ML023250202

Second Ten-Year Interval Inservice Inspection Program Pressure Retaining Piping Welds Relief Requests B-2-06 & B-2-07

ML023250202
Person / Time
Site:	San Onofre
Issue date:	11/19/2002
From:	Scherer A Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML023250202 (32)

Text

U SOUTHERN CALIFORNIA A. Edward Scherer E SManager of EDISON Nuclear Regulatory Affairs An EDISON INTERNATIONAL Company November 19, 2002 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

Subject:

Docket No. 50-362 Second Ten-Year Interval Inservice Inspection Program Pressure Retaining Piping Welds Relief Requests B-2-06 and B-2-07 San Onofre Nuclear Generating Station Unit 3 Gentlemen:

This letter requests NRC approval of Relief Requests (RRs) B-2-06 and B-2-07 for San Onofre Nuclear Generating Station Unit 3. RR B-2-06 (Enclosure 1) is a request for relief from ASME Code,Section XI, Appendix VIII qualification requirements for inspection of Class 1 pressure retaining piping welds. RR B-2-07 (Enclosure 2) is a request for relief from ASME Code requirements for ultrasonic examination from the inside surface of Class 1 pressure retaining piping welds. These RRs are needed for Unit 3 to comply with the revised 10 CFR 50.55a(g)(6)(ii)(C)(1), which requires implementation of ASME Code,Section XI, Appendix VIII, Supplements 3 and 10 by May 22, 2000 and November 22, 2002, respectively.

These RRs are consistent with the overall Performance Demonstration Initiative (PDI) effort, and PDI will administer the alternative programs described in these RRs.

The ASME Code,Section XI, 1995 Edition, 1996 Addenda, Appendix VIII, Supplement 10 requires qualification of procedures, personnel, and equipment for examination of Section XI, Appendix VIII, Category B-F, pressure retaining, dissimilar metal welds. In lieu of certain of these ASME Code, Supplement 10 requirements, RR B-2-06 requests use of PDI developed alternative qualification requirements for inspection of these pressure retaining welds. The Attachment to Enclosure I provides PDI developed proposed revisions to Supplement 10, and the proposed revisions are identified by bold print or by line out.

The ASME Code,Section XI, 1995 Edition, 1996 Addenda, Appendix VIII, Supplement 3 requires qualification of procedures, personnel, and equipment for inside surface examination of Class 1 pressure retaining Category B-J piping welds. In lieu of certain of these ASME Code, Supplement 3 requirements, RR B-2-07 requests use of PDI developed alternative qualification requirements for inside surface inspection of these pressure retaining piping welds. The PDI developed alternative requirements are provided in the proposed ASME Code,Section XI, Appendix VIII, Supplement 14 (Enclosure 2, Attachment 2). These Supplement 14 proposed alternative requirements will be coordinated with the proposed initiative for the Supplement 10 implementation program.

P 0 Box 128\A San Clemente, CA 92674-0128 \Y\

949-368-7501 Fax 949-368-7575

Document Control Desk November 19, 2002 The NRC is requested to approve these relief requests to support the Unit 3, Cycle 12 refueling outage, which is currently scheduled to begin on January 6, 2003.

If you have any questions or need additional information regarding this matter, please feel free to contact me or Mr. Jack Rainsberry at (949) 368-7420.

Sincerely, Enclosures cc: E. W. Merschoff, Regional Administrator, NRC Region IV B. M. Pham, NRC Project Manager, San Onofre Units 2, and 3 C. C. Osterholtz, NRC Senior Resident Inspector, San Onofre Units 2 & 3

ENCLOSUREI SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3 SECOND TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST RR-B-2-06 SYSTEMICOMPONENT(S) FOR WHICH RELIEF IS REQUESTED ASME Section XI, 1989 Edition, no Addenda, Class 1, Category B-F, Pressure Retaining Piping Welds, Item Numbers B5.40, B5.130, subject to ultrasonic examination using procedures, personnel, and equipment qualified to ASME Section XI, 1995 Edition, 1996 Addenda, Appendix VIII, Supplement 10 criteria.

CODE REQUIREMENTS The following paragraphs or statements are from ASME Section XI, Rules for Inservice Inspection of Nuclear Power plant Components, 1995 Edition, 1996 Addenda, Appendix VIII, Supplement 10, Qualification Requirements for Dissimilar Metal Piping Welds, and identify the specific requirements that are included in this request for relief.

Item 1 - Paragraph 1.1(b) states in part - Pipe diameters within a range of 0.9 to 1.5 times a nominal diameter shall be considered equivalent.

Item 2 - Paragraph 1.1(d) states - All flaws in the specimen set shall be cracks.

Item 3 - Paragraph 1.1(d)(1) states - At least 50% of the cracks shall be in austenitic material. At least 50% of the cracks in austenitic material shall be contained wholly in weld or buttering material. At least 10% of the cracks shall be in ferritic material. The remainder of the cracks may be in either austenitic or ferritic material.

Item 4 - Paragraph 1.2(b) states in part - The number of unflawed grading units shall be at least twice the number of flawed grading units.

Item 5 - Paragraph 1.2(c)(1) and 1.3(c) state in part - At least 1/3 of the flaws, rounded to the next higher whole number, shall have depths between 10% and 30% of the nominal pipe wall thickness. Paragraph 1.4(b) distribution table requires 20% of the flaws to have depths between 10% and 30%.

Item 6 - Paragraph 2.0 first sentence states - The specimen inside surface and identification shall be concealed from the candidate.

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ENCLOSURE1 Item 7 - Paragraph 2.2(b) states in part - The regions containing a flaw to be sized shall be identified to the candidate.

Item 8 - Paragraph 2.2(c) states in part - For a separate length sizing test, the regions of each specimen containing a flaw to be sized shall be identified to the candidate.

Item 9 - Paragraph 2.3(a) states - For the depth sizing test, 80% of the flaws shall be sized at a specific location on the surface of the specimen identified to the candidate.

Item 10 - Paragraph 2.3(b) states - For the remaining flaws, the regions of each specimen containing a flaw to be sized shall be identified to the candidate. The candidate shall determine the maximum depth of the flaw in each region.

Item 11 - Table VII-S2-1 provides the false call criteria when the number of unflawed grading units is at least twice the number of flawed grading units.

RELIEF REQUESTED Relief is requested to use the following alternative requirements for implementation of Appendix VIII, Supplement 10 requirements. They will be implemented through the PDI Program.

