JPN-02-011, Request for Relief RR-29, Third 10-Year Inservice Inspection Interval Program Plan
ML021300186 | |
Person / Time | |
---|---|
Site: | FitzPatrick ![]() |
Issue date: | 05/08/2002 |
From: | Kansler M Entergy Nuclear Northeast, Entergy Nuclear Operations |
To: | Document Control Desk, Office of Nuclear Reactor Regulation |
References | |
GL-88-001, JPN-02-011, RR-29 | |
Download: ML021300186 (18) | |
Text
Entergy Nuclear Northeast
- 'Entergy- Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601-1813 Tel 9142723500 May 8, 2002 JPN-02-011 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1-17 Washington, DC 20555-0001
Subject:
James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59 Relief Request RR-29 for Third 10-Year Inservice Inspection Interval Program Plan
Reference:
- 1. USNRC letter, W. H. Bateman to M. Bratton, PDI Chairman, dated January 15, 2002, regarding "Weld Overlay Performance Demonstration Administered by PDI as an Alternative for Generic Letter 88-01 Recommendations"
Dear Sir:
This letter submits a request for relief (Attachment 1) to use the Performance Demonstration Initiative (PDI) Program in lieu of the 1995 Edition, 1996 Addenda of ASME Section Xl, Appendix VIII, Supplement 11 requirements for examination of Class 1 piping welds at the James A. FitzPatrick Nuclear Power Plant (JAF). This request for relief is submitted pursuant to 10 CFR 50.55a(a)(3)(i) because the proposed alternatives would provide an acceptable level of quality and safety, as evaluated and determined by the USNRC staff (Reference 1).
Approval for this relief request is needed by August 30, 2002 for implementation during the upcoming Refueling Outage R015.
There are no new commitments made by this letter. If you have any questions, please contact Ms. Charlene Faison at 914-272-3378.
Michael R. Kansler Senior Vice President and L/ Chief Operating Officer
Attachment:
- 1. James A. FitzPatrick Third Inspection Interval Relief Request No. 29 cc: next page
cc: Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector's Office James A. FitzPatrick U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 Mr. Guy S. Vissing, Project Manager Project Directorate I Division of Licensing Project Management U.S. Nuclear Regulatory Commission Mail Stop 8C2 Washington, DC 20555
Attachment I to JPN-02-011 JAMES A. FITZPATRICK THIRD INSPECTION INTERVAL RELIEF REQUEST NO. 29 A: ARTICLE IDENTIFICATION / COMPONENT IDENTIFICATION:
Class 1, Pressure Retaining Welds in Piping, subject to Appendix VIII, Supplement 11, examination.
B: CODE REQUIREMENTS The Code requirements for which relief is requested are all contained within Appendix VIII, Supplement 11. For example, paragraph 1.1 (d)(1), requires that all base metal flaws be cracks. Paragraph 1.1 (e)(1) requires that at least 20%
but less than 40% of the flaws shall be oriented within +20 deg. of the pipe axial direction. Paragraph 1.1 (e)(1) also requires that the rules of IWA-3300 shall be used to determine whether closely spaced flaws should be treated as single or multiple flaws. Paragraph 1.1 (e)(2)(a)(1) requires that a base grading unit shall include at least 3 in. of the length of the overlaid weld. Paragraph 1.1 (e)(2)(b)(1) requires that an overlay grading unit shall include the overlay material and the base metal-to-overlay interface of at least 6 sq. in. The overlay grading unit shall be rectangular, with minimum dimensions of 2 in. Paragraph 3.2(b) requires that all extensions of base metal cracking into the overlay material by at least 0.1 in.
are reported as being intrusions into the overlay material.
C: RELIEF REQUESTED Relief is requested to use the proposed Performance Demonstration Initiative (PDI) Program for implementation of Appendix VIII, Supplement 11 requirements.
D. BASIS FOR RELIEF This relief is submitted pursuant to 10 CFR 50.55a(a)(3)(i) that the proposed alternatives would provide an acceptable level of quality and safety. Appendix VIII, Supp. 11, Paragraph 1.1 (d)(1), requires that all base metal flaws be cracks.
As illustrated below in Figure 1, implanting a crack requires excavation of the base material on at least one side of the flaw. While this 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 percent of the flaws in the detection and sizing test shall be cracks and the remainder shall be alternative flaws.
I
Attachment I to JPN-02-011 JAMES A. FITZPATRICK THIRD INSPECTION INTERVAL RELIEF REQUEST NO. 29
/Eýtmim Mechanical fatigue crack in Base material Figure 1 Relief is requested to allow closer spacing of flaws provided they didn't interfere with detection or discrimination. The existing specimens used to date for qualification to the Tri-party (NRC/BWROG/EPRI) agreement have a flaw population density greater than allowed by the 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 Tri-party agreement program to Supplement 11, the PDI Program has merged the Tri-party test specimens into their weld overlay program. For example: the requirement for using IWA-3300 for proximity flaw evaluation in paragraph 1.1 (e)(1) was excluded, instead indications will be sized based on their individual merits; 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; paragraph 1.1 (e)(2)(a)(1) was modified to require that a base metal grading unit include at least 1 in. of the length of the overlaid weld, rather than 3 inches; paragraph 1.1(e)(2)(a)(3) was modified to require sufficient unflawed overlaid weld and base metal to exist on all sides of the grading unit to preclude interfering reflections from adjacent flaws, rather than the I inch requirement of Supplement 11; paragraph 1.1 (e)(2)(b)(I) was modified to define an overlay fabrication grading unit as including the overlay material and the base metal-to-overlay interface for a length of at least 1 in, rather than the 6 sq. in. requirement of Supplement 11; and 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 in. at both ends, rather than around its entire perimeter.
