BSEP 05-0100, Relief Request RR-36, Use of Ultrasonic Examinations in Lieu of Radiographic Non-Destructive Examinations

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Relief Request RR-36, Use of Ultrasonic Examinations in Lieu of Radiographic Non-Destructive Examinations
ML052280213
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 08/09/2005
From: O'Neil E
Progress Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 05-0100
Download: ML052280213 (13)
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Text

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Progress Energy 10 CFR 50.55a(a)(3)(i)

AUG 0 9 2005 SERIAL: BSEP 05-0100 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324fLicense Nos. DPR-71 and DPR-62 Relief Request RR-36, Use of Ultrasonic Examinations in Lieu of Radiographic Non-Destructive Examinations Ladies and Gentlemen:

In accordance with 10 CFR 50.55a(a)(3)(i), Carolina Power & Light Company, now doing business as Progress Energy Carolinas, Inc. (PEC), hereby requests NRC approval of a relief request for the third 10-year interval Inservice Inspection Program for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The relief request involves an alternative to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section III, NB-5200 and NC-5200, requiring the examination of Code Class 1 and 2 piping welds following repairs or replacements using the radiographic (RT) method.

The details of Relief Request RR-36 are provided in Enclosure 1.

Approval of Relief Request RR-36 is requested by February 1, 2006, to support planning and preparation activities for the BSEP Unit 1 Refueling 15 (B116R1) outage that is scheduled to begin March 4, 2006. During this outage, the inboard and outboard main steam line drain isolation valves, 1B21-F016 and 1B21-F019, are scheduled to be replaced.

PEC currently plans to use the proposed alternative during the replacement work for these two valves.

Please refer any questions regarding this submittal to Mr. Leonard R. Beller, Supervisor -

Licensing/Regulatory Programs, at (910) 457-2073.

Sincerely, Edward T. ONeil Manager - Support Services Brunswick Steam Electric Plant Progress Energy Carolinas, Inc.

Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461

Document Control Desk BSEP 05-0100 / Page 2 WRM/wrm

Enclosures:

1. 10 CFR 50.55a Request Number RR-36
2. ASME Section III Code Case N-659 cc (with enclosures):

U. S. Nuclear Regulatory Commission, Region II ATTN: Dr. William D. Travers, Regional Administrator Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-8931 U. S. Nuclear Regulatory Commission ATIN: Mr. Eugene M. DiPaolo, 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 Mr. Jack Given, Bureau Chief North Carolina Department of Labor Boiler Safety Bureau 1101 Mail Service Center Raleigh, NC 27699-1101

BSEP 05-0100 Enclosure 1 Page I of 8 10 CFR 50.55a Request Number RR-36 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

- Alternative Provides Acceptable Level of Quality and Safety -

1. ASME Code Components Affected Code Class: Class 1 and Class 2 Category: Not applicable.

System: Not applicable.

Affected Components: ASME Code,Section XI, Class 1 and 2 piping welds

2. Applicable Code Edition and Addenda

The Code of Record for the third 10-year inservice inspection interval at the Brunswick Steam Electric Plant (BSEP), Units 1 and 2, is the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, 1989 Edition, with no addenda.

The third 10-year inservice inspection interval began May 11, 1998, and will conclude on May 10, 2008.

3. Applicable Code Pequirement The ASME Code,Section XI, JWA4120(a) and IWA-7210(b), requires that items used for repair or replacement meet the owner's design specification and original construction Code for the component.

The ASME Code,Section III, 1B-5200, "Required Examination of Welds," requires that circumferential welded joints in piping, pumps, and valves be examined using the radiographic (RT) method and either liquid penetrant or magnetic particle examination methods.

The ASME Code,Section III, NC-5200, "Examination of Welds," requires that circumferential welded joints in piping, pumps, and valves be radiographed when either member exceeds 3/16-inch thickness.

