws detected or postulatcd in the original weldinent shall be projected to the end of the xpectd life of the overlay. Crack gro t-dw o, . itted. Co nsida'toa,,

both stress corrosion and fatigue shall be evaluated. Flaw -characterization and Formatted: Indent: Left:0.7S, No evaluation shall be based on the ultrasonic examination results  % D.,ledo :anesig (1) For repair overlays, the initial flaw size for crack growth'v shall be b-sed on--eted EDeted: . including the as-found fla%%. ........... n (2) For mitigative overlays, the initial postulated flaw size for crack growth - Dleted: ocrakgrowth, shall be assumed consistent with the examinations performed. either pre or f Deleted: evaluated in theinaterials

.. accordance with IWB-3641. Itthe flaw in post overlay. The axial flaw length shall be set at 1.5 inches (38 mm) or the is a onnm mthebondary ortwo diffetent ccombined irc u mnferewidth n tia l flof le nweld awthe plus gth sh a ll bbuttering, e assum e d to b e 3 6 0 isd egreater.

whichever The btihmater tiaIts iof growta g, * ,. b t *t l *

• i a Deleted: conidered (a) If an examination is performcd prior to application of the overlay, iIMreerted: .... i&d which is qualified in accordance with.Apendix VIII, Supplement II , Defalted::

and no inside surface connected planar flaws are discovered, initial Formatted: Indent: Loft:0.75" flaws (originated from the inside surface of the weldment) equal to "FOatted:

F'," Bullets and Numbering 10% of the original wall thickness shall be assumed in both the axial " Deleted: .i and circumferential directions. D*leted: 3.0blow.

(b) If no examination is performed 7 5 prior toapplication of the ovcrlay,

% through the original wall thickness initial flaws equal to at least shall he assumed, in both the axial and circumfercntial directions, consistent with the overlay inservice inspection volume in Fig. 2.

(c) There may be circumstances in which an overlay examination is perforend using an ultrasonic examination procedurc which is qualified in accordance witliAppendix VIII Supplement II for deths e..

leted: 3.Obrteo greater than the outer 25% of the original wall thickness (Fig. 2). For such cases, initial tlaw sizes may be assumed consistent with the depth to which the examination procedure is Qualified.

(d) Any inside surface connected planar flawfound by the overlay - d: indication preservice inspection of paragraph I(b), which exceed the depth of Dleted: .0 (a), (b) or (c) above, shall be used as the initial flaw depth in determining the expected life of the overlay. Overlays mecting this condition shall be considered a repair.

(b) Structural Design and Sizing of the Overlay The design of the weld overlay shall satisfy the following, using the Formatted: Indent: Left: 0.75', No assumptions and flaw characterization restrictions in 2(a), The following bullets or numbering design analysis shall be completed in accordance with IWA-4311. Deleted: .0 3

U. S. Nuclear Regulatory Commission Attachment 3 3F0507-03 Page 4 of 14 BC06-1651 2-7-07 editing and review Final (1) The axial length and end slope of the weld overlay shall cover the weld Formatted: Outlinenumbered

+

aLevl: 4 + Numbering SWte:1, 2, 3, and the heat affected zones on each side of the weld, and shall provide for + Strt at: I + Algnment: Left +

load redistribution from the item into the weld overlay and back into the Aligned at: 0.75- + Tab after: 1I +

item without violating applicable stress limits of NB-3200 or the Indent at: 1' Consltuction Code. Any laminar flaws in the weld overlay shall be evaluated in the analysis to ensure that load redistribution complies with me aoove. tnese requirements will usually oe satisfied isme welo overlay Deleted full thickness length extends axially beyond the projected flaw by at . ,t, da:

least0.75,/I7, where R Iis the outer radius of the item and I is the nominal . , ' Deleted: 45 wall thickness of the item. ,' ' t*leted'. , itfthcourbi,,d 1-gt is (2) Unless specifically analyzed in accordance with 24b) (]),-the end transition ,'. - gmathan lrofthcimumfemneof slope of the overlay shall not exceed.3 deg. A slope of not more than 1:3 " th item is recommended. ' Deleted: Forimeirner-illahy-riented flawsirtli eomrbicd length (3) For determining the combined length of circumferentially-oriented flaws dsot eaxceeW, o.,t, in the underlving base material or weld, multiple flaws shall be treated as eimrntmfctoftl ihem. tbuflawsshall one flaw of length equal to the sum of the lengths of the individual flaws beoasnmed to be100%through the oneoriginalwall thickonessotho itemfor, characterized in accordance with IWA-3300. circumferential length equaltothe (4) For circumferentially-oriented flaw.%in the underl,,ing base material or rrmbinedlength of theflaws weld, the flaws shall be assumed to be 100% through the original wall Deleted: 1.5 Deletd: (38 m) thickness of the item for the entire circumference of the item, ............. .. (Delet:.

