BSEP 03-0019, Response to Request for Information Regarding Third 10-Year Inservice Inspection Program Relief Request for Inspection of Piping Weld Overlays

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Response to Request for Information Regarding Third 10-Year Inservice Inspection Program Relief Request for Inspection of Piping Weld Overlays
ML030550132
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 02/11/2003
From: O'Neil E
Carolina Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 03-0019, TAC MB5631, TAC MB5632
Download: ML030550132 (23)


Text

C4 ý CP&L AProgress Energy Company FEB 1 12003 SERIAL: BSEP 03-0019 U. .S. Nuclear Regulatory Commission TATTN: Document Control Desk kWashington, DC 20555-0001 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324/LICENSE NOS. DPR-71 AND DPR-62 RESPONSE TO REQUEST FOR INFORMATION REGARDING THIRD 10-YEAR INSERVICE INSPECTION PROGRAM RELIEF REQUEST FOR INSPECTION OF PIPING WELD OVERLAYS (NRC TAC NOS. MB5631 AND MB5632)

Ladies and Gentlemen:

By letter dated July 16, 2002 (i.e., Serial: BSEP 02-0119), Progress Energy Carolinas, Inc.

(i.e., Carolina Power & Light Company) submitted a request for relief for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The request involves relief from certain requirements of American Society of Mechanical Engineers (ASME) Code,Section XI, Appendix VIII, Supplement 11, regarding qualification requirements for inspecting piping weld overlays using ultrasonic testing (LUT). The requested relief is applicable to the third 10-year interval Inservice Inspection (ISI) Program.

In a telephone discussion on December 17, 2002, the NRC requested that Progress Energy Carolinas, Inc. provide additional information regarding the relief request. Specifically, the NRC requested that Progress Energy Carolinas, Inc. address the same questions referenced in an October 4, 2002, letter submitted by the Southern Nuclear Operating Company (SNC) for the Edwin I. Hatch Nuclear Plant (i.e., ADAMS Accession Number ML0228200260). The Electric Power Research Institute (EPRI) assisted SNC with the responses to those questions by coordinating with the Performance Demonstration Initiative (PDI) representatives. The Progress Energy Carolinas, Inc.'s responses to these same NRC questions are provided in Enclosure 1. Progress Energy Carolinas, Inc.'s July 16, 2002, letter included a comparison of the ASME Code,Section XI, Appendix VIII, Supplement 11 to both ASME Code Case N-653 and the EPRI PDI alternative.

Enclosure 2 provides an updated version of this comparison using the revised PDI alternative.

Brunswick Nuclear Plant P0 Box 10429 Southport, NC 28461

Document Control Desk BSEP 03-0019 / Page 2 Please refer any questions regarding this submittal to Mr. Leonard R. Beller, Supervisor Licensing/Regulatory Programs, at (910) 457-2073.

Sincerely, Edward T. O'Neil Manager - Support Services Brunswick Steam Electric Plant WRM/wrm

Enclosures:

1. Response to Request for Additional Information
2. Revised Comparison of the ASME Code,Section XI, Supplement 11 to ASME Code Case N-653 and the EPRI PDI Program Alternative

Document Control Desk BSEP 03-0019 / Page 3 cc (with enclosures):

U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Luis A. Reyes, Regional Administrator Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-8931 U. S. Nuclear Regulatory Commission ATTN: Mr. Theodore A. Easlick, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission (Electronic Copy Only)

ATTN: Ms. Brenda L. Mozafari (Mail Stop OWFN 8G9) 11555 Rockville Pike Rockville, MD 20852-2738 Ms. Jo A. Sanford Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Division of Boiler and Pressure Vessel North Carolina Department of Labor ATTN: Mr. Jack Given, Assistant Director of Boiler & Pressure Vessels 4 West Edenton Street Raleigh, NC 27601-1092

If!'. 1 BSEP 03-0019 Enclosure 1 Page 1 of 5 Response to Request for Additional Information By letter dated July 16, 2002 (i.e., Serial: BSEP 02-0119), Progress Energy Carolinas, Inc. (i.e.,

Carolina Power & Light Company) submitted a request for relief for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The request involves relief from certain requirements of American Society of Mechanical Engineers (ASME) Code,Section XI, Appendix VIII, Supplement 11, regarding qualification requirements for inspecting piping weld overlays using ultrasonic testing (UT). The requested relief is applicable to the third 10-year interval Inservice Inspection (ISI) Program.

