ML030990328
| ML030990328 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 04/01/2003 |
| From: | Wanczyk R Entergy Nuclear Operations, Entergy Nuclear Vermont Yankee |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BVY 03-28 | |
| Download: ML030990328 (92) | |
Text
Docket No. 50-271 BVY 03-28 Attachment I Vermont Yankee Nuclear Power Station Fourth-Interval Inservice Inspection Program Plan, Fourth-Interval Inservice Inspection Pressure Test Program and Request for Approval of ISI Relief Requests List of Commitments
SUMMARY
OF VERMONT YANKEE COMMITMENTS BVY NO.: 03-28 The following table identifies commitments made in this document by Vermont Yankee. Any other actions discussed in the submittal represent intended or planned actions by Vermont Yankee. They are described to the NRC for the NRC's information and are not regulatory commitments. Please notify the Licensing Manager of any questions regarding this document or any associated commitments.
COMMITMENT COMMITTED DATE l_ OR "OUTAGE" None N/A I _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Docket No. 50-271 BVY 03-28 Attachment 2 Vermont Yankee Nuclear Power Station Fourth-Interval Inservice Inspection Program Plan, Fourth-Interval Inservice Inspection Pressure Test Program and Request for Approval of ISI Relief Requests ISI Program Plan
VERMONT YANKEE NUCLEAR POWER STATION
,1~i?. J .X. XPROGRAM PROCEDURE W ,' _
PP 7015 REVISION 3 VERMONT YANKEE INSERVICE INSPECTION PROGRAM USE CLASSIFICATION: INFORMATION LPC Effective Affected Pages No. Date Implementation Statement: Due to the extent of the changes in this revision, no revision bars have been used.
Issue Date:
PP 7015 Rev. 3 Page 1 of 24
TABLE OF CONTENTS 1.0 PURPOSE, SCOPE, AND DISCUSSION ................................ 3 2.0 DEFINITIONS. 9 3.0 PRIMARY RESPONSIBILITIES. 9 4.0 PROCEDURE ................................ 13 4.1. Class 1 Scope, Examination Requirements, and Exemptions .13 4.2. Class 2 Scope, Examination Requirements, and Exemptions .15 4.3. Class 3 Scope, Examination Requirements, and Exemptions .16 4.4. Component Supports Scope, Examination Requirements, and Exemptions .17 4.5. Successive Inspections (Follow-up Examinations) .19 4.6. Additional Examinations (Expansions) .20 4.7. Implementing Procedures and Documents .20
5.0 REFERENCES
AND COMMITMENTS .. ............................. 22 6.0 FINAL CONDITIONS .............................. 23 7.0 ATTACHMENTS .............................. 24 PP 7015 Rev. 3 Page 2 of 24
1.0 PURPOSE, SCOPE, AND DISCUSSION 1.1. Purpose The purpose of the Entergy Nuclear Vermont Yankee Inservice Inspection (ENVYISI) Program Procedure is to identify safety class systems, sub-systems, and components required to be examined, outline the examination requirements, and increase or expand examination scope as required such that the requirements of 10CFR50.55a are satisfied.
1.2. Scope The scope of this procedure is to identify, plan, and schedule components for examination as required by the Code of Federal Regulations, 10CFR50.55a and the ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda. This program procedure scope does not include the examination requirements for metal containment (Subsection IWE), which are found in PP 7024, reactor internals (Subsection IWB, Categories B-N-1 and B-N-2), which are found in PP 7027 and pressure testing (Subsections IWB, Category B-P, IWC, Category C-H, Subsection IWD, Category D-B, and Articles IWX-5000), which are found in PP 7034. Inservice Testing requirements are controlled by the IST Program Procedure. The scope of this program procedure is focused on the requirements of ASME Section XI, Subsections IWA, IWB, IWC, IWD, and IWF. Appendix A contains relief requests that address alternative examination requirements.
1.3. Discussion
Background:
Vermont Yankee is a General Electric designed 1593 Mwt boiling water reactor (BWR) power plant built in accordance with the ANSI B31.1 Construction Code, 1967 Edition. The safety class boundaries used by this program are based on the assignment of safety classifications as designated in the VY Safety Classification Manual. The primary reference document for the Safety Classification Manual is ANS-22, Draft 4, Revision 1.
The ENVY ISI Program is designed to ensure that the structural integrity of all Class 1, 2, and 3 systems and associated supports are maintained at the level required by the Code of Federal Regulations, 10CFR50.55a, and augmented by the ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda. A preservice, or baseline, inspection of program components was performed to assure freedom from defects greater than code-allowable. This baseline data also provides a basis for evaluating subsequent inspection results. Since plant startup, additional inspection criteria for Class 2 and 3 components have been imposed by the Code of Federal Regulations, 10CFR50.55a for which baseline data has also been obtained.
Current results are compared, as appropriate, to baseline data, other previous test results, and acceptance criteria of the ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda, for evaluation of any evidence of degradation.
PP 7015 Rev. 3 Page 3 of 24
Vermont Yankee utilizes Inspection Program B for schedule determination of all components requiring inspection per Subsections IWB, IWC, IWD and IWF.
All inspection results, associated procedures and documentation, and calibration standards are maintained on-site for the life of the plant.
Governing Codes The fourth interval inservice inspection (ISI) requirements are outlined in this program procedure. The requirements of Title 10 Code of Federal Regulations, Part 50, Section 50.55a, Codes and Standards (IOCFR50.55a), and, by reference, the American Society for Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," are satisfied in this program procedure. The Code Edition and Addenda used for the Fourth Interval is the 1998 Edition with 2000 Addenda as addressed by Relief Request ISI-01.
Code Cases This program incorporates alternative inspection and examination requirements for components governed by certain Code Cases as outlined in Regulatory Guide 1.147 Revision 13. In particular, this program utilizes the alternative requirements of the following Code Cases:
N-460, Alternative Examination Coverage for Class 1 and 2 Welds N-526, Alternative Requirements for Successive Inspections of Class 1 and 2 Vessels N-532, Alternative Requirements to Repair and Replacement Documentation Requirements and Inservice Summary Report Preparation and Submission as Required by IWA-4000 and IWA-6000 N-552, Alternative Methods - Qualifications for Nozzle Inside Radius Section from the Outside Surface N-629, Use of Fracture Toughness Test Data to Establish Reference Temperature for Pressure Retaining Materials This program also incorporates alternative inspection and examination requirements for components governed by the following Code Cases for which relief has been sought from the USNRC:
N-560, Alternative Examination Requirements for Class 1, Category B-J Piping Welds N-613, Ultrasonic Examination of Full Penetration Nozzles in Vessels, Examination Category B-D, Item Nos. B3.10 and B3.90, Reactor Vessel-to-Nozzle Welds, Fig. IWB-2500-7(a), (b),
and (c)
PP 7015 Rev. 3 Page 4 of 24
N-652, Alternative Requirements to Categories B-G-1, B-G-2, and C-D Bolting Examination Methods and Selection Criteria N-663, Alternative Requirements for Class 1 and 2 Surface Examinations Specific requirements relative to these Code Cases have been incorporated into applicable implementing procedures and the requirements provided in Table 8, the ISI Database.
Requests for Relief The below listed Requests for Relief from existing regulatory requirements are part of this Program:
ISI-01) Not utilized ISI-02) Use of Code Case N-560 as an alternative to ASME Section MI, Category B-J for Examination of Piping Welds ISI-03) Use of Code Case N-652 as an alternative to ASME Section XI, Categories B-G-1, B-G-2, and C-D for Examination of Bolting ISI-04) Use of N-663 as an alternative to ASME Section Xl, Class 1, Categories B-F, C-F-1, and C-F-2 for Surface Examinations ISI-05) Alternative Requirements to ASME Section XI, Appendix VII, Supplement 10 for Examination of Dissimilar Metal Welds ISI-06) On hold ISI-07) Use of BWRVIP-75 as an alternative to GL 88-01 for Frequency of Overlay Examinations ISI-08) Use of RMS for Grading Purposes as an alternative to ASME Section XI, Appendix VIII, Supplement 4, Paragraph 3.2.c for Examination of RPV Shell Welds ISI-09) Use of Code Case N-613 as an alternative to ASME Section XI, Appendix VIII, Supplement 7 for Examination of RPV Nozzle-to-Shell Welds ISI-010) Alternative Requirements to ASME Section XI, Appendix VIII, Supplement 11 for Examination of Overlaid Piping ISI-01 1) Use of Appendix VIII of ASME Section XI, as modified by 10CFR50.55a(b)(2),
for Examination of RPV Flange-to-Shell Weld PP 7015 Rev. 3 Page 5 of 24
NRC Commitments The following items constitute commitments to NRC that are not addressed by customary regulatory documents:
- 1. BVY 2001-002_03, "Perform Ultrasonic Inspections of Feedwater Nozzles In Accordance With GE-NE-523-A71-0594, Revision 1" Interval Schedule:
The fourth inspection interval for VY began on September 1, 2003 and extends to August 31, 2013. Schedule 1, below outlines the inspection interval dates as well as the starting and ending dates of each period within the intervals. VY's ISI Program is based on ASME Inspection Program B (IWA-2432), which has four 10-year inspection intervals.
Schedule 1:
Period 1I Period 22 II Period II Period Period 3 i
Interval 1 On-line Dec. 1, 1972' To April 30, 19832 May 1, 1983 Sept. 1, 1986 Sept. 1990 Interval 2 To To To Aug. 31, 19863 Aug. 31, 1990 Aug. 31, 1993 Sept. 1, 1993 Sept. 1, 1996 Sept. 1, 2000 Interval 3 To To To Aug. 31, 19964 Aug. 31, 2000 Aug. 31, 2003 Sept. 1, 2003 Sept. 1, 2006 Sept. 1, 2010 Interval 4 To To To Aug. 31, 2006 Aug. 31, 2010 Aug. 31, 20134 Notes:
1 The 15t Interval was five years long, due to the delay in the development and implementation of ASME Section XI.
2 The end date of the 1 5t Interval was extended by five months, in accordance with IWA-2430(c), to permit inspections concurrent with a plant refueling outage.
Consequently, all subsequent intervals were adjusted back (later) five months.
3 In the 2 nd Interval, the end date of Period 1 was extended by four months to reflect the 1985-86 pipe replacement/refueling outage (nine months duration), in accordance with IWA-2430(e). Consequently, all subsequent intervals were adjusted back (later) four months.
4 Vermont Yankee's operating license expires March 21, 2012.
PP 7015 Rev. 3 Page 6 of 24
Components scheduled by percentage to complete for each period in the 4th Interval are given below:
Code Scheduled Components and Percentages by Period Category Total Period Percentage Period Percentage Ped ercentage Shdld 1 Min. =16% 2 Min = 50% 3 Min.
100%=
Scheduled 1 Max. = 50% Max. = 75%
B-A 28 9 32% 11 71% 8 100%
B-D 58 18 31% 24 72% 16 100%
B-F 23 8 35% 7 54% 8 100%
B-G-1 208 44 21% 88 63% 76 100%
B-G-2 135 Performed when disassembled 100%
B-J 65 22 34% 24 71% 19 100%
B-K 3 1 33% 1 67% 1 100%
B-L-2 2 Performed when disassembled 100%
B-M-2 43 Performed when disassembled 100%
B-O 6 2 33% 2 67% 2 100%
C-A 4 1 25% 2 50% 1 100%
C-B 2 1 50% 0 50% 1 100%
C-C 5 1 17% 3 67% 1 100%
C-F-2 63 22 35% 23 71% 18 100%
D-A 10 2 20% 4 60% 4 100%
F-A 109 37 34% 45 75% 27 100%
ISI Program Revisions Revisions to the ISI Program shall be implemented to reflect changes in code requirements (additions or reductions in scope), augmented exams, or regulatory requirements. Changes will be initiated by the Inservice Inspection Program Coordinator (ISIPC) or designee. When additions or deletions to the Program are identified, they shall be promptly revised to reflect the current requirements. Revisions shall be processed in accordance with the requirements of AP 0095, Plant Procedures.
PP 7015 Rev. 3 Page 7 of 24
Drawing Revisions:
The ISI drawings are coordinated to the Vermont Yankee seismic isometric drawings and controlled by AP 6802. Both drawings are very similar in content, however, different information is contained on each. The ISI drawings contain information specific to the ISI program, such as component numbers, support identification numbers, weld locations, etc.
When the seismic isometric drawings are revised for design changes, corrective update, or for any other reason, the companion ISI drawings are flagged for revision, and revised as necessary.
This ensures that the ISI drawings remain accurate and updated.
Summary of Organizational Responsibilities:
The ISI Program is organized under the System Engineering Department, Code Programs Group.
The Inservice Inspection Program Coordinator (ISIPC) is the designated owner and central information point regarding ISL. The ISIPC reports to the System Engineering Programs Supervisor (SEPS). The ISIPC shall report any examination results that could have an adverse affect on plant equipment or operation. The SEPS will keep Plant Management informed of examination progress, discrepancies, or any other aspects related to ISL. Design Engineering will support the ISI Program, as necessary, to evaluate and make recommendations on examination discrepancies. QAD is responsible for periodically auditing the ISI Program for code compliance and adherence.
Plant procedures, i.e. AP 0048, AP 0021, AP 0070, OP 4101, can affect and implement portions of this program as reflected in each procedure. The EMPAC data base identifies equipment and components to which ASME Section XI, ISI applies and is utilized to determine if the requirements of this program apply.
PP 7015 Rev. 3 Page 8 of 24
2.0 DEFINITIONS 2.1. Authorized Nuclear Inservice Inspector - a person who is employed and has been qualified by an Authorized Inspection Agency to verify that examinations, test, and repairs are performed in accordance with the rules and requirements of Section XI.
2.2. Component - an item in a nuclear power plant such as a vessel, pump, valve, piping system, or component support.
2.3. Evaluation - the process of determining the significance of examination or test results, including the comparison of examination or test results with applicable acceptance criteria or previous results.
2.4. Examination Category - a grouping of items to be examined or tested.
2.5. Inservice Inspection - methods and actions for assuring the structural and pressure-retaining integrity of safety-related nuclear power plant components in accordance with Section XI.
2.6. Inspection Program - the plan and schedule for performing examinations or tests.
2.7. Nondestructive Examination - an examination by the visual, surface, or volumetric method.
3.0 PRIMARY RESPONSIBILITIES 3.1. Inservice Inspection Program Coordinator (ISIPC) Responsibilities NOTE At the discretion of the SEPS, selected ISIPC responsibilities may be delegated to qualified Entergy or contracted personnel.
The detailed responsibilities of the ISIPC are as follows:
3.1.1. Provide for overall maintenance, review and coordination of the ISI Program.
3.1.2. Review the Examination procedures for compliance with regards to the applicable edition of ASME section XI and Plant Tech. Specs.
3.1.3. Prepare the ISI Program per applicable regulatory requirements and Plant Technical Specifications. This shall include planning and scheduling of the ISI efforts.
3.1.4. Ensure components scheduled for examination are properly prepared and accessible.
3.1.5. Ensure components examined are properly restored.
PP 7015 Rev. 3 Page 9 of 24
3.1.6. Interface with the cognizant department, as needed, to ensure all repair/replacement ISI examination requirements are satisfied.
3.1.7. Ensure the ISI records are permanently stored per AP 6807, Collection, Temporary Storage and Retrieval of QA Records.
3.1.8. Prepare and submit the NIS-1 Summary Report to the regulatory authorities and answer all inquiries.
3.1.9. Keep the SEPS informed on the progress of the ISI task(s).
3.1.10. Ensure changes or additions to Class 1, Class 2, and Class 3 pressure boundaries and component support classifications are incorporated into the ISI Program.
3.1.11. Review design changes and maintenance documents, as necessary, to assess the impact of the proposed task upon the ISI Program, and recommend action when appropriate.