The ASME Code,Section XI, IWA-4700, "Pressure Test," requires the performance of a hydrostatic test following repairs by welding. ASME Code Case N-416-2, "Alternative Pressure Test Requirement for Welded Repairs, Fabrication Welds for Replacement Parts and Piping Subassemblies, or Installation of Replacement Items by Welding, Class 1, 2, and 3 Section XI, Division 1," allows a system leakage test in lieu of the performance of a

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BSEP 05-0100 Enclosure 1 Page 2 of 8 hydrostatic pressure test. However, Code Case N-416-2 requires that non-destructive examination (NDE) methods and acceptance criteria for welded repairs, fabrication, and installation joints meet the applicable subsection requirements of the 1992 Edition of the ASME Code,Section III. This ASME Code Case is listed in NRC Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1," Revision 13, as being conditionally accepted provided the provisions of IWA-5213, "Test Condition Holding Times," 1989 Edition, are used.

4. Reason for Request

The bases for the NDE requirements in the design specification used during the construction of the two Brunswick units were the 1965 and 1968 Edition of the ASME Code,Section III, which dealt only with pressure vessels at that time; the 1967 Edition of United States of America Standard (USAS) B31.1.0; the 1965 Edition of American National Standards Institute (ANSI) B31.7; and the collective engineering opinion of what the anticipated NDE requirements of the 1971 Edition of the ASME Code,Section III (i.e., this edition introduced requirements for piping) would be.

In 1987, a piping specification and Code reconciliation was performed and established the 1986 Edition of the ASME Code,Section III, as the specification requirement for NDE of Piping classified as ASME Class 1, 2, and 3. The 1967 Edition of USAS B31.1.0 remained the Code of Record for design.

During the third inspection interval, Carolina Power & Light Company, now doing business as Progress Energy Carolinas, Inc. (PEC), is implementing the alternative requirements specified in ASME Code Case N-416-2. This ASME Code Case is listed in NRC Regulatory Guide 1.147, Revision 13, as being conditionally accepted provided the provisions of IWA-5213, "Test Condition Holding Times," 1989 Edition, are used. The Code Case allows a system leakage test in lieu of the performance of a hydrostatic pressure test. To use this alternative, the NDE methods and acceptance criteria for welded repairs, fabrication, and installation joints must meet the applicable subsection requirements of the 1992 Edition of the ASME Code, Section MI.Later revisions to Code Case N-416 may be implemented by PEC following their incorporation into Regulatory Guide 1.147.

In both the 1986 and 1992 Edition of the ASME Code,Section III, the use of the radiographic examination (RT) method is required in subarticle NB-5200 and NC-5200. The use of the ultrasonic examination (UT) method as an acceptable alternative is not allowed for circumferential welded joints in piping.

Since the performance of the RT method involves the use of highly radioactive isotopes, inadvertent or accidental exposure of personnel can and has occurred within the nuclear industry. To remove the inherent hazards associated with industrial radiography, PEC proposes to use a qualified UT method in lieu of the RT method specified in the ASME Code,Section III. PEC has evaluated the use of this alternative method and determined that its use will provide a level of quality and safety that is equivalent or superior to RT.

A BSEP 05-0100 Enclosure 1 Page 3 of 8

5. Proposed Alternative and Basis for Use Proposed Alternative In accordance with 10 CFR 50.55a(a)(3)(i), PEC proposes to use a qualified UT method as an acceptable alternative to the RT method specified in PEC's specification for NDE (i.e., the 1986 Edition of the ASME Code,Section III) for weld repairs, fabrication of welds for replacement parts and piping subassemblies, or installation of replacement items. PEC plans to continue using ASME Section XI Code Case N-416-2. Since Section XI Code Case N-416-2 requires use of the RT method mandated by the 1992 Edition of the ASME Code,Section III, use of a qualified UT method as an alternative to the RT method mandated by the 1992 Edition of the ASME Code,Section III, is also proposed by PEC.

This proposed alternative method is similar to the guidance provided in ASME Section III Code Case N-659 and, is described below. A copy of ASME Section III Code Case N-659 is provided in Enclosure 2.

For ASME Class 1 and 2 welds installed under the Repair/Replacement Program, where the UT method will be performed in lieu of RT, the following requirements will be implemented:

1. The nominal weld thickness will be 0.200 inch or greater.
2. The ultrasonic examination area will include 100 percent of the volume of the entire weld, plus 0.5T on each side of the weld, where T is the nominal thickness of the weld.
3. The UT will be in performed in accordance with the following requirement.