lo:ger, o . iv rmr (5) For axial flaws inthe underlying base material or wed, the flaws shall be .., . (Deleted: I ngv

,or forfiormo assumed to be 100% through the original wall thickness of the item for the Deleted: i entire axial length of the flaw or combined flaws, as applicable for the Deted:

entire circumfierence. " Deleted:

(6) For mitigative full structural overlays, the assumed flaw in the underlyin , Deleted: ii base matcrial or weld is lo be based on the limiting case of the two below: Deleted:

(a. 100% through wall for the entire circumference, or I 1Mt"h (b) J-00%0-through wall for 1.5 in,138 mm)-or the cobiined width oftle _,., .Deleted: ohe weld plus buttering. whichever is Lreater, in the axial direction for the lteeed:chu 1."nm)or the entire circumference. cimbirud widt o'le weldplus (7) The overlay design thickness shall be based on the measured butterint. which- isgmuioe. inthe axiol detionm forthe enulro

-circumference, using only the weld overlay thickness conforming to the " " mii"ferenoe.1 deposit analysis requirements of lIg). The combined wall thickness at the Fo,.matted: Outline numbered +

weld overlay, any planar flaws in the weld overlay, and the effects of any ,c'. Level: 4 + Numbering Style: 1, 2, 3, discontinuities e..g., another weld overlay or reinforcement for a branch , ',II + Startaeat:0.75+ 1÷ Tabait7:Left:

connection) within a distance of 2.5,5t7 from the toes of the weld Indent at: V overlay, including the flaw size assumptions defined in 1b1(4)., 5). or(6) Deleted: ofhems**ntg2tiol(4) o above shall be evaluated and shall meet the requirements of IWB-3640, ' v  : diusie IWC-3640Qor IWD-3640,as appli~cable. , edt (jTeeffects of any changes in applied loads, assa result of weld shrinkage Deleted:.d Deetd:

from the entire overlay, on other items in the piping system (e.g., support Deleted: d loads and clearances, nozzle loads, changes in system flexibility and Deted: disoouety weight due to the weld overlay) shall be evaluated. Existing flaws 'Deleted:.t Deleted:

Deleted:.

4

U. S. Nuclear Regulatory Commission Attachment 3 3F0507-03 Page 5 of 14

,3C06-1651 Dele.ted: DCo4-1003 2-7-07 editing and review Final Deleted: ,-*-7Rt previously accepted by analytical evaluation shall be evaluated in accordance with IWB-3640, IWC-3640orlIWD-364_0ia[s_applicable.-

Fomatted: Snap to grid 2 -kExmm inat~ioq ... ......... .. ...... ....... ......... . ... ............ L Formatted: Don't snap to grid In lieu of all other examination requirements, the examination requirements of this Case - S JFormatted: No bullets or

.'. numbering shall be met. Nondestructive examination methods shall be in accordance with IWA-

" .*Deleted: .0 2200, except as specified herein. Nondestructive examination personnel shall be qualified in accordance with IWA-2300. Ultrasonic examination procedures and Deleted: and Inspection personnel shall be qualified in accordance with Appendix VIII Sunnlcment 11. Formatted: Indent: First line: 0" LajAcceptance Examination Comment*s I would Ike o add (1) The weld overlay shall have a surface finish of 250 micro-in. (6.3 * "Supplem et II maimnplenm. tedthtough micrometers) RMS or better and a flatness that is sufficient to allow for " th. EPR] PDI program'. Thi i. nee-dd S toetimiminc mlietr.,s mlU l, withte NRC adequate examination in accordance with procedures qualified per Appendix Deleted: ScnonmXI VIII. The weld overlay shall be examined to verify acceptable configuration.

(2) The weld overlay and the adjacent base material for at least 1/2ain. (13 mm) Formatted: Indent: Left:0.2S", No bullets or numbering from each side of the weld shall be examined using the liquid penetrant Formatted: Outline numbered +

method. The weld overlay shall satisfy the surface examination acceptance Level: 3 + Numbering Style: 1, 2, 3, criteria for welds of the Construction Code or NB-5300. The adjacent base ... Start at: 1 + Alignment: Left +

AJigned at: 0.5' + Tab after: 0.75" metal shall satisfy the surface examination acceptance criteria for base + Indent at: 0.75" material of the Construction Code or NB -2500. If ambient temperature temper bead welding is used, the liquid penetrant examination shall be conducted at least 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after the completed overlay has returned to ambient temperature.