3.1.12. Review outstanding AP 0028 commitment items prior to each outage and the end of each 10-yr ISI interval.
NOTE Unacceptable inspection results shall be reported to the ISIPC by the examination agency or cognizant department for resolution. The Authorized Nuclear Inservice Inspector (ANII) shall be informed of the resolution.
3.1.13. Determine any additional examinations made necessary by discovery of unacceptable indications during scheduled inspections in accordance with DP 4027.
3.1.14. Periodically review each Relief Request for continued applicability.
3.1.15. Provide technical advice on all aspects of the program.
3.1.16. Arrange for on-site services as requested by the Level III.
3.1.17. Prepare diagrams or drawings delineating the scope of the ISI Program.
3.1.18. Ensure that cognizant departments are informed of unacceptable conditions to facilitate completion of appropriate paperwork (ERs, WRs, etc.).
3.1.19. Ensure that the ISI Examination Database (Table 8) is properly maintained.
3.1.20. Maintain a history of all ISI examinations (scheduled and unscheduled).
PP 7015 Rev. 3 Page 10 of 24
3.1.21. Maintain the calibration blocks, examination tool(s), and their associated documentation. The calibration blocks (with a few exceptions due to size) are stored in locked cabinets located in the Reactor Building and are maintained for the life of the plant. The examination tools are also stored in secured lockers.
3.2. NDE Level III/ISI Supervisor The detailed responsibilities of the contracted Level III/ISI Supervisor are as follows:
3.2.1. Review the ISI Program for compliance to the applicable edition and addenda of ASME section XI and the Plant Tech. Specs.
3.2.2. Initiate changes to ISI Program and Examination procedures, as necessary, to ensure code compliance is maintained.
3.2.3. Ensure appropriate selection of Examination Personnel.
3.2.4. Review and ensure all NDE Personnel qualifications are current.
3.2.5. Ensure ANII has reviewed all NDE procedures and personnel qualifications, and any other applicable ASME Section XI documents.
3.2.6. Resolve any ANII comments regarding review of NDE procedures, personnel qualifications, or other ASME Section XI related issues as applicable.
3.2.7. Oversee NDE personnel indoctrination and performance demonstration.
3.2.8. Advise ISIPC of scheduling conflicts, staffing needs, and resource availability.
3.2.9. Review all NDE documentation to ensure ISI examinations have been properly documented.
3.2.10. Provide input, as necessary, to the ISIPC and Design Engineering regarding examination findings.
3.2.11. Provide input, as necessary, to aid in completion of the Summary Report (NIS-1).
3.2.12. Notify the ISIPC of any unacceptable inspection results in a timely manner.
PP 7015 Rev. 3 Page 11 of 24
3.3. Quality Assurance Department (QAD)
The detailed responsibilities of the QAD are as follows:
3.3.1. Surveillance of documentation pertinent to the Inservice Inspection and Test Program.
3.4. Examination Agency The examination agency shall provide NDE personnel as specified in the specific purchase order.
3.5. Design Engineering Design Engineering will support the ISI Program, as needed, by evaluating unacceptable examination results. The specific task(s) associated with evaluating the examination results and the specific duties of the Design Engineer are outlined in DP 4027.
3.6. Maintenance Department Perform Visual, or Surface examination requirements of this procedure as they pertain to repairs and replacement activities and as may be required for specific work activities.
3.7. RIMS Ensure the ISI records are permanently stored and available for the plant lifetime.
PP 7015 Rev. 3 Page 12 of 24
4.0 PROCEDURE 4.1. Class 1 Scope, Examination Requirements, and Exemptions
4.1.1. Scope
4.1.1.1. All Class 1 pressure retaining components and their welded attachments are included in the inspection program, except for those items exempted from examination by ASME Section XI, 1989 Edition, no addenda, Subsection IWB, Article JWB-1000, paragraph IWB-1220. For Class 1 components, Appendix B, Table 1 identifies: the code categories, the code item numbers, the number of components scheduled for examination within each code category and item, and notes clarifying various code requirements. Unique Feedwater Nozzle Inner Radius examination requirements are addressed in paragraph 4.1.2.2 below.
4.1.2. Examination Requirements:
4.1.2.1. Examination and schedule requirements are identified for Class 1 components in Appendix C, Table 5.
4.1.2.2. Feedwater nozzle inner radius examinations as required by Code Category B-D shall be performed in accordance with VY Calculation VYC-1005, Revision 1 and GE Nuclear Energy document GE-NE-523-A71-0594-A, Revision 1, DRF 137-0010-7 Class II, May 2000, entitled "Alternate BWR Feedwater Nozzle Inspection Requirements." (BVY 2001-002_03) 4.1.2.3. Magnetic particle and liquid penetrant examinations may be used interchangeably without revision to this program for ferritic steel components requiring surface exams (reference ASME Section XI, subsection IWA, paragraph IWA-2220).
4.1.2.4. Category B-J piping welds are selected and examined in accordance with Code Case N-560 and Relief Request ISI-02.
4.1.2.5. Categories B-G-1 and B-G-2 bolting selection and examinations are performed in accordance with Code Case N-652 and Relief Request ISI-03.
4.1.2.6. Surface examinations for Category B-F dissimilar-metal piping welds are selected and examined in accordance with Code Case N-663 and Relief Request ISI-04.
4.1.2.7. Category B-A, Code Item No. B 1.l 1 reactor vessel circumferential shell welds are selected and examined in accordance with Relief Request ISI-06.
PP 7015 Rev. 3 Page 13 of 24
4.1.2.8. The core spray overlays (Category B-F - GL 88-01 Category E) are selected and examined in accordance with Relief Request ISI-07.
4.1.2.9. Category B-D reactor vessel nozzle-to-shell welds are examined in accordance with Code Case N-613 and Relief Request ISI-09.
4.1.3. Exemptions
4.1.3.1. Exemptions are in accordance with ASME Section XI, 1989 Edition, no addenda, Subsection IWB, Article IWB-1000, paragraph IWB-1220.
Selected specific exemptions are identified in paragraphs 4.1.3.2 through 4.1.3.3 below.
4.1.3.2. ASME Section XI, subsection IWB, paragraph IWB-1220(a) exempts Class 1 components connected to the reactor coolant system, that are of size and shape such that a postulated rupture is within the capacity of the make-up systems. Vermont Yankee Calculation No. VYC-1 118 justifies exempting the following components by determining that a line break on a 1.455" ID pipe for saturated water or on a 2.375" ID pipe for saturated steam could be made up by systems operable from on-site emergency power. The following pipe lines are exempted:
- 2" head vent line off the N7 reactor nozzle (nominal 1.687" ID steam)
- 2" MSD2A, B, C, and D main steam drain lines (nominal 1.687" ID steam)
- 1.5" MSD420, MSD421, MSD422 main steam drain lines (nominal 1.338" ID steam)
- 1.5" reactor vessel instrumentation lines off the NI lA, N 1B, N12A, and N12B nozzles (nominal 1.338" ID water) 4.1.3.3. ASME Section XI, subsection IWB, paragraph IWB-1220(c) exempts vessel head connection 2 inch N.P.S. and smaller made inaccessible due to control rod drive penetrations. Thus, vessel drain nozzle, N15, and piping welds, CU400-F1 (terminal end), CU400-FW1 (dissimilar metal weld),
CU400-FW2, CU400-FW3, and CU400-FW4, are exempted from examination due to CRD penetrations making these welds inaccessible.
PP 7015 Rev. 3 Page 14 of 24
4.2. Class 2 Scope, Examination Requirements, and Exemptions
4.2.1. Scope
4.2.1.1. All Class 2 pressure retaining components and their welded attachments are included in the inspection program, except for those lines exempted from examination by ASME Section XI, 1998 Edition, 2000 addenda, Article IWC-1000, paragraph IWC-1220. For Class 2 components, Appendix B, Table 2 identifies: the code categories, the code item numbers, the number of components scheduled for examination within each code category and item, and notes clarifying various code requirements.
4.2.1.2. Category C-D bolting selection and examination are performed in accordance with Code Case N-652 and Relief Request ISI-03.
4.2.1.3. Surface examinations for Category C-F-1 and C-F-2 piping welds are selected and examined in accordance with Code Case N-663 and Relief Request ISI-04.
4.2.2. Examination Requirements:
4.2.2.1. Examination and schedule requirements are identified for Class 2 components in Appendix C, Table 6.
4.2.2.2. Magnetic particle and liquid penetrant examinations may be used interchangeably without revision to this program for ferritic steel components requiring surface exams (reference ASME Section XI, subsection IWA, paragraph IWA-2220).
4.2.3. Exemptions
4.2.3.1. ASME Section XI, subsection IWC, paragraph IWC-1221(a) and (c) or IWC-1222(a) and (b) exempts components that are 4 inch N.P.S. or less for boiling water reactor plants. Exemptions are in accordance with ASME Section XI, 1998 Edition, 2000 addenda, Subsection IWC, Article IWC-1000, paragraph IWC-1220. Selected specific exemptions are identified in paragraphs 4.2.3.2 through 4.2.3.3 below.
4.2.3.2. ASME Section XI, subsection IWC, paragraph IWC-1222(c) exempts components that are not part of the RHR, ECC, or CHR systems, have design pressure less than 275 psig and design temperature less than 200'F.
Thus, pipe line CT-3 of the Condensate Transfer System and pipe lines AC-14A, AC-14B and AC-22 of the primary containment and atmospheric control system are exempt from examination.
PP 7015 Rev. 3 Page 15 of 24
4.2.3.3. The Condensate Storage Tank (TK-4-1A) is not included in the program.
ASME Section XI, subsection IWA, paragraph JWA-1310 addresses storage tanks, however, the tank is not a pressure vessel and therefore is not addressed by any Code Category. This examination exemption is supported by ASME Section XI Code Interpretation XI-1-89-51.
4.3. Class 3 Scope, Examination Requirements, and Exemptions
4.3.1. Scope
4.3.1.1. All Class 3 components and systems greater than 4 inch N.P.S. are included in the Program, excepted for those items exempted below. All Class 3 pressure retaining components and their welded attachments in support of the below listed functions are included in the program except for those items exempted from examination by ASME Section XI, 1998 Edition, 2000 addenda, Subsection IWD, Article IWD-1000, paragraph IWD-1220.
- reactor shutdown
- emergency core cooling
- containment heat removal
- atmosphere cleanup
- reactor residual heat removal
- residual heat removal from spent fuel storage pool For Class 3 components, Appendix B, Table 3 identifies: the Code Categories, the code item numbers, the number of components scheduled for examination within each code category and item, and notes clarifying various code requirements.
4.3.2. Examination Requirements:
4.3.2.1. Examination and schedule requirements are identified for Class 3 components in Appendix C, Table 7.
PP 7015 Rev. 3 Page 16 of 24
4.3.3. Exemptions
4.3.3.1. Exemptions are in accordance with ASME Section XI, 1998 Edition, 2000 addenda, Subsection IWD, Article IWD-1000, paragraph IWD-1220 which exempts integral attachments and supports of SC3 components that are 4 inch N.P.S. or less within the bounds of examination Categories D-A, D-B, and D-C, from visual examination (VT-3).
4.3.3.2. ASME Section XI, subsection IWD, paragraph IWD-1220.2 exempts integral attachments to components exceeding 4 inch N.P.S provided: the components are not required in support of reactor residual heat removal, or containment heat removal, or emergency core cooling, and operate at a pressure less than 275 psig and at a temperature less than 200'F. Thus, the fuel pool cooling system is exempted from examination.
4.4. Component Supports Scope, Examination Requirements, and Exemptions
4.4.1. Scope
4.4.1.1. All Class 1, 2, 3 and MC component supports are included in the program except for those items exempted from examination by ASME Section XI, 1998 Edition, 2000 addenda, Subsection IWF, Article IWF-1000, paragraph IWF-1220.
4.4.1.2. Appendix B, Table 4 identifies: the code categories, the code item numbers, the number of components scheduled for examination within each code category and item, and notes clarifying various code requirements.
4.4.2. Examination Requirements:
4.4.2.1. Examination and schedule requirements are identified for component supports in Appendix C, Table 8.
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4.4.3. Exemptions
4.4.3.1. Support exemptions are in accordance with ASME Section XI, 1998 Edition, 2000 addenda, Subsection IWF, Article IWF-1000, paragraph IWF-1220. Selected specific exemptions are identified in paragraphs 4.4.3.2 through 4.4.3.7 below.
4.4.3.2. By ASME Section XI, subsection IWB, paragraph IWB-1220(a) the following lines are exempted. These exemptions are supported by VY Calculation No. VYC-1118, which determines that a line break on a 1.46" ID pipe for saturated water or a 2.38" ID pipe for saturated steam could be made up by systems operable from on-site emergency power.
- 2" head vent line off the N7 reactor nozzle (nominal 1.687" ID steam)
- 2" MSD2A, B, C, and D main steam drain lines (nominal 1.687" ID steam)
- 1.5" MSD420, MSD421, MSD422 main steam drain lines (nominal 1.338" ID steam)
- 1.5" reactor vessel instrumentation lines off the N 1lA, N 11B, N12A, and N12B nozzles (nominal 1.338" ID water) 4.4.3.3. By ASME Section XI, subsection IWB, paragraph IWB-1220(b) components on systems 1 inch N.P.S. and smaller are exempt from examination.
4.4.3.4. By ASME Section XI, subsection IWC, paragraph IWC-1221(a) and (c) or IWC-1222(a) and (b), components that are 4 inch N.P.S. or less are exempt from examination.
4.4.3.5. ASME Section XI, subsection IWC, paragraph IWC-1222(c) exempts components from examination that are not part of RHR, ECC, or CHR systems and they have design pressures less than 275 psig and design temperatures less than 200'F. Thus, pipeline CT-3 of the Condensate Transfer System and pipelines AC-14A and AC-14B of the primary containment and atmospheric control system are exempted from examination.
4.4.3.6. By ASME Section XI, subsection IWD, paragraph IWD-1220.1, components that are 4 inch N.P.S. or less are exempt from examination.
4.4.3.7. By ASME Section XI, subsection IWD, paragraph IWD-1220.2, the fuel pool cooling system is exempted from examination due to the system not being required to support reactor residual heat removal, containment heat removal, or emergency core cooling, and the system operates at a pressure less than 275 psig and at a temperature less than 200'F.
PP 7015 Rev. 3 Page 18 of 24
4.5. Successive Inspections (Follow-up Examinations) 4.5.1. If flaws or relevant conditions in Class 1 components are accepted by analytical evaluation, the areas containing such flaws shall be reexamined during the next three inspection periods. Alternatively, acoustic emission may be used to monitor growth of existing flaws in accordance with paragraph IWA-2234 of the ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda. If flaws or relevant conditions remain essentially unchanged for three successive inspection periods, the component examination schedule may revert to the original schedule of successive inspections. If welded attachments are examined as a result of identified component support deformation, and the results of these examinations exceed the acceptance standards of Table IWB-3410-1 of the ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda, successive examinations shall be performed, if determined necessary, based on an evaluation by the Vermont Yankee Design Engineering Department.
4.5.2. If flaws or relevant conditions in Class 2 components are accepted by analytical evaluation, the areas containing such flaws shall be reexamined during the next inspection period. Alternatively, acoustic emission may be used to monitor growth of existing flaws in accordance with IWA-2234 of ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda. If flaws or relevant conditions remain essentially unchanged for the next inspection period, the component examination schedule may revert to the original schedule of successive inspections. If welded attachments are examined as a result of identified component support deformation, and the results of these examinations exceed the acceptance standards of Table IWC-3410-1 of the ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda, successive examinations shall be performed, if determined necessary, based on an evaluation by the Vermont Yankee Design Engineering Department.
4.5.3. If flaws or relevant conditions in Class 3 components are accepted by analytical evaluation, the areas containing such flaws shall be reexamined during the next inspection period. If flaws or relevant conditions remain essentially unchanged for the next inspection period, the component examination schedule may revert to the original schedule of successive inspections. If welded attachments are examined as a result of identified component support deformation, and the results of these examinations exceed the acceptance standards of IWD-3000 of the ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda, successive examinations shall be performed, if determined necessary, based on an evaluation by the Vermont Yankee Design Engineering Department.