In a telephone discussion on December 17, 2002, the NRC requested that Progress Energy Carolinas, Inc. provide additional information regarding the relief request. Specifically, the NRC requested that Progress Energy Carolinas, Inc. address the same questions referenced in an October 4, 2002, letter submitted by the Southern Nuclear Operating Company (SNC) for the Edwin I. Hatch Nuclear Plant (i.e., ADAMS Accession Number ML0228200260). The Electric Power Research Institute (EPRI) assisted SNC with the responses to those questions by coordinating with the Performance Demonstration Initiative (PDI) representatives. The following are Progress Energy Carolinas, Inc.'s responses to these NRC questions, for BSEP, Units 1 and 2.

NRC Question 1 Item 1.1(b) - This item concerns the maximum thickness for which a procedure may be qualified.

The appendix VIII position is that qualification for the range of overlay thickness is valid when at least one specimen is used whose overlay thickness is within -0.10 inch to +0.25 inch of the maximum nominal overlay thickness for which the procedure is applicable. The PDI program implies that qualification may be performed on any specimens that are greater than -0.25 inches of the maximum overlay for the procedure. This appears to be a relaxation of requirements.

Please provide a justification.

Response

The PDI has made the following clarification to the PDI Program alternative:

The specimen set shall include specimens with overlays not thicker than 0.1 inch more than the minimum thickness nor thinner than 0.25 inch of the maximum nominal overlay thickness for which the examination procedure is applicable.

According to the PDI, their intent has always been to provide an allowance to examine overlays that were slightly larger than the maximum that was qualified. Also, according to the PDI, the Appendix VIII Committee concluded that 0.25 inch was adequate and any deviation greater than

BSEP 03-0019 Enclosure 1 Page 2 of 5 that would require additional qualification. Progress Energy Carolinas, Inc. agrees with the PDI clarification and will adopt the change made to the PDI Program alternative.

NRC Question 2 Item 1.1(d)(1)(a) - In Appendix VIII, it is stated that all flaws must be cracks and IGSCC when available. In Code Case N-653 there is an opportunity to use alternative flaws when implantation of cracks precludes obtaining a realistic UT response. It is unclear what a "realistic" UT response may encompass. Also, in the PDI program, the wording has been changed to "precludes obtaining an effective UT response." This is also unclear. Please provide the actions you propose to implement in this area.

Response

The PDI has made the following clarification to the PDI Program alternative:

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

Progress Energy Carolinas, Inc. agrees with the PDI clarification and will adopt the change made to the PDI Program alternative.

NRC Question 3 Items 1.1 (e)(2)(a)(1) and (b)(1) - The PDI program states that grading units must be at least 1 inch. There needs to be additional clarification as to the directions of the length and width of the grading units and whether they will all be the same size.

Response

The PDI has made the following clarification to the PDI Program alternative:

(a)(1) The base metal grading unit includes the overlay material and outer 25% of the overlaid weld. The base metal grading unit shall extend circumferentially for at least 1 inch and shall start at the weld centerline and be wide enough in the axial direction to encompass one half of the original weld crown and a minimum of 0.50 inches of the adjacent base material.