(3) The acceptance examination volume A-B-C-D in Fig.12a shall be ultrasonically examined to assure adequate fusion (i.e., adequate bond) with the base metal and to detect welding flaws, such as interbead lack of fusion, inclusions, or cracks. The interface C-D shown between the overlay and the weld includes the bond and the heat affected zone from the overlay. If ambient temperature temper bead welding is used, the ultrasonic examination shall be conducted at least 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after the completed overlay has returned to ambient temperature.

Planar flaws detected in the weld overlay acceptance examination shall meet the preservice examination standards of Table IWB-3514-2. In applying the DletedIK:, , wall th~ickness t*' ehall be acceptance standards.o planar indications within the volumc. E-F-G-H. in -..

/the thickmnasofthbe wcnldovortay.

Fig. I(b), the thickness "ti" shall be used as the nominal wall thickness in Table IWB-3514-2. For planar indications outside this examination volume, the nominal wall thickness shall be "t2" as shown in FiR. I(c), for volumes A-E-H1-D and F-B-C-G.

Deleted::

Laminar flaws shall meet the following --------- Formatted. Indent: Lett: 0.5-, First (a)..Laminar flaws shall meet the acceptance standards of Table IWB-3514-3 line: 0.25", No bullets or numbering with the additional limitation that the total laminar flaw shall not exceed Formatted: Outline numbered +

10% of the weld surface area and that no linear dimension of the laminar Level: I + Numbering Style: a, b, c,

- + Start at: 1 + Alignment: Left +

Aligned at: 0.75' + Tab after: I" +

Indent at: 1" 5

U. S. Nuclear Regulatory Commission Attachment 3 3F0507-03 Page 6 of 14

,,C06-1651 2-7-07 editing and review Final Dlted. ?-31-07RRA j~~

flaw area exceeds 3.0 in. (76 mm.), or 10,% of the nominal pipe_ eleted:)

circumference, whichever is m-cater- _-"-"----elete: --- ,t

(.bThe reduction in coverage ofthe examination volume A-B-C-D in Fig. Deleted: I 1(a) due to laminar flaws shall be less than 10%. Thenuninspnctable. Formatted: Outline numbered +

volume is the volume in the weld overlay underneath the laminar flaws for Level:1 + Numbering Style: a, b, c, which coverage cannot he achieved withngle beam examination., '., ... + Start at: 1 + Alignment: Left+

.. ........... ..... ....... .. Aligned at: 0.75" + Tab after: 1"+

c)..Any uninspectable volume in the weld overlay shall be assumed to contain indent at: t" the largest radial planar flaw that could exist within that volume. This . "Desn*eed: dimnneiom ofthl assumed flaw shall meet the nreservice examination standards of Table Deleted'. -u mdnnu- onr IWB-3514-2. with nominal wall thickness as defined above for Planar Deletted:

flaws. Alternately, the assumed flaw shall be evaluated and,meet the Dted; orth ovt~y.

requirements oflWB-3640, IWC-3640, or IWD-3640,as applicable. Both De't ry axial and circumferential planar flaws shall be assumed. Deleted: I (4) After completion of all welding activities, affected restraints, supports, and .. ,  : n snubbers shall be VT-3 visually examined to verify that design tolerances are Delted: ,olt met. D leted: .

(b) Preservice Inspection Formatted; ouine numbered +

(1) The examination volume in Fig, 2 shall be ultrasonically examined. The angle -. Level: 3 + Numbering Style: 1,2, 3,

+ Start at: 1 + Alignment: Left +

beam shall be directed perpendicular and parallel to the piping axis, with Aligned at: 0.5- + Tab after: 0.75" scanning performed in four directions, to locate and size any cracks that might + Inrent at: 0.75" have propagated into the upper 25% of the base material or into the weld Formatted: Outline numbered +

overlay. , Level:2 + Numbering Sle: a, b, c,

• ... + Start at: I + Alignment: Left +

(2) The preservice examination acceptance standards of Table IWB-35 14-2 shall ]Aligned at: 0.25' + Tab after: 0.5' be met for the weld overlay. In applying the acceptance standards, wall +_Indent at: 0.5" thickness, tI, shall be the thickness of the weld overlay. Cracks in the outer Formatted: Outline numbered +

25% of the base metal shall meet the design analysis requirements of 2,......Level: 3+ Numbering Style: 1.2,3

.... To ... + Start at: I + Alignment: Left +

(3) The law evaluation rules of IWB-3640, IWC-3640 or. 1WD-3640 shall not be ", Aligned at: 0.5" + Tab after: 0.75" applied to indications identified during preservice examination which exceed LIndent at: 0.75' the preserice examination standards of Table IWB-3514-2. Deleted: .