4.5.4. If flaws or relevant conditions in component supports are accepted by analytical evaluation, the component support shall be reexamined during the next inspection period. If flaws or relevant conditions do not require additional corrective measures during the next inspection period, the component examination schedule may revert to the original schedule of successive inspections.
PP 7015 Rev. 3 Page 19 of 24
4.6. Additional Examinations (Expansions) 4.6.1. Component examinations with the exception of Examination Categories B-P, C-H and D-B, that reveal flaws or relevant conditions that exceed applicable acceptance standards, shall be extended to include additional examinations as required by IWB-2430, IWC-2430, IWD-2430 or IWF-2430 as applicable.
4.7. Implementing Procedures and Documents 4.7.1. ASME Section XI, 1998 Edition, 2000 Addenda Section XI outlines the rules and requirements for performing inservice inspection and inservice testing at nuclear power plants. ASME Section XI identifies as a minimum rules and requirements for areas subject to inspection, responsibilities, provisions for accessibility, examination methods, frequency of inspections, procedures, personnel qualification, and examination documentation. This code is not only applicable to existing components but also new construction, repairs, and replacements.
4.7.2. DP 4026 Pressure Boundary Repair Procedure The purpose of this procedure is to provide written instruction for the removal of surface indications detected during ISIs conducted in accordance with Section XI of the ASMIE Code. This document is limited to the removal or reduction in size of indications detected by any of the visual examination techniques in ferritic or austenitic piping.
4.7.3. DP 4027 Inspection Discrepancy Reports The purpose of this procedure is to provide timely response to inservice inspection findings (indications, flaws, discrepancies, and deficiencies) identified during implementation of the ISI program procedure. ISI discrepancies could affect system operability and/or jeopardize plant safety. As such, timely evaluation, notification, and disposition of findings are necessary.
4.7.4. The following Nondestructive Examination (NDE) Procedures are used to implement ISI NDE inspection requirements:
NE 8042, Training for Contract NDE Personnel NE 8043, Training, Qualification and Certification of NDE Personnel NE 8044, Preparation of Examination Surfaces and Reference Marking of Welds for Nondestructive Examination NE 8045, Visual Examination Procedure for VT-1 NE 8046, Visual Examination Procedure for VT-2 NE 8047, Visual Examination Procedure for VT-3 and General Visual NE 8048, In-Vessel Visual Inspection NE 8049, Liquid Penetrant Examination - Solvent Removable, Visible Dye Technique NE 8050, Magnetic Particle Examination PP 7015 Rev. 3 Page 20 of 24
NE 8052, Ultrasonic System Performance Checks NE 8053, Ultrasonic Thickness Measurement NE 8054, Procedure for Ultrasonic Examination of Ferritic Piping Welds NE 8055, Procedure for Ultrasonic Examination of Austenitic Piping Welds NE 8056, Manual Ultrasonic Exam of Overlaid Austenitic Piping Welds NE 8057, Manual Ultrasonic Through-wall Sizing of Surface Connected Planar Flaws NE 8058, Ultrasonic Testing of Components NE 8059, Procedure for Straight Beam Ultrasonic Examination of Studs and Bolts NE 8060, Ultrasonic Exam of Class 1 Reactor Pressure Vessel Threads in Flange Area NE 8061, Ultrasonic Examination of Reactor Pressure Vessel Nozzle to Shell Welds per USNRC Regulatory Guide 1.150 NE 8064, Non-Code Visual Examination Methods as Good Maintenance Practice NE 8066, Required Volumetric Coverage for Ultrasonic Testing of Category B-J Butt Welds NE 8067, Reactor Vessel Internals Inspection Details PP 7015 Rev. 3 Page 21 of 24
5.0 REFERENCES
AND COMMITMENTS 5.1. Technical Specifications and Site Documents 5.1.1. T.S. Section 3.6.E 5.1.2. T.S. Section 4.6.E 5.1.3. UFSAR Section 4.2.6 5.1.4. VOQAM, Vermont Yankee Operational Quality Assurance Manual 5.2. Administrative Limits 5.2.1. None NOTE AP 6024, Plant Housekeeping requirements, are established via the AP 0021, Work Order process. (INPO93ES41MEC5) 5.3. Codes, Standards, and Regulations 5.3.1. Code of Federal Regulations, 10CFR50.55a 5.3.2. ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda 5.3.3. ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition, including the Summer 1975 Addenda 5.3.4. Regulatory Guide 1.58, Rev. 1, "Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel" 5.3.5. Regulatory Guide 1.147, Rev. 13, "Inservice Inspection Code Case Applicability" 5.3.6. Regulatory Guide 1.150, Rev. 1, "Ultrasonic Testing of Reactor Vessel Welds During Inservice Inspection" 5.4. Commitments 5.4.1. None 5.5. Supplemental References 5.5.1. Vermont Yankee Calculation VYC-1118, "Line Size Exemptions From ISI Section XI, IWB-1220 Examination Requirements" 5.5.2. GE Nuclear Energy Document GE-Ne-523-A71-0594-A, Revision 1, DRF 137-0010-7 Class II, May 2000, Titled "Alternate BWR Feedwater Nozzle Inspection Requirements" 5.5.3. Vermont Yankee Calculation VYC-1005, Revision 1 Entitled "Crack Growth evaluation of the Vermont Yankee FW Nozzles" 5.5.4. AP 0009, Event Reports 5.5.5. AP 0021, Work Orders 5.5.6. AP 0048, Work Planning PP 7015 Rev. 3 Page 22 of 24
5.5.5. AP 0021, Work Orders 5.5.6. AP 0048, Work Planning 5.5.7. AP 0070, ASME Section XI Repair and Replacement Procedure 5.5.8. AP 0095, Plant Procedures 5.5.9. DP 4027, Disposition of Inservice Inspection Findings 5.5.10. OP 4101, RPV Operational System Leakage Test 5.5.11. AP 6024, Plant Housekeeping and Foreign Material Exclusion/Cleanliness Control 5.5.12. AP 6807, Collection, Temporary Storage and Retrieval of QA Records 5.5.13. PP 7024, Containment Inservice Inspection Program (IWE) 5.5.14. PP 7034, Inservice Inspection Pressure Test Program 6.0 FINAL CONDITIONS 6.1. Final ISI Report Preparation The ISIPC is responsible for preparation, review, and submittal to the NRC and ANII of form NIS-1, Owner's Report for Inservice Inspection.
6.2. Records All ISI records including personnel certifications, equipment certifications, calibration sheets, examination data sheets, records of repairs, radiographic film, pertinent correspondence and form NIS-1 shall be submitted to the ISIPC for filing.
6.3. ISI Closeout The following conditions must be verified after each outage and prior to ISI closeout:
6.3.1. All required examinations have been completed.
6.3.2. Final inspection results, supporting documentation, and resolution of nonconformance have been compiled, reviewed, and retained.
6.3.3. All Indication Discrepancy Reports (DP 4027 forms) have been closed.
6.3.4. The NIS-1 form has been approved by the Plant Manager or designee and the ANH.
NOTE Additional copies of the Final ISI Report may be issued as "Unofficial" copies by the plant.
6.3.5. The ISIPC has received the approved copy of the Final ISI Report for retention.
PP 7015 Rev. 3 Page 23 of 24
7.0 ATTACHMENTS 7.1. Appendix A Relief Requests 7.2. Appendix B Selection and Bases Tables 7.3. Appendix C Examination and Schedule Tables 7.4. Appendix D Calibration Block Index 7.5. Appendix E Deleted 7.6. Appendix F Deleted 7.7. Appendix G Deleted PP 7015 Rev. 3 Page 24 of 24
APPENDIX A LICENSEE/UTILITY NAME - Entergy Nuclear Operations, Inc.
PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEST FOR RELIEF No. ISI-01 NOT UTILIZED Appendix A PP 7015, Rev. 3 Page 1 of 57
APPENDIX A (Continued)
LICENSEE/UTILITY NAME - Entergy Nuclear Operations, Inc.
PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEST FOR RELIEF No. ISI-02 Information to Support NRC Re-Approval of a 10CFR50.55a Request for Use During a New 10-Year Interval
- 1. Previous 10CFR50.55a Request Approved by NRC Request proposed in Reference I and approved as agreed to in Reference 9. Applicable items are ASME Section XI, Class 1, Examination Categories B-J, Code Item Nos. B9.10, B9.20, and B9.30, Pressure Retaining Welds in Piping
- 2. Changes to the Applicable ASME Code Section For Examination Category B-J, the differences between the 1986 Edition (Third Interval) and the 1998 Edition with Addenda through 2000 (Fourth Interval) are as follows:
- 1) The requirement for examination of longitudinal welds has been eliminated, except as noted in Notes (4), (5), and (6) at the intersections of circumferential welds.
- 2) Note (1)(c) clarifies which Category B-J dissimilar metal welds are included (no technical change).
These changes do not affect the use of Code Case N-560. There are no longitudinal welds in the Category B-J population at Vermont Yankee.
- 3. Component AMing Factors Component aging factors are addressed in Code Case N-560, (a)(7), which states, "Modifications to the selected examination zones may be made based on relevant industry experience, changes in plant design or operation, new metallurgical knowledge, or prior examination results." None of the above input factors has resulted in a change to the original examination sample selection.
At the present time, injection of hydrogen water chemistry has been delayed at Vermont Yankee.
However, Vermont Yankee still intends to assure that each of the stainless steel welds in the Category B-J population has been mitigated against IGSCC by two methods, or addressed by other means, as stated in Reference 12. As promised in Reference 12, an evaluation was conducted by Structural Integrity Associates to determine the effectiveness of induction heating stress improvement (IHSI) applied to certain welds (Reference 13) in order to possess two mitigating methods under all scenarios of HWC and NMCA injection. Based on the decision and timing of the use of hydrogen water chemistry, Vermont Yankee will expand the population of welds to receive such an evaluation.
Appendix A PP 7015, Rev. 3 Page 2 of 57
APPENDIX A (Continued)
- 4. Changes in Technology for Inspecting the Affected ASME Code Components Use of Code Case N-560 resulted in a change to the examination zones for each weld; however, Code Case N-560 governs selection of welds and areas for inspection, and does not address the means necessary to perform the inspection. Therefore, changes in technology are not applicable to use of this Code Case.
- 5. Confirmation of Renewed Applicability The relief granted for Vermont Yankee's Third Interval is still applicable for the Fourth Interval.
The use of risk-informed methodology for selection of components for examination embodies Vermont Yankee's philosophy for Class 1 piping inspection.
- 6. Duration of Re-Approved 10CFR50.55a Request It is proposed to use the alternative for the duration of the Vermont Yankee Fourth Ten-Year Interval (September 1, 2003 through August 31, 2013).
- 7. References
- 1. BVY 97-99, dated August 6, 1997, "Implementation of ASME Code Case N-560 at Vermont Yankee Nuclear Power Station"
- 2. BVY 97-105, dated August 15, 1997, "Implementation of ASME Code Case N-560 at Vermont Yankee Nuclear Power Station"
- 3. NVY 97-137, dated September 5, 1997, "Meeting with Vermont Yankee Nuclear Power Corporation"
- 4. NVY 97-163, dated October 9, 1997 "Summary of September 17, 1997, Meeting and September 23, 1997, Telecon Regarding the American Society of Mechanical Engineers Code Case N-560"
- 5. BVY 97-137, dated October 23, 1997, "Implementation of ASME Code Case N-560 at Vermont Yankee Nuclear Power Station - Response to NRC Questions"
- 6. NVY 98-32, dated March 11, 1998, "Request for Additional Information Regarding Implementation of ASME Code Case N-560 at Vermont Yankee Nuclear Power Station (TAC No. M99389)"
- 7. BVY 98-114, dated July 31, 1998, "Request for Additional Information Regarding Implementation of ASME Code Case N-560 at Vermont Yankee Nuclear Power Station"
- 8. BVY 98-138, dated September 4, 1998, "Submittal of Additional Information Regarding Implementation of ASME Code Case N-560 at Vermont Yankee Nuclear Power Station"
- 9. NVY 98-155, dated November 9, 1998, "Request to Use Code Case N-560 As an Alternative to the Requirements of ASME Code,Section XI, Table IWB-2500-1 at Vermont Yankee Nuclear Power Station"
- 10. NVY 98-168, dated December 30, 1998, "Request for Information Concerning Use of Code Case N-560 - Vermont Yankee Nuclear Power Station"
- 11. BVY 99-26, dated March 19, 1999, "Response to Request for Information Concerning Use of Code Case N-560 - Vermont Yankee Nuclear Power Station"
- 12. BVY 00-74, dated August 28, 2000, "Follow-up to Request for Information Concerning Use of Code Case N-560" Appendix A PP 7015, Rev. 3 Page 3 of 57
APPENDIX A (Continued)
- 13. Structural Integrity Report No. SIR-01-161, Revision A, dated "November 19, 2002",
Evaluation of Effectiveness of Induction Heating Stress Improvement of Austenitic Stainless Steel Piping Welds at Vermont Yankee" Appendix A PP 7015, Rev. 3 Page 4 of 57
APPENDIX A (Continued)
LICENSEEIUTILITY NAME - Entergy Nuclear Operations, Inc.
PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEST FOR RELIEF No. ISI-03 Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(i)
--Alternative Provides Acceptable Level of Quality and Safety--
- 1. ASME Code Component(s) Affected ASME Section XI, Class 1, Examination Category B-G-1, Code Item Nos. B6.120, B6.150, B6.160, and B6.170; Examination Category B-G-2, Code Item Nos. B7.10, B7.40, B7.50, B7.60, and B7.70; and Examination Category C-D, Code Item No. C4.20
- 2. Applicable Code Edition and Addenda 1998 Edition with Addenda through 2000
- 3. Applicable Code Requirements
- 1. ASME Section XI, Category B-G-1, Code Item Nos. B6.120, B6.150, B6.180, and B6.210 requires volumetric examination of bolts and studs in heat exchangers, piping, pumps, and valves regardless of whether the bolts or studs are examined in place or removed.
- 2. For ASME Section XI, Category B-G-1, Code Item Nos. B6.150, B6.180, and B6.210, volumetric examinations of bolting on heat exchangers, pumps, and valves are limited to components selected for examination under Examination Categories B-B, B-J, B-L-2, and B-M-2.
- 3. ASME Section XI, Category B-G-1, Code Item Nos. B6.150, B6.160, and B6.170; Category B-G-2, Code Item No. B7.50; and Category C-D, Code Item No. C4.20 require inspection of 100% of bolts and studs at each bolted connection in piping selected for examination under Code Categories B-J and C-F.
- 4. ASME Section XI, Category B-G-2, Code Item Nos. B7.10, B7.40, B7.50, B7.60, and B7.70 require visual examination of all Class 1 bolts, studs, and nuts 2 inches and less in diameter in place under tension, when the connection is disassembled, or when the bolting is removed.
- 4. Reason for Request To avoid unnecessary inspections and to conserve radiological dose, while still maintaining an adequate level of quality and safety for examination of the affected bolting.
- 5. Proposed Alternative Appendix A PP 7015, Rev. 3 Page 5 of 57
APPENDIX A (Continued)
Bolting will be selected and examined in accordance with Code Case N-652. Specifically:
I. In accordance with Code Case N-652, Category B-G-1, Note 2, a surface examination of bolts and studs in heat exchangers, piping, pumps, and valves may be substituted for volumetric examination when the bolts or studs are removed.
- 2. In accordance with Code Case N-652, Category B-G-1, Note 4, volumetric examinations may be conducted on one heat exchanger, one pump, or one valve among a group of heat exchangers, pumps, or valves that are similar in design, type, and function. In addition, when the component to be examined contains a group of bolted connections of similar design and size, such as flanged connections, examination may be conducted on one bolted connection among the group.