A copy of the proposed revision to Supplement 10 is attached. It identifies the proposed alternatives and allows them to be viewed in context. It also identifies additional clarifications and enhancements for information. It has been submitted to the ASME Code Committee for consideration.

BASIS FOR RELIEF Item 1 - The proposed alternative to Paragraph 1.1(b) states:

"The specimen set shall include the minimum and maximum pipe diameters and thicknesses for which the examination procedure is applicable. Pipe diameters within a range of 1/2 in. (13 mm) of the nominal diameter shall be considered equivalent. Pipe diameters larger than 24 in. (610 mm) shall be considered to be flat. When a range of thicknesses is to be examined, a thickness tolerance of

+25% is acceptable."

Technical Basis - The change in the minimum pipe diameter tolerance from 0.9 times the diameter to the nominal diameter minus 0.5 inch provides tolerances more in line with industry practice. Though the alternative is less stringent for small pipe diameters they typically have a thinner wall thickness than larger 2 of 7

ENCLOSURE I diameter piping. A thinner wall thickness results in shorter sound path distances that reduce the detrimental effects of the curvature. This change maintains consistency between Supplement 10 and the recent revision to Supplement 2.

Item 2 - The proposed alternative to Paragraph 1.1(d) states:

"At least 60% of the flaws shall be cracks, the remainder shall be alternative flaws. Specimens with IGSCC shall be used when available.

Alternative flaws, if used, shall provide crack-like reflective characteristics and shall be limited to the case where implantation of cracks produces spurious reflectors that are uncharacteristic of actual flaws. Alternative flaw mechanisms shall have a tip width of less than or equal to 0.002 in.

(.05 mm). Note, to avoid confusion the proposed alternative modifies instances of the term "cracks" or "cracking" to the term "flaws" because of the use of alternative flaw mechanisms."

Technical Basis - As illustrated below, 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. In addition, it is important to preserve the dendritic structure present in field welds that would otherwise be destroyed by the implantation process. To resolve these issues, the proposed alternative allows the use of up to 40% fabricated flaws as an alternative flaw mechanism under controlled conditions. The fabricated flaws are isostatically compressed which produces ultrasonic reflective characteristics similar to tight cracks.

SMechanical fatigue crac[

.. Ato in Base matenal Item 3 - The proposed alternative to Paragraph 1.1 (d)(1) states:

"At least 80% of the flaws shall be contained wholly in weld or buttering material.

At least one and a maximum of 10% of the flaws shall be in ferritic base material. At least one and a maximum of 10% of the flaws shall be in austenitic base material."

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ENCLOSURE I Technical Basis - Under the current Code, as few as 25% of the flaws are contained in austenitic weld or buttering material. Recent experience has indicated that flaws contained within the weld are the likely scenarios. The metallurgical structure of austenitic weld material is ultrasonically more challenging than either ferritic or austenitic base material. The proposed alternative is therefore more challenging than the current Code.

Item 4 - The proposed alternative to Paragraph 1.2(b) states:

"Detection sets shall be selected from Table VIII-S10-1. The number of unflawed grading units shall be at least one and a half times the number of flawed grading units."

Technical Basis - Table S10-1 provides a statistically based ratio between the number of unflawed grading units and the number of flawed grading units. The proposed alternative reduces the ratio to 1.5 times to reduce the number of test samples to a more reasonable number from the human factors perspective.

However, the statistical basis used for screening personnel and procedures is still maintained at the same level with competent personnel being successful and less skilled personnel being unsuccessful. The acceptance criteria for the statistical basis are in Table VIII-S10-1.

Item 5 - The proposed alternative to the flaw distribution requirements of Paragraph 1.2(c)(1) (detection) and 1.3(c) (length) is to use the Paragraph 1.4(b)

(depth) distribution table (see below) for all qualifications.

Flaw Depth Minimum

(% Wall Thickness) Number of Flaws 10-30% 20%

31-60% 20%

61-100% 20%

In addition, the proposed alternative includes the following: "At least 75% of the flaws shall be in the range of 10 to 60% of wall thickness."

Technical Basis - The proposed alternative uses the depth sizing distribution for both detection and depth sizing because it provides for a better distribution of flaw sizes within the test set. This distribution allows candidates to perform detection, length, and depth sizing demonstrations simultaneously utilizing the same test set. The requirement that at least 75% of the flaws shall be in the range of 10 to 60% of wall thickness provides an overall distribution tolerance yet the distribution uncertainty decreases the possibilities for testmanship that would be inherent to a uniform distribution. It must be noted that it is possible to achieve 4 of 7

ENCLOSUREI the same distribution utilizing the present requirements, but it is preferable to make the criteria consistent.

Item 6 - The proposed alternative to Paragraph 2.0 first sentence states:

"For qualifications from the outside surface, the specimen inside surface and identification shall be concealed from the candidate. When qualifications are performed from the inside surface, the flaw location and specimen identification shall be obscured to maintain a "blind test"."

Technical Basis - The current Code requires that the inside surface be concealed from the candidate. This makes qualifications conducted from the inside of the pipe (e.g., PWR nozzle to safe end welds) impractical. The proposed alternative differentiates between ID and OD scanning surfaces, requires that they be conducted separately, and requires that flaws be concealed from the candidate.

This is consistent with the recent revision to Supplement 2.

Items 7 and 8 - The proposed alternatives to Paragraph 2.2(b) and 2.2(c) state:

"... containing a flaw to be sized may be identified to the candidate."

Technical Basis - The current Code requires that the regions of each specimen containing a flaw to be length sized shall be identified to the candidate. The candidate shall determine the length of the flaw in each region (Note, that length and depth sizing use the term "regions" while detection uses the term "grading units" - the two terms define different concepts and are not intended to be equal or interchangeable). To ensure security of the samples, the proposed alternative modifies the first "shall" to a "may" to allow the test administrator the option of not identifying specifically where a flaw is located. This is consistent with the recent revision to Supplement 2.

Items 9 and 10 - The proposed alternative to Paragraph 2.3(a) and 2.3(b) state:

"... regions of each specimen containing a flaw to be sized may be identified to the candidate."

Technical Basis - The current Code requires that a large number of flaws be sized at a specific location. The proposed alternative changes the "shall" to a "may" which modifies this from a specific area to a more generalized region to ensure security of samples. This is consistent with the recent revision to Supplement 2. It also incorporates terminology from length sizing for additional clarity.