Additionally, the requirement for axially oriented overlay fabrication flaws in paragraph 1.1(e)(1) was excluded from the PDI Program as an improbable scenario. Weld overlays are typically applied using automated gas tungsten arc welding techniques with the filler metal being 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 in paragraph 3.2(b) for reporting all extensions of cracking into the overlay is omitted from the PD1 Program because it is redundant to the RMS calculations performed in paragraph 3.2(c) and it's 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.
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Attachment 1 to JPN-02-011 JAMES A. FITZPATRICK THIRD INSPECTION INTERVAL RELIEF REQUEST NO. 29 PDI has submitted these changes as a Code Case and they have been approved, but the Code Case will not be published until later in 2002. A detailed comparison matrix (Attachment 1) between Supplement 11, the proposed ASME Section XI Code Case N-654, and the PDI Program is enclosed as supporting documentation. The first column identifies the current requirements in the 95 Edition and 96 Addenda of Supplement 11, while the second (middle) column identifies the changes made by the Code Case.
There are however some additional changes that were inadvertently omitted from the Code Case. The most important change is paragraph 1.1(a)(1) where 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. Additionally, to avoid confusion, the overlay thickness tolerance contained in paragraph 1.1(b) last sentence, was reworded and the phrase "and the remaindershall be alternative flaws" was added to the next to last sentence in paragraph 1.1 (d)(1). These changes are identified by bold print in the third column of the enclosure.
Also included as an attachment is a copy of the letter from the NRC to the PDI Chairman with their determination that PDI's performance demonstration program for weld overlays is an acceptable alternative to the performance demonstration recommendations of GL-88-01, "NRC Position on IGSCC (intergranular stress corrosion cracking) in BWR (Boiling Water Reactor)
Austenitic Stainless Steel Piping".
E. ALTERNATIVE EXAMINATION In lieu of the requirements of ASME Section XI, 1995 Edition, 1996 Addenda, Appendix VIII, Supplement 11, the PDI Program as described in Table 1, 3 rd column of this request for relief shall be used.
F. IMPLEMENTATION SCHEDULE The requirements as specified in this relief request will be incorporated into JAF Inspection Program for the duration of the 3 rd Ten-Year Interval.
G. ATTACHMENT Table 1, "Proposed Alternatives to 95/96 ASME Section XI, App. VIII, Supp. 11 Requirements" 3
James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section Xl, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) _I 1.0 SPECIMEN REQUIREMENTS CC N-654 PDI Program Qualification test specimens shall meet the No Change 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 No Change No Change conform to the following requirements.
(a) Specimens shall have sufficient volume No Change No Change to minimize spurious reflections that may interfere with the interpretation process.
(b) The specimen set shall consist of at No Change (b) The specimen set shall consist of at least three specimens having different least three specimens having different nominal pipe diameters and overlay nominal pipe diameters and overlay thicknesses. They shall include the thicknesses. They shall include the minimum and maximum nominal pipe minimum and maximum nominal pipe diameters for which the examination diameters for which the examination procedure is applicable. Pipe diameters procedure is applicable. Pipe diameters within a range of 0.9 to 1.5 times a nominal within a range of 0.9 to 1.5 times a nominal diameter shall be considered equivalent. If diameter shall be considered equivalent. If the procedure is applicable to pipe the procedure is applicable to pipe diameters of 24 in. or larger, the specimen diameters of 24 in. or larger, the specimen 1 of 13
James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section XI, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) set must include at least one specimen 24 set must include at least one specimen 24 in. or larger but need not include the in. or larger but need not include the maximum diameter. The specimen set maximum diameter. The specimen set must include at least one specimen with shall include specimens with overlay overlay thickness within -0.1 in. to +0.25 in. thickness within +0.1 in. of the of the maximum nominal overlay thickness minimum nominal overlay thickness for which the procedure is applicable, and within -0.25 in. of the maximum nominal overlay thickness for which the procedure is applicable.
(c) The surface condition of at least two No Change No Change specimens shall approximate the roughest surface condition for which the examination procedure is applicable.
(d) Flaw Conditions PDI Program (1) Base metal flaws. All flaws must be (1) Base metal flaws. All flaws must be in (1) Base metal flaws. All flaws must be in cracks in or near the butt weld heat- or near the butt weld heat-affected zone, or near the butt weld heat-affected zone, affected zone, open to the inside surface, open to the inside surface, and extending open to the inside surface, and extending and extending at least 75% through the at least 75% through the base metal wall. at least 75% through the base metal wall.
base metal wall. Flaws may extend 100% Intentional overlay fabrication flaws shall Intentional overlay fabrication flaws shall through the base metal and into the not interfere with ultrasonic detection or not interfere with ultrasonic detection or overlay material; in this case, intentional characterization of the cracking. characterization of the base metal flaws.
overlay fabrication flaws shall not interfere Specimens containing IGSCC shall be Specimens containing IGSCC shall be with ultrasonic detection or used when available. At least 70 percent used when available. At least 70 percent characterization of the cracking. of the flaws in the detection and sizing of the flaws in the detection and sizing Specimens containing IGSCC shall be tests shall be cracks. Alternative flaw tests shall be cracks and the remainder used when available, mechanisms, if used, shall provide crack- shall be alternative flaws. Alternative flaw 2 of 13
James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section XI, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) like reflective characteristics and shall be mechanisms, if used, shall provide crack limited by the following: like reflective characteristics and shall be limited by the following:
(a) Flaws shall be limited to when implantation of cracks precludes obtaining (a) Flaws shall be limited to when a realistic ultrasonic response. implantation of cracks precludes obtaining an effective ultrasonic response.