- 3. In accordance with Code Case N-652, Category B-G-1, Note 6; Category B-G-2, Note 3; and Category C-D, Note 4, examination of flanged piping bolting may be limited to one connection of a group of connections similar in design, size, function, and service.
- 4. In accordance with Code Case N-652, Category B-G-2, Note 1, bolting will only be examined when a connection is disassembled or the bolting is removed. (Effectively, the alternative only applies to piping bolting.)
Basis for Use The service experience of bolting throughout the industry is exemplary. Degradation is only associated with leakage and other provisions address examination of bolting at leaking connections.
- 1. New notes (Note 2 of Category B-G-I and Note 5 of Category C-D in Code Case N-652) were added to Categories B-G-1 and C-D to allow surface examination to be substituted for volumetric examination when bolting is removed for the examination. This recognizes that bolting failures initiate from the OD surface and that a surface exam is an acceptable technique for detection of such defects.
The existing examination methods require volumetric examination of removed bolting greater than two inches, even when surface examination is at least an equal, and possibly a more appropriate, examination.
Appendix A PP 7015, Rev. 3 Page 6 of 57
APPENDIX A (Continued)
Code Case 307-2, in which examination of the borehole surfaces of bolts and studs was eliminated, demonstrates that cracking initiates on the outside surfaces of bolts and studs.
For this reason, a qualified surface examination meeting the acceptance standards of IWB-3515 would provide at least the sensitivity for flaw detection that an end shot ultrasonic examination would provide on bolts and studs that have been removed for examination. Consequently, when bolts or studs are removed for examination, either a surface or volumetric examination should be allowed.
- 2. Note 3 of Section XI Category B-G-1 was changed (Note 4 in Code Case N-652 Category B-G-1) to require heat exchangers, pumps, and valves to be grouped based on design, type, and function, and then one component among the group to be volumetrically examined during the interval. In addition, if the component selected for examination included more than one bolted connection, then only one of those bolted connections is required to be examined. The note was also revised to apply only to volumetric examination as a new note was added to address visual examination of bolting for heat exchangers, pumps, and valves. Reference to examination of bolting for piping was also removed as a new note was added to address this.
Previously, the Code only required bolting for heat exchangers, pumps and valves to be examined when the component was selected for examination under Categories B-B, B-L-2, or B-M-2. These Categories require the components to be selected for examination only when the component is disassembled. There appears to be no technical justification to tie volumetric examination of bolting to component disassembly. This change makes the Class 1 requirements for volumetric examination of bolting on these type components identical to the existing Class 2 requirements.
Under existing Section XI examination rules, Category B-G-1 volumetric examination of bolted connections in heat exchangers, pumps, and valves is required only when the major component is disassembled for maintenance, repair, or volumetric examination.
This is inconsistent with, and actually less stringent than, the requirements of Category C-D, wherein volumetric examination of a sample of bolted connections in vessels, pumps and valves is required regardless of whether the component is disassembled for maintenance or repair.
Therefore, even though bolting inspection will be performed under a sample program (one connection of like connections), the change made by Code Case N-652 is more restrictive in that it will require examination of Category B-G-1 bolting regardless of whether the connection is disassembled.
- 3. A new note (Note 6 in Code Case N-652, Category B-G-1) was added in Category B-G-1 to clarify the requirements for examination of flange bolting in piping systems. It requires examination of one bolted connection among a group of bolted connections that are similar to design, type, function, and service.
Appendix A PP 7015, Rev. 3 Page 7 of 57
APPENDIX A (Continued)
A new Note 3 was added in Code Case N-652, Category B-G-2 to clarify the requirements for examination of flange bolting in piping systems. It requires examination of one bolted connection among a group of bolted connections that are similar to design, type, function, and service.
Note 2 of Category C-D was editorially revised to clarify the language. No technical changes were made to this note.
Note 3 of Category C-D was revised to clarify the requirements for examination of flange bolting in piping systems. It requires examination of one bolted connection among a group of bolted connections that are similar to design, type, function, and service.
The current code requires examination of bolting for piping when the component is selected for examination under Categories B-J or C-F, which is very difficult to comprehend. For bolting Categories B-G-I and B-G-2 the existing notes require the examination of bolted connections in piping to be tied to components selected for examination under piping examination Category B-J. For bolting Category C-D, examination of bolted connections in piping is tied to piping examination Category C-F.
These notes are confusing since it is difficult to limit examination of flange bolting in piping based on the piping welds selected for examination.
Therefore, even though bolting inspection will be performed under a sample program (one connection of like connections), the change made by Code Case N-652 is more restrictive in that it will require examination of piping bolting regardless of when the piping is selected under other Categories.
- 4. Note I of Category B-G-2 was revised to state that visual examination of bolting is required only when the connection is disassembled or removed.
Note 2 of Category B-G-2 was revised to clarify that visual examination of bolting for vessels, pumps, and valves is required only when the component is examined under Category B-B, B-L-2, or B-M-2. Reference to examination of bolting for piping was also removed as a new note (Note 6 in Code Case N-652) was added to address this.
The existing Section XI requires visual examination of this bolting when the component is "selected" for examination. Note 1 for Category B-G-2 of Code Case N-652 clarifies that examination is only required when the component is disassembled. It also clarifies that examination of any given bolted connection is required only once during the interval.
The existing Section XI Category B-G-2 Note 1 states that bolting may be examined in place under tension, when connection is disassembled, or when bolting is removed. This revision recognizes the fact that visual examination on bolting in place and under tension is not meaningful. Furthermore, the existing Section XI Category B-G-2 rules for piping do not tie the examination to disassembly of the connection as they do for heat exchangers, pumps, and valves.
Appendix A PP 7015, Rev. 3 Page 8 of 57
APPENDIX A (Continued)
Unlike volumetric examination, performing visual examinations of bolting while in place and under tension does not provide any meaningful information on the integrity of the bolting. Typically, the only portion of the bolting visible is the nuts and stud ends or the bolt head. Also, the only real degradation mechanism for flange bolting occurs when the connection is leaking. All Class I piping is subjected to a leakage test after each refueling outage and JWA-5000 already requires leaking flanges to be partially disassembled and the bolting to be examined for degradation. Performing a visual examination of bolting in place and under tension once every 10 years adds little value.
This requirement is also inconsistent with the Class I rules for visual examination of bolting associated with heat exchangers pumps and valves, wherein the examination is tied to disassembly of the component. For these reasons it is more appropriate to tie the examination of bolted connections in piping to disassembly of the flange.
Compliance with the proposed alternatives described above will provide an adequate level of quality and safety for examination of the affected welds, and will not adversely impact the health and safety of the public.
- 6. Duration of Proposed Alternative It is proposed to use the alternative for the duration of the Vermont Yankee Fourth Ten-Year Interval (September 1, 2003 through August 31, 2013).
Appendix A PP 7015, Rev. 3 Page 9 of 57
APPENDIX A (Continued)
LICENSEE/UTILITY NAME - Entergy Nuclear Operations, Inc.
PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEST FOR RELIEF No. ISI-04 Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(i)
--Alternative Provides Acceptable Level of Quality and Safety--
- 1. ASME Code Component(s) Affected ASME Section XI, Class 1, Examination Categories B-F, C-F-I, and C-F-2, Code Item Nos.
B5. I0, C5.1 1, C5.4 1, C5.5 1, and C5.8 1, Pressure Retaining Dissimilar Metal Welds in Reactor Vessel Nozzle-to-Safe-End Butt Welds 4 inch NPS and larger; Pressure Retaining Circumferential Welds and Branch Connection Welds in Austenitic Stainless Steel or High Alloy Piping 4 inch NPS and larger; and Pressure Retaining Circumferential Welds and Branch Connection Welds in Carbon or Low Alloy Steel Piping 4 inch NPS and larger
2. Applicable Code Edition and Addenda
1998 Edition with Addenda through 2000
- 3. Applicable Code Requirements Surface examination of essentially 100% of each weld requiring examination must be performed.
All Category B-F welds 4 inch NPS and larger require surface examination. Of the total population of non-exempt Category C-F-I and C-F-2 piping welds greater than 4 inch NPS, 7.5%, but not less than 28 welds, require surface examination.
4. Reason for Request
To avoid unnecessary inspections and to conserve radiological dose, while still maintaining an adequate level of quality and safety for examination of the affected welds.
- 5. Proposed Alternative Surface examination of the subject welds (Categories B-F, C-F-I, and C-F-2 4 inch NPS and larger) shall be conducted in accordance with Code Case N-663. All areas of the subject welds identified as susceptible to outside surface attack shall be surface examined during the Vermont Yankee Fourth Ten-Year Interval in accordance with Code Case N-663. [Code Case N-663 also includes Category B-J, but Vermont Yankee will examine Category B-J in accordance with Relief Request ISI-02.]
Appendix A PP 7015, Rev. 3 Page 10 of 57
APPENDIX A (Continued)
Basis for Use The subject item numbers in ASME Section XI require a volumetric and/or surface exam on selected piping welds to ensure that generic degradation mechanisms are not active on either the inside diameter (I.D.) or the outside diameter (O.D.). However, these welds are selected using a deterministic set of requirements that are un-informed as to any possible degradation mechanisms. ASME Code Case N-663 provides an alternative to the current ASME Section XI requirements for defining the number and location of surface examinations for piping components.
The ASME Section XI Task Group on ISI Optimization, Report No. 92-01-01, Evaluation of Inservice Inspection Requirementsfor Class 1, Category B-J PressureRetaining Welds in Piping, dated July 1995, concluded (with 50 units responding with a total of 9333 welds inspected) only 2 welds (0.02%) were found to have flaws detected by Section XI surface examinations. These flaws were determined to be fabrication-induced. In parallel with the above, several risk-informed Code cases have been developed for use on piping welds (e.g.,
ASME Code Cases N-560, N-577, and N-578). One of the methods for risk-informing piping examinations is via use of EPRI TR-1 12657, Rev. B-A, Revised Risk-Informed Inservice Inspection Evaluation Procedure (NRC SER dated 10/28/99). Table 4-1, Summary of Degradation-SpecificInspection Requirements and Examination Methods, of the EPRI report lists the required degradation mechanisms to be evaluated in Class 1, 2, and 3 piping. It also identifies the risk-informed examination method required for each of these degradation mechanisms. The only degradation mechanism that requires a surface examination is O.D.
chloride cracking. These two initiatives led ASME to investigate the value of surface examinations.
Code Case N-663 incorporates lessons learned from the risk-informed initiatives and industry examination experience into Section XI by requiring that an evaluation be conducted to identify locations, if any, where a surface examination would be of benefit from a generic piping degradation perspective. The results of this evaluation identify where O.D. degradation is most likely to occur by reviewing plant-specific programs and practices, and operating experience. If the potential for degradation is identified, Code Case N-663 defines examination techniques, volumes, and frequencies. As such, implementing Code Case N-663 will identify appropriate locations for surface examination, if any, and eliminate unnecessary examinations.
Other ASME Section XI examination requirements for the subject piping welds, including volumetric examinations and pressure testing, will continue to be performed. Examination requirements for other components, including Class I piping less than NPS 4, will continue to meet all Section XI requirements and are not subject to this request.
Code Case N-663 was approved by the ASME Boiler and Pressure Vessel Code Committee on September, 17, 2002, but has not yet been included in the most recent listing of NRC approved code cases provided in Revision 12 of Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability - ASME Section XI Division L."
Appendix A PP 7015, Rev. 3 Page 11 of 57
APPENDIX A (Continued)
Compliance with the proposed alternatives described above will provide an adequate level of quality and safety for examination of the affected welds, and will not adversely impact the health and safety of the public.
- 6. Duration of Proposed Alternative It is proposed to use the alternative for the duration of the Vermont Yankee Fourth Ten-Year Interval (September 1, 2003 through August 31, 2013).
Appendix A PP 7015, Rev. 3 Page 12 of 57
APPENDIX A (Continued)
LICENSEE/UTILITY NAME - Entergy Nuclear Operations, Inc.
PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEST FOR RELIEF No. ISI-05 Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(i)
--Alternative Provides Acceptable Level of Quality and Safety--
- 1. ASME Code Component(s) Affected Pressure Retaining Piping Welds subject to examination using procedures, personnel, and equipment qualified to ASME Section XI, Appendix VIII, Supplement 10 criteria.
2. Applicable Code Edition and Addenda
1998 Edition with Addenda through 2000
- 3. Applicable Code Requirements The following paragraphs or statements are from ASME Section XI, Appendix VIII, Supplement 10 and identify the specific requirements that are included in this request for relief:
Item I - 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 l.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.
Item 7 - Paragraph 2.2(b) states in part - The regions containing a flaw to be sized shall be identified to the candidate.
Appendix A PP 7015, Rev. 3 Page 13 of 57
APPENDIX A (Continued)
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 I I - Table VIII-S2-1 provides the false call criteria when the number of unflawed grading units is at least twice the number of flawed grading units.
4. Reason for Request
Section XI, Appendix VIII, Supplement 10 has not kept pace with the experience gained administering the Performance Demonstration Initiative. The proposed alternative is based on forthcoming Code action and was generated from a PDI model prepared by EPRI.
- 5. Proposed Alternative In lieu of the requirements of ASME Section XI, 1998 Edition, 2000 Addenda, Appendix VIII, Supplement 10, the proposed alternative described in the enclosure shall be used. The proposed alternative 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 for consideration and as of December 2002 had been approved by the NDE Subcommittee.
Basis for Use Item I - 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."
Appendix A PP 7015, Rev. 3 Page 14 of 57
APPENDIX A (Continued)
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 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.
i~ati7I .- Mechanical fatigue crack I i in Base maternal 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."
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.
Appendix A PP 7015, Rev. 3 Page 15 of 57
APPENDIX A (Continued)
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 S 10-1 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-S IO-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%
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 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.
Appendix A PP 7015, Rev. 3 Page 16 of 57
APPENDIX A (Continued)
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) states:
"... 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.
Appendix A PP 7015, Rev. 3 Page 17 of 57
APPENDIX A (Continued)
Item I I - The proposed alternative modifies the acceptance criteria of Table VIII-S2-I as follows:
TABLE VIII-S-1" 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 0 6 6 12 1 7 6 14 1 8 7 162 9 7 10 2 10 8 o- 15 2 11 9 2- 17 3-3 12 9 24-18 3 13 10 2- 20 4-3 14 10 26 21 5 3 15 11 3e 23 3 16 12 3H-24 4 17 12 3 26 6-4 18 13 36-27 4 19 13 3-f29 7-4 20 14 40- 30 8- 5 Technical Basis - The proposed alternative is identified as new Table SIO-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, PNNL has reviewed the statistical significance of these revisions and offered the revised Table SI O-1.
Compliance with the proposed alternatives described above in Items l through 10 will provide an adequate level of quality and safety for examination of the affected welds, and will not adversely impact the health and safety of the public.
Appendix A PP 7015, Rev. 3 Page 18 of 57
APPENDIX A (Continued)
- 6. Duration of Proposed Alternative It is proposed to use the alternative for the duration of the Vermont Yankee Fourth Ten-Year Interval (September 1, 2003 through August 31, 2013).
- 7. Precedents This proposed alternative is essentially identical to the model provided by the Performance Demonstration Initiative on the EPRI website.
Appendix A PP 7015, Rev. 3 Page 19 of 57
APPENDIX A (Continued)
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 the regarding the applicable range of each inside or outside surface. Supplement 10 is individual Supplement. The exclusion of not applicable to piping welds containing CRC provides consistency between supplemental corrosion resistant clad (CRC) Supplement 10 and the recent revision to applied to mitigate IntergranularStress Supplement 2 (Reference BC 00-755). Note, Corrosion Cracking (IGSCC). an additional change identifying CRC as "in course of preparation" is being processed separately.