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ENCLOSUREI Item 11 - The proposed alternative modifies the acceptance criteria of Table VIII S2-1 as follows:

TABLE VIII-S -1K PERFORMANCE DEMONSTRATION DETECTION TEST ACCEPTANCE CRITERIA Detection Test False Call Test Acceptance Critera Acceptance Criteria No. of No. of Maximum Flawed Minimum Unflawed Number Grading Detection Grading of False Units Criteria Units Calls S10 0 S6 12 1 7 6 14 1 7 16 2 9 7 18 2 10 8 2-o- 15 2 11 9 2e--17 3-- 3 12 9 24- 18 3- 3 13 10 26-20 4--3 14 10 28-- 21 5-- 3 15 11 0- 23 5- 3 16 12 3"2--24 6---4 17 12 34-26 6-4 18 13 36-27 7- 4 19 13 30-29 7-4 20 14 4-30 8-5 Technical Basis - The proposed alternative is identified as new Table S10-1 above. It was modified to reflect the reduced number of unflawed grading units and allowable false calls. As a part of ongoing Code activities, Pacific Northwest National Laboratory (PNNL) has reviewed the statistical significance of these revisions and offered the revised Table S1 0-1.

ALTERNATIVE EXAMINATION In lieu of the requirements of ASME Section XI, 1995 Edition, 1996 Addenda, Appendix VIII, Supplement 10, the proposed alternative shall be used. The proposed alternative is described in the attachment.

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ENCLOSURE I JUSTIFICATION FOR GRANTING RELIEF Pursuant to 10 CFR 50.55a(a)(3)(i), approval is requested to use the proposed alternatives described above in lieu of the ASME Section Xl, 1995 Edition, 1996 Addenda, Appendix VIII, Supplement 10 requirements. Compliance with the proposed alternatives will provide an adequate level of quality and safety for examination of the affected welds.

IMPLEMENTATION SCHEDULE The NRC is requested to approve this relief request to support the San Onofre Unit 3, Cycle 12 refueling outage, which is currently scheduled to begin on January 6, 2003.

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SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning 1.0 SCOPE Supplement 10 is applicable to dissimilar A scope statement provides added clarity metal piping welds examined from either regarding the applicable range of each the inside or outside surface. individual Supplement. The exclusion of Supplement 10 is not applicable to piping CRC provides consistency between welds containing supplemental corrosion Supplement 10 and the recent revision to resistant clad (CRC) applied to mitigate Supplement 2 (Reference BC 00-755).

Intergranular Stress Corrosion Cracking Note, an additional change identifying (IGSCC). CRC as "in course of preparation" is being processed separately.

1.0 SPECIMEN REQUIREMENTS 2.0 SPECIMEN REQUIREMENTS Renumbered Qualification test specimens shall meet Qualification test specimens shall meet the No Change the requirements listed herein, unless a requirements listed herein, unless a set of set of specimens is designed to specimens is designed to accommodate accommodate specific limitations stated in specific limitations stated in the scope of the the scope of the examination procedure examination procedure (e.g., pipe size, weld (e.g., pipe size, weld joint configuration, joint configuration, access limitations). The access limitations). The same specimens same specimens may be used to may be used to demonstrate both demonstrate both detection and sizing detection and sizing qualification, qualification.

1.1 General. The specimen set shall 2.1 General. The specimen set shall Renumbered conform to the following requirements. conform to the following requirements.

(a) The minimum number of flaws in a test New, changed minimum number of flaws set shall be ten. to 10 so sample set size for detection is consistent with length and depth sizing.

(a) Specimens shall have sufficient (b) Specimens shall have sufficient volume Renumbered volume to minimize spurious reflections to minimize spurious reflections that may that may interfere with the interpretation interfere with the interpretation process.

process. I Page 1 of 13 Enclosure 1, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (b) The specimen set shall include the (c) The specimen set shall include the Renumbered, metricated, the change in minimum and maximum pipe diameters minimum and maximum pipe diameters and pipe diameter tolerance provides and thicknesses for which the examination thicknesses for which the examination consistency between Supplement 10 and procedure is applicable. Pipe diameters procedure is applicable. Pipe diameters the recent revision to Supplement 2 within a range of 0.9 to 1.5 times a within a range of 1/2 in. (13 mm) of the (Reference BC 00-755) nominal diameter shall be considered nominal diameter shall be considered equivalent. Pipe diameters larger than equivalent. Pipe diameters larger than 24 in.

24 in. shall be considered to be flat. When (610 mm) shall be considered to be flat.

a range of thicknesses is to be examined, When a range of thicknesses is to be a thickness tolerance of +25% is examined, a thickness tolerance of +25% is acceptable. acceptable.

(c) The specimen set shall include (d) The specimen set shall include examples Renumbered, changed "condition" to examples of the following fabrication of the following fabrication conditions: conditions" condition:

(1) geometric conditions that normally (1) geometric and material conditions that Clarification, some of the items listed require discrimination from flaws (e.g., normally require discrimination from flaws relate to material conditions rather than counterbore or weld root conditions, (e.g., counterbore or weld root conditions, geometric conditions. Weld repair areas cladding, weld buttering, remnants of cladding, weld buttering, remnants of were added as a result of recent field previous welds, adjacent welds in close previous welds, adjacent welds in close experiences.

proximity); proximity, and weld repair areas);

(2) typical limited scanning surface (2) typical limited scanning surface Differentiates between ID and OD conditions (e.g., diametrical shrink, single- conditions (e.g., weld crowns, diametrical scanning surface limitations. Requires side access due to nozzle and safe end shrink, single-side access due to nozzle and that ID and OD qualifications be conducted external tapers). safe end external tapers for outside independently (Note, new paragraph 2.0 surface examinations; and internal (identical to old paragraph 1.0) provides tapers, exposed weld roots, and cladding for alternatives when "a set of specimens conditions for inside surface is designed to accommodate specific examinations). Qualification limitations stated in the scope of the requirements shall be satisfied separately examination procedure.").

for outside surface and inside surface examinations.

Page 2 of 13 Enclosure 1, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (d) All flaws in the specimen set shall be Deleted this requirement, because new cracks. paragraph 2.3 below provides for the use of "alternative flaws" in lieu of cracks.

(1) At least 50% of the cracks shall be in 2.2 Flaw Location. At least 80% of the Renumbered and re-titled. Flaw location austenitic material. At least 50% of the flaws shall be contained wholly in weld or percentages redistributed because field cracks in austenitic material shall be buttering material. At least one and a experience indicates that flaws contained contained wholly in weld or buttering maximum of 10% of the flaws shall be in in weld or buttering material are probable material. At least 10% of the cracks shall ferritic base material. At least one and a and represent the more stringent be in ferritic material. The remainder of maximum of 10% of the flaws shall be in ultrasonic detection scenario.

the cracks may be in either austenitic or austenitic base material.

ferritic material.