According to the PDI, base material flaws are located in the base material contained within the original weld heat affected zone. Because the width of the weld crown and heat affected zone vary from pipe to pipe, latitude must be given in the Code to allow the user to vary the width of the grading units. Therefore, the PDI has concluded that the words provided above allow

BSEP 03-0019 Enclosure 1 Page 3 of 5 sufficient latitude. Progress Energy Carolinas, Inc. agrees with the PDI clarification and will adopt the changes made to the PDI Program alternative.

NRC Question 4 Item 2.3 - The candidate shall determine the maximum depth of the flaw in each grading unit, as stated in both the Code Case and the PDI program. It is not clear as to what the candidate must do. The term grading unit has been associated with some surface area. Will the candidate be provided with a template and told to size the largest flaw in a surface area? Or on a volume?

Clarification is required.

Response

The PDI has made the following clarification to the PDI Program alternative:

2.3 Depth Sizing Test (a) The depth sizing test may be conducted separately or in conjunction with the detection test.

(b) When the depth sizing test is conducted in conjunction with the detection test and the detected flaws do not satisfy the requirements of 1.1 (f), additional specimens shall be provided to the candidate. The 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.

Grading units are not associated with length or depth sizing. Candidates are instructed to find the maximum flaw height in a specific region of the sample. The region is large enough to encompass the flaw to be sized but small enough that they do not size the wrong flaw. Progress Energy Carolinas, Inc. agrees with the PDI clarification and will adopt the changes made to the PDI Program alternative.

NRC Question 5 Item 3.1 - Appendix VIII calls for procedures, personnel, and equipment to meet the acceptance criteria in Table VIII-S2-1 for both detection and false calls. The Code Case and the PDI program break-out procedure qualification separately and state that all flaws must be detected (by each inspector or in sum for all those qualifying the procedure) and must satisfy the

BSEP 03-0019 Enclosure 1 Page 4 of 5 acceptance criteria of Table VIII-S2-1 for false calls. This is unclear and very ambiguous. Does each inspector have to pass the detection test? How many inspectors are needed to qualify a procedure? How many test sets must be inspected and to what level of performance? Why is this wording different than the wording for the draft code case (BC01-150, ISO 01-03)

Supplement 4, 1.0(g) "For initial procedure qualification, the detection set shall include the equivalent of three personnel qualification sets (and the performance demonstration must detect all flaws and not exceed the false calls in Table VIII-S2-1.) To qualify new values of essential variables, at least one personnel qualification set is required."

Response

The PDI has made the following clarification to the PDI Program alternative:

3.1 Detection Acceptance Criteria (a) Examination procedures are qualified for detection when:

(1) All flaws within the scope of the procedure are detected and the results of the performance demonstration satisfy the acceptance criteria of Table VIII-S2-1 for false calls.

(2) At least one successful personnel demonstration has been performed meeting the acceptance criteria defined in (b).

(b) 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.

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

The three times procedure qualification requirements identified above are in addition to the ASME Code; a request for relief is not required for its use. Except as noted elsewhere in the request for relief (e.g., alternative flaws, etc.), the proposed PDI Program alternative for personnel and equipment qualifications is identical to and in full compliance with the current Code requirements for procedures, personnel, and equipment.

Progress Energy Carolinas, Inc. agrees with the PDI clarification and will adopt the changes made to the PDI Program alternative.

BSEP 03-0019 Enclosure 1 Page 5 of 5 NRC Question 6 Item 3.2(a) the RMS error of the flaw length measurements, as compared to the true flaw lengths, is less than or equal to 0.75 inch. With the minimum grading unit length being 1.0 inch circumferential, examiners could potentially use this information to satisfy the length sizing criteria, i.e., for a 1.0 inch circumferential grading unit, a sized length of 0.5 inch will always satisfy the RMS no matter what the true length. Please explain how this will be avoided.

Response

The PDI has made the following clarification to the PDI Program alternative:

(1.1)(f)(1) Sizing Specimens (1) The minimum number of flaws shall be ten. At least 30% of the flaws shall be overlay fabrication flaws. At least 40% of the flaws shall be 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.