1.0 SPECIMEN REQUIREMENTS 2.0 SPECIMEN REQUIREMENTS Renumbered Qualification test specimens shall meet the Qualification test specimens shall meet the No Change requirements listed herein, unless a set of requirements listed herein, unless a set of specimens is designed to accommodate specimens is designed to accommodate specific specific limitations stated in the scope of the limitations stated in the scope of the examination examination procedure (e.g., pipe size, weld procedure (e.g., pipe size, weld joint joint configuration, access limitations). The configuration, access limitations). The same same specimens may be used to demonstrate specimens may be used to demonstrate both both detection and sizing qualification. detection and sizing qualification.
1.1 General. The specimen set shall conform 2.1 General. The specimen set shall conform to Renumbered to the following requirements. the following requirements.
(a) The minimum number of flaws in a test set New, changed minimum number of flaws to shall be ten. 10 so sample set size for detection is consistent with length and depth sizing.
(a) Specimens shall have sufficient volume to (b) Specimens shall have sufficient volume to Renumbered minimize spurious reflections that may minimize spurious reflections that may interfere interfere with the interpretation process. with the interpretation process.
Appendix A PP 7015, Rev. 3 Page 20 of 57
APPENDIX A (Continued)
SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change I Reasoning (b) The specimen set shall include the (c) The specimen set shall include the minimum Renumbered, metricated, the change in pipe minimum and maximum pipe diameters and and maximum pipe diameters and thicknesses for diameter tolerance provides consistency thicknesses for which the examination which the examination procedure is applicable. between Supplement 10 and the recent procedure is applicable. Pipe diameters within Pipe diameters within a range of 1/2 in. (13 mm) revision to Supplement 2. (Reference BC a range of 0.9 to 1.5 times a nominal diameter of the nominal diameter shall be considered 00-755) shall be considered equivalent. Pipe diameters equivalent. Pipe diameters larger than 24 in. (610 larger than 24 in. shall be considered to be flat. mm) shall be considered to be flat. When a When a range of thicknesses is to be range of thicknesses is to be examined, a examined, a thickness tolerance of +25% is thickness tolerance of +25% is acceptable.
acceptable.
(c) The specimen set shall include examples of (d) The specimen set shall include examples of Renumbered, changed "condition" to the following fabrication condition: the following fabrication conditions: "conditions" (l) geometric conditions that normally require (1) geometric and material conditions that Clarification, some of the items listed relate discrimination from flaws (e.g., counterbore or normally require discrimination from flaws (e.g., to material conditions rather than geometric weld root conditions, cladding, weld buttering, counterbore or weld root conditions, cladding, conditions. Weld repair areas were added as remnants of previous welds, adjacent welds in weld buttering, remnants of previous welds, a result of recent field experiences.
close proximity); adjacent welds in close proximity, and weld repair areas);
(2) typical limited scanning surface conditions (2) typical limited scanning surface conditions Differentiates between ID and OD scanning (e.g., diametrical shrink, single-side access (e.g., weld crowns, diametrical shrink, surface limitations. Requires that ID and due to nozzle and safe end external tapers). single-side access due to nozzle and safe end OD qualifications be conducted external tapers for outside surface independently (Note, new paragraph 2.0 examinations; and internal tapers, exposed (identical to old paragraph 1.0) provides for weld roots, and cladding conditions for inside alternatives when "a set of specimens is surface examinations). Qualification designed to accommodate specific requirements shall be satisfied separately for limitations stated in the scope of the outside surface and inside surface examination procedure.").
examinations.
Appendix A PP 7015, Rev. 3 Page 21 of 57
APPENDIX A (Continued)
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 flaws Renumbered and re-titled. Flaw location austenitic material. At least 50% of the cracks shall be contained wholly in weld or buttering percentages redistributed because field in austenitic material shall be contained material. At least one and a maximum of 10% experience indicates that flaws contained in wholly in weld or buttering material. At least of the flaws shall be in ferritic base material. At weld or buttering material are probable and 10% of the cracks shall be in ferritic material. least one and a maximum of 10% of the flaws represent the more stringent ultrasonic The remainder of the cracks may be in either shall be in austenitic base material. detection scenario.
austenitic or ferritic material.
(2) At least 50% of the cracks in austenitic 2.3 Flaw Type. Renumbered and re-titled. Alternative flaws base material shall be either IGSCC or thermal (a) At least 60% of the flaws shall be cracks, are required for placing axial flaws in the fatigue cracks. At least 50% of the cracks in the remainder shall be alternative flaws. HAZ of the weld and other areas where ferritic material shall be mechanically or Specimens with IGSCC shall be used when implantation of a crack produces thermally induced fatigue cracks. available. Alternative flaws, if used, shall metallurgical conditions that result in an provide crack-like reflective characteristics unrealistic ultrasonic response. This is and shall be limited to the case where consistent with the recent revision to implantation of cracks produces spurious Supplement 2 (Reference BC 00-755).
reflectors that are uncharacteristic of actual flaws. Alternative flaw mechanisms shall have The 40% limit on alternative flaws is needed a tip width of less than or equal to 0.002 in. to support the requirement for up to 70%
(.05 mm). axial flaws. Metricated (3) At least 50% of the cracks shall be (b) At least 50% of the flaws shall be coincident Renumbered. Due to inclusion of coincident with areas described in (c) above. with areas described in 2.1(d) above. "alternative flaws", use of "cracks" is no longer appropriate.
Appendix A PP 7015, Rev. 3 Page 22 of 57
APPENDIX A (Continued)
SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning 2.4 Flaw Depth. All flaw depths shall be greater Moved from old paragraph 1.3(c) and 1.4 than 10% of the nominal pipe wall thickness. and re-titled. Consistency between detection Flaw depths shall exceed the nominal clad and sizing specimen set requirements (e.g.,
thickness when placed in cladding. 20% vs. 1/3 flaw depth increments, e.g.,
Flaws in the sample set shall be distributed as original paragraph 1.3(c))
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 set Renumbered and re-titled and moved to shall include detection specimens that meet paragraph 3.1(a). No other changes the following requirements.
(a) Specimens shall be divided into grading Renumbered to paragraph 3.1 (a)(1).
units. Each grading unit shall include at least No other changes.
3 in. of weld length. If a 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.
Appendix A PP 7015, Rev. 3 Page 23 of 57
APPENDIX A (Continued)
SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (b) Detection sets shall be selected from Table Moved to new paragraph 3.1 (a)(2).
VIII-S2- 1. The number of unflawed grading units shall be at least twice the number of flawed grading units.
(c) Flawed grading units shall meet the Flaw depth requirements moved to new following criteria for flaw depth, orientation, paragraph 2.4, flaw orientation requirements and type. moved to new paragraph 2.5, flaw type requirements moved to new paragraph 2.3, "Flaw Type".
(I) All flaw depths shall be greater than 10% Deleted, for consistency in sample sets the of the nominal pipe wall thickness. At least depth distribution is the same for detection 1/3 of the flaws, rounded to the next higher and sizing.
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 the 2.5 Flaw Orientation. Note, this distribution is applicable for flaws, rounded to the next higher whole (a) At least 30% and no more than 70% of the detection and depth sizing. Paragraph number, shall be oriented axially. The flaws, rounded to the next higher whole number, 2.5(b)(1) requires that all length- sizing remainder of the flaws shall be oriented shall be oriented axially. The remainder of the flaws be oriented circumferentially.
circumferentially. flaws shall be oriented circumferentially.
1.3 Length Sizing Specimens. The specimen Renumbered and re-titled and moved to new set shall include length-sizing specimens that paragraph 3.2 meet the following requirements.
Appendix A PP 7015, Rev. 3 Page 24 of 57
APPENDIX A (Continued)
FSUPPLE M ENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS L Current Requirement Proposed Change Reasoning (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 above ten.
(c) All flaw depths shall be greater than 10% Moved, included in new paragraph 2.4 above of the nominal pipe wall thickness. At least after revision for consistency with detection 1/3 of the flaws, rounded to the next higher distribution 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 specimen Moved, included in new paragraphs 2.1, 2.3, set shall include depth-sizing specimens that 2.4 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 wholly Moved, potential conflict with old paragraph contained within cladding and shall be 1.2(c)(1); "However, flaw depths shall distributed as follows: exceed the nominal clad thickness when placed in cladding.". Revised for clarity and included in new paragraph 2.4 Appendix A PP 7015, Rev. 3 Page 25 of 57
APPENDIX A (Continued)
SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning 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.
3 1-60% 20%
61-100% 20%
The remaining flaws shall be in any of the above categories.
(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 in Included for clarity. Previously addressed 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 identification For qualifications from the outside surface, the Differentiate between qualifications shall be concealed from the candidate. All specimen inside surface and identification shall conducted from the outside and inside examinations shall be completed prior to be concealed from the candidate. When surface.
grading the results and presenting the results qualifications are performed from the inside to the candidate. Divulgence of particular surface, the flaw location and specimen specimen results or candidate viewing of identification shall be obscured to maintain a unmasked specimens after the performance "blind 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.
Appendix A PP 7015, Rev. 3 Page 26 of 57
APPENDIX A (Continued)
SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning 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 1.2.
specimens that meet the following requirements.
(1) Specimens shall be divided into grading units. Renumbered, moved from old paragraph Each grading unit shall include at least 3 in. (76 1.2(a). Metricated. No other changes.
mm) of weld length. If a 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.
(2) Detection sets shall be selected from Table Moved from old paragraph 1.2(b). Table VIII-S10-1. The number of unflawed grading revised to reflect a change in the minimum units shall be at least one and a half times the sample set to 10 and the application of 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 be Moved from old paragraph 2.1 randomly mixed.
Appendix A PP 7015, Rev. 3 Page 27 of 57
APPENDIX A (Continued)
SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (b) Examination equipment and personnel are Moved from old paragraph 3.1. Modified to qualified for detection when personnel reflect the 100% detection acceptance demonstrations satisfy the acceptance criteria of criteria of procedures versus personnel and Table VIII S10-1 for both detection and false equipment contained in new paragraph 4.0 calls. 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.
2.2 Length Sizing Test 3.2 Length Sizing Test Renumbered (a) The length-sizing test may be conducted (a) Each reported circumferential flaw in the Provides consistency between Supplement separately or in conjunction with the detection detection test shall be length sized. 10 and the recent revision to Supplement 2 test. (Reference BC 00-755).
(b) When the length-sizing test is conducted in (b) When the length-sizing test is conducted in Change made to ensure security of samples, conjunction with the detection test, and less conjunction with the detection test, and less than consistent with the recent revision to than ten circumferential flaws are detected, ten circumferential flaws are detected, additional Supplement 2 (Reference BC 00-755).
additional specimens shall be provided to the specimens shall be provided to the candidate such candidate such that at least ten flaws are sized. that at least ten flaws are sized. The regions Note, length and depth sizing use the term The regions containing a flaw to be sized shall containing a flaw to be sized may be identified to "regions" while detection uses the term be identified to the candidate. The candidate the candidate. The candidate shall determine the "grading units". The two terms define shall determine the length of the flaw in each length of the flaw in each region. different concepts and are not intended to be region. equal or interchangeable.
(c) For a separate length-sizing test, the (c) For a separate length-sizing test, the regions Change made to ensure security of samples, regions of each specimen containing a flaw to of each specimen containing a flaw to be sized consistent with the recent revision to be sized shall be identified to the candidate. may be identified to the candidate. The Supplement 2 (Reference BC 00-755).
The candidate shall determine the length of the candidate shall determine the length of the flaw flaw in each region. in each region.
Appendix A PP 7015, Rev. 3 Page 28 of 57
APPENDIX A (Continued)
SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (d) Examination procedures, equipment, and Moved from old paragraph 3.2(a) includes personnel are qualified for length sizing when the inclusion of "when" as an editorial change.
RMS error of the flaw length measurements, as Metricated.
compared to the true flaw lengths, is less than or equal to 0.75 in. (19 mm).
2.3 Depth Sizing Test 3.3 Depth Sizing Test Renumbered (a) For the depth-sizing test, 80% of the flaws (a) The depth-sizing test may be conducted Change made to ensure security of samples, shall be sized at a specific location on the separately or in conjunction with the detection consistent with the recent revision to surface of the specimen identified to the test. For a separate depth-sizing test, the Supplement 2 (Reference BC 00-755).
candidate. regions of each 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 conducted in Change made to be consistent with the each specimen containing a flaw to be sized conjunction with the detection test, and less recent revision to Supplement 2 (Reference shall be identified to the candidate. The than ten flaws are detected, additional BC 00-755).
candidate shall determine the maximum depth specimens shall be provided to the candidate of the flaw in each region. such that at least ten flaws are sized. The Changes made to ensure security of samples, regions of each specimen containing a flaw to be consistent with the recent revision to sized may be identified to the candidate. The Supplement 2 (Reference BC 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 the Metricated.
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).
Appendix A PP 7015, Rev. 3 Page 29 of 57
APPENDIX A (Continued)
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 S 10 from S2 because of personnel are qualified for detection when the the change in the minimum number of flaws results of the performance demonstration and the reduction in unflawed grading units satisfy the acceptance criteria of Table from 2X to I .5X.
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, and Moved to new paragraph 3.2(d), included personnel are qualified for length sizing the word "when" as an editorial change.
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, and Moved to new paragraph 3.3(c) 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.
Appendix A PP 7015, Rev. 3 Page 30 of 57
APPENDIX A (Continued)
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 3 (a) The specimen set shall include the personnel sets (i.e., a minimum of 30 flaws) equivalent of at least three personnel sets. is required to provide enough flaws to Successful personnel demonstrations may be adequately test the capabilities of the combined to satisfy these requirements. procedure. Combining successful (b) Detectability of all flaws within the scope of demonstrations allows a variety of the procedure shall be demonstrated. Length examiners to be used to qualify the and depth sizing shall meet the requirements procedure. Detectability of each flaw within of paragraph 3.2 and 3.3. the scope of the procedure is required to (c) At least one successful personnel ensure an acceptable personnel pass rate.
demonstration has been performed. The last sentence is equivalent to the (d) To qualify new values of essential variables, previous requirements and is satisfactory for at least one personnel qualification set is expanding the essential variables of a required. previously qualified procedure Appendix A PP 7015, Rev. 3 Page 31 of 57
APPENDIX A (Continued)
SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning TABLE VIII-S71 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 5 100 612 1.
7 6 14 1 7 16 2 9 7 1a 2 10 8 20- 15 3 2 11 9 22- 17 3- 3 12 9 24- 18 3 3 13 10 26-20 3 14 10 2- 21 5 3 15 11 3-e- 23 5- 3 16 12 3--- 24 .4 17 12 3+ 26 6- 4 18 13 36-27 '-4 19 13 36-29 7-4 20 14 4 30 8 5 Appendix A PP 7015, Rev. 3 Page 32 of 57
APPENDIX A (Continued)
LICENSEE/UTILITY NAME - Entergy Nuclear Operations, Inc.
PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEST FOR RELIEF No. ISI-06 On hold Appendix A PP 7015 Rev. 3 Page 33 of 57
APPENDIX A (Continued)
LICENSEE/UTILITY NAME - Entergy Nuclear Operations, Inc.
PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEST FOR RELIEF No. ISI-07 Information to Support NRC Re-Approval of a 10CFR50.55a Request for Use During a New 10-Year Interval
- 1. Previous 10CFR50.55a Request Approved by NRC Vermont Yankee letter to USNRC, BVY 00-102, dated October 31, 2000, (Reference 3 below) requested approval to use an alternate inspection frequency for Category E Weld Repair Overlays (ASME Section XI, Class 1, Examination Category B-F, Code Item No. B5.10, Pressure Retaining Dissimilar Metal Welds in Vessel Nozzles) in accordance with BWRVIP-75 (Reference I below) and the NRC's SE on that document (Reference 2 below). USNRC letter to Vermont Yankee, NVY 01-21, dated March 22, 2001 (Reference 4 below), reviewed and approved that request.