(2) At least 50% of the cracks in austenitic 2.3 Flaw Type. Renumbered and re-titled. Alternative base material shall be either IGSCC or (a) At least 60% of the flaws shall be flaws are required for placing axial flaws in thermal fatigue cracks. At least 50% of the cracks, the remainder shall be alternative the HAZ of the weld and other areas cracks in ferritic material shall be flaws. Specimens with IGSCC shall be where implantation of a crack produces mechanically or thermally induced fatigue used when available. Alternative flaws, if metallurgical conditions that result in an cracks. used, shall provide crack-like reflective unrealistic ultrasonic response. This is characteristics and shall be limited to the consistent with the recent revision to case where implantation of cracks Supplement 2 (Reference BC 00-755).

produces spurious reflectors that are uncharacteristic of actual flaws. The 40% limit on alternative flaws is Alternative flaw mechanisms shall have a needed to support the requirement for up tip width of less than or equal to 0.002 in. to 70% axial flaws. Metricated

(.05 mm).

(3) At least 50% of the cracks shall be (b) At least 50% of the flaws shall be Renumbered. Due to inclusion of coincident with areas described in (c) coincident with areas described in 2.1(d) "alternative flaws", use of "cracks" is no above, above, longer appropriate.

2.4 Flaw Depth. All flaw depths shall be Moved from old paragraph 1.3(c) and 1.4 greater than 10% of the nominal pipe wall and re-titled. Consistency between thickness. Flaw depths shall exceed the detection and sizing specimen set nominal clad thickness when placed in requirements (e.g., 20% vs. 1/3 flaw depth cladding, increments, e.g., original paragraph 1.3(c))

Page 3 of 13 Enclosure 1, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning Flaws in the sample set shall be distributed as follows:

Flaw Depth Minimum

(% Wall Thickness) Number of Flaws 10-30% 20%

31-60% 20%

61-100% 20%

At least 75% of the flaws shall be in the range of 10 to 60% of wall thickness.

1.2 Detection Specimens. The specimen Renumbered and re-titled and moved to set shall include detection specimens that paragraph 3.1(a). No other changes meet the following requirements.

(a) Specimens shall be divided into Renumbered to paragraph 3.1(a)(1).

grading units. Each grading unit shall No other changes.

include at least 3 in. of weld length. Ifa grading unit is designed to be unflawed, at least I in. of unflawed material shall exist on either side of the grading unit. The segment of weld length used in one grading unit shall not be used in another grading unit. Grading units need not be uniformly spaced around the pipe specimen.

(b) Detection sets shall be selected from Moved to new paragraph 3.1(a)(2).

Table VIII-S2-1. The number of unflawed grading units shall be at least twice the number of flawed grading units.

Page 4 of 13 Enclosure 1, Attachment

SUPPLEMENT 10- QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (c) Flawed grading units shall meet the Flaw depth requirements moved to new following criteria for flaw depth, paragraph 2.4, flaw orientation orientation, and type. requirements moved to new paragraph 2.5, flaw type requirements moved to new paragraph 2.3, "Flaw Type".

(1) All flaw depths shall be greater than Deleted, for consistency in sample sets the 10% of the nominal pipe wall thickness. At depth distribution is the same for detection least 1/3 of the flaws, rounded to the next and sizing.

higher whole number, shall have depths between 10% and 30% of the nominal pipe wall thickness. However, flaw depths shall exceed the nominal clad thickness when placed in cladding. At least 1/3 of the flaws, rounded to the next whole number, shall have depths greater than 30% of the nominal pipe wall thickness.

(2) At least 30% and no more than 70% of 2.5 Flaw Orientation. Note, this distribution is applicable for the flaws, rounded to the next higher (a) At least 30% and no more than 70% of detection and depth sizing. Paragraph whole number, shall be oriented axially. the flaws, rounded to the next higher whole 2.5(b)(1) requires that all length- sizing The remainder of the flaws shall be number, shall be oriented axially. The flaws be oriented circumferentially.

oriented circumferentially. remainder of the flaws shall be oriented circumferentially.

1.3 Length Sizing Specimens. The Renumbered and re-titled and moved to specimen set shall include length sizing new paragraph 3.2 specimens that meet the following requirements.

(a) All length sizing flaws shall be oriented Moved, included in new paragraph 3.2(a) circumferentially.

(b) The minimum number of flaws shall be Moved, included in new paragraph 2.1 ten. above Page 5 of 13 Enclosure 1,Attachment

SUPPLEMENT 10- QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Proposed Change Reasoning Current Requirement (c) All flaw depths shall be greater than Moved, included in new paragraph 2.4 10% of the nominal pipe wall thickness. At above after revision for consistency with least 1/3 of the flaws, rounded to the next detection distribution higher whole number, shall have depths between 10% and 30% of the nominal pipe wall thickness. However, flaw depth shall exceed the nominal clad thickness when placed in cladding. At least 1/3 of the flaws, rounded to the next whole number, shall have depths greater than 30% of the nominal pipe wall thickness.

1.4 Depth Sizing Specimens. The Moved, included in new paragraphs 2.1, specimen set shall include depth sizing 2.3, 2.4 specimens that meet the following requirements.

(a) The minimum number of flaws shall be Moved, included in new paragraph 2.1 ten.

(b) Flaws in the sample set shall not be Moved, potential conflict with old wholly contained within cladding and shall paragraph 1.2(c)(1); "However, flaw be distributed as follows: depths shall exceed the nominal clad thickness when placed in cladding.".

Revised for clarity and included in new paragraph 2.4 Flaw Depth Minimum Moved, included in paragraph 2.4 for

(% Wall Thickness) Number of Flaws consistent applicability to detection and 10-30% 20% sizing samples.

31-60% 20%

61-100% 20%

The remaining flaws shall be in any of the above categories.

Page 6 of 13 Enclosure 1, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (b) Sizing Specimen sets shall meet the Added for clarity following requirements.

(1) All length-sizing flaws shall be oriented Moved from old paragraph 1.3(a) circumferentially.