Grading units are not associated with length or depth sizing. Flawed grading units are a minimum of one inch, but the flaw can be shorter than the size of the grading unit. For flaws greater than one inch, the grading unit includes the entire flaw. The examination contains many flaws greater than 3 or 4 inches long. The inclusion of too much detail on the minimum and maximum size of the flaws could encourage testmanship, not stop it. Progress Energy Carolinas, Inc. agrees with the PDI clarification and will adopt the changes made to the PDI Program alternative.

BSEP 03-0019 Enclosure 2 Page 1 of 15 Revised Comparison of the ASME Code,Section XI, Supplement 11 to ASME Code Case N-653 and the EPRI PDI Program Alternative American Society of Mechanical Engineers ASME Code Case N-653 (ASME) Code,Section XI, Performance Demonstration Supplement 11 (Provided for Information Only) Initiative Program 1.0 SPECIMEN REQUIREMENTS Qualification test specimens shall meet the No Change requirements listed herein, unless a set of specimens is designed to accommodate specific limitations stated in the scope of the examination procedure (e.g., pipe size, weld joint configuration, access limitations). The same specimens may be used to demonstrate both detection and sizing qualification.

1.1 General. The specimen set shall conform No Change No Change to the following requirements.

(a) Specimens shall have sufficient volume to No Change No Change minimize spurious reflections that may interfere with the interpretation process.

(b) The specimen set shall consist of at least No Change (b) The specimen set shall consist of at least three specimens having different nominal three specimens having different nominal pipe diameters and overlay thicknesses. They pipe diameters and overlay thicknesses. They shall include the minimum and maximum shall include the minimum and maximum

BSEP 03-0019 Enclosure 2 Page 2 of 15 Revised Comparison of the ASME Code,Section XI, Supplement 11 to ASME Code Case N-653 and the EPRI PDI Program Alternative American Society of Mechanical Engineers ASME Code Case N-653 (ASME) Code,Section XI, Performance Demonstration Supplement 11 (Provided for Information Only) Initiative Program nominal pipe diameters for which the nominal pipe diameters for which the examination procedure is applicable. Pipe examination procedure is applicable. Pipe diameters within a range of 0.9 to 1.5 times a diameters within a range of 0.9 to 1.5 times a nominal diameter shall be considered nominal diameter shall be considered equivalent. If the procedure is applicable to equivalent. If the procedure is applicable to pipe diameters of 24 inch or larger, the pipe diameters of 24 inch or larger, the specimen set must include at least one specimen set must include at least one specimen 24 inch or larger but need not specimen 24 inch or larger but need not include the maximum diameter. The include the maximum diameter. The specimen set must include at least one specimen set shall include specimens with specimen with overlay thickness within - overlays not thicker than 0.1 inch more 0.1 inch to +0.25 inch of the maximum than the minimum thickness nor thinner nominal overlay thickness for which the than 0.25 inch of the maximum nominal procedure is applicable, overlay thickness for which the examination procedure is applicable.

(c) The surface condition of at least two No Change specimens shall approximate the roughest surface condition for which the examination procedure is applicable.

BSEP 03-0019 Enclosure 2 Page 3 of 15 Revised Comparison of the ASME Code,Section XI, Supplement 11 to ASME Code Case N-653 and the EPRI PDI Program Alternative American Society of Mechanical Engineers ASME Code Case N-653 (ASME) Code,Section XI, Performance Demonstration Supplement 11 (Provided for Information Only) Initiative Program (d) Flaw Conditions (1) Base metal flaws. All flaws must be (1) Base metal flaws. All flaws must be in or (1) Base metal flaws. All flaws must be in or cracks in or near the butt weld heat-affected near the butt weld heat-affected zone, open to near the butt weld heat-affected zone, open to zone, open to the inside surface, and the inside surface, and extending at least the inside surface, and extending at least extending at least 75% through the base 75 percent through the base metal wall. 75 percent through the base metal wall.