(b) Flaws shall be semielliptical with a tip width of less than or equal to 0.002 inches. (b) Flaws shall be semielliptical with a tip width of less than or equal to 0.002 inches.
(2) Overlay fabrication flaws. 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 PDI Program (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 base metal flaws shall be oriented within base metal flaws shall be oriented within the pipe axial direction. The remainder +20 deg. of the pipe axial direction. The +20 deg. of the pipe axial direction. The shall be oriented circumferentially. Flaws remainder shall be oriented remainder shall be oriented shall not be open to any surface to which circumferentially. Flaws shall not be open circumferentially. Flaws shall not be open the candidate has physical or visual to any surface to which the candidate has to any surface to which the candidate has access. The rules of IWA-3300 shall be physical or visual access. physical or visual access.
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James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section XI, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) used to determine whether closely spaced flaws should be treated as single or multiple flaws.
(2) Specimens shall be divided into base (2) Specimens shall be divided into base (2) Specimens shall be divided into base and over-lay grading units. Each specimen metal and overlay fabrication grading units, metal and overlay fabrication grading units.
shall contain one or both types of grading Each specimen shall contain one or both Each specimen shall contain one or both units. 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 (a)(1) A base metal grading unit shall least 3 in. of the length of the overlaid include at least 1 in. of the length of the include at least 1 in. of the length of the weld. The base grading unit includes the overlaid weld. The base metal grading unit overlaid weld. The base metal grading outer 25% of the overlaid weld and base includes the outer 25% of the overlaid weld unit includes the outer 25% of the metal on both sides. The base grading unit and base metal on both sides. The base overlaid weld. The base metal grading shall not include the inner 75% of the metal grading unit shall not include the unit shall not include the inner 75% of the overlaid weld and base metal overlay inner 75% of the overlaid weld and base overlaid weld and base metal overlay material, or base metal-to-overlay metal overlay material, or base metal-to- material, or base metal-to-overlay interface, overlay interface, interface.
(a)(2) When base metal cracking (a)(2) When base metal cracking (a)(2) When base metal flaws penetrate penetrates into the overlay material, the penetrates into the overlay material, the into the overlay material, the base metal base grading unit shall include the overlay base metal grading unit shall not be used grading unit shall not be used as part of metal within 1 in. of the crack location. This as part of any overlay fabrication grading any overlay fabrication grading unit.
portion of the overlay material shall not be unit.
used as part of any overlay grading unit._II (a)(3) When a base grading unit is (a)(3) Sufficient unflawed overlaid weld (a)(3) Sufficient unflawed overlaid weld designed to be unflawed, at least 1 in. of and base metal shall exist on all sides of and base metal shall exist on all sides of 4 of 13
James A. FitzPatrick Third Inspection Interval Relief Request No. 29 J P N-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section XI, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) unflawed overlaid weld and base metal the grading unit to preclude interfering the grading unit to preclude interfering shall exist on either side of the base reflections from adjacent flaws. reflections from adjacent flaws.
grading unit. The 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.
(bXl) An overlay grading unit shall include (b)(1) An overlay fabrication grading unit (b)(1) 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 in. of at least I in.
with minimum dimensions of 2 in.-
(b)(2) An overlay grading unit designed to (b)(2) Overlay fabrication grading units (b)(2) Overlay fabrication grading units be unflawed shall be surrounded by designed to be unflawed shall be designed to be unflawed shall be unflawed overlay material and unflawed separated by unflawed overlay material separated by unflawed overlay material base metal-to-overlay interface for at least and unflawed base metal-to-overlay and unflawed base metal-to-overlay 1 in. around its entire perimeter. The interface for at least 1 in. at both ends. interface for at least 1 in. at both ends.
specific area used in one overlay grading Sufficient unflawed overlaid weld and base Sufficient unflawed overlaid weld and base unit shall not be used in another overlay metal shall exist on both sides of the metal shall exist on both sides of the grading unit. Overlay grading units need overlay fabrication grading unit to preclude overlay fabrication grading unit to preclude not be spaced uniformly about the interfering reflections from adjacent flaws. interfering reflections from adjacent flaws.
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 Overlay fabrication grading units need not 5 of 13
James A. FitzPatrick Third Inspection Interval Relief Request No. 29 J PN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section Xl, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) be spaced uniformly about the specimen. be 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 VIII-S2-1. The minimum detection Table VIII-S2-1. The minimum detection Table VIll-S2-1. The minimum detection sample set is five flawed base grading sample set is five flawed base metal sample set is five flawed base metal units, ten unflawed base grading units, five grading units, ten unflawed base metal grading units, ten unflawed base metal flawed overlay grading units, and ten grading units, five flawed overlay grading units, five flawed overlay unflawed overlay grading units. For each fabrication grading units, and ten unflawed fabrication grading units, and ten unflawed type of grading unit, the set shall contain at overlay fabrication grading units. For each overlay fabrication grading units. For each least twice as many unflawed as flawed type of grading unit, the set shall contain at type of grading unit, the set shall contain at grading units. least twice as many unflawed as flawed least twice as many unflawed as flawed grading units. For initial procedure grading units. For initial procedure qualification, detection sets shall include qualification, detection sets shall include the equivalent of three personnel the equivalent of three personnel qualification sets. To qualify new values of qualification sets. To qualify new values of essential variables, at least one personnel essential variables, at least one personnel qualification set is required. qualification set is required.