(a) The examination will be performed using two techniques.

The first will be a manual UT in accordance with the ASME Code,Section V, Article 5, up to and including the 2001 Edition. A straight beam and two angle beams having nominal angles of 45 and 60 degrees will generally be used; however, other pairs of angle beams may be used, provided the measured difference between the angles is at least 10 degrees.

The second technique will be a manual phased array technique capable of recording the scans and generating angles of propagation that encompass the angles used during the manual technique (i.e., from 40 to 65 degrees).

Examination scans will be in four directions: two beam path directions perpendicular to the weld axis and two beam path directions parallel to the weld axis. Where the examination scan perpendicular to the weld is limited on one side, the second leg of the V-path may be used to achieve the two beam path directions provided that the detection capability of that technique is included in the procedure demonstration described in paragraphs 4 and 5 below.

-Vnt.--e -n, BSEP 05-0100 Enclosure 1 Page 4 of 8 A supplemental straight beam wili also be used to scan the weld and adjacent base metal.

(b) As an alternative to the manual ASME Section V technique described in paragraph 3.(a) above, the examination may be performed by a procedure qualified in accordance with the performance demonstration methodology of the ASME Code,Section XI, Appendix VIII, as delineated in Appendix I. The examination volume, as defined in paragraph 4 below, will be included in the demonstration. Examination scans will be in four directions: two beam path directions perpendicular to the weld axis and two beam path directions parallel to the weld axis. A supplemental straight beam will also be used.

4. A written procedure will be prepared and followed. The procedure will be demonstrated to perform acceptably on a qualification block or specimen that includes a weld with both surface and subsurface flaws as described in paragraph 6 below.
5. The qualification block material will conform to the requirements applicable to the calibration block and in addition meet the following requirements.

(a) The material from which blocks are fabricated will be one of the following: a nozzle dropout from the component; a component prolongation; or material of the same material specification, product form, and heat treatment condition as one of the materials joined. For piping, if material of the same product form and specification is not available, material of similar chemical analysis', tensile properties, and metallurgical structure 2 may be used.

(b) Where two or more base material thicknesses are involved, the calibration block thickness will be of a size sufficient to contain the entire examination path.

(c) Qualification block configuration will contain a weld representative of the joint to be ultrasonically examined, including, for austenitic materials, the same welding process.

6. The qualification block will include flaws in accordance with paragraphs (a) or (b) below.

XChemical composition should be within the same ranges as required in the original material specification. The chemical ranges of the calibration block may vary from the material specification if: (1) it is within the chemical range for the components specification to be inspected, and (2) the phase and grain shape are maintained in the same ranges produced by the thermal process required by the material specification.

2 Same phase and grain shape as produced by the thermal process for the original specification.

BSEP 05-0100 Enclosure 1 Page 5 of 8 K4 (a) At least two planar flaws will be included in the qualification block weld, one surface and one subsurface oriented parallel to the fusion line. The flaws will be no larger in the through-wall direction than the diameter of the applicable side-drilled hole in the calibration block shown in Figure T-542.2.1 of ASME Code,Section V,Article 5, and no longer than the shortest unacceptable elongated discontinuity length listed in NB-5330 or NC-5330 of the ASME Code,Section III, for the thickness of the weld that will be examined.

(b) Where an ASME Code,Section XI, Appendix VIII, performance demonstration methodology is used, supplemental qualification to a previously approved procedure may be demonstrated through the use of a blind test with appropriate specimens that contain a minimum of three different construction-type and fabrication-type flaws distributed throughout the thickness of the specimen(s).

7. The UT method will not be applied to weld examination volumes that include cast product forms or austenitic corrosion-resistant-clad piping butt welds.
8. A documented examination plan will be provided showing the transducer placement, movement, and component coverage that provides a standardized and repeatable methodology for weld acceptance. The examination plan will also include the ultrasonic beam angles used, beam directions with respect to weld centerline, and volume examined for each weld.
9. The ultrasonic examination will be performed using a computer data acquisition system that records the UT data. The UT data will be recorded in unprocessed form.