metal wall. Flaws may extend 100% through Intentional overlay fabrication flaws shall not Intentional overlay fabrication flaws shall not the base metal and into the overlay material; interfere with ultrasonic detection or interfere with ultrasonic detection or in this case, intentional overlay fabrication characterization of the cracking. Specimens characterization of the base metal flaws.

flaws shall not interfere with ultrasonic containing IGSCC shall be used when Specimens containing IGSCC shall be used detection or characterization of the cracking. available. At least 70 percent of the flaws in when available. At least 70 percent of-the Specimens containing IGSCC shall be used the detection and sizing tests shall be cracks, flaws in the detection and sizing tests shall be when available. Alternative flaw mechanisms, if used, shall cracks and the remainder shall be alternative provide crack-like reflective characteristics flaws. Alternative flaw mechanisms, if used, and shall be limited by the following: shall provide crack-like reflective characteristics and shall be limited by the (a) Flaws shall be limited to when following:

implantation of cracks precludes obtaining a realistic ultrasonic response. (a) The use of alternative flaws shall be limited to when the implantation of cracks (b) Flaws shall be semi-elliptical with a tip produces spurious reflectors that are width of less than or equal to 0.002 inches. uncharacteristic of actual flaws.

BSEP 03-0019 Enclosure 2 Page 4 of 15 Revised Comparison of the ASME Code,Section XI, Supplement 11 to ASME Code Case N-653 and the EPRI PDI Program Alternative American Society of Mechanical Engineers ASME Code Case N-653 (ASME) Code,Section XI, Performance Demonstration Supplement 11 (Provided for Information Only) Initiative Program (b) Flaws shall be semi-elliptical with a tip width of less than or equal to 0.002 inches.

(2) Overlay fabricationflaws. At least 40% No Change No Change of the flaws shall be non-crack fabrication flaws (e.g., sidewall lack of fusion or laminar lack of bond) in the overlay or the pipe-to overlay interface. At least 20% of the flaws shall be cracks. The balance of the flaws shall be of either type.

(e) Detection Specimens (1) At least 20% but less than 40% of the (1) At least 20% but less than 40% of the (1) At least 20% but less than 40% of the flaws shall be oriented within +20 deg. of the base metal flaws shall be oriented within +20 base metal flaws shall be oriented within +/-20 pipe axial direction. The remainder shall be deg. of the pipe axial direction. The deg. of the pipe axial direction. The oriented circumferentially. Flaws shall not be remainder shall be oriented circumferentially. remainder shall be oriented circumferentially.

open to any surface to which the candidate Flaws shall not be open to any surface to Flaws shall not be open to any surface to has physical or visual access. The rules of which the candidate has physical or visual which the candidate has physical or visual IWA-3300 shall be used to determine access. access.

whether closely spaced flaws should be treated as single or multiple flaws.

BSEP 03-0019 Enclosure 2 Page 5 of 15 Revised Comparison of the ASME Code,Section XI, Supplement 11 to ASME Code Case N-653 and the EPRI PDI Program Alternative American Society of Mechanical Engineers ASME Code Case N-653 (ASME) Code,Section XI, Performance Demonstration Supplement 11 (Provided for Information Only) Initiative Program (2) Specimens shall be divided into base and (2) Specimens shall be divided into base (2) Specimens shall be divided into base over-lay grading units. Each specimen shall metal and overlay fabrication grading units. metal and overlay fabrication grading units.

contain one or both types of grading units. Each specimen shall contain one or both Each specimen shall contain one or both types of grading units. Flaws shall not types of grading units. Flaws shall not interfere with ultrasonic detection or interfere with ultrasonic detection or characterization of other flaws, characterization of other flaws.