(f) Sizing Specimen PDI Program (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 overlay fabrication flaws. At least 40% of overlay fabrication flaws. At least 40% of the flaws shall be cracks open to the inside the flaws shall be cracks open to the inside the flaws shall be open to the inside surface. surface. For initial procedure qualification, surface. For initial procedure qualification, sizing sets shall include the equivalent of sizing sets shall include the equivalent of three personnel qualification sets. To three personnel qualification sets. To qualify new values of essential variables, qualify new values of essential variables, 6 of 13
James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section XI, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.orgfPDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) at least one personnel qualification set is at least one personnel qualification set is required. 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.
(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 No Change (4) Depth sizing specimen sets shall include at least two distinct locations where include at least two distinct locations where cracking in the base metal extends into the flaws in the base metal extend into the overlay material by at least 0.1 in. in the overlay material by at least 0.1 in. in the through-wall direction. through-wall direction.
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James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section XI, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) _1 2.0 CONDUCT OF PERFORMANCE CC N-654 PDI Program 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 Divulgence of particular specimen results Divulgence of particular specimen results or candidate viewing of unmasked or candidate viewing of unmasked or candidate viewing of unmasked specimens after the performance specimens after the performance specimens after the performance demonstration is prohibited. demonstration is prohibited. The overlay demonstration is prohibited. The overlay fabrication flaw test and the base metal fabrication flaw test and the base metal flaw test may be performed separately. flaw test may be performed separately.
2.1 Detection Test. PDI Program Flawed and unflawed grading units shall Flawed and unflawed grading units shall Flawed and unflawed grading units shall be randomly mixed. Although the be randomly mixed. Although the be randomly mixed. Although the boundaries of specific grading units shall boundaries of specific grading units shall boundaries of specific grading units shall not be revealed to the candidate, the not be revealed to the candidate, the not be revealed to the candidate, the candidate shall be made aware of the type candidate shall be made aware of the type candidate shall be made aware of the type or types of grading units (base or overlay) or types of grading units (base metal or or types of grading units (base metal or that are present for each specimen. overlay fabrication) that are present for overlay fabrication) that are present for each specimen. each specimen.
2.2 Length Sizing Test PDI Program (a) The length sizing test may be No Change conducted separately or in conjunction with 8 of 13
James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section XI, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) the detection test.
(b) When the length sizing test is No Change No Change 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 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, (d) For flaws in base metal grading units, candidate shall estimate the length of that the candidate shall estimate the length of the candidate shall estimate the length of part of the flaw that is in the outer 25% of that part of the flaw that is in the outer 25% that part of the flaw that is in the outer 25%
the base wall thickness. of the base metal wall thickness. of the base metal wall thickness.
2.3 Depth Sizing Test. PDI Program For the depth sizing test, 80% of the flaws The candidate shall determine the depth of The candidate shall determine the depth of shall be sized at a specific location on the the flaw in each region. the flaw in each region.
surface of the specimen identified to the candidate. For the remaining flaws, the regions of each specimen containing a flaw to be sized shall be identified to the 9 of 13
James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section Xl, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) candidate. The candidate shall determine the maximum depth of the flaw in each region.
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James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section Xl, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) 3.0 ACCEPTANCE CRITERIA 3.1 Detection Acceptance Criteria. CC N-654 PDI Program Examination procedures, equipment, and Examination procedures are qualified for Examination procedures are qualified for personnel are qualified for detection when detection when all flaws within the scope of detection when all flaws within the scope of the results of the performance the procedure are detected and the results the procedure are detected and the results demonstration satisfy the acceptance of the performance demonstration satisfy of the performance demonstration satisfy criteria of Table VIII-S2-1 for both detection the acceptance criteria of Table VIII-S2-1 the acceptance criteria of Table VIII-S2-1 and false calls. The criteria shall be for false calls. Examination equipment and for false calls. Examination equipment and satisfied separately by the demonstration personnel are qualified for detection when personnel are qualified for detection when results for base grading units and for the results of the performance the results of the performance overlay grading units. demonstration satisfy the acceptance demonstration satisfy the acceptance criteria of Table VIII-S2-1 for both detection criteria of Table VIII-S2-1 for both detection and false calls. The criteria shall be and false calls. The criteria shall be satisfied separately by the demonstration satisfied separately by the demonstration results for base metal grading units and for results for base metal grading units and for overlay fabrication grading units. overlay fabrication grading units.
3.2 Sizing Acceptance Criteria. PDI Program Examination procedures, equipment, and No Change No Change personnel are qualified for sizing when the 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 measurements, as compared to the true flaw lengths, is less than or equal to 0.75 flaw lengths, is less than or equal to 0.75 inch. The length of base metal cracking is inch. The length of base metal flaws is 11 of 13
James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section Xl, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) measured at the 75% through-base-metal measured at the 75% through-base-metal position. Iposition.
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James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95196 ASME Section Xl, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcO0- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only)
(b) All extensions of base metal cracking This requirement is omitted. This requirement is omitted.
into the overlay material by at least 0.1 in.
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 measurements, as compared to the true measurements, as compared to the true flaw depths, is less than or equal to 0.125 flaw depths, is less than or equal to 0.125 flaw depths, is less than or equal to 0.125 in. in. in.
