ML032600852

Inservice Inspection Program Relief Request S2-I2-RR-A16

ML032600852
Person / Time
Site:	Salem
Issue date:	09/10/2003
From:	Salamon G Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LRN-03-0396
Download: ML032600852 (24)

Text

I PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 SEP 1 0 2003 LRN-03-0396 United States Nuclear Regulatory Commission Q PSEG Document Control Desk NuclearLLC Washington, DC 20555-001 INSERVICE INSPECTION PROGRAM RELIEF REQUEST S2-12-RR-A16 SALEM UNIT 2 GENERATING STATION FACILITY OPERATING LICENSE NO. DPR-75 DOCKET NO.60-311 Pursuant to 10 CFR 50.55a(a)(3), PSEG Nuclear, LLC (PSEG Nuclear) requests approval of the enclosed relief request. Approval for relief is requested in accordance with the alternative examination provisions of IOCFR50.55a(a)(3)(i). PSEG Nuclear proposes to use an alternative performance demonstration method for ultrasonic examination of Salem Generating Station Unit 2 system piping.

Specifically, this proposed alternative concerns dissimilar metal piping welds as implemented by the American Society of Mechanical Engineers (ASME) Code Section Xl, Rules for Inservice Inspection of Nuclear Power Plant Components, 1995 Edition, 1996 Addenda, Appendix VIII, Supplement 10, Qualification Requirements for Dissimilar Metal Piping Welds. The proposed alternative is described in Enclosure 1. Enclosure 2 contains a copy of the proposed revisions to Supplement 10 as provided by the Performance Demonstration Initiative (PDI). The proposed revisions provided by the PDI identify additional clarifications and enhancements. Based on the evaluation contained in the enclosure, PSEG Nuclear has concluded that the proposed alternative provides an acceptable level of quality and safety. Accordingly, this proposal satisfies the requirements of 10 CFR 50.55a(a)(3)(i).

This relief request is applicable to PSEG Nuclear Salem Generating Station Unit 2.

PSEG Nuclear requests that the NRC approve this request by October 2003 in order to support Salem Unit 2 refueling outage 2R1 3 scheduled to commence October 10, 2003.

Should you have any questions regarding this request, please contact Mr. Howard Berrick at 856-339-1862.

69& G. alamon Manager - Nuclear Safety and Licensing

Enclosures:

1. ISI Relief Request S2-12-RR-A16

2. Supplement 10- Qualification Requirements For Dissimilar Metal Piping Welds A/50F7 05-2168 REV. 7/9

Document Control Desk LR-N03-0396 SEP 1 a 2003 C

Mr. H. Miller, Administrator Regional Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. R. Fretz Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08B2 11555 Rockville Pike Rockville, MD 20852 USNRC Senior Resident Inspector - Salem (X24)

Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P.O. Box415 Trenton, NJ 08625

Document Control Desk Enclosure I LR-N03-0396 Relief Request S2-12-RR-A16 ASME Code Component(s) Affected Dissimilar metal piping welds subject to examination using procedures, personnel and equipment qualified to ASME Xl, Appendix Vil, Supplement 10 criteria.

Applicable Code Edition and Addenda

The code of record for Salem Unit 2 ISI Program is Section Xl of the ASME Code, 1986 Edition.

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

1.

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

2.

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

3.

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

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.

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%.

6.

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

7.

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

Proposed Altemative In Accordance with 10 CFR 50.55a(a)(3)(i)

- Altemative Provides Acceptable Level of Quality and Safety -

Page 1 of 7

Document Control Desk Enclosure I LR-N03-0396 Relief Request S2-12-RR-A16

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.

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.

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.

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

Proposed Alternative and Basis for Use Pursuant to I OCFR50.55a(a)(3)(i), PSEG Nuclear LLC (PSEG) requests relief to use the following alternative requirements for implementation of Appendix Vill, Supplement 10 requirements. They will be implemented through the PDI Program. is a table of the proposed revision to Supplement 10. It identifies the proposed alternatives and allows them to be viewed in context. It also identifies additional clarifications and enhancements for information. This has been submitted to the ASME Code Committee for consideration.

1. The proposed alternative to Paragraph 1.1(b) states:

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

+25% is acceptable."

Technical Basis - The change in the minimum pipe diameter tolerance from 0.9 times the diameter to the nominal diameter minus 0.5 inch provides tolerances more in line with industry practice. Though the alternative is less stringent for small pipe diameters, they typically have a thinner wall thickness than larger diameter piping. A thinner wall thickness results in shorter sound path distances Proposed Altemative In Accordance with 10 CFR 50.55a(a)(3)(i)

- Alternative Provides Acceptable Level of Quality and Safety -

Page 2 of 7

Document Control Desk Enclosure I LR-N03-0396 Relief Request S2-12-RR-A16 that reduce the detrimental effects of the curvature. This change maintains consistency between Supplement 10 and the recent revision to Supplement 2.

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. (0.05 mm).

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. 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."