(a)(1) A base grading unit shall include at (a)(1) A base metal grading unit shall include (a)(1) The base metal grading unit includes least 3 in. of the length of the overlaid weld. at least 1 in. of the length of the overlaid the overlay material and outer 25% of the The base grading unit includes the outer 25% weld. The base metal grading unit includes overlaid weld. The base metal grading of the overlaid weld and base metal on both the outer 25% of the overlaid weld and base unit shall extend circumferentially for at:

sides. The base grading unit shall not include metal on both sides. The base metal grading least 1 inch and shall start at the weld the inner 75% of the overlaid weld and base unit shall not include the inner 75% of the centerline and be wide enough in the axial metal overlay material, or base metal-to- overlaid weld and base metal overlay direction to encompass one half of the overlay interface, material, or base metal-to-overlay interface, original weld crown and a minimum of 0.50 inches of the adjacent base material.

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

overlay material shall not be used as part of I I

BSEP 03-0019 Enclosure 2 Page 6 of 15 Revised Comparison of the ASME Code,Section XI, Supplement 11 to ASME Code Case N-653 and the EPRI PDI Program Alternative American Society of Mechanical Engineers ASME Code Case N-653 (ASME) Code,Section XI, Performance Demonstration Supplement 11 (Provided for Information Only) Initiative Program any overlay grading unit.

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

segment of weld length used in one base grading unit shall not be used in another base grading unit. Base grading units need not be uniformly spaced around the specimen.

(b)(1) An overlay grading unit shall include (b)(1) An overlay fabrication grading unit (b)(l) An overlay fabrication grading unit the overlay material and the base metal-to- shall include the overlay material and the shall include the overlay material and the overlay interface of at least 6 sq. in. The base metal-to-overlay interface for a length base metal-to-overlay interface for a length overlay grading unit shall be rectangular, of at least 1 inch. of at least 1 inch.

with minimum dimensions of 2 inch.

(b)(2) An overlay grading unit designed to be (b)(2) Overlay fabrication grading units (b)(2) Overlay fabrication grading units unflawed shall be surrounded by unflawed designed to be unflawed shall be separated by designed to be unflawed shall be separated by overlay material and unflawed base metal-to- unflawed overlay material and unflawed base unflawed overlay material and unflawed base overlay interface for at least 1 in. around its metal-to-overlay interface for at least 1 in. at metal-to-overlay interface for at least 1 in. at entire perimeter. The specific area used in both ends. Sufficient unflawed overlaid weld both ends. Sufficient unflawed overlaid weld

BSEP 03-0019 Enclosure 2 Page 7 of 15 Revised Comparison of the ASME Code,Section XI, Supplement 11 to ASME Code Case N-653 and the EPRI PDI Program Alternative American Society of Mechanical Engineers ASME Code Case N-653 (ASME) Code,Section XI, Performance Demonstration Supplement 11 (Provided for Information Only) Initiative Program one overlay grading unit shall not be used in and base metal shall exist on both sides of the and base metal shall exist on both sides of the another overlay grading unit. Overlay overlay fabrication grading unit to preclude overlay fabrication grading unit to preclude grading units need not be spaced uniformly interfering reflections from adjacent flaws, interfering reflections from adjacent flaws.

about the specimen. The specific area used in one overlay The specific area used in one overlay fabrication grading unit shall not be used in fabrication grading unit shall not be used in another overlay fabrication grading unit. another overlay fabrication grading unit.

Overlay fabrication grading units need not be Overlay fabrication grading units need not be spaced uniformly about the specimen. spaced uniformly about the specimen.

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

BSEP 03-0019 Enclosure 2 Page 8 of 15 Revised Comparison of the ASME Code,Section XI, Supplement 11 to ASME Code Case N-653 and the EPRI PDI Program Alternative American Society of Mechanical Engineers ASME Code Case N-653 (ASME) Code,Section XI, Perrormance Demonstration Supplement 11 (Provided for Information Only) Initiative Program set is required. set is required.