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Entergy Nuclear Northeast
- 'Entergy- Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601-1813 Tel 9142723500 May 8, 2002 JPN-02-011 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1-17 Washington, DC 20555-0001
Subject:
James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59 Relief Request RR-29 for Third 10-Year Inservice Inspection Interval Program Plan
Reference:
- 1. USNRC letter, W. H. Bateman to M. Bratton, PDI Chairman, dated January 15, 2002, regarding "Weld Overlay Performance Demonstration Administered by PDI as an Alternative for Generic Letter 88-01 Recommendations"
Dear Sir:
This letter submits a request for relief (Attachment 1) to use the Performance Demonstration Initiative (PDI) Program in lieu of the 1995 Edition, 1996 Addenda of ASME Section Xl, Appendix VIII, Supplement 11 requirements for examination of Class 1 piping welds at the James A. FitzPatrick Nuclear Power Plant (JAF). This request for relief is submitted pursuant to 10 CFR 50.55a(a)(3)(i) because the proposed alternatives would provide an acceptable level of quality and safety, as evaluated and determined by the USNRC staff (Reference 1).
Approval for this relief request is needed by August 30, 2002 for implementation during the upcoming Refueling Outage R015.
There are no new commitments made by this letter. If you have any questions, please contact Ms. Charlene Faison at 914-272-3378.
Michael R. Kansler Senior Vice President and L/ Chief Operating Officer
Attachment:
- 1. James A. FitzPatrick Third Inspection Interval Relief Request No. 29 cc: next page
cc: Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector's Office James A. FitzPatrick U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 Mr. Guy S. Vissing, Project Manager Project Directorate I Division of Licensing Project Management U.S. Nuclear Regulatory Commission Mail Stop 8C2 Washington, DC 20555
Attachment I to JPN-02-011 JAMES A. FITZPATRICK THIRD INSPECTION INTERVAL RELIEF REQUEST NO. 29 A: ARTICLE IDENTIFICATION / COMPONENT IDENTIFICATION:
Class 1, Pressure Retaining Welds in Piping, subject to Appendix VIII, Supplement 11, examination.
B: CODE REQUIREMENTS The Code requirements for which relief is requested are all contained within Appendix VIII, Supplement 11. For example, paragraph 1.1 (d)(1), requires that all base metal flaws be cracks. Paragraph 1.1 (e)(1) requires that at least 20%
but less than 40% of the flaws shall be oriented within +20 deg. of the pipe axial direction. Paragraph 1.1 (e)(1) also requires that the rules of IWA-3300 shall be used to determine whether closely spaced flaws should be treated as single or multiple flaws. Paragraph 1.1 (e)(2)(a)(1) requires that a base grading unit shall include at least 3 in. of the length of the overlaid weld. Paragraph 1.1 (e)(2)(b)(1) requires that an overlay grading unit shall include the overlay material and the base metal-to-overlay interface of at least 6 sq. in. The overlay grading unit shall be rectangular, with minimum dimensions of 2 in. Paragraph 3.2(b) requires that all extensions of base metal cracking into the overlay material by at least 0.1 in.
are reported as being intrusions into the overlay material.
C: RELIEF REQUESTED Relief is requested to use the proposed Performance Demonstration Initiative (PDI) Program for implementation of Appendix VIII, Supplement 11 requirements.
D. BASIS FOR RELIEF This relief is submitted pursuant to 10 CFR 50.55a(a)(3)(i) that the proposed alternatives would provide an acceptable level of quality and safety. Appendix VIII, Supp. 11, Paragraph 1.1 (d)(1), requires that all base metal flaws be cracks.
As illustrated below in Figure 1, implanting a crack requires excavation of the base material on at least one side of the flaw. While this 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 percent of the flaws in the detection and sizing test shall be cracks and the remainder shall be alternative flaws.
I
Attachment I to JPN-02-011 JAMES A. FITZPATRICK THIRD INSPECTION INTERVAL RELIEF REQUEST NO. 29
/Eýtmim Mechanical fatigue crack in Base material Figure 1 Relief is requested to allow closer spacing of flaws provided they didn't interfere with detection or discrimination. The existing specimens used to date for qualification to the Tri-party (NRC/BWROG/EPRI) agreement have a flaw population density greater than allowed by the 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 Tri-party agreement program to Supplement 11, the PDI Program has merged the Tri-party test specimens into their weld overlay program. For example: the requirement for using IWA-3300 for proximity flaw evaluation in paragraph 1.1 (e)(1) was excluded, instead indications will be sized based on their individual merits; 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; paragraph 1.1 (e)(2)(a)(1) was modified to require that a base metal grading unit include at least 1 in. of the length of the overlaid weld, rather than 3 inches; paragraph 1.1(e)(2)(a)(3) was modified to require sufficient unflawed overlaid weld and base metal to exist on all sides of the grading unit to preclude interfering reflections from adjacent flaws, rather than the I inch requirement of Supplement 11; paragraph 1.1 (e)(2)(b)(I) was modified to define an overlay fabrication grading unit as including the overlay material and the base metal-to-overlay interface for a length of at least 1 in, rather than the 6 sq. in. requirement of Supplement 11; and 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 in. at both ends, rather than around its entire perimeter.
Additionally, the requirement for axially oriented overlay fabrication flaws in paragraph 1.1(e)(1) was excluded from the PDI Program as an improbable scenario. Weld overlays are typically applied using automated gas tungsten arc welding techniques with the filler metal being 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 in paragraph 3.2(b) for reporting all extensions of cracking into the overlay is omitted from the PD1 Program because it is redundant to the RMS calculations performed in paragraph 3.2(c) and it's 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.