A complete data set with no gating, filtering, or thresholding for response from the examination volume in paragraph 2 above will be included in the data record.

10. Personnel who acquire and analyze ultrasonic data will be qualified and trained using the same type of equipment as in paragraph 9 above, and demonstrate their capability to detect and characterize the flaws using the procedure as described in paragraph 4 above.
11. The evaluation and acceptance criteria will be in accordance with the applicable requirements of NB-5330 or NC-5330 of the ASME Code,Section III. Flaws exceeding the applicable acceptance criteria will be repaired, and the weld subsequently re-examined using the same UT method that detected the flaw.
12. For welds subject to inservice inspection UT examination, the examination and evaluation will also meet preservice requirements specified in the ASME Code,Section XI, 1989 Edition.
13. Review and acceptance of the UT procedure by the Authorized Nuclear Inservice Inspector will be obtained.
14. All other related requirements of Repair/Replacement Program will be met.

BSEP 05-0100 Enclosure I Page 6 of 8 Basis for Use In accordance with 10 CFR 50.55a(a)(3)(i), relief is being requested on the basis that the proposed alternative provides an acceptable level of quality and safety to that of the applicable Code requirement.

The RT and UT methods are complementary, and are not directly comparable or equivalent.

Depending on flaw type (i.e., volumetric or planar) and orientation, the RT method may be superior to the UT method or vice versa.

The RT method is most effective in detecting changes in material density, such as volumetric type flaws (i.e., slag and porosity), and planar type flaws with detectable density differences, such as lack-of-fusion and open cracks that are oriented in a plane parallel to the X-ray beam.

However, the RT method is limited in detecting small changes in density such as tight, irregular planar flaws and non-optimal oriented planar flaws with respect to the X-ray beam.

The RT method is also limited in determining depth characteristics. The flaws that are easiest for the RT method to detect are associated with construction (i.e., 3-dimensional) with the exception of tight planar flaws from the welding process.

In contrast, the UT method is capable of detecting the features in a component that reflects sound waves. The degree of reflection depends largely on the physical state of matter on the opposite side of the reflective surface and to a lesser extent on specific physical properties of that matter. For instance, sound waves are almost completely reflected at metal-gas interfaces, and partially reflected at metal-to-solid interfaces. Discontinuities that act as metal-gas'interfaces, like cracks, laminations, shrinkage cavities, bursts, flakes, pores, and bonding faults, are easily detected.

The UT method is less effective in detecting flaws in a plane parallel to the sound beam, because of target size, and volumetric type flaws such as slag, porosity, and other inhomogeneities, because of sound dispersion from irregular surfaces. The UT method may also have difficulty in detecting discontinuities (i.e., flaws) that are present in the shallow layer immediately beneath the surface and in separating discontinuities from background noises that are caused by certain metal characteristics like large grains in stainless steels.

However, current UT techniques involving partial reflection of sound waves have successfully detected flaws parallel to the sound beam and volumetric type flaws, and the UT method is capable of characterizing flaws.

In the proposed alternative, the examination coverage consists of scanning with angle beam transducers in two opposite directions perpendicular to the weld axis, in two opposite directions parallel to the weld axis, and with a straight beam transducer scanning through-wall. The scan volume is 100 percent of the weld volume and the adjacent base material for a distance of one-half the nominal through-wall weld thickness on each side. Where the scan perpendicular to the weld is limited on one side, a full V-path will be used for the second direction provided the procedure is qualified for a full V-path. These scans provide assurance that planar flaws, regardless of orientation, will be detected and non-planar, construction

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BSEP 05-0100 Enclosure 1 Page 7 of 8 flaws will be easier to discern from inhomogeneities. In additioh, an examination of the weld area for laminar flaws with a straight beam scan will be performed.

The proposed qualification process will assure that the UT procedure contains sufficient detail and that the personnel have the necessary skills for detecting various types of flaws. In order to detect construction and material type flaws occurring axially, circumferentially, and volumetrically, the coverage will include 100 percent of the weld volume and adjacent base metal as discussed above.