(c) Inservice Inspection . Formattfed..r.i (1) The weld overlay examination volume in Fig. 2 shall be added to the - Formatte inspection plan andupitrasonically examined during the first or second . Deleted; h.lt re e nIIg outalge: o.ILw11 ngppcll on.;it~l (2) Alternatively, for mitigative weld overlays, in which examinations are performed in accordance with 21a).22)(a), 3(a). and 31b). and noinside surface IDeleted:.

connected planar flaws are discovered, the overlay may be placed directly into ,.....leojt~a:.0 the population to be examined in accordance with (c)(5) below. Deleted, i

(,3)The weld overlay examination volume in Fig. 2 shall be ultrasonically (Deleted: .0 examined to determine if any new or existing cracks have propagated into the Deleted: defent upper 25% of the base material or into the overlay. The angle beam shall be IFormatt'ed directed perpendicular and parallel to the piping axis, with scanning performed in four directions.

f4hThe inservice examination acceptance standards of Table IWB-3514-2 shall f Deleted: Alt-tively, f., Cls 1.

be met for the weld overlay. Jf the acceptance criteria of Table IWB-351 4-2 Deleted:

cannot be met, the acceptance criteria oflWB-3600, IWC-3600, or IWD-3600Q .013 piping sys=--ý Deleted: ,

U. S. Nuclear Regulatory Commission Attachment 3 3F0507-03 Page 7 of 14 J3C06-1651 ..-" [Delted: eted(: BC04-1003 1-31107 RRA 2-7-07 editing and review Final as applicablshall be met for the -weld ovverlay. _Cracks in tlthe outer 25% of Deleted:.

Deleted: .0 the base metal shall meet the design analysis requirements of Section 2,(.b._

(5LýWeld overlay examination volumes in Fi,. 2 that show no indication of crack growth or new cracking shall be placed into a population to be examined on a sample basis. Twenty-five percent of this population shall be examined once - Deleted: t everyJ,.Q years. . .. ........ .....

(6) f inservice examinations reveal crack growth, or new cracking, whi-ch meet the acceptance criteria oflWB-35 14, 1WB-3600. IWC-3600, or IWD-3600 the .. Deleted: standards, weld overlay examination volume shall be reexamined during the first or Deleted: Table second refueling outage following discovery of the growth or new cracking! _- S ComMeft Bamfordot socres to rao (7)..For weld overlay examination volumes with unacceptable indications that this should bh required whether or Accordine to _3c)(),_the weld overlay shall be removed, including the original not the indications meet the stwndrdns.If they can bhecvolsted, this requirement defective weld, and the item shall be corrected by a repair/replacement should also apply. I suggest that tw soy somethin8like this: IflSl veats gowth activity in accordance with IWA-4000. of more than 20% in length or depth, the (d) Additional Examinations. If inservice examinations reveal an unacceptable 0WOL ecum volume....

indication according to "1c)1(4)), crack growth into the weld overlay design Deleted: s described in thickness, or axial crack growth beyond the specified examination volume, Deleted. .0 additional weld overlay examination volumes, equal to the number scheduled for "(Deleted: 2)and(3 the current inspection period, shall be examined prior to return to service. If Formatted: Outline numbered +

additional unacceptable indications are found in the second sample, a total of 50% Level: 2 + Numbering Style: a, b, c, of the total population of weld overlay examination volumes shall be examined ... + Start at: I + Alignment: Left +

prior to operation. If additional unacceptable indications are found, the entire "+Aligned Indentat: 0.5" + Tab after: 0.5" at: 0.25" remaining population of weld overlay examination volumes shall be examined F aDeleted:

.0 prior to return to service.

4.0 Pressure Testing .........-

A system leakage test shall be performed in accordance with IWA-5000. Formatted: No bullets or numbering

• IFormatted: No bullets or 5.0 Documentation Lnumbering Use of this Case shall be documented on Form NIS-2.

7

U. S. Nuclear Regulatory Commission Attachment 3 3F0507-03 Page 8 of 14 D3C06-1651 I Deleted: BC04-1003 2-7-07 editing and review Final.