2
Attachment 1 to JPN-02-011 JAMES A. FITZPATRICK THIRD INSPECTION INTERVAL RELIEF REQUEST NO. 29 PDI has submitted these changes as a Code Case and they have been approved, but the Code Case will not be published until later in 2002. A detailed comparison matrix (Attachment 1) between Supplement 11, the proposed ASME Section XI Code Case N-654, and the PDI Program is enclosed as supporting documentation. The first column identifies the current requirements in the 95 Edition and 96 Addenda of Supplement 11, while the second (middle) column identifies the changes made by the Code Case.
There are however some additional changes that were inadvertently omitted from the Code Case. The most important change is paragraph 1.1(a)(1) where 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. Additionally, to avoid confusion, the overlay thickness tolerance contained in paragraph 1.1(b) last sentence, was reworded and the phrase "and the remaindershall be alternative flaws" was added to the next to last sentence in paragraph 1.1 (d)(1). These changes are identified by bold print in the third column of the enclosure.
Also included as an attachment is a copy of the letter from the NRC to the PDI Chairman with their determination that PDI's performance demonstration program for weld overlays is an acceptable alternative to the performance demonstration recommendations of GL-88-01, "NRC Position on IGSCC (intergranular stress corrosion cracking) in BWR (Boiling Water Reactor)
Austenitic Stainless Steel Piping".
E. ALTERNATIVE EXAMINATION In lieu of the requirements of ASME Section XI, 1995 Edition, 1996 Addenda, Appendix VIII, Supplement 11, the PDI Program as described in Table 1, 3 rd column of this request for relief shall be used.
F. IMPLEMENTATION SCHEDULE The requirements as specified in this relief request will be incorporated into JAF Inspection Program for the duration of the 3 rd Ten-Year Interval.
G. ATTACHMENT Table 1, "Proposed Alternatives to 95/96 ASME Section XI, App. VIII, Supp. 11 Requirements" 3
James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section Xl, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) _I 1.0 SPECIMEN REQUIREMENTS CC N-654 PDI Program Qualification test specimens shall meet the No Change 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 No Change No Change conform to the following requirements.
(a) Specimens shall have sufficient volume No Change No Change to minimize spurious reflections that may interfere with the interpretation process.
(b) The specimen set shall consist of at No Change (b) The specimen set shall consist of at least three specimens having different least three specimens having different nominal pipe diameters and overlay nominal pipe diameters and overlay thicknesses. They shall include the thicknesses. They shall include the minimum and maximum nominal pipe minimum and maximum nominal pipe diameters for which the examination diameters for which the examination procedure is applicable. Pipe diameters procedure is applicable. Pipe diameters within a range of 0.9 to 1.5 times a nominal within a range of 0.9 to 1.5 times a nominal diameter shall be considered equivalent. If diameter shall be considered equivalent. If the procedure is applicable to pipe the procedure is applicable to pipe diameters of 24 in. or larger, the specimen diameters of 24 in. or larger, the specimen 1 of 13
James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section XI, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) set must include at least one specimen 24 set must include at least one specimen 24 in. or larger but need not include the in. or larger but need not include the maximum diameter. The specimen set maximum diameter. The specimen set must include at least one specimen with shall include specimens with overlay overlay thickness within -0.1 in. to +0.25 in. thickness within +0.1 in. of the of the maximum nominal overlay thickness minimum nominal overlay thickness for which the procedure is applicable, and within -0.25 in. of the maximum nominal overlay thickness for which the procedure is applicable.
(c) The surface condition of at least two No Change No Change specimens shall approximate the roughest surface condition for which the examination procedure is applicable.
(d) Flaw Conditions PDI Program (1) Base metal flaws. All flaws must be (1) Base metal flaws. All flaws must be in (1) Base metal flaws. All flaws must be in cracks in or near the butt weld heat- or near the butt weld heat-affected zone, or near the butt weld heat-affected zone, affected zone, open to the inside surface, open to the inside surface, and extending open to the inside surface, and extending and extending at least 75% through the at least 75% through the base metal wall. at least 75% through the base metal wall.
base metal wall. Flaws may extend 100% Intentional overlay fabrication flaws shall Intentional overlay fabrication flaws shall through the base metal and into the not interfere with ultrasonic detection or not interfere with ultrasonic detection or overlay material; in this case, intentional characterization of the cracking. characterization of the base metal flaws.
overlay fabrication flaws shall not interfere Specimens containing IGSCC shall be Specimens containing IGSCC shall be with ultrasonic detection or used when available. At least 70 percent used when available. At least 70 percent characterization of the cracking. of the flaws in the detection and sizing of the flaws in the detection and sizing Specimens containing IGSCC shall be tests shall be cracks. Alternative flaw tests shall be cracks and the remainder used when available, mechanisms, if used, shall provide crack- shall be alternative flaws. Alternative flaw 2 of 13
James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section XI, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) like reflective characteristics and shall be mechanisms, if used, shall provide crack limited by the following: like reflective characteristics and shall be limited by the following:
(a) Flaws shall be limited to when implantation of cracks precludes obtaining (a) Flaws shall be limited to when a realistic ultrasonic response. implantation of cracks precludes obtaining an effective ultrasonic response.
(b) Flaws shall be semielliptical with a tip width of less than or equal to 0.002 inches. (b) Flaws shall be semielliptical with a tip width of less than or equal to 0.002 inches.