In the Final SE of BWRVIP-75, dated May 14, 2001, (Reference 5 below) the USNRC only stipulated that for Category E welds the licensee include a note stating which welds are made of non-resistant materials. Per the original submittal (BVY 00-102 - Reference 3), the overlays were installed using Inconel 82, which is considered material resistant to IGSCC, as stated in Appendix A of the original USNRC SE to BWRVIP-75 (Reference 2).
- 2. Changes to the Applicable ASME Code Section Neither the ASME Section XI, 1986 Edition nor the Section XI, 1998 Edition with 2000 Addenda addresses structural overlays.
- 3. Component Aming Factors Component aging factors are addressed in the NRC's SE of BWRVIP-75, dated September 15, 2000 (Reference 2).
- 4. Changes in Technology for Inspecting the Affected ASME Code Components Ultrasonic inspection of overlaid components has been conducted in accordance with techniques qualified under the auspices of the three-party NDE Coordination Plan, which the NRC endorsed in GL 88-01. These techniques have been generally improved since their initial use and help support the basis as offered in BWRVIP-75 (Reference 1).
Appendix A PP 7015 Rev. 3 Page 34 of 57
APPENDIX A (Continued)
- 5. Confirmation of Renewed Applicability The relief granted for Vermont Yankee's Third Interval is still applicable for the Fourth Interval.
BWRVIP-75, published in October 1999, and the NRC's Safety Evaluation of BWRVIP-75 are still the current applicable guidance documents for inspection of structurally overlaid components.
- 6. Duration of Re-Approved 10CFR50.55a Request It is proposed to use the alternative for the duration of the Vermont Yankee Fourth Ten-Year Interval (September 1, 2003 through August 31, 2013).
- 7. References
- 1. BWRVIP-75, dated October 1999, "Technical Basis for Revisions to Generic Letter 88-01 Inspection Schedules"
- 2. Letter, USNRC to BWRVIP, dated September 15, 2000, "Safety Evaluation of the 'BWRVIP Technical Basis for Revisions to Generic Letter 88-01 Inspection Schedules (BWRVIP-75)'
EPRI Report TR-1 13932, October 1999"
- 3. Vermont Yankee letter to USNRC, BVY 00-102, dated October 31, 2000, "Request for Alternate Inspection Frequency for Weld Repair Overlays"
- 4. USNRC letter to Vermont Yankee, NVY 01-21, dated March 22, 2001 ,"Vermont Yankee Nuclear Power Station, Review of a Request for an Alternate Inspection Frequency for Overlay Repaired Welds"
- 5. Letter, USNRC to BWRVIP, dated May 14, 2002, "Final Safety Evaluation of the 'BWRVIP Technical Basis for Revisions to Generic Letter 88-01 Inspection Schedules (BWRVIP-75)'
EPRI Report TR-1 13932, October 1999" Appendix A PP 7015 Rev. 3 Page 35 of 57
APPENDIX A (Continued)
LICENSEE/UTILITY NAME - Entergy Nuclear Operations, Inc.
PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEST FOR RELIEF No. ISI-08 Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(i)
--Alternative Provides Acceptable Level of Quality and Safety--
- 1. ASME Code Component(s) Affected ASME Section XI, Class 1, Examination Category B-A, Item No. B1.10 Longitudinal and Circumferential Shell Welds and B1.20 Head Welds subject to Appendix VIII, Supplement 4, examination.
2. Applicable Code Edition and Addenda
1998 Edition with Addenda through 2000
- 3. Applicable Code Requirements IOCFR50.55a(b)(2) was amended to reference Section XI of the Code through the 1998 Edition with the 2000 Addenda. 10CFR50.55a(b)(2)(xv)(C)(1) requires a depth sizing acceptance criteria of 0.15 inch root mean square (RMS) be used in lieu of the requirements of ASME Section XI, 1998 Edition with the 2000 Addenda, Appendix VIII, Supplement 4, Subparagraph 3.2(b). However, Supplement 4, Subparagraph 3.2(c) contains additional criteria for performance demonstration depth sizing and requires that results be plotted and certain statistical parameters be satisfied.
4. Reason for Request
Section XI, Appendix VIII, Supplement 4 has not kept pace with the experience gained administering the Performance Demonstration Initiative. The NRC recognized this and provided extensive verbiage in IOCFR50.55a(b)(2) to correct this shortcoming. However, this request for an alternative corrects what is perceived to be a publishing mistake in the rule. It is based on a model prepared by EPRI for the PDI.
- 5. Proposed Alternative In lieu of the depth sizing requirements of ASME Section XI, 1998 Edition, 2000 Addenda, Appendix VIII, Supplement 4, Subparagraph 3.2(c), a depth sizing qualification criteria of 0.15 RMSE will be used [as stated in 10CFR50.55a(b)(2)(xv)(C)(l)]. The proposed alternative will be implemented through the PDI Program.
Appendix A PP 7015 Rev. 3 Page 36 of 57
APPENDIX A (Continued)
Basis for Use In a public meeting on October 11, 2000 at NRC offices in White Flint, MD (Reference 1), the PDI identified the discrepancy between the Subparagraph 3.2(c) and the PDI program. The NRC agrees that Paragraph 10CFR50.55a(b)(2)(xv)(C)(l) should have excluded Subparagraph 3.2(c) as a requirement.
The U.S. nuclear utilities created the PDI to implement demonstration requirements contained in Appendix VIII. PDI developed a performance demonstration program for qualifying UT techniques. In 1995, the NRC staff performed an assessment of the PDI program and reported that there were differences between Appendix VIII and the way PDI was implementing the program, but did not take exception to PDI's implementation. The staff requested that the differences between PDI and the Code be resolved.
The solution for resolving the differences between the PDI program and the Code was for PDI to participate in development of a Code case that reflected PDI's program. The Code Case was presented to ASME for discussion and consensus building. NRC representatives participated in this process. ASME approved the Code Case and published it as Code Case N-622, "Ultrasonic Examination of RPV and Piping, Bolts and Studs,Section XI, Division 1."
Operating in parallel with the actions of PDI, the staff incorporated most of Code Case N-622 criteria in the rule published in the Federal Register, 64 FR 51370. 10CFR 50.55a(b)(2)(xv) was subsequently revised in Federal Register, 67FR187. Appendix lI to Code Case N-622 contains the proposed alternative sizing criteria, which has been authorized by the staff. The staff agrees that the inclusion of the statistical sizing parameters of Paragraph 3.2(c) of Supplement 4 to Appendix VII was an oversight.
Compliance with the proposed alternatives described above will provide an adequate level of quality and safety for examination of the affected welds, and will not adversely impact the health and safety of the public.
- 6. Duration of Proposed Alternative It is proposed to use the alternative for the duration of the Vermont Yankee Fourth Ten-Year Interval (September 1, 2003 through August 31, 2013).
- 7. Precedents This proposed alternative is derived from the model provided by the Performance Demonstration Initiative on the EPRI website.
- 8. References I. USNRC Letter from D. G. Naujock to E. J. Sullivan, dated November 13, 2000, "Summary of Public Meeting Held On October 11, 2000, with PDI Representatives" Appendix A PP 7015 Rev. 3 Page 37 of 57
APPENDIX A (Continued)
LICENSEE/UTILITY NAME - Entergy Nuclear Operations, Inc.
PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEST FOR RELIEF No. ISI-09 Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(i)
--Alternative Provides Acceptable Level of Quality and Safety--
- 1. ASME Code Component(s) Affected ASME Section XI, Class 1, Examination Category B-D, Item B3.90 - Pressure Retaining Nozzle-to-Vessel Welds
2. Applicable Code Edition and Addenda
1998 Edition with Addenda through 2000
- 3. Applicable Code RequirementsSection XI, Figure IWB-2500-7(b) specifies the examination volume for nozzle-to-vessel welds.
4. Reason for Request
To decrease the amount of time performing examination of unnecessary weld volume and to conserve radiological dose, while still maintaining an adequate level of quality and safety for examination of the affected welds.
- 5. Proposed Alternative In lieu of the requirements of ASME Section XI, 1998 Edition, 2000 Addenda, Figure IWB-2500-7(b), it is proposed to use the alternative examination volume requirements of Code Case N-613 and its Figure 2.
Basis for Use The examination volume for the reactor vessel pressure retaining nozzle-to-vessel welds extends far beyond the weld into the base metal, and is unnecessarily large. This prolongs the examination time significantly, and results in no net increase in safety, as the area being examined is a base metal region which is not prone to in-service cracking and has been extensively examined before the vessel was put into service, in addition to the first, second, and third interval examinations.
Appendix A PP 7015 Rev. 3 Page 38 of 57
APPENDIX A (Continued)
Code Case N-613 reduces the examination volume next to the widest part of the weld from half of the vessel wall thickness to one-half (1/2) inch. This removes examination of the base metal that was extensively examined during construction and in three subsequent in-service inspections. This region is not in the high residual stress region associated with the weld; cracks, should they initiate, occur in the high-stressed areas of the weld. These high-stressed areas are contained in the volume that is defined by Code Case N-613 and are subject to examination.
Code Case N-613 also eliminates the requirement to detect flaws perpendicular to the weld-base metal interface; however, relief for this aspect of Code Case N-613 is not being sought.
Compliance with the proposed alternatives described above in the above items will provide an adequate level of quality and safety for examination of the affected welds, and will not adversely impact the health and safety of the public.
- 6. Duration of Proposed Alternative It is proposed to use the alternative for the duration of the Vermont Yankee Fourth Ten-Year Interval (September 1, 2003 through August 31, 2013).
- 7. Precedents This proposed alternative is essentially identical to the model provided by the Performance Demonstration Initiative on the EPRI website.
Appendix A PP 7015 Rev. 3 Page 39 of 57
APPENDIX A (Continued)
LICENSEE/UTILITY NAME - Entergy Nuclear Operations, Inc.
PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEST FOR RELIEF No. ISI-10 Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(i)
--Alternative Provides Acceptable Level of Quality and Safety--
- 1. ASME Code Component(s) Affected ASME Section XI, Class 1, Pressure Retaining Welds in Piping, subject to Appendix VIII, Supplement 11, examination.
2. Applicable Code Edition and Addenda
1998 Edition with Addenda through 2000
- 3. Applicable Code Requirements The Code requirements for which relief is requested are all contained within Appendix VIII, Supplement I 1. For example, paragraph 1.1 (d)(1), requires that all base metal flaws be cracks.
Paragraph I.I(e)(l) 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.
4. Reason for Request
Section XI, Appendix VIII, Supplement 11 has not kept pace with the experience gained administering the Performance Demonstration Initiative. The proposed alternative is based on forthcoming Code action and was generated from a PDI model prepared by EPRI.
- 5. Proposed Alternative In lieu of the requirements of ASME Section XI, 1998 Edition, 2000 Addenda, Appendix VIII, Supplement 11, the proposed alternative described in the enclosure shall be used. The proposed alternative will be implemented through the PDI Program.
Appendix A PP 7015 Rev. 3 Page 40 of 57
APPENDIX A (Continued)
Basis for Use Paragraph 1.1(d)(1), requires that all base metal flaws be cracks. 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. 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.
E' i Mechanical fatigue crack (txareat I in Base matenial 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.l(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.l(e)(2)(b)(1) 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 I 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.
Appendix A PP 7015 Rev. 3 Page 41 of 57
APPENDIX A (Continued)
Additionally, the requirement for axially oriented overlay fabrication flaws in paragraph l.I(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 PDI Program because it is redundant to the RMS calculations performed in paragraph 3.2(c) and its presence adds confusion and ambiguity to depth sizing as required by paragraph 3.2(c). This also makes the weld overlay program consistent with the Supplement 2 depth sizing criteria.
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 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 remainder shall be alternativeflawvs" was added to the next to last sentence in paragraph 1.l(d)(1). These changes are identified by bold print in the third column of the enclosure.
Compliance with the proposed alternatives described above in the above items will provide an adequate level of quality and safety for examination of the affected welds, and will not adversely impact the health and safety of the public.
- 6. Duration of Proposed Alternative It is proposed to use the alternative for the duration of the Vermont Yankee Fourth Ten-Year Interval (September 1, 2003 through August 31, 2013).
- 7. Precedents This proposed alternative is essentially identical to the model provided by the Performance Demonstration Initiative on the EPRI website.
Appendix A PP 7015 Rev. 3 Page 42 of 57
APPENDIX A (Continued) 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 least No Change (b) The specimen set shall consist of at least three specimens having different nominal three specimens having different nominal pipe pipe diameters and overlay thicknesses. diameters and overlay thicknesses. They shall They shall include the minimum and include the minimum and maximum nominal maximum nominal pipe diameters for which pipe diameters for which the examination the examination procedure is applicable. procedure is applicable. Pipe diameters within Pipe diameters within a range of 0.9 to 1.5 a range of 0.9 to 1.5 times a nominal diameter times a nominal diameter shall be considered shall be considered equivalent. If the equivalent. If the procedure is applicable to procedure is applicable to pipe diameters of 24 pipe diameters of 24 in. or larger, the in. or larger, the specimen set must include at specimen set must include at least one least one specimen 24 in. or larger but need specimen 24 in. or larger but need not not include the maximum diameter. The include the maximum diameter. The specimen set shall include specimens with specimen set must include at least one overlays not thicker than 0.1 in. more than specimen with overlay thickness within -0.1 the minimum thickness, nor thinner than in. to +0.25 in. of the maximum nominal 0.25 in. of the maximum nominal overlay overlay thickness for which the procedure is thickness for which the examination applicable. procedure is applicable.
Appendix A PP 7015 Rev. 3 Page 43 of 57
APPENDIX A (Continued)
(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 (I) Base metalflaws. All flaws must be (1) Base metal flaws. All flaws must be in or (1) Base metal flaws. All flaws must be in or cracks in or near the butt weld heat-affected near the butt weld heat-affected zone, open to near the butt weld heat-affected zone, open to zone, open to the inside surface, and the inside surface, and extending at least 75% the inside surface, and extending at least 75%
extending at least 75% through the base through the base metal wall. Intentional through the base metal wall. Intentional metal wall. Flaws may extend 100% overlay fabrication flaws shall not interfere overlay fabrication flaws shall not interfere through the base metal and into the overlay with ultrasonic detection or characterization with ultrasonic detection or characterization of material; in this case, intentional overlay of the cracking. Specimens containing the base metal flaws. Specimens containing fabrication flaws shall not interfere with IGSCC shall be used when available. At least IGSCC shall be used when available. At least ultrasonic detection or characterization of 70 percent of the flaws in the detection and 70 percent of the flaws in the detection and the cracking. Specimens containing IGSCC sizing tests shall be cracks. Alternative flaw sizing tests shall be cracks and the remainder shall be used when available. mechanisms, if used, shall provide crack-like shall be alternative flaws. Alternative flaw reflective characteristics and shall be limited mechanisms, if used, shall provide crack-like by the following: reflective characteristics and shall be limited by the following:
(a) Flaws shall be limited to when implantation of cracks precludes obtaining a (a) Flaws shall be limited to the cases where realistic ultrasonic response. implantation of cracks produces spurious reflectors that are uncharacteristic of actual (b) Flaws shall be semielliptical with a tip flaws.
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.
Appendix A PP 7015 Rev. 3 Page 44 of 57
APPENDIX A (Continued)
(2) Overlayfabricationflaws. 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 base (1) At least 20 % but less than 40% of the flaws shall be oriented within +20 deg. of metal flaws shall be oriented within +20 deg. base metal flaws shall be oriented within the pipe axial direction. The remainder shall of the pipe axial direction. The remainder +20 deg. of the pipe axial direction. The be oriented circumferentially. Flaws shall shall be oriented circumferentially. Flaws remainder shall be oriented not be open to any surface to which the shall not be open to any surface to which the circumferentially. Flaws shall not be open candidate has physical or visual access. The candidate has physical or visual access. to any surface to which the candidate has rules of IWA-3300 shall be used to physical or visual access.
determine whether closely spaced flaws should be treated as single or multiple flaws.