(2) Depth sizing flaws shall be oriented as Included for clarity. Previously addressed in 2.5(a). by omission (i.e., length, but not depth had a specific exclusionary statement) 2.0 CONDUCT OF PERFORMANCE 3.0 CONDUCT OF PERFORMANCE Renumbered DEMONSTRATION DEMONSTRATION The specimen inside surface and For qualifications from the outside Differentiate between qualifications identification shall be concealed from the surface, the specimen inside surface and conducted from the outside and inside candidate. All examinations shall be identification shall be concealed from the surface.

completed prior to grading the results and candidate. When qualifications are presenting the results to the candidate. performed from the inside surface, the Divulgence of particular specimen results flaw location and specimen identification or candidate viewing of unmasked shall be obscured to maintain a "blind specimens after the performance test". All examinations shall be completed demonstration is prohibited. prior to grading the results and presenting the results to the candidate. Divulgence of particular specimen results or candidate viewing of unmasked specimens after the performance demonstration is prohibited.

2.1 Detection Test. Flawed and unflawed 3.1 Detection Qualification. Renumbered, moved text to paragraph grading units shall be randomly mixed 3.1 (a)(3)

(a) The specimen set shall include detection Renumbered, moved from old paragraph specimens that meet the following 1.2.

requirements.

Page 7 of 13 Enclosure 1, Attachment

I SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (1) Specimens shall be divided into grading Renumbered, moved from old paragraph units. Each grading unit shall include at least 1.2(a). Metricated. No other changes.

3 in. (76 mm) of weld length. If a grading unit is designed to be unflawed, at least 1 in.

(25 mm) of unflawed material shall exist on either side of the grading unit. The segment of weld length used in one grading unit shall not be used in another grading unit. Grading units need not be uniformly spaced around the pipe specimen.

(2) Detection sets shall be selected from Moved from old paragraph 1.2(b). Table Table VIII-SIO-1. The number of unflawed revised to reflect a change in the minimum grading units shall be at least one and a half sample set to 10 and the application of times the number of flawed grading units. equivalent statistical false call parameters to the reduction in unflawed grading units.

Human factors due to large sample size.

(3) flawed and unflawed grading units shall Moved from old paragraph 2.1 be randomly mixed.

(b) Examination equipment and personnel Moved from old paragraph 3.1. Modified are qualified for detection when personnel to reflect the 100% detection acceptance demonstrations satisfy the acceptance criteria of procedures versus personnel criteria of Table VIII S10-1 for both detection and equipment contained in new and false calls. paragraph 4.0 and the use of 1.5X rather than 2X unflawed grading units contained in new paragraph 3.1(a)(2). Note, the modified table maintains the screening criteria of the original Table VIII-S2-1.

Page 8 of 13 Enclosure 1, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning 2.2 Length Sizing Test 3.2 Length Sizing Test Renumbered (a) The length sizing test may be (a) Each reported circumferential flaw in Provides consistency between conducted separately or in conjunction the detection test shall be length sized. Supplement 10 and the recent revision to with the detection test. Supplement 2 (Reference BC 00-755).

(b) When the length sizing test is (b) When the length sizing test is conducted Change made to ensure security of conducted in conjunction with the in conjunction with the detection test, and samples, consistent with the recent detection test, and less than ten less than ten circumferential flaws are revision to Supplement 2 (Reference BC circumferential flaws are detected, detected, additional specimens shall be 00-755).

additional specimens shall be provided to provided to the candidate such that at least the candidate such that at least ten flaws ten flaws are sized. The regions containing a Note, length and depth sizing use the term are sized. The regions containing a flaw to flaw to be sized may be identified to the "regions" while detection uses the term be sized shall be identified to the candidate. The candidate shall determine the "grading units". The two terms define candidate. The candidate shall determine length of the flaw in each region. different concepts and are not intended to the length of the flaw in each region. __ be equal or interchangeable.

(c) For a separate length sizing test, the (c) For a separate length sizing test, the Change made to ensure security of regions of each specimen containing a regions of each specimen containing a flaw samples, consistent with the recent flaw to be sized shall be identified to the to be sized may be identified to the revision to Supplement 2 (Reference BC candidate. The candidate shall determine candidate. The candidate shall determine the 00-755).

the length of the flaw in each region. length of the flaw in each region.

(d) Examination procedures, equipment, and Moved from old paragraph 3.2(a) includes personnel are qualified for length sizing inclusion of "when" as an editorial change.

when the RMS error of the flaw length Metricated.

measurements, as compared to the true flaw lengths, is less than or equal to 0.75 in.

(19 mm).

Page 9 of 13 Enclosure 1, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning 2.3 Depth Sizing Test 3.3 Depth Sizing Test Renumbered (a) For the depth sizing test, 80% of the (a) The depth sizing test may be Change made to ensure security of flaws shall be sized at a specific location conducted separately or in conjunction samples, consistent with the recent on the surface of the specimen identified with the detection test. For a separate revision to Supplement 2 (Reference BC to the candidate, depth sizing test, the regions of each 00-755).

specimen containing a flaw to be sized may be identified to the candidate. The candidate shall determine the maximum depth of the flaw in each region.

(b) For the remaining flaws, the regions of (b) When the depth sizing test is Change made to be consistent with the each specimen containing a flaw to be conducted in conjunction with the recent revision to Supplement 2 sized shall be identified to the candidate. detection test, and less than ten flaws are (Reference BC 00-755).

The candidate shall determine the detected, additional specimens shall be maximum depth of the flaw in each region. provided to the candidate such that at Changes made to ensure security of least ten flaws are sized. The regions of samples, consistent with the recent each specimen containing a flaw to be sized revision to Supplement 2 (Reference BC may be identified to the candidate. The 00-755).

candidate shall determine the maximum depth of the flaw in each region.

(c) Examination procedures, equipment, and Moved from old paragraph 3.2(b).

personnel are qualified for depth sizing when Metricated.

the RMS error of the flaw depth measurements, as compared to the true flaw depths, is less than or equal to 0.125 in. (3 mm).

Page 10 of 13 Enclosure 1, Attachment

SUPPLEMENT 10- QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning 3.0 ACCEPTANCE CRITERIA Delete as a separate category. Moved to new paragraph detection (3.1) and sizing 3.2 and 3.3 3.1 Detection Acceptance Criteria. Moved to new paragraph 3.1(b), reference Examination procedures, equipment, and changed to Table S10 from 82 because of personnel are qualified for detection when the change in the minimum number of the results of the performance flaws and the reduction in unflawed demonstration satisfy the acceptance grading units from 2X to 1.5X.

criteria of Table VIII-S2-1 for both detection and false calls.