A

a. A=W.*an -WF..admoVolumeA,.BC-D (N 1 .I 0

b, Thkk-.s IM1)WoT.b. IWB-3514-c.ThUl n. 52)forT,ý 1-1.354-2 Fig. I Acceptance Examination Volume and Thickness Definitions Notes:

(1) For axial or circumferential flaws, the axial extent of the examination volume shall extend at least V2in.(113mm) beyond the toes of the origtinal weld.

(2) The weld includes the weld end butter, where applied 8

U. S. Nuclear Regulatory Commission Attachment 3 3F0507-03 Page 9 of 14 BC06-l651 1Deleted: HCi 1003 2-7-07 cditinl, and review Final-t E.-nI,,.Uo. Volumn.A-B--D

,NOTE.: Deleted: ýp LF.or tmial or-circumnferential flaws, the axial extent of tlhe examination volume shall - jDeintedltll extend at least Y. in. (13mrm) beyond the as-found flaw and at least t4 in. (I13mm) -(Forratfted: Bullets end Num~bering beyond the toes of the original weld, _ _ . -............

• (Deleted:.

(2) The weld includen weld end butter, where applied..

-fDeleted: iaciadia

• Deleted: I Fig. 2 Preservice and Inservice Examination Volume I 9

U. S. Nuclear Regulatory Commission Attachment 3 3F0507-03 Page 10 of 14 Final .n 270 di06-1651 - - and review

,2-7-07 editing and review Final .... eed*:+/-31-07 RKA I Mandatory Appendix J _ Formatted: Font: 16 pt- Bold Ambient Temperature Temper Bead Welding

-" Formatted: Outline numbered +

I GENERAL REQUIREMENTS Level: 1 + Numbering Style: 1, 2, 3, (a) This appendix applies 1 to dissimilar austeniticiller metal welds between P-Noi.1, ... + Start at: I + Aignment: Left +

12A, 12B, and 12C materials and their associated welds and welds joining P-No. 8 or . Aligned at: 0" + Tab alter: 0.4" +

1 43 materials to P-No. 1, 3, 12A, 12B, and 12C materials with the following limitation: Indent at: 1.35" This Appendix shall not be used to repair SA-302 Grade B material unless the material 1Deleted:

has been modified to include from 0.4% to 1.0% nickel, quenching and tempering, and application of a fine grain practice. Deleted: s (b) The maximum area ofan individual weld overlay based on the finished surface over the ferritic base material shall be 500 sq. in. (325,000 sq. mm).

(c) Repair/replacement activities on a dissimilar-metal weld in accordance with this Appendix are limited to those along the fusion line of a nonferritic weld to ferritic base material on which 1/8 in. (3 mm), or less of nonferritic weld deposit exists above the original fusion line.

(d) if a defectpnetrates into the ferritic beasem n LeaiJpa.of the base material, using a nonferritic weld filler material, may be perfornmed in accordance with this Appendix, provided the depth of repair in the base material does not exceed 3/8 in. (10pim).

(a) Prior to welding the area to be welded and a band around the area of at least 1-1/2 times '

the component thickness or 5 in. (130 mm), whichever is less, shall be at least 5OF (10 C).

(0) Welding materials shall meet the Owner'sRequirements and the Construction Code and Casesgcecified in the Repair/Replacement Plan. Welding materials shall be controlled so that they are identified as acceptable until consumed.

(g) Peening may be used, except on the initial and final layers.

2 WELDING QUALIFICATIONS The welding procedures and the welding operators shall be qualified in accordance with Section IXand the requirements of 2.1 and 2.2.

2.1 Procedure Qualification (a) The base materials for the welding procedure qualification shall be of the same P-Number and Group Number, as the materials to be welded. The materials shall be postweld heat treated to at least the time and temperature that was applied to the materials being welded.

(b) The root width end included angle of the cavity in the test assembly shall be no greater than the minimum specified for the repair.

(c) The maximum interpass temperature for the first three layers of the test assembly shall be 150F (66C).

(d) The test assembly cavity depth shall be at least 1 in. (25 mm). The test assembly thickness shall be at least twice the test assembly cavity depth. The test assembly shall be large enough to permit removal of the required test specimens. The test assembly dimensions surrounding the cavity shall be at least the test assembly thickness and at least 6 in. (150 mm). The qualification test plate shall be prepared in accordance with Fig. 1-1.

(e) Ferritic base material for the procedure qualification test shall meet the impact test requirements of the Construction Code and Owner's Requirements. If such requirements are not in the Construction Code and Owner's Requirements, the impact properties shall be determined by Charpy V-notch impact tests of the procedure qualification base material at or below the lowest service temperature of the item to be repaired. The location and orientation of the test specimens shall be similar to those required in 2.1(f) below, but shall be in the base metal.