(f) Sizing Specimen (1) The minimum number of flaws shall be (1) The minimum number of flaws shall be (1) The minimum number of flaws shall be ten. At least 30% of the flaws shall be ten. At least 30% of the flaws shall be ten. At least 30% of the flaws shall be overlay fabrication flaws. At least 40% of the overlay fabrication flaws. At least 40% of the overlay fabrication flaws. At least 40% of flaws shall be cracks open to the inside flaws shall be cracks open to the inside the flaws shall be open to the inside surface.

surface. surface. For initial procedure qualification, Sizing sets shall contain a distribution of sizing sets shall include the equivalent of flaw dimensions to assess sizing three personnel qualification sets. To qualify capabilities. For initial procedure new values of essential variables, at least one qualification, sizing sets shall include- the personnel qualification set is required. equivalent of three personnel qualification sets. To qualify new values of essential variables, at least one personnel qualification set is required.

(2) At least 20% but less than 40% of the No Change No Change flaws shall be oriented axially. The remainder shall be oriented circumferentially. Flaws shall not be open to any surface to which the candidate has physical or visual access.

BSEP 03-0019 Enclosure 2 Page 9 of 15 Revised Comparison of the ASME Code,Section XI, Supplement 11 to ASME Code Case N-653 and the EPRI PDI Program Alternative American Society of Mechanical Engineers ASME Code Case N-653 (ASME) Code,Section XI, Performance Demonstration Supplement 11 (Provided for Information Only) Initiative Program (3) Base metal cracking used for length No Change (3) Base metal flaws used for length sizing sizing demonstrations shall be oriented demonstrations shall be oriented circumferentially. circumferentially.

(4) Depth sizing specimen sets shall include No Change (4) Depth sizing specimen sets shall include at least two distinct locations where cracking at least two distinct locations where a base in the base metal extends into the overlay metal flaw extend into the overlay material material by at least 0.1 inch in the through- by at least 0.1 inch in the through-wall wall direction. direction.

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

Divulgence of particular specimen results or Divulgence of particular specimen results or Divulgence of particular specimen results or candidate viewing of unmasked specimens candidate viewing of unmasked specimens candidate viewing of unmasked specimens after the performance demonstration is after the performance demonstration is after the performance demonstration is prohibited. prohibited. The overlay fabrication flaw test prohibited. The overlay fabrication flaw test

BSEP 03-0019 Enclosure 2 Page 10 of 15 Revised Comparison of the ASME Code,Section XI, Supplement 11 to ASME Code Case N-653 and the EPRI PDI Program Alternative American Society of Mechanical Engineers ASME Code Case N-653 (ASME) Code,Section XI, Performance Demonstration Supplement 11 (Provided for Information Only) Initiative Program and the base metal flaw test may be and the base metal flaw test may be performed separately. performed separately.

2.1 Detection Test.

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

2.2 Length Sizing Test (a) The length sizing test may be conducted No Change No Change separately or in conjunction with the detection test.

(b) When the length sizing test is conducted No Change No Change in conjunction with the detection test and the detected flaws do not satisfy the requirements of 1.1(f), additional specimens shall be

BSEP 03-0019 Enclosure 2 Page 11 of 15 Revised Comparison of the ASME Code,Section XI, Supplement 11 to ASME Code Case N-653 and the EPRI PDI Program Alternative American Society of Mechanical Engineers ASME Code Case N-653 (ASME) Code,Section XI, Performance Demonstration Supplement 11 (Provided for Information Only) Initiative Program provided to the candidate. The regions containing a flaw to be sized shall be identified to the candidate. The candidate shall determine the length of the flaw in each region.

(c) For a separate length sizing test, the No Change No Change regions of each specimen containing a flaw to be sized shall be identified to the candidate.

The candidate shall determine the length of the flaw in each region.