3.2 Sizing Acceptance Criteria Deleted as a separate category. Moved to new paragraph on length 3.2 and depth 3.3 (a) Examination procedures, equipment, Moved to new paragraph 3.2(d), included and personnel are qualified for length word "when" as an editorial change.

sizing the RMS error of the flaw length measurements, as compared to the true flaw lengths, is less than or equal to 0.75 inch.

(b) Examination procedures, equipment, Moved to new paragraph 3.3(c) and personnel are qualified for depth sizing when the RMS error of the flaw depth measurements, as compared to the true flaw depths, is less than or equal to 0.125 in.

Page 11 of 13 Enclosure 1, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning 4.0 PROCEDURE QUALIFICATION New Procedure qualifications shall include the New. Based on experience gained in following additional requirements. conducting qualifications, the equivalent of (a) The specimen set shall include the 3 personnel sets (i.e., a minimum of 30 equivalent of at least three personnel sets. flaws) is required to provide enough flaws Successful personnel demonstrations to adequately test the capabilities of the may be combined to satisfy these procedure. Combining successful requirements. demonstrations allows a variety of (b) Detectability of all flaws within the examiners to be used to qualify the scope of the procedure shall be procedure. Detectability of each flaw demonstrated. Length and depth sizing within the scope of the procedure is shall meet the requirements of paragraph required to ensure an acceptable 3.2 and 3.3. personnel pass rate. The last sentence is (c) At least one successful personnel equivalent to the previous requirements demonstration has been performed. and is satisfactory for expanding the (d) To qualify new values of essential essential variables of a previously qualified variables, at least one personnel procedure qualification set is required.

Page 12 of 13 Enclosure 1, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning TABLE VIII-S -1" PERFORMANCE DEMONSTRATION DETECTION TEST ACCEPTANCE CRITERIA Detection Test False Call Test Acceptance Critera Acceptance Criteria No. of No. of Maximum Flawed Minimum Unflawed Number Grading Detection Grading of False Units Criteria Units Calls 5 5 10 t_6 121 v7 6 14 1 '

8 7 16 2 9 7 18 2 10 8 20- 15 3--2 11 9 n- 17 3-3 12 9 2+- 18 3--3 13 10 -- 20 4-3 14 10 28-21 5--3 15 11 30-23 5--3 16 12 3--24 6--.4 17 12 34- 26 6-4 18 13 36-27 7--4 19 13 H- 29 7--4 20 14 4-30 8--5 Page 13 of 13 Enclosure 1, Attachment

ENCLOSURE2 SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3 SECOND TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST B-2-07 SYSTEMICOMPONENT(S) FOR WHICH RELIEF IS REQUESTED ASME Code,Section XI, 1989 Edition, no Addenda, Class 1, Category B-J, Item Numbers B9.11 and B9.12, Pressure Retaining Piping Welds ultrasonically examined from the inside surface of Pressurized Water Reactors using procedures, personnel, and equipment qualified to ASME Section Xl, 1995 Edition, 1996 Addenda, Appendix VIII, Supplement 3 criteria.

CODE REQUIREMENTS Relief is requested from the qualification requirements for piping welds contained in Table Vi11-3110-1 of Appendix VIII to ASME Section Xl, 1995 Edition, 1996 Addenda, Supplement 3 criteria.

RELIEF REQUESTED Relief is requested to use the enclosed proposed alternative for implementation of Appendix VIII, Supplement 3, as coordinated with the proposed alternative for the Supplement 10 implementation program (Attachment to Enclosure 1 (RR-B-06)). The Performance Demonstration Initiative (PDI) will administer the alternative program.

BASIS FOR RELIEF Depending upon the particular design, the nozzle to main coolant piping may be fabricated using ferritic, austenitic, or cast stainless components and assembled using ferritic, austenitic, or dissimilar metal welds. Additionally, differing combinations of these assemblies may be in close proximity, which typically means the same ultrasonic essential variables are used for each weld and the most challenging ultrasonic examination process is employed (e.g., the ultrasonic examination process associated with a dissimilar metal weld would be applied to a ferritic or austenitic weld.) San Onofre Unit 3 is a Combustion Engineering (CE) designed plant, and the piping and welds connected to the reactor vessel are ferritic material with stainless steel clad. Attachment 1 provides the list and sketch of welds for which relief is requested.

Separate qualifications to Supplements 2, 3, and 10 are redundant when done in accordance with the PDI Program. For example, during a personnel qualification Page l of 3

Enclosure 2 to the PDI Program, the candidate would be exposed to a minimum of 10 flawed grading units for each individual supplement. Personnel qualification to Supplements 2, 3, and 10 would therefore require a total of 30 flawed grading units. Test sets this large and tests of this duration are impractical. Additionally, a full procedure qualification (i.e. 3 personnel qualifications) to the PDI Program requirements would require 90 flawed grading units. This is particularly burdensome for a procedure that will use the same essential variables or the same criteria for selecting essential variables for all 3 supplements.

To resolve these issues, the PDI Program recognizes the Supplement 10 qualification as the most stringent and technically challenging ultrasonic application. The essential variables used for the examination of Supplements 2, 3, and 10 are equivalent and a coordinated implementation would be sufficiently stringent to qualify all 3 Supplements if the requirements used to qualify Supplement 10 are satisfied as a prerequisite. The basis for this conclusion is the fact that the majority of the flaws in Supplement 10 are located wholly in austenitic weld material, which is known to be challenging for ultrasonic techniques due to the variable dendritic structure of the weld material. Flaws in Supplements 2 and 3 are located in fine-grained base materials, which are known to be less challenging.

Additionally, the proposed alternative is more stringent than current Code requirements for a detection and length sizing qualification. For example, the current Code would allow a detection procedure, personnel, and equipment to be qualified to Supplement 10 with 5 flaws, Supplement 2 with 5 flaws, and Supplement 3 with 5 flaws, a total of only 15 flaws. The proposed alternative of qualifying Supplement 10 using 10 flaws and adding on Supplement 2 with 5 flaws and Supplement 3 with 3 flaws results in a total of 18 flaws which will be multiplied by a factor of 3 for the procedure qualification.

Based on the above, the use of a limited number of Supplement 2 or 3 flaws is sufficient to access the capabilities of procedures and personnel who have already satisfied Supplement 10 requirements. The statistical basis used for screening personnel and procedures is still maintained at the same level with competent personnel being successful and less skilled personnel being unsuccessful. The proposed alternative is consistent with other coordinated qualifications currently contained in Appendix VIII.