(2) Overlay fabrication flaws. 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 PDI Program (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 base metal flaws shall be oriented within base metal flaws shall be oriented within the pipe axial direction. The remainder +20 deg. of the pipe axial direction. The +20 deg. of the pipe axial direction. The shall be oriented circumferentially. Flaws remainder shall be oriented remainder shall be oriented shall not be open to any surface to which circumferentially. Flaws shall not be open circumferentially. Flaws shall not be open the candidate has physical or visual to any surface to which the candidate has to any surface to which the candidate has access. The rules of IWA-3300 shall be physical or visual access. physical or visual access.
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James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section XI, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) used to determine whether closely spaced flaws should be treated as single or multiple flaws.
(2) Specimens shall be divided into base (2) Specimens shall be divided into base (2) Specimens shall be divided into base and over-lay grading units. Each specimen metal and overlay fabrication grading units, metal and overlay fabrication grading units.
shall contain one or both types of grading Each specimen shall contain one or both Each specimen shall contain one or both units. 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 (a)(1) A base metal grading unit shall least 3 in. of the length of the overlaid include at least 1 in. of the length of the include at least 1 in. of the length of the weld. The base grading unit includes the overlaid weld. The base metal grading unit overlaid weld. The base metal grading outer 25% of the overlaid weld and base includes the outer 25% of the overlaid weld unit includes the outer 25% of the metal on both sides. The base grading unit and base metal on both sides. The base overlaid weld. The base metal grading shall not include the inner 75% of the metal grading unit shall not include the unit shall not include the inner 75% of the overlaid weld and base metal overlay inner 75% of the overlaid weld and base overlaid weld and base metal overlay material, or base metal-to-overlay metal overlay material, or base metal-to- material, or base metal-to-overlay interface, overlay interface, interface.
(a)(2) When base metal cracking (a)(2) When base metal cracking (a)(2) When base metal flaws penetrate penetrates into the overlay material, the penetrates into the overlay material, the into the overlay material, the base metal base grading unit shall include the overlay base metal grading unit shall not be used grading unit shall not be used as part of metal within 1 in. of the crack location. This as part of any overlay fabrication grading any overlay fabrication grading unit.
portion of the overlay material shall not be unit.
used as part of any overlay grading unit._II (a)(3) When a base grading unit is (a)(3) Sufficient unflawed overlaid weld (a)(3) Sufficient unflawed overlaid weld designed to be unflawed, at least 1 in. of and base metal shall exist on all sides of and base metal shall exist on all sides of 4 of 13
James A. FitzPatrick Third Inspection Interval Relief Request No. 29 J P N-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section XI, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) unflawed overlaid weld and base metal the grading unit to preclude interfering the grading unit to preclude interfering shall exist on either side of the base reflections from adjacent flaws. reflections from adjacent flaws.
grading unit. The 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.
(bXl) An overlay grading unit shall include (b)(1) An overlay fabrication grading unit (b)(1) 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 in. of at least I in.
with minimum dimensions of 2 in.-
(b)(2) An overlay grading unit designed to (b)(2) Overlay fabrication grading units (b)(2) Overlay fabrication grading units be unflawed shall be surrounded by designed to be unflawed shall be designed to be unflawed shall be unflawed overlay material and unflawed separated by unflawed overlay material separated by unflawed overlay material base metal-to-overlay interface for at least and unflawed base metal-to-overlay and unflawed base metal-to-overlay 1 in. around its entire perimeter. The interface for at least 1 in. at both ends. interface for at least 1 in. at both ends.
specific area used in one overlay grading Sufficient unflawed overlaid weld and base Sufficient unflawed overlaid weld and base unit shall not be used in another overlay metal shall exist on both sides of the metal shall exist on both sides of the grading unit. Overlay grading units need overlay fabrication grading unit to preclude overlay fabrication grading unit to preclude not be spaced uniformly about the interfering reflections from adjacent flaws. interfering reflections from adjacent flaws.
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 Overlay fabrication grading units need not 5 of 13
James A. FitzPatrick Third Inspection Interval Relief Request No. 29 J PN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section Xl, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) be spaced uniformly about the specimen. be 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 VIII-S2-1. The minimum detection Table VIII-S2-1. The minimum detection Table VIll-S2-1. The minimum detection sample set is five flawed base grading sample set is five flawed base metal sample set is five flawed base metal units, ten unflawed base grading units, five grading units, ten unflawed base metal grading units, ten unflawed base metal flawed overlay grading units, and ten grading units, five flawed overlay grading units, five flawed overlay unflawed overlay grading units. For each fabrication grading units, and ten unflawed fabrication grading units, and ten unflawed type of grading unit, the set shall contain at overlay fabrication grading units. For each overlay fabrication grading units. For each least twice as many unflawed as flawed type of grading unit, the set shall contain at type of grading unit, the set shall contain at grading units. least twice as many unflawed as flawed least twice as many unflawed as flawed grading units. For initial procedure grading units. For initial procedure qualification, detection sets shall include qualification, detection sets shall include the equivalent of three personnel the equivalent of three personnel qualification sets. To qualify new values of qualification sets. To qualify new values of essential variables, at least one personnel essential variables, at least one personnel qualification set is required. qualification set is required.
(f) Sizing Specimen PDI Program (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 overlay fabrication flaws. At least 40% of overlay fabrication flaws. At least 40% of the flaws shall be cracks open to the inside the flaws shall be cracks open to the inside the flaws shall be open to the inside surface. surface. For initial procedure qualification, surface. For initial procedure qualification, sizing sets shall include the equivalent of sizing sets shall include the equivalent of three personnel qualification sets. To three personnel qualification sets. To qualify new values of essential variables, qualify new values of essential variables, 6 of 13
James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section XI, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.orgfPDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) at least one personnel qualification set is at least one personnel qualification set is required. 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.