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

2.3 Depth Sizing Test.

For the depth sizing test, 80% of the flaws The candidate shall determine the depth of (a) The depth sizing test may be conducted shall be sized at a specific location on the the flaw in each region. separately or in conjunction with the surface of the specimen identified to the detection test.

candidate. For the remaining flaws, the

BSEP 03-0019 Enclosure 2 Page 12 of 15 Revised Comparison of the ASME Code,Section XI, Supplement 11 to ASME Code Case N-653 and the EPRI PDI Program Alternative American Society of Mechanical Engineers ASME Code Case N-653 (ASME) Code,Section XI, Performance Demonstration Supplement 11 (Provided for Information Only) Initiative Program 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.

(b) When the depth sizing test is conducted in conjunction with the detection test and the detected flaws do not satisfy the requirements of 1.1(f), additional specimens shall be provided to the candidate. The 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.

i i (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.

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BSEP 03-0019 Enclosure 2 Page 13 of 15 Revised Comparison of the ASME Code,Section XI, Supplement 11 to ASME Code Case N-653 and the EPRI PDI Program Alternative American Society of Mechanical Engineers ASME Code Case N-653 (ASME) Code,Section XI, Performance Demonstration Supplement 11 (Provided for Information Only) Initiative Program 3.0 ACCEPTANCE CRITERIA 3.1 Detection Acceptance Criteria.

Examination procedures, equipment, and Examination procedures are qualified for (a) Examination procedures are qualified for personnel are qualified for detection when detection when all flaws within the scope of detection when; the results of the performance demonstration the procedure are detected and the results of satisfy the acceptance criteria of the performance demonstration satisfy the Table VIII-S2-1 for both detection and false acceptance criteria of Table VIII-S2-1 for calls. The criteria shall be satisfied separately false calls. Examination equipment and by the demonstration results for base grading personnel are qualified for detection when units and for overlay grading units. the results of the performance demonstration satisfy the acceptance criteria of Table VIII-S2-1 for both detection and false calls. The criteria shall be satisfied separately by the demonstration results for base metal grading units and for overlay fabrication grading units.

(1) All flaws within the scope of the procedure are detected and the results of the performance demonstration satisfy the

BSEP 03-0019 Enclosure 2 Page 14 of 15 Revised Comparison of the ASME Code,Section XI, Supplement 11 to ASME Code Case N-653 and the EPRI PDI Program Alternative American Society of Mechanical Engineers ASME Code Case N-653 (ASME) Code,Section XI, Performance Demonstration Supplement 11 (Provided for Information Only) Initiative Program acceptance criteria of Table VIII-S2-1 for false calls.

(2) At least one successful personnel demonstration has been performed meeting the acceptance criteria defined in (b).

(b) 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.

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

3.2 Sizing Acceptance Criteria.

Examination procedures, equipment, and No Change No Change personnel are qualified for sizing when the ,_I

BSEP 03-0019 Enclosure 2 Page 15 of 15 Revised Comparison of the ASME Code,Section XI, Supplement 11 to ASME Code Case N-653 and the EPRI PDI Program Alternative American Society of Mechanical Engineers ASME Code Case N-653 (ASME) Code,Section XI, Performance Demonstration Supplement 11 (Provided for Information Only) Initiative Program results of the performance demonstration satisfy the following criteria.

(a) The RMS error of the flaw length No Change (a) The RMS error of the flaw length measurements, as compared to the true flaw measurements, as compared to the true flaw lengths, is less than or equal to 0.75 inch. The lengths, is less than or equal to 0.75 inch. The length of base metal cracking is measured at length of base metal flaws is measured at the the 75% through-base-metal position. 75% through-base-metal position.

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

the overlay material by at least 0.1 inch are reported as being intrusions into the overlay material.

(c) The RMS error of the flaw depth (b) The RMS error of the flaw depth (b) The RMS error of the flaw depth measurements, as compared to the true flaw measurements, as compared to the true flaw measurements, as compared to the true flaw depths, is less than or equal to 0.125 inch. depths, is less than or equal to 0.125 inch. depths, is less than or equal to 0.125 inch.

Changes shown in bold.