The proposed alternative will require that detected flaws will be evaluated in accordance with the acceptance criteria of NB-5330 (i.e., for Class 1 items) or NC-5330 (i.e., for Class 2 items) of the ASME Code,Section III, which is the same for crack-type flaws detected by RT.-

To the extent practical, the guidance outlined in ASME Section m Code Case N-659 was followed. Two exceptions were taken regarding weld material limitation and the use of an automated computer data acquisition system.

Since PEC has piping with material wall thickness less than 0.500 inch (i.e., low energy piping such as the pump suction piping), the proposed alternative reduces the minimum weld thickness to 0.200 inch and greater. Performing UT of weld materials less than 0.500 inch has been demonstrated through the Performance'Demonstration Initiative (PDI) process using cracks located within the lower one-third volume, and the 0.200 inch minimum thickness is allowed per Appendix III of the ASME Code,Section XI, 1989 Edition. Use of a qualification block, as required by Code Case N-659, will also demonstrate the procedure's ability to inspect welds less than 0.500 inch.

To meet the requirement of using an automated computer data acquisition system, PEC proposes the use of a manual phased array technique. The manual phased array system electronically generates and displays sector scan images which can be stored and recalled for subsequent review. Sector scans represent the angular coverage of the volume at a specific probe position and contain signal amplitude and reflector depth information plotted against the sweep angle of the ultrasonic beam. This system is also capable of processing a B-Scan image of each scan angle. Scanning positions can be recorded by documenting the positions according to file numbers. Flaw depth and through-wall dimensions can be measured using cursors. Actual measurements will be taken to record positions and lengths of recordable reflectors.

In summary, the objective of the examination method specified in NB-5200 and NC-5200 for new welds is to detect flaws as a means to measure the quality of the workmanship. Based on the evaluation performed by PEC using an alternative, qualified UT method would provide results equivalent or superior to the single RT method specified by the ASME Code,Section III, for detecting construction related flaws. As such, workmanship quality will be verified and intent of the ASME Code,Section III, met.

BSEP 05-0100 Enclosure 1 Page 8 of 8

6. Duration of Proposed Alternative Use of the alternative is proposed for the remainder of the current 10-year inservice inspection interval.
7. Precedents This proposed alternative is similar, but not identical, to a relief request submitted by the Callaway Plant in a letter dated November 18, 2004 (i.e., ADAMS Accession Number ML043450359), as approved by NRC letter dated May 19, 2005 (i.e., ADAMS Accession Number ML050760129).
8. References
1. Title 10 of the Code of Federal Regulations, Part 50, Section 55a, Codes and Standards (i.e., 10 CFR 50.55a).
2. ASME Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, 1989 Edition (no Addenda).
3. ASME Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, 1995 Edition with 1996 Addenda for Appendix VIII
4. ASME Code Case N-659, Use of Ultrasonic Examination In Lieu of Radiography for Weld Examination,Section III, Division 1
5. ASME Code,Section V, Nondestructive Examination
6. ASME Code,Section III, Rules for the Construction of Nuclear Power Plants
7. EPRI Technical Report 1003545, Alternative Volumetric Examination Methods: IUT in Lieu of RT for Repair/Replacement Activity
8. NRC Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1," Revision 13, January 2004.
1a BSEP 05-0100 Enclosure 2 ASME Section III Code Case N-659

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1

.14 CASE N-659 CASES OF ASME BOILER AND PRESSURE VESSEL CODE

' Approval Date: September 17, 2002 See Numeric Index for expiration and any reaffirmation dates.