The proposed alternate program is provided as Attachment 2 and is identified as Supplement 14. It has been submitted to the ASME Code Committee for consideration as new Supplement 14 to Appendix VIII.

Page 2 of 3

Enclosure 2 ALTERNATIVE EXAMINATION In lieu of the requirements of ASME Section XI, 1995 Edition, 1996 Addenda, Appendix VIII, Table VIII-3110-1, the Performance Demonstration Initiative (PDI)

Program for implementation of Appendix VIII, Supplement 3, as coordinated with the alternative PDI Supplement 10 implementation program shall be used (see the Attachment to Enclosure 1 (RR B-2-06)). The PDI Program alternative is described in Attachment 2.

JUSTIFICATION FOR GRANTING RELIEF Pursuant to 10 CFR 50.55a(a)(3)(i), approval is requested to use the proposed alternatives described above in lieu of the ASME Section Xl, Appendix VIII, Supplement 3, requirements. Compliance with the proposed alternatives will provide an adequate level of quality and safety for examination of the affected welds.

IMPLEMENTATION SCHEDULE The NRC is requested to approve this relief request to support the San Onofre Unit 3, Cycle 12 refueling outage, which is currently scheduled to begin on January 6, 2003.

Page 3 of 3

RELIEF REQUEST B-2-07 WELDS Code Class 1 Category B-J Pressure Retaining Welds in Piping Items B9. 11 Circumferential Welds Four (4) - 42" Dia. Circumferential Welds Twelve (12) - 30" Dia. Circumferential Welds B9.12 Longitudinal Welds Four (4) - Longitudinal Welds on 42" dia. pipe Sixteen (16) - Longitudinal Welds on 30" dia.

pipe No. ISI ID Description Category Item 1 03-001-033 Hot Leg Nozz-to-Ext Piece Weld B-J B9.11 03-001-034 Cold Leg Nozz-to-Ext Piece Weld B-J B9.11 2

03-001-035 Cold Leg Nozz-to-Ext Piece Weld B-J B9 11 3

03-001-036 Hot Leg Nozz-to-Ext Piece Weld B-J B9.11 4

5 03-001-037 Cold Leg Nozz-to-Ext Piece Weld B-J B9.11 03-001-038 Cold Leg Nozz-to-Ext Piece Weld B-J B9.11 6

03-006-005 Pipe Longitudinal Weld B-J B9.12 7

8 03-006-006 Pipe Longitudinal Weld B-J B9.12 03-006-007 Pipe-to-Outlet Nozz Ext Pc. Weld B-i B9.11 9

03-007-005 Pipe Longitudinal Weld B-J B9.12 10 11 03-007-006 Pipe Longitudinal Weld B-J B9.12 12 03-007-007 Pipe-to-Outlet Nozz Ext Pc Weld B-J B9.11 03-009-005 Pipe-to-Elbow Weld B-J B9.11 13 03-009-003 Pipe Longitudinal Weld B-J B9.12 14 03-009-004 Pipe Longitudinal Weld B-J B9.12 15 03-009-006 Elbow Longitudinal Weld B-J B9.12 16 Elbow Longitudinal Weld B-J B9.12 17 03-009-007 03-009-008 Elbow-to-Inlet Nozz Ext Pc. Weld B-J B9.11 18 03-011-005 Pipe-to-Elbow Weld B-J B9.11 19 03-011-003 Pipe Longitudinal Weld B-J B9 12 20 03-011-004 Pipe Longitudinal Weld B-J B9.12 21 03-011-006 Elbow Longitudinal Weld B-J B9.12 22 23 03-011-007 Elbow Longitudinal Weld B-J B9.12 03-011-008 Elbow-to-Inlet Nozz Ext Pc. Weld B-J B9.11 24 03-013-005 Pipe-to-Elbow Weld B-J B9 11 25 26 03-013-003 Pipe Longitudinal Weld B-J B9 12 03-013-004 Pipe Longitudinal Weld B-J B9.12 27 03-013-006 Elbow Longitudinal Weld B-J B9.12 28 03-013-007 Elbow Longitudinal Weld B-J B9.12 29 03-013-008 Elbow-to-Inlet Nozz Ext Pc. Weld B-J B9.11 30 03-015-005 Pipe-to-Elbow Weld B-J B9.11 31 03-015-003 Pipe Longitudinal Weld B-J B9.12 32 03-015-004 Pipe Longitudinal Weld B-J B9.12 33 03-015-006 Elbow Longitudinal Weld B-J B9.12 34 B9.12 35 03-015-007 Elbow Longitudinal Weld B-J 03-015-008 Elbow-to-Inlet Nozz Ext Pc. Weld B-J B9.11 36 ENCLOSURE 2, ATTACHMMENT I Page l of 2

FIGURE 1. RELIEF REQUEST B-2-07 WELDS ENCLOSURE 2, ATTACHMMENT I Page 2 of 2

SUPPLEMENT 14- QUALIFICATION REQUIREMENTS FOR COORDINATED SUPPLEMENT 2 AND 3 QUALIFICATION PERFORMED FROM THE INSIDE SURFACE Proposed Requirements Technical Basis 1.0 SCOPE Reasoning This Supplement provides requirements for There is currently no available Code action expansion of Supplement 10 procedure, allowing for a coordinated implementation equipment, and personnel inside surface of the fundamental qualifications required qualifications with add-ons of Supplements for the typical examinations performed 2 and 3 qualifications. The same ultrasonic from the IDof PWR nozzles. Without this essential variables values, or, when Code Case/Change, qualifications would appropriate, the same criteria for selecting require an excessive amount of flawed and values as demonstrated in Supplement 10 unflawed grading units. This proposed shall be used. This Supplement is supplement uses the more technically applicable to examinations conducted from stringent Supplement 10 qualification as a the inside surface. base and then incorporates a limited number of Supplement 2 and Supplement 3 samples. This proposal is consistent with the philosophy of Supplement 12, the proposed changes to Supplement 10, and the approved changes to Supplement 2 and 11.

2.0 SPECIMEN REQUIREMENTS 2.1 General Qualification test specimens shall meet the 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, access limitations). The same specimens may be used to demonstrate both detection and sizing qualification. The specimen sets shall conform to the followinq requirements. V -1 (a) Specimens shall have sufficient volume to minimize spurious reflections that may interfere with the interpretation process. -L (b) The specimen set shall include the This criteria is consistent with minimum and maximum pipe diameters Supplement 10.

and thicknesses for which the examination procedure is applicable. Pipe diameters within 1/2 in. (13 mm) of the nominal diameter shall be considered equivalent.