(2) Specimens shall be divided into base and (2) Specimens shall be divided into base metal (2) Specimens shall be divided into base over-lay grading units. Each specimen shall and overlay fabrication grading units. Each metal and overlay fabrication grading contain one or both types of grading units. specimen shall contain one or both types of units. Each specimen shall contain one or grading units. Flaws shall not interfere with both types of grading units. Flaws shall not ultrasonic detection or characterization of other interfere with ultrasonic detection or flaws. characterization of other flaws.
(a)(l) A base grading unit shall include at (a)(l) A base metal grading unit shall include at (a)(l) A base metal grading unit includes least 3 in. of the length of the overlaid weld. least I in. of the length of the overlaid weld. The the overlay material and the outer 25% of The base grading unit includes the outer base metal grading unit includes the outer 25% the original overlaid weld. The base metal 25% of the overlaid weld and base metal on of the overlaid weld and base metal on both grading unit shall extend circumferentially both sides. The base grading unit shall not sides. The base metal grading unit shall not for at least 1 in. and shall start at the weld include the inner 75% of the overlaid weld include the inner 75% of the overlaid weld and centerline and be wide enough in the axial and base metal overlay material, or base base metal overlay material, or base direction to encompass one half of the metal-to-overlay interface. metal-to-overlay interface. original weld crown and a minimum of 0.50" of the adjacent base material.
Appendix A PP 7015 Rev. 3 Page 45 of 57
APPENDIX A (Continued)
(a)(2) When base metal cracking penetrates (a)(2) When base metal cracking penetrates into (a)(2) When base metal flaws penetrate into into the overlay material, the base grading the overlay material, the base metal grading unit the overlay material, the base metal grading unit shall include the overlay metal within 1 shall not be used as part of any overlay unit shall not be used as part of any overlay in. of the crack location. This portion of the fabrication grading unit. fabrication grading unit.
overlay material shall not be used as part of any overlay grading unit.
(a)(3) When a base grading unit is designed (a)(3) Sufficient unflawed overlaid weld and (a)(3) Sufficient unflawed overlaid weld and to be unflawed, at least I in. of unflawed base metal shall exist on all sides of the grading base metal shall exist on all sides of the overlaid weld and base metal shall exist on unit to preclude interfering reflections from grading unit to preclude interfering reflections either side of the base grading unit. The adjacent flaws. from adjacent flaws.
segment of weld length used in one base grading unit shall not be used in another base grading unit. Base grading units need not be uniformly spaced around the specimen.
(b)(l) An overlay grading unit shall include (b)(l) An overlay fabrication grading unit shall (b)(l) An overlay fabrication grading unit the overlay material and the base include the overlay material and the base shall include the overlay material and the base metal-to-overlay interface of at least 6 sq. in. metal-to-overlay interface for a length of at least metal-to-overlay interface for a length of at The overlay grading unit shall be I in. least I in.
rectangular, with minimum dimensions of 2 in.
Appendix A PP 7015 Rev. 3 Page 46 of 57
APPENDIX A (Continued)
(b)(2) An overlay grading unit designed to (b)(2) Overlay fabrication grading units designed (b)(2) Overlay fabrication grading units be unflawed shall be surrounded by to be unflawed shall be separated by unflawed designed to be unflawed shall be separated by unflawed overlay material and unflawed overlay material and unflawed base unflawed overlay material and unflawed base base metal-to-overlay interface for at least I metal-to-overlay interface for at least I in. at metal-to-overlay interface for at least I in. at in. around its entire perimeter. The specific both ends. Sufficient unflawed overlaid weld both ends. Sufficient unflawed overlaid weld area used in one overlay grading unit shall and base metal shall exist on both sides of the and base metal shall exist on both sides of the not be used in another overlay grading unit. overlay fabrication grading unit to preclude overlay fabrication grading unit to preclude Overlay grading units need not be spaced interfering reflections from adjacent flaws. The interfering reflections from adjacent flaws.
uniformly about the specimen. specific area used in one overlay fabrication The specific area used in one overlay grading unit shall not be used in another overlay fabrication grading unit shall not be used in fabrication grading unit. Overlay fabrication another overlay fabrication grading unit.
grading units need not be spaced uniformly Overlay fabrication grading units need not be about the specimen. spaced uniformly about the specimen.
(b)(3) Detection sets shall be selected from (b)(3) Detection sets shall be selected from Table (b)(3) Detection sets shall be selected from Table VIII-S2-1. The minimum detection VIII-S2-1. The minimum detection sample set is Table VIII-S2-1. The minimum detection sample set is five flawed base grading units, five flawed base metal grading units, ten sample set is five flawed base metal grading ten unflawed base grading units, five flawed unflawed base metal grading units, five flawed units, ten unflawed base metal grading units, overlay grading units, and ten unflawed overlay fabrication grading units, and ten five flawed overlay fabrication grading units, overlay grading units. For each type of unflawed overlay fabrication grading units. For and ten unflawed overlay fabrication grading grading unit, the set shall contain at least each type of grading unit, the set shall contain at units. For each type of grading unit, the set twice as many unflawed as flawed grading least twice as many unflawed as flawed grading shall contain at least twice as many unflawed units. units. For initial procedure qualification, as flawed grading units. For initial procedure detection sets shall include the equivalent of qualification, detection sets shall include the three personnel qualification sets. To qualify equivalent of three personnel qualification new values of essential variables, at least one sets. To qualify new values of essential personnel qualification set is required. variables, at least one personnel qualification set is required.
Appendix A PP 7015 Rev. 3 Page 47 of 57
APPENDIX A (Continued)
(I) 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 overlay ten. At least 30% of the flaws shall be overlay fabrication flaws. At least 40% of fabrication flaws. At least 40% of the flaws overlay fabrication flaws. At least 40% of the the flaws shall be cracks open to the inside shall be cracks open to the inside surface. For flaws shall be open to the inside surface.
surface. initial procedure qualification, sizing sets Sizing sets shall contain a distribution of shall include the equivalent of three personnel flaw dimensions to assess sizing qualification sets. To qualify new values of capabilities. For initial procedure essential variables, at least one personnel qualification, sizing sets shall include the qualification set is required. equivalent of three personnel qualification sets. To qualify new values of essential variables, at least one personnel qualification set is required.
(2) At least 20% but less than 40% of the No Change No Change flaws shall be oriented axially. The remainder shall be oriented circumferentially. Flaws shall not be open to any surface to which the candidate has physical or visual access.
(3) Base metal cracking used for length No Change (3) Base metal flaws used for length sizing sizing demonstrations shall be oriented demonstrations shall be oriented circumferentially. circumferentially.
(4) Depth sizing specimen sets shall include No Change (4) Depth sizing specimen sets shall include at least two distinct locations where cracking at least two distinct locations where flaws in the base metal extends into the overlay in the base metal extend into the overlay material by at least 0.1 in. in the material by at least 0.1 in. in the through-wall direction. through-wall direction.
Appendix A PP 7015 Rev. 3 Page 48 of 57
APPENDIX A (Continued) 2.0 CONDUCT OF PERFORMANCE CC N-654 PDI Program DEMONSTRATION The specimen inside surface and The specimen inside surface and identification The specimen inside surface and identification shall be concealed from the shall be concealed from the candidate. All identification shall be concealed from the candidate. All examinations shall be examinations shall be completed prior to grading candidate. All examinations shall be completed prior to grading the results and the results and presenting the results to the completed prior to grading the results and presenting the results to the candidate. candidate. Divulgence of particular specimen presenting the results to the candidate.
Divulgence of particular specimen results or results or candidate viewing of unmasked Divulgence of particular specimen results or candidate viewing of unmasked specimens specimens after the performance demonstration candidate viewing of unmasked specimens after the performance demonstration is is prohibited. The overlay fabrication flaw test after the performance demonstration is prohibited. and the base metal flaw test may be performed prohibited. The overlay fabrication flaw test separately. and the base metal flaw test may be performed separately.
2.1 Detection Test. PDI Program Flawed and unflawed grading units shall be Flawed and unflawed grading units shall be Flawed and unflawed grading units shall be randomly mixed. Although the boundaries randomly mixed. Although the boundaries of randomly mixed. Although the boundaries of of specific grading units shall not be specific grading units shall not be revealed to the specific grading units shall not be revealed to revealed to the candidate, the candidate shall candidate, the candidate shall be made aware of the candidate, the candidate shall be made be made aware of the type or types of the type or types of grading units (base metal or aware of the type or types of grading units grading units (base or overlay) that are overlay fabrication) that are present for each (base metal or overlay fabrication) that are present for each specimen. specimen. present for each specimen.
2.2 Length Sizing Test PDI Program (a) The length sizing test may be conducted No Change separately or in conjunction with the detection test.
Appendix A PP 7015 Rev. 3 Page 49 of 57
APPENDIX A (Continued)
(b) When the length sizing test is conducted No Change No Change in conjunction with the detection test and the detected flaws do not satisfy the requirements of 1.1 (f), additional specimens shall be provided to the candidate. The regions containing a flaw to be sized shall be identified to the candidate. The candidate shall determine the length of the flaw in each region.
(c) For a separate length sizing test, the No Change No Change regions of each specimen containing a flaw to be sized shall be identified to the candidate. The candidate shall determine the length of the flaw in each region.
(d) For flaws in base grading units, the (d) For flaws in base metal grading units, the (d) For flaws in base metal grading units, candidate shall estimate the length of that candidate shall estimate the length of that the candidate shall estimate the length of part of the flaw that is in the outer 25% of part of the flaw that is in the outer 25% of the that part of the flaw that is in the outer the base wall thickness. base metal wall thickness. 25% of the base metal wall thickness.
Appendix A PP 7015 Rev. 3 Page 50 of 57
APPENDIX A (Continued)
- l.
2.3 Depth Sizing Test. PDI Program PDI Pro2ram For Depth 2.3 Sizing the depth Test.
sizing test, 80% of the flaws 4
The candidate shall determine the depth of the 4
2.3 Depth Sizing Test shall be sized at a specific location on the flaw in each region. (a) The depth sizing test may be surface of the specimen identified to the conducted separately or in conjunction candidate. For the remaining flaws, the with the detection test.
regions of each specimen containing a flaw (b) When the depth sizing test is to be sized shall be identified to the conducted in conjunction with the candidate. The candidate shall determine detection test and the detected flaws do the maximum depth of the flaw in each not satisfy the requirements of 1.1(f),
region. additional specimens shall be provided to the candidate. The regions containing a flaw to be sized shall be identified to the candidate. The candidate shall determine the maximum depth of the flaw in each region.
(c) For a separate depth sizing test, the regions of each specimen containing a flaw to be sized shall be identified to the candidate. The candidate shall determine the maximum depth of the flaw in each region.
Appendix A PP 7015 Rev. 3 Page l of 57
APPENDIX A (Continued) 3.0 ACCEPTANCE CRITERIA 3.1 Detection Acceptance Criteria. CC N-654 PDI Program Examination procedures, equipment, and Examination procedures are qualified for a) Examination procedures are qualified personnel are qualified for detection when detection when all flaws within the scope of the for detection when; the results of the performance demonstration procedure are detected and the results of the All flaws within the scope of the procedure satisfy the acceptance criteria of Table performance demonstration satisfy the are detected and the results of the VIII-S2-1 for both detection and false calls. acceptance criteria of Table VIII-S2-l for false performance demonstration satisfy the The criteria shall be satisfied separately by calls. Examination equipment and personnel are acceptance criteria of Table VIII-S2-1 for the demonstration results for base grading qualified for detection when the results of the false calls.
units and for overlay grading units. performance demonstration satisfy the At least one successful personnel acceptance criteria of Table VIII-S2-l for both demonstration has been performed meeting detection and false calls. The criteria shall be the acceptance criteria defined in (b).
satisfied separately by the demonstration results b) Examination equipment and personnel for base metal grading units and for overlay are qualified for detection when the results of fabrication grading units. the performance demonstration satisfy the acceptance criteria of Table VIII-S2-1 for both detection and false calls.
(c) The criteria in (a), (b) shall be satisfied separately by the demonstration results for base metal grading units and for overlay fabrication grading units.
3.2 Sizing Acceptance Criteria. 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 flaw measurements, as compared to the true flaw lengths, is less than or equal to 0.75 inch. lengths, is less than or equal to 0.75 inch. The The length of base metal cracking is length of base metal flaws is measured at the measured at the 75% through-base-metal 75% through-base-metal position.
position.
Appendix A PP 7015 Rev. 3 Page 52 of 57
APPENDIX A (Continued)
(b) All extensions of base metal cracking into This requirement is omitted. This requirement is omitted.
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 flaw measurements, as compared to the true flaw measurements, as compared to the true flaw depths, is less than or equal to 0.125 in. depths, is less than or equal to 0.125 in. depths, is less than or equal to 0.125 in.
Appendix A PP 7015 Rev. 3 Page 53 of 57
APPENDIX A (Continued)
LICENSEE/UTILITY NAME - Entergy Nuclear Operations, Inc.
PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEST FOR RELIEF No. ISI-11 Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(i)
--Alternative Provides Acceptable Level of Quality and Safety--
- 1. ASME Code Component(s) Affected ASME Section XI, Class 1, Examination Category B-A, Code Item No. B 1.30
2. Applicable Code Edition and Addenda
1998 Edition with Addenda through 2000
- 3. Applicable Code Requirements ASME Section XI, 1998 Edition with Addenda through 2000, Appendix I, Subparagraph 1-21 10(b) requires that ultrasonic examination (UT) of reactor vessel flange-to-shell welds be conducted in accordance with Article 4 of ASME Section V, supplemented by the requirements of Table 1-2000-1. In addition, Regulatory Guide 1.150, Revision 1, "Ultrasonic Testing of Reactor Vessel Welds During Preservice and Inservice Examinations," serves as regulatory guidance for the UT examination of RPV welds.
4. Reason for Request
To gain ultrasonic technique and requirement synergy with the examination of the other RPV shell welds and to conserve radiological dose, while still maintaining an adequate level of quality and safety for examination of the affected weld.
- 5. Proposed Alternative It is proposed to use a Performance Demonstration Initiative (PDI) qualified procedure to complete the UT of the RPV vessel-to-flange weld in accordance with ASME Section XI, 1998 Edition with Addenda through 2000, Appendix VIII Supplements 4 and 6 as amended by the Federal Register Notice 67FR187, dated September 26, 2002.
Appendix A PP 7015 Rev. 3 Page 54 of 57
APPENDIX A (Continued)
Basis for Use Federal Register Notice 67FRl 87, dated September 26, 2002, requires that ASME Section XI, Appendix VIII, Supplement 4, "Qualification Requirements for the Clad/Base Metal Interface of Reactor Vessel", and Supplement 6, "Qualification Requirements for Reactor Vessel Welds other than Clad/Base Metal Interface", be implemented for most of the RPV welds, starting November 22, 2000. Per ASME Section XI, Appendix I, Subparagraph I-2110(b), reactor vessel-to-flange and head-to-flange welds are the only reactor vessel pressure boundary welds not included in Appendix VIII.
During the upcoming ten-year RPV weld examinations [due during the First Period of the Fourth Interval per IOCFR50.55a(g)], Vermont Yankee will be employing personnel, procedures, and equipment, demonstrated and qualified by the PDI and in accordance with ASME Code,Section XI, 1998 Edition, with Addenda through 2000, Appendix VIII, Supplements 4 and 6 as amended by the Federal Register Notice 67FR1 87, dated September 26, 2002 for examination of RPV shell welds.
Appendix VIII was developed to ensure the effectiveness of UT examinations within the nuclear industry by means of a rigorous item-specific performance demonstration. The performance demonstration is conducted on an RPV mockup containing flaws of various sizes and locations.
The demonstration establishes the capability of equipment, procedures, and personnel to find flaws that could be detrimental to the integrity of the RPV.