Case N-659 The material from which blocks are fabricated shall Use of Ultrasonic Examination in Lieu of be one of the following: a nozzle dropout from the Radiography for 'Weld Examination component; a component prolongation; or material of Section III, Division I the same material specification, product form, and heat treatment condition as one of the materials joined. For Inquiry: Under what conditions and limitations may piping, if material of the same product form and an ultrasonic examination be used in lieu of radiography specification is not available, material of similar chemi-where radiography is required by NB-5200, NC-5200, cal analysis, tensile properties, and metallurgical strus-ND-5200 and substitution of ultrasonic examination ture may be used. Where two or more base material would not otherwise be permitted? thicknesses are involved, the calibration block thickness shall be of a size sufficient to contain the entire Reply: It is the opinion of the Committee that all examination path. The qualification block configuration welds in material 1/2 in. or greater in thickness may shall contain a weld representative of the joint to be be examined using the ultrasonic (UT) method in lieu examined, including, for austenitic materials, the same of the radiographic (RT) method, provided that all of welding process. The qualification blocks shall include the following requirements are met: at least two planar flaws in the weld, one surface and (a) The ultrasonic examination area shall include one subsurface oriented parallel to the fusion line, no 100% of the volume of the entire weld, plus 0.5T of larger in the through-wall direction than the diameter each side of the welds, where T is the thickness of of the applicable side-drilled hole in the calibration the weld. The ultrasonic examination area shall be block shown in Fig. T-542.2.1 of Section V, Article accessible for angle beam examination in four directions, 5, and no longer than the shortest unacceptable elongated two directions perpendicular to the weld axis and two discontinuity length listed in NB-5330, NC-5330, or directions parallel to the weld axis. Where perpendicular ND-5330 for the thickness of the weld being examined.

scanning is limited on one side of the weld, a technique Where a Section XI, Appendix VIII, performance dem-using the second leg of the V-path may be credited onstration methodology is used, supplemental qualifica-as access for the second perpendicular examination tion to a previously approved procedure may be demon-direction provided that the detection capability of that strated through the use of a blind test with appropriate technique is included in the procedure demonstration specimens that contain a minimum of three different described in (c) and (d) below. construction-type and fabrication-type flaws distributed (b) The ultrasonic examination shall be performed throughout the thickness of the specimen.

in accordance with Section V, Article 5 up to and (e) This Case shall not be applied to weld examina-including the 2001 Edition. A straight beam and two tion volumes that include cast products forms or corro-angle beams having nominal angles of 45 and 60 deg sion-resistant-clad austenitic piping butt welds.

should generally be used; however, other pairs of angle (J) A documented examination plan shall be provided beams may be used provided the measured difference showing the transducer placement, movement and com-between the angles is at least 10 deg. Alternatively, ponent coverage that provides a standardized and repeat-ultrasonic examination may be performed by a procedure able methodology for weld acceptance. The examination qualified in accordance with the performance demonstra- plan shall also include ultrasonic beam angle used, tion methodology of Section XI, Appendix VIII provided beam directions with respect to weld centerline, and the entire volume of the weld examination is included volume examined for each weld.

in the demonstration. (g) The evaluation and acceptance criteria shall be (c) A written procedure shall be followed. The proce- in accordance with NB-5330, NC-5330, or ND-5330, dure shall be demonstrated to perform acceptably on as acceptable.

a qualification block or specimen with both surface (Ih)For welds subject to inservice ultrasonic examina-and subsurface flaws as described in (d) below. tion, the examination and evaluation shall also meet (d) The qualification block material shall conform the requirements of the applicable Edition of Section to the requiremnts applicable to the calibration block. Xl for preservice examination.

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CASE (continued)

N-659 CASES OF ASME BOILER AND PRESSURE VESSEL CODE (l) The ultrasonic examination shall be' performed (l) Review and acceptance of the procedure by the using a device with an automated computer data acquisi- i- Authorized Nuclear Inspector is required.

tion system. (m) All other related requirements of the applicable U) Data shall be recorded in unprocessed form. A subsection shall be met.

complete data set with no gating, filtering, or thresh 1- (n) Flaws exceeding the acceptance criteria refer-olding for response from examination volume in (a; enced in this Case shall be repaired, and the weld shall be included in the data record. subsequently reexamined using the same ultrasonic ex-(k) Personnel who acquire and analyze UT data shal 11 amination procedure that detected the flaw.

be qualified and trained using the same type of equip, - (o) This Case number shall be recorded on the Data ment as in (i), and demonstrate their capability tcD Report.

detect and characterize the flaws using the procedure as described in (c).

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