(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 No Change (4) Depth sizing specimen sets shall include at least two distinct locations where include at least two distinct locations where cracking in the base metal extends into the flaws in the base metal extend into the overlay material by at least 0.1 in. in the overlay material by at least 0.1 in. in the through-wall direction. through-wall direction.
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James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section XI, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) _1 2.0 CONDUCT OF PERFORMANCE CC N-654 PDI Program 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 Divulgence of particular specimen results Divulgence of particular specimen results or candidate viewing of unmasked or candidate viewing of unmasked or candidate viewing of unmasked specimens after the performance specimens after the performance specimens after the performance demonstration is prohibited. demonstration is prohibited. The overlay demonstration is prohibited. The overlay fabrication flaw test and the base metal fabrication flaw test and the base metal flaw test may be performed separately. flaw test may be performed separately.
2.1 Detection Test. PDI Program Flawed and unflawed grading units shall Flawed and unflawed grading units shall Flawed and unflawed grading units shall be randomly mixed. Although the be randomly mixed. Although the be randomly mixed. Although the boundaries of specific grading units shall boundaries of specific grading units shall boundaries of specific grading units shall not be revealed to the candidate, the not be revealed to the candidate, the not be revealed to the candidate, the candidate shall be made aware of the type candidate shall be made aware of the type candidate shall be made aware of the type or types of grading units (base or overlay) or types of grading units (base metal or or types of grading units (base metal or that are present for each specimen. overlay fabrication) that are present for overlay fabrication) that are present for each specimen. each specimen.
2.2 Length Sizing Test PDI Program (a) The length sizing test may be No Change conducted separately or in conjunction with 8 of 13
James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section XI, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) the detection test.
(b) When the length sizing test is No Change No Change 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 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, (d) For flaws in base metal grading units, candidate shall estimate the length of that the candidate shall estimate the length of the candidate shall estimate the length of part of the flaw that is in the outer 25% of that part of the flaw that is in the outer 25% that part of the flaw that is in the outer 25%
the base wall thickness. of the base metal wall thickness. of the base metal wall thickness.
2.3 Depth Sizing Test. PDI Program For the depth sizing test, 80% of the flaws The candidate shall determine the depth of The candidate shall determine the depth of shall be sized at a specific location on the the flaw in each region. the flaw in each region.
surface of the specimen identified to the candidate. For the remaining flaws, the regions of each specimen containing a flaw to be sized shall be identified to the 9 of 13
James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section Xl, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) candidate. The candidate shall determine the maximum depth of the flaw in each region.
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James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section Xl, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) 3.0 ACCEPTANCE CRITERIA 3.1 Detection Acceptance Criteria. CC N-654 PDI Program Examination procedures, equipment, and Examination procedures are qualified for Examination procedures are qualified for personnel are qualified for detection when detection when all flaws within the scope of detection when all flaws within the scope of the results of the performance the procedure are detected and the results the procedure are detected and the results demonstration satisfy the acceptance of the performance demonstration satisfy of the performance demonstration satisfy criteria of Table VIII-S2-1 for both detection the acceptance criteria of Table VIII-S2-1 the acceptance criteria of Table VIII-S2-1 and false calls. The criteria shall be for false calls. Examination equipment and for false calls. Examination equipment and satisfied separately by the demonstration personnel are qualified for detection when personnel are qualified for detection when results for base grading units and for the results of the performance the results of the performance overlay grading units. demonstration satisfy the acceptance demonstration satisfy the acceptance criteria of Table VIII-S2-1 for both detection criteria of Table VIII-S2-1 for both detection and false calls. The criteria shall be and false calls. The criteria shall be satisfied separately by the demonstration satisfied separately by the demonstration results for base metal grading units and for results for base metal grading units and for overlay fabrication grading units. overlay fabrication grading units.
3.2 Sizing Acceptance Criteria. PDI Program Examination procedures, equipment, and No Change No Change personnel are qualified for sizing when the 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 measurements, as compared to the true flaw lengths, is less than or equal to 0.75 flaw lengths, is less than or equal to 0.75 inch. The length of base metal cracking is inch. The length of base metal flaws is 11 of 13
James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95/96 ASME Section Xl, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcOO- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only) measured at the 75% through-base-metal measured at the 75% through-base-metal position. Iposition.
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James A. FitzPatrick Third Inspection Interval Relief Request No. 29 JPN-02-011 Table 1 - Proposed Alternatives to 95196 ASME Section Xl, App. VIII, Supp. 11 Requirements SUPPLEMENT 11 - QUALIFICATION PROPOSED CODE CASE N-654 PDI PROGRAM:
REQUIREMENTS FOR FULL Extracted from: The Proposed Alternative to STRUCTURAL OVERLAID http://www.boilercode.org/PDF/bcO0- Supplement 11 Requirements WROUGHT AUSTENITIC PIPING 756R.pdf WELDS (Provided for Information Only)
(b) All extensions of base metal cracking This requirement is omitted. This requirement is omitted.
into the overlay material by at least 0.1 in.
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 measurements, as compared to the true measurements, as compared to the true flaw depths, is less than or equal to 0.125 flaw depths, is less than or equal to 0.125 flaw depths, is less than or equal to 0.125 in. in. in.
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