10

U. S. Nuclear Regulatory Commission Attachment 3 3F0507-03 Page 11 of 14

,BC06-1651 Dele t-2-7-07 editing and rcview Final D-elted: 1-37 rR (f) Charpy V-notch tests of the ferntic heat-affected zone (HAZ) shall be performed at the same temperature as the base metal test of 2.1 (e) above. Number, location, and orientation of test specimens shall be as follows:

(1) The specimens shall be removed from a jocation asnear as practical to a depth of ... ited: wcation one-half the thickness of the deposited weld metal. The coupons for HAZ impact specimens shall be taken transverse to the axis of the weld and etched to define the HAZ. The notch of the Charpy V-notch specimen shall be cut approximately normal to the material surface in such a manner as to include as much HAZ as possible in the resulting fracture. When the material thickness permits, the axis of a specimen shall be inclined to allow the root of the notch to be aligned parallel to the fusion line.

(2) If the test material is in the form of a plate or a forging, the axis of the weld shall be oriented parallel to the principal direction of rolling or forging.

.LfThe Charpy V-notch test shall be performed inaccordance with SA-370. Specimens Formattede:it: Left: 0.4-shall be in accordance with SA-370, Fig. 11, Type A. The lest shall consist of a set of three t energy, full-size 10 mm X 10 mm specimens. The lateral expansion, percent shear, absorbed test temperature, orientation and location of all test specimens shall be reported in the Procedure Qualification Record.

(g) The average lateral expansion value of the three HAZ Charpy V-notch specimens -- Foatted: ldet: Left: 0.4",

shall be equal to or greater than the average lateral expansion value of the three Hanging: 0.35" unaffected base metal specimens. However, ifthe average lateral expansion value of the HAZ Charpy V-notch specimens is less than the average value for the unaffected base metal specimens and the procedure qualification meets all other requirements of this appendix, either of the following shall be performed:

(1) The welding procedure shall be requalified.

(2) AnAAdjustment Temperature for the procedure _qualification shall be determined, Form-atted: Font: Net ttalic in accordance with the applicable provisions of NB-4335.2 of Section III, 2001 Edition with 2002 Addenda. The RTNDT or lowest service temperature of the materials for which the welding procedure will be used shall be increased by a temperature equivalent to that of the Adjustment Temperature.

2.2,Performance Qualification Formatted: indent: Lett: 0.4V

-Welding operators shall be qualified in accordance with Section IX. Deleted:

3.0,,WELDING PROCEDURE REQUIREMENTS Formatted: Indent: Lef: 0.25" The welding procedure shall include the following requirement" Deleted:.

lDeleted:.

(a) The weld metal shall be deposited by the automatic or machine GTAW process.

(b) Dissimilar metal welds shall be made using A-No. 8 weld metal (QW-442) for P-No. 8 to P- No. 1. 3. or 12 (A. B, or C) weld joints or F-No. 43 weld metal (QW-432) for P-No. 8 or 43 to P-No. 1, 3, or 12 (A, B, or C) weld joints.

(c) The area to be welded shall be buttered with a deposit of at least three layers to achieve at least 1/8 in. (3mm) overlay thickness with the heat input for each layer controlled to within +/-10% of that used in the procedure qualification test. The heat input of the first three layers shall not exceed 45J/in. (8_8J/mm) under any Deleted: .000 conditions. Particular care shall be taken in the placement of the weld layers of-the theeted: 80D austenitic overlay filler material at the toe of the overlay to ensure that the HAZ and ferritic base metal are tempered. Subsequent layers shall be deposited with a heat input not exceeding that used for layers beyond the third layer in the procedure qualification.

(d) The maximum interpass temperature for field applications shall be 350F (180C) for all weld layers regardless of the interpass temperature used during qualification. The interpass temperature limitation of QW-406.3 need not be applied.

(a) The interpass temperature shall be determined by. .. ......... I =t onoofthfo II

U. S. Nuclear Regulatory Commission Attachment 3 3F0507-03 Page 12 of 14 BC06-1651 ..[Del[ete: BC04-1003 2-7-07 editing and review Final R*A De.lete: 1-31-07 (1) Temperature measurement (e.g. pyrometers, temperature indicating crayons, D[eleted:,ep, thermocouples) during welding. When it is impractical to use interpass temperature measurements described in this paragraph due to situations where the weldment area is not accessible such as internal bore welding or when there are extenuating radiological concerns. either paragraph 3(e)(21 or paragraph 3(e)(3) may be used.