Pipe diameters larger than 24 in. (610 mm) shall be considered to be flat. When a range of thicknesses is to be examined, a thickness tolerance of + 25% is acceptable.

ENCLOSURE 2, ATTACHMMENT 2 Page I of 5

SUPPLEMENT 14- QUALIFICATION REQUIREMENTS FOR COORDINATED SUPPLEMENT 2 AND 3 QUALIFICATION PERFORMED FROM THE INSIDE SURFACE Proposed Requirements Technical Basis (c) The specimen set shall include examples of the following fabrication conditions:

(1) geometric and material conditions that normally require discrimination from flaws (e.g., counterbore or weld root conditions, cladding, weld buttering, remnants of previous welds, adjacent welds in close proximity, and weld repair areas);

(2) typical limited scanning surface conditions (e.g., internal tapers, exposed weld roots, and cladding conditions).

2.2 At least 70% of the Supplement 2 flaws shall be cracks, the remainder shall be alternative flaws. Specimens with IGSCC shall be used when available Alternative flaws, if used, shall provide crack-like reflective characteristics and shall be limited to the case where implantation of cracks produces spurious reflectors that are uncharacteristic of actual flaws.

Alternative flaw mechanisms shall have a tip width of less than or equal to 0.002 in.

(0.05 mm).

2.3 Supplement 3 flaws shall be mechanical or thermal fatigue cracks.

2.4 The specimen set shall contain a Since the number of flaws will be limited representative distribution of flaws. Flawed words such as "uniform distribution" could and unflawed grading units shall be lead to testmanship and are considered randomly mixed. inappropriate.

3.0 CONDUCT OF PERFORMANCE DEMONSTRATION The flaw location and specimen identification shall be obscured to maintain a "blind test". All examinations shall be completed prior to grading the results and presenting the results to the candidate.

Divulgence of particular specimen results or candidate viewing of unmasked specimens after the performance demonstration is prohibited. -j ENCLOSURE 2, ATTACHMMENT 2 Page 2 of 5

SUPPLEMENT 14 - QUALIFICATION REQUIREMENTS FOR COORDINATED SUPPLEMENT 2 AND 3 QUALIFICATION PERFORMED FROM THE INSIDE SURFACE Proposed Requirements Technical Basis 4.0 DETECTION QUALIFICATION The coordinated implementation shall include the following requirements for personnel detection qualification.

4.1 The specimen set for Supplement 2 qualification shall include at least five flawed grading units and ten unflawed grading units in austenitic piping. A maximum of one flaw shall be oriented axially.

4.2 The specimen set for Supplement 3 qualification shall include at least three flawed grading units and six unflawed grading units in ferritic piping. A maximum of one flaw shall be oriented axially.

4.3 Specimens shall be divided into grading units. Each grading unit shall include at least 3 in. (76 mm) of weld length. Ifa grading unit is designed to be unflawed, at least I in. (25 mm) of unflawed material shall exist on either side of the grading unit.

The segment of weld length used in one grading unit shall not be used in another grading unit. Grading units need not be uniformly spaced around the pipe specimen. 1.

4.4 All grading units shall be correctly identified as being either flawed or unflawed.

5.0 LENGTH SIZING QUALIFICATION -i The coordinated implementation shall include the following requirements for nersonnel lenath sizina aualification.

5.1 The specimen set for Supplement 2 Axial flaws are not length sized in qualification shall include at least four flaws Supplement 2.

in austenitic material.

5.2 The specimen set for Supplement 3 qualification shall include at least three flaws in ferritic material.

ENCLOSURE 2, ATTACHMMENT 2 Page 3 of 5

SUPPLEMENT 14- QUALIFICATION REQUIREMENTS FOR COORDINATED SUPPLEMENT 2 AND 3 QUALIFICATION PERFORMED FROM THE INSIDE SURFACE Proposed Requirements Technical Basis 5.3 Each reported circumferential flaw in the detection test shall be length sized.

When only length sizing is being tested, the regions of each specimen containing a flaw to be sized may be identified to the candidate. The candidate shall determine the length of the flaw in each region.

5.4 Supplement 2 examination procedures, equipment, and personnel are qualified for length sizing when the flaw lengths estimated by ultrasonics, as compared with the true lengths, does not exceed 0.75 in. (19 mm) RMS when they are combined with a successful Supplement 10 qualification.

5.5 Supplement 3 examination procedures, equipment, and personnel are qualified for length sizing when the flaw lengths estimated by ultrasonics, as compared with the true lengths, does not exceed 0.75 in. (19 mm) RMS when they are combined with a successful Supplement 10 qualification.

6.0 DEPTH SIZING QUALIFICATION The coordinated implementation shall include the following requirements for personnel depth sizing qualification.

6.1 The specimen set for Supplement 2 Axial flaws are not depth sized in qualification shall include at least four Supplement 2.

circumferentially oriented flaws in austenitic material.

6.2 The specimen set for Supplement 3 qualification shall include at least three flaws in ferritic material.

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

ENCLOSURE 2, ATTACHMMENT 2 Page 4 of 5

SUPPLEMENT 14- QUALIFICATION REQUIREMENTS FOR COORDINATED SUPPLEMENT 2 AND 3 QUALIFICATION PERFORMED FROM THE INSIDE SURFACE Proposed Requirements T Technical Basis 6.4 Supplement 2 examination procedures, equipment, and personnel are qualified for depth sizing when the flaw depths estimated by ultrasonics, as compared with the true depths, does not exceed 0.125 in. (3 mm) RMS when they are combined with a successful Supplement 10 qualification.

6.5 Supplement 3 examination procedures, equipment, and personnel are qualified for depth sizing when the flaw depths estimated by ultrasonics, as compared with the true depths, does not exceed 0.125 in. (3 mm) RMS when they are combined with a successful Supplement 10 qualification.

7.0 PROCEDURE QUALIFICATION Procedure qualifications shall include the following additional requirements.

(a) The specimen set shall include the equivalent of at least three personnel sets.

Successful personnel demonstrations may be combined to satisfy these requirements.

(b) Detectability of all flaws within the scope of the procedure shall be demonstrated. Length and depth sizing shall meet the requirements of paragraph 5.0 and 6.0.

(c) At least one successful personnel demonstration has been performed.

(d) To qualify new values of essential variables, at least one personnel qualification set is required.

ENCLOSURE 2, ATTACHMMENT 2 Page 5 of 5