Although Appendix VIII is not a requirement for this weld, the qualification process to Appendix VIII criteria demonstrates that the examination and evaluation techniques are equal or surpass the requirements of Appendix I, Subparagraph 2110(b), ASME Section V, Article 4, and the guidance in RG 1.150.
A comparison between the ASME Section V, Article 4 based UT methods and the procedures developed to satisfy the PDI and Appendix VIII can be best described as a comparison between a compliance-based procedure (ASME Section V, Article 4) and a results-based procedure (PDI/Appendix VIII). ASME Section V, Article 4 procedures use an amplitude-based technique and a known reflector. The proposed alternate UT method was established independently from the acceptance standards for flaw size found in ASME Section XI.
A PDI-qualified sizing method is considered more accurate than the method used in ASME Code,Section V, Article 4. The proposed alternate UT examination technique provides an acceptable level of quality and examination repeatability as compared to the Article 4 requirements.
Appendix A PP 7015 Rev. 3 Page 55 of 57
APPENDIX A (Continued)
Vermont Yankee will obtain the examination vendor's Performance Demonstration Qualification Sheet (PDQS), which will attest that their procedure is in compliance with the detection and sizing tolerance requirements of Appendix VIII. The PDI qualification method is based on a group of samples, which validate the acceptable flaw sizes in ASME Section XI. The sensitivity necessary to detect these flaws is considered to be equal to or better than the sensitivity obtained through ASME Section V, Article 4, because sensitivity necessary to detect implanted cracks is generally better than that necessary to calibrate on a machined notch.
The examination and sizing procedures for all potential qualified examination vendors use echo-dynamic motion and tip diffraction characteristics of the flaw instead of the amplitude characteristics required by ASME Section V, Article 4. The search units are required to interrogate the same examination volume as depicted by ASME Section XI, Figure IWB-2500-4 for the shell-to-flange weld joint.
Procedures used for satisfying the requirements of ASME Section V, Article 4 for the UT examination of the RPV-to-flange weld has not undergone such a rigorous demonstration or received the same qualifications as a PDI qualified procedure.
The Vermont Yankee shell-to-flange geometry compares very favorably with the geometry of the PDI qualification specimens. The inside diameter surface (the scan surface) of the shell-to-flange weld and adjacent base material is theoretically a cylinder; there is no taper associated with this joint on the RPV ID at Vermont Yankee. The shell base material thickness (excluding clad) is 5 5/16". The flange thickness (excluding clad) within the extremity of the required examination volume is 10 5/8". Vermont Yankee will require that the vendor's PDQS bound this thickness range. It is expected that an examination will be able to be performed from both the shell and the flange sides of the weld.
The shell-to-flange weld was examined radiographically and ultrasonically as a part of the RPV fabrication. During the second ten-year inservice inspection interval this weld was re-examined.
In 1996, the weld was examined by remote automated inspection per IOCFR50a(g) during the first period of the third ten-year inservice inspection interval. This last examination was conducted in accordance with Appendix VIII using PDI-demonstrated procedures, even though Appendix VIII was not mandatory at the time.
If Vermont Yankee were to conduct examination of the RPV vessel-to-flange weld in accordance with ASME Section V, Article 4 and RG 1.150, it is expected that the examination would be performed using manual techniques from the vessel OD inside the drywell at the top of the bio-shield wall, and also from the vessel flange mating surface in the reactor refueling cavity.
The use of Appendix VIII Supplements 4 and 6 for examination of this weld using remote automated inspection tooling is expected to significantly reduce personnel radiation exposure.
Compliance with the proposed alternatives described above will provide an adequate level of quality and safety for examination of the affected welds, and will not adversely impact the health and safety of the public.
Appendix A PP 7015 Rev. 3 Page 56 of 57
APPENDIX A (Continued)
- 6. Duration of Proposed Alternative It is proposed to use the alternative for the Vermont Yankee Fourth Ten-Year Interval (September 1, 2003 through August 31, 2013).
- 7. Precedents The NRC has granted similar relief to Salem Generating Station, Unit 1 (Reference 1),
Comanche Peak Steam Electric Station, Unit 2 (Reference 2), Point Beach Unit 2 (Reference 3),
Cooper Nuclear Station (Reference 4), and San Onofre Nuclear Generating Station, Unit 3 (Reference 5).
- 8. References Letter from J. Clifford (NRC) to H. W. Keiser (PSEG Nuclear) dated May 3, 2001, "Salem Nuclear Generating Station, Unit No. 1-Relief from ASME Code Requirements Related to the Inservice Inspection Program, Second 10-Year Interval, Relief Request RR-B I I (TAC No.
MB1234)
Letter from Robert A. Gramm (NRC) to C. Lance Terry (TXU Generation Company) dated April 16, 2002, "Comanche Peak Steam Electric Station (CPSES), Unit-2, Re: First 10-Year Inservice Inspection (ISI) Interval Request for Relief from the Requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) concerning Relief Requests A-4, Revision 1; A-5, Revision 2; A-6, A-7 and A-8 (TAC No. MB3039)
Appendix A PP 7015 Rev. 3 Page 57 of 57
APPENDIX B I -' Item Number/Comments II Iv -a v- I 131.11 131.12 BI1.21 BL1.22 B 1.30 B 1.40 Bi .51 AM ASME Section XI,;Table IWB-2500-1 and Vermont Yankee Request for Relief # ISI 05 bases.- In accordance with the Final Safety 4 8 2 16 1 1 0 Evaluation of BWRVIP-05 a'volumetric examination of essentially 100% of the weld length of all axial pressure retaining shell welds, Item 1B1.12, including those portions of the circumferential shell welds that C en 100% 100% 100% 100% 100% N/A would be examined with the axial welds at their intersections, will be Comment v performed. o 0 8 2 16 1 1 0 pfom B2.21 B2.22 B2.51 B2.52 B2.60 B2.70 B2.80
- S C No B-B Category welds exist at Vermont Yankee See Comment v*- r B3.90 B3.100 B3.150 B3.160 ASME Section XL Table IWB-2500-1 bases.
29 29 0 0 In accordance with Request for Relief #ISI 08 Code Case N-613 is used for examination of Item B3.90 welds in the axial direction only. '
100% 100% N/A N/A 29 29 0 0 - Code Case N-552 is used for Item B3.100 nozzle inner radius miodeling'. -v B5.10 B5.20 B5.30 B5.100 B5.110 B5.120 ASME Section XI, Table IWB-2500-1 bases.
and
.Vermont Yankee Request for Relief #IS1 04 which allows the use'of Code Case 18 5 0 0 0 0 N-662 which eliminates surface examination for Item B5.10 welds.
Request for Relief #ISI 06 allows the use of BWRVIP-75 for examination 100% 100% N/A N/A N/A N/A frequency for overlaid piping.
Request for Relief # ISI 10 grants the use of PDI for Supplement 10 18 5 0 0 0 0 -qualification.
Request for Relief #ISI 09 grants the use of PDI for Supplement 11 1__ __ ,_
_ _'qualification.
Appendix B PP 7015 Revision 3 Page 1 of 8
APPENDIX B (Continued)
B6.10 B6.20 I B6.30 B6.40 B650 B6.180 B6.190 B6.200 Item numbers B6.120, B6.130, B6.140, B6.150, B6.160, B6.170,
'B2.10, B2.20 and B2.30 are not 64 64 64 64 32 2 32 applicable to Vermont Yankee.
In'accordancee'with Request for-100% i100% See 100% 100% , 100% 100% 100% Relief # ISI 03 Code Case N-652 is Comment used for examination method and When When When Disass- selection criteria.-Item number 64 64 64 16 Disass- B6.30 does not exist in Code Case Removed embled embled N-652. -
B7.10 B7.40 B7.50 B7.60 B7.70 B7.80
. \ A.I-IE Section XI, Table'IVM-2500-1 bases.
0The B7.80 Item is eliminated from the'ASME Section XI 1998 0 0 3 0 43 89 Edition through 2000 Addenda, however, the VT-I examination,
'is required when the connection is disassembled by the N/A N/A 100% N/A 100% 100% IOCFR50.55a Rulemaking, Volume 66, No. 150.
When When When 0 0 Disass- 0 Disass- Disass- Inaccordance With Request for Relief #ISI 03 Code Case N-652-i used for examination method and selection criteria.
is embled embled embled B9.11 B9.18 None B9.32 B9.40 -ASME Section XI, Table IWB-2500-1 bases.- -
The Item B9.1 1, B9.18 and "None"'selections are done in accordance with Code, 432 3 82 'Case N-560 10% selection criteria. "None" are items that in accordance with -
Code Case N-560'no degradation mechanism was identified but are included in the selection population. Item B9.40, socket welds, are not included in the Code -
10% 10% 25% § Case N-560 population, they3are selected in accordance with the'ASME Section XI, 1998 Edition through 2000 Addenda 25% selection criteria.*
Request for Relief# ISI 02 approves the use of Code Case N-560.
43 1 21 Appendix B PP 7015 Revision 3 Page 2 of 8
APPENDIX B (Continued)
_III eo Item Number/Comments I Tntnal B10.10 B 10.20 B 10.30 B 10.40 ASME Section XI, Table IWB-2500-1 bases.
5 7 0 0 In accordance with ASME Section XI, 1998 Edition, through 2000 Addenda, Table IWB-2500-1, CategoryB-K, Item B10.10, Note4 states: ."Formultiple vessels of similar design, function and service, only one welded attachment of only one of the~
See 10% NIA N/A multiple vessels shall be selected for examination: Item B 10.20, Note 5 states "For Comment piping, pumps, and valves, a saimjple of 10% of the welded attachments associated with the component supports selected for examination under IWF-2510 shall be examined." Also, ASME Section XI, 1998 Edition through 2000 Addenda, Item #
2 1 0 0 B 10.10, allows single sided surface examination, however, the 10 CFR 50.55a Rulemaking, Vol. 66 requires both sides be examined.
B12.10 X . -
Coment .No B-L-1 Category welds exist at Vermont Yankee -
Comment- * .- . . -- -I )
B 12.20 , ,
2 In accordance with ASME Section XI, 1998 Edition, through 2000 Addenda, Table IWB-2500-1, Category B-L-2, 100% . Item B 12.20, Notes 1 and 2 only one (1) pump in a group of pumps are required to be examined and then oinly when See . -. . disassembled for maintenance, repair, or volumetric examination. ,
S eea nt - -
Comment . *.f Appendix B PP 7015 Revision 3 Page 3 of 8
APPENDIX B (Continued) 1 Li I L . %JU I L. ILz..
No B-M-1 Category welds exist at Vermont Yankee See Comment B 12.. 0 ..
B 12.50 In-accordance with ASME Section XI, 1998 Edition, through 2000 Addenda, Table IWB-2500-1, Category B-M-2, 43,Item B 12.50 "Examination is required only when a pump or valve is disassembled for maintenance, repair, or 1- r v volumetric examination."
0 B13.10 - --
- The examination requirements for Category B-N-I are defined in Program Procedure PP 7027 "Reactor Vessel See Comment Internals Inspection Program".
B 13.20 B 13.30 B 13.40
_`.The examination requirements for Category B-N-2 are defined in Program Procedure See Comment PP 7027 "Reactor Vessel Internals Inspection'Program".
B 14.10 56 zASME Section XI, Table IWB-2500-1 bases.
10%
6 The examination selection and frequency for Category B-P is defined in Program Procedure PP 7034 "Inservice Inspection Pressure Test
- - - .- I Program".
Appendix B PP 7015 Revision 3 Page 4 of 8
APPENDIX B (Continued)
________111.
~MI Ie1,,v,, -MeM Item Number/Comments
--- ¢ _
I CL.1O CI.20 C1.30 - -
6 2 0 . . i In accordance with ASME Section XI, 1998 Edition; through 2000 Addenda, Table 1WC-2500-1, Category C-A examinations may be'limited to one-vessel or distributed among multiple similar See See N/A - X vessels. Item C1.10 is limited to gross structural discontinuities only.
Comment Comment 3 1 0 C2.11 C2.21 C2.22 C2.31 C2.32 C2.33 , ', , _
. 2In accordance with ASME Section XI, 1998 Edition, through 2000 Addenda, Table IWC-2500-1, Category C-B.
0examinations may be limited to one vessel or distributed
- among multiple similar vessels. The two Item C2.33 N/A N/A N/A See N See examinations are performed in accordance with Program Comment NA Comment Procedure PP 7034 'Inservice Inspection Pressure Test 0 0 0 2 0 2 Program".
C3.10 C3.20 C3.30 C3.40 'ASME Section XI, 1998 Edition, through 2000 Addenda, Table IWC-2500-1, 9 15 2 0 Category C-C, Note 4 states: "For multiple vessels of similar design, function and service, only one welded attachment of only one of the multiple vessels shall be selected for examination." Note 5 states: "For piping, pumps, and valves, a sample of See See See N/A 10%'of the welded attachments associated with the component supports selected for Comment Comment Comment examination under IWF-2510 shall be examined.":Also, Note 6 states: "Examination is required whenever component support member deformation, e.g. broken, bent, or 2 2 1 0 pulled out parts, is identified during operation, refueling, maintenance, examination or
,- ~ ^testing." .
Appendix B PP 7015 Revision 3 Page 5 of 8
APPENDIX B (Continued)
C4.10 I C4.20 I C4.30 I C4.40 No Category C-D bolting exists at Vermont .Yankee.
See Comment C5.11 C5.21 C5.30 C5.41 No Category C-F-1 welds exist at Vermont Yankee.,,
See Comment C5.51 C5.61 C5.70 C5.81 820 0 0 15 Section XI Table IWC-2500-1 bases, including Vermont Yankee Request for Relief# ISI 04 which allows the use of Code Case N-662 which eliminates surface examination for Item C5.51 and C5.81 7.5% N/A N/A 7.5% welds; - - . - - - -
62 0 0 1 A . _
C6.10 C6.20 - . -
-No Category C-G welds exist at.Vermont Yankee. ,
See Comment
' - I I , , I I ,F L The examination selection and frequency for Category C-H is defined in Program Procedure PP 7034 "Inservice Inspection Pressure Test
- - ' Program". - ..
Appendix B PP 7015 Revision 3 Page 6 of 8
APPENDIX B (Continued)
.r MEl-i I I11_
.Item Number/Comments .I Totals I D1.10 I2I _ Iks9 ASME Section XI, Table IWD-2500-1 bases.
2 ASME Section XI, 1998 Edition, through 2000 Addenda, Table IWD-2500-1, Category D-A Note 3 states: .. AII welded attachments selected for exam ination shall be those most subject to corrosion, as,-'
10% determined by the Owner, such as the welded attachments of the Service Water or Emergency Service Water systems. For multiple vessels of similar design, function and service, the welded attachments of only one of the multiple vessels shall be selected for examination. For welded attachments of piping, pumps and valves, a 10% sample shall be selected for examination. This percentage sample shall be 1 proportional to the total number of nonexempt welded attachments connected to the piping, pumps and
-valves in each system subject to these examinations.
The examination selection and frequency for Category D-B is defined in Program Procedure PP 7034 "Inservice Inspection Pressure Test
-v ? - - Program". - i _
Appendix B PP 7015 Revision 3 Page 7 of 8
APPENDIX B (Continued)
_ I 1,1I111111I 11IM1- uppo- i_ _ - ---- lgollllilli Item Number *- Comments I Totals. -I F1.10 F1.20 F1.30 F11.40
- -- , .t.Section XI, Table IWF-2500- 1bases. "
100 219 254 49 ASME Section XI, 1998 Edition, through 2000 Addenda, Table IWF-2500- 1, Category F-A, Item
-F1.40, Note 3 states: "For multiple components other than piping, within a system of similar design, 25% 15% 10% See function, and service, the supports of only one of the multiple components are required to be Comment examined." -
25 34 25 25 4I Appendix B PP 7015 Revision 3 Page 8 of 8