(2) Heat flow calculations using the variables listed below as a minimum: - Deleted: heat (i) welding heat input (ii) initial base material temperature (iii) configuration, thickness, and mass of the item being welded (iv) thermal conductivity and diffusivity of the materials being welded (v) arc time per weld pass and delay time between each pass (vi) arc time to complete the weld (3). Measurement of the maximum interpass temperature on a test coupon that is -[ -Deleted:-esrne equal to or less than the thickness of the item to be welded. The maximum heat input of the welding procedure shall be used in the welding of the test coupon.

(f) Particular care shall be given to ensure that the weld region is free of all potential sources of hydrogen. The surfaces to be welded, filler metaland shielding gas shall IDeleted:

be suitably controlled.

12

U. S. Nuclear Regulatory Commission Attachment 3 3F0507-03 Page 13 of 14 DC06-1651 Deleted: BC04-1003

.2-7-07 editing and review Final DeleW: 1-31-07 RKA GENERAL NOTE: Base metal Charpy impact specimens are not Deleted: Thisfigasmilluatmlesa shown __ fg similar-m-ta wld.

,rig. i-IQUALJFICATIN TEsTI P-LATE...

D eleted: I 13

U. S. Nuclear Regulatory Commission Attachment 3 3F0507-03 Page 14 of 14 BC06-1651 "Deleted: BC04-003 D.-eletedl: 1-31-07 RRA

.2-7-07 editing and review Final Formatted: Left: 1.25", Right:

S1.25%,Top: I", Bottom: 1", Width:

"8.5", Height: 11" 0 1 Edition wih003 1995 Kdition with 1995 Edition with 1989 Edition with 1986 Edition with' Addenda thrnogh 2004 1996 Addenda 1995 Addenda 1991 Addenda 1980 Addenda

• f Deleted: 2001 Edition with 2003 Edition with throocl 2001 through 1995 through 1989 Edition Addenda through 2004 Edition with 2006Addeudo Edidon with 2002 Edition with 1990 Addenda 2005 Addend.

Addenda Deleted: Rrn cs IWA-400M IWA-410(0 IWA-4000I IWA-400 IWA-401H) & IWA-Deleted: I Renair;Replacement 7000 Artiyiiicri IWA-43* 1 (oroiai IWA -4311 1WA -4311 NA Deleted: 1980 Deleted:winter 901t IWA-4410Wddin' IWA 4410 IWA 4410 WA 441WA 44111 Fornatted: Lef, tndeet: FirLt line:

Brazin. Metal Remval. (r arid hnstallhtion -

(ieneral RequireweLots_

IWA-7lO0 Flao IA-33(0 IWA-33M0 IWA-3300 IWA-3300 IWA-4611 reu:t IWA-461 I IWA-4421 & IWA -4170 (b) WA -4120 R-enaoul IWA-4424 IWB-3514 Standard, for M1WB-3314 1WI3-3514 IW[3-S514 IWBS-3514 IWHiS/D -3611) IWB['(.'JI) -3600 IWiC/t) -3600 I\i3,iC'I) -3600 vIW(,i.'D -3600 Anadynial Evaluation 1 lWB:C!D-3640 IWllt" -36410 or IWB1C.3 40) or IWB/C -3640 or iWWC -3640 E valuation Prnncd urcv i IW i/C -165) tW BS'C .3650-Table I Refercncc for Alternative Editions and Addenda of Section XI Applicability: 1)86 Edition with 1988 Addenda through 2004 Edition with 2006 Addenda

• Starline with the 1989 Ed. the 1989 Addenda

( Deleted:

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 ATTACHMENT 4 BARRIER LAYER TO PREVENT HOT CRACKING IN HIGH SULFUR STAINLESS STEEL

U. S. Nuclear Regulatory Commission Attachment 4 3F0507-03 Page 1 of 4 Barrier Layer to Prevent Hot Cracking in High Sulfur Stainless Steel

Background

During some recent dissimilar metal weld (DMW) overlay activities, where use of ERNiCrFe-7A (Alloy 52M) and ERNiCrFe-7 (Alloy 52) has been used for the filler metal, flaws in the first layer have occurred in the portion of the overlay deposited on the austenitic stainless steel portions (safe ends, pipe etc.) of the assemblies.

The applicable stainless steel base materials at Crystal River Unit 3 (CR3) where the full structural weld overlay (SWOL) will be deposited are as follows:

Pressurizer surge nozzle safe end is A 336 Class F8M.

Relief nozzle flanges are SA-182 Grade F316.

Piping attached to the "A" hot leg surge nozzle buttering and to the pressurizer spray nozzle safe end is wrought seamless austenitic stainless steel A 376 TP 316 Discussion The flaw characteristics observed above are indicative of hot cracking. This phenomenon has not been observed on the ferritic steel or ENiCrFe-3 (Alloy 182) DMW portions of the assemblies when welding Alloy 52M thereon.

Further studies have determined that this problem may occur when using Alloy 52M filler metal on austenitic stainless steel materials with high sulfur content.

Limited tests and evaluations recently performed by AREVA have resulted in the conclusion that welding with Alloy 52M on stainless steel base material with 0.020 wt% sulfur results in cracking while welding on stainless steel base materials with less than 0.010 wt% have resulted in no cracking.

To reduce the susceptibility of hot cracking occurrence due to welding Alloy 52M on the stainless steel base materials with high sulfur, AREVA has selected ER309L filler metal as the preferred filler metal to provide a barrier layer between the Alloy 52M and the high sulfur stainless steel base material. This filler metal is compatible with the base material and promotes primary weld metal solidification as ferrite rather than austenite. The ferrite is more accommodating of residual elements therein and in the underlying base material thereby significantly reducing the susceptibility to hot cracking. ER309L is also compatible with the Alloy 52M subsequently welded thereon. However, the barrier layer will consist of ERNiCr-3 (Alloy 82) being used locally at the interface between the Alloy 182 DMW and the stainless steel item. ER309L welding on Alloy 182 may result in cracking of the ER309L weld. Welding on high sulfur stainless steel with Alloy 82 has not been a concern relevant to hot cracking occurrence.

AREVA welded a mockup to evaluate the interactive effects, such as hot cracking and lack of fusion between the Alloy 182 DMW, the stainless steel base material, the ER309L and Alloy 82

U. S. Nuclear Regulatory Commission Attachment 4 3F0507-03 Page 2 of 4 barrier layer, and the subsequent Alloy 52M weld overlay. The mockup assembly consisted of a stainless steel pipe (0.020 wt% sulfur) with an Alloy 182 groove weld performed therein. The barrier layer and overlay were welded in the same sequence as performed in the field (barrier layer ER309L and Alloy 82 and then two layers of Alloy 52M overlay). The barrier layer and overlay welding parameters used in the mockup were similar to those used in the field however, slightly reduced wire feed rates were used for conservatism.

The following examinations were performed on the final mockup and no recordable indications were detected:

PT was performed on the:

• High sulfur stainless steel base material

• Alloy 182 Groove Weld

• ER309L Barrier Layer

• Alloy 82 Barrier Layer

• Alloy 52M Overlay Limited PDI UT

• 00 Transducer with Full Coverage

• 450 Transducer with Full Coverage

• OD Creeper Transducer with Full Coverage

• 600 Transducer with limited coverage, (focal depth exceeded UT procedure allowable in places due to overlay being of insufficient thickness. Only two layers of Alloy 52M were deposited)

Initial metallographic examination searching for any type of discontinuity, flaw or other anomaly (single specimen with "rough" polish and etch) has been performed on the first specimen. See Figure 1.

Metallography will also be performed on seven additional specimens (total of eight specimens removed in approximate 450 circumferential increments around the pipe) searching for any discontinuities, flaws or other anomalies. Preliminary evaluations of all the specimens have shown no conditions causing concern at this stage.

Final metallography on all specimens will be performed as soon as possible.

Conclusion More tests and evaluations would be necessary to accurately determine the threshold where the base metal sulfur content would require barrier layer welding.

CR3 will use the barrier layer on the stainless steel items prior to overlay since all the items have sulfur contents greater than 0.010 wt%. The barrier layer will use ER309L on the stainless steel and Alloy 82 on the stainless steel near the DMW to stainless steel fusion zone only.

U. S. Nuclear Regulatory Commission Attachment 4 3F0507-03 Page 3 of 4 Structural credit will not be assumed for the barrier layer in determining the required minimum overlay thickness since ASME Section XI Code Case N-740-1, Draft February 2007 does not address the use of ER309L filler metal.

The barrier layer welding will be performed in accordance with ASME Section IX qualified welding procedure specification(s). PT will be performed on the barrier layer surface and its volume will be included in the final UT of the overlay.

U. S. Nuclear Regulatory Commission Attachment 4 3F0507-03 Page 4 of 4 Figure 1; High Sulfur Stainless Pipe Exhibiting Alloy 82 (ERNiCr-3) Deposit Between Alloy 182 (ENiCrFe-3), ER309L, and Alloy 52M (ERNiCrFe-7A) Deposits.