Won

~~~Mechanical fatigue crack

] i~r I

/

l hin base matenral

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. The metallurgical structure of Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

- Alternative Provides Acceptable Level of Quality and Safety -

Page 3 of 7

Document Control Desk Enclosure I LR-N03-0396 Relief Request S2-12-RR-A16 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.

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

"Detection sets shall be selected from Table VIll -S 0-1. The number of unflawed grading units shall be at least one and a half times the number of flawed grading units."

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

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

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 (below) for all qualifications.

Flaw Depth Minimum Number of Flaws 10-30%

20%

31-60%

20%

61-100%

20%

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

Technical Basis - The proposed alternative uses the depth sizing distribution for both detection and depth sizing because it provides for a better distribution of flaw sizes within the test set. This distribution allows candidates to perform detection, length, and depth sizing demonstrations simultaneously utilizing the same test set. The requirement that at least 75% of the flaws shall be in the range of 10 to 60% of wall thickness provides an overall distribution tolerance yet the distribution uncertainty decreases the possibilities for testmanship that would be inherent to a uniform distribution. It must be noted that it is possible to achieve Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

- Alternative Provides Acceptable Level of Quality and Safety -

Page 4 of 7

Document Control Desk Enclosure I LR-N03-0396 Relief Request S2-12-RR-A16 the same distribution utilizing the present requirements, but it is preferable to make the criteria consistent.

6.

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.

7. 1 _ The proposed alternatives to Paragraph 2.2(b) and 2.2(c) state:

8.

j

• .. 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.

9. 1 _ The proposed alternative to Paragraph 2.3(a) and 2.3(b) state:

10. j

"... 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 Proposed Altemative In Accordance with 10 CFR 50.55a(a)(3)(i)

- Altemative Provides Acceptable Level of Quality and Safety -

Page 5 of 7

Document Control Desk LR-N03-0396 Enclosure I Relief Request S2412-RR-A16 Supplement 2. It also incorporates terminology from length sizing for additional clarity.

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

TABLE VII 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

laa o

6 6

12 1

7 6

14 1

e 7

2 9

7 is 2

10 8

-20. 15 2

11 9

te-17 3

12 9

14-18 1-3 13 10 2

20 3 14 10 28 21 e 3 15 11 3D 23

-5 3

16 12 3T24 4

17 12 3

26 4

18 13 36-27 7

4 19 13 W 29 74 20 14

-4 30 5 Technical Basis - The proposed alternative is identified as new Table S1 0-1 above. It was modified to reflect the reduced number of unflawed grading units and allowable false calls. As a part of ongoing Code activities, Pacific Northwest National Laboratory (PNNL) has reviewed the statistical significance of these revisions and offered the revised Table S10-1.

Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

- Alternative Provides Acceptable Level of Quality and Safety -

Page 6 of 7

Document Control Desk Enclosure I LR-N03-0396 Relief Request S2-12-RR-A16 Duration of Proposed Alternative Salem Unit 2-Second Ten-Year Interval (ASME Xl 1986 Edition)

Precedents None References

1. Hope Creek Relief Request HC-RR-A08 (TAC # MB8761)

2. Exelon Nuclear Limerick Generating Station Units I & 2, Alternative Number VIII-4

3. San Onofre Nuclear Generating Station Unit 3, Relief Request B-2-06

4. South Carolina Electric & Gas Co., V.C. Summer Nuclear Station Relief Request RR-11-20.

Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

- Alternative Provides Acceptable Level of Quality and Safety -

Page 7 of 7

Document Control Desk LR-N03-0396 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning 1.0 SCOPE Supplement 10 Is applicable to dissimilar A scope statement provides added clarity metal piping welds examined from either regarding the applicable range of each the nsid oroutsde srfae. Sppleent individual Supplement. The exclusion of 10 is not applicable to piping welds CRC provides consistency between 10ntisnot applmable t opige Supplement 10 and the recent revision to containing supplemental corrosion Splmn RfrneiC0-5) resistant clad (CRC) applied to mitigate Supplement 2 (Reference BC 00-755).

Intergranular Stress Corrosion Cracking as "in course of preparatioe idenifying CRC (IGSCC).

processed separately.

1.0 SPECIMEN REQUIREMENTS 2.0 SPECIMEN REQUIREMENTS Renumbered.

Qualification test specimens shall meet Qualification test specimens shall meet the No Change.

the requirements listed herein, unless a requirements listed herein, unless a set of set of specimens is designed to specimens is designed to accommodate accommodate specific limitations stated specific limitations stated in the scope of the 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 specimens may be used to demonstrate same specimens may be used to both detection and sizing qualification.

demonstrate both detection and sizing qualification.

1.1 General. The specimen set shall 2.1 General. The specimen set shall conform Renumbered.

conform to the following requirements.

to the following requirements.

Renumbered.

(a) The minimum number of flaws in a test New. Changed minimum number of flaws to set shall be ten.

10 so sample set size for detection is consistent with length and depth sizing.

Proposed Alternative In Accordance with 10 CFR 50.55a(a) (3) (1)

- Alternative Provides Acceptable Level of Quality and Safety -

Page 1 of 15

Document Control Desk LR-N03-0396 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (a) Specimens shall have sufficient volume (b) Specimens shall have sufficient volume Renumbered.

to minimize spurious reflections that may to minimize spurious reflections that may interfere with the interpretation process.

interfere with the interpretation process.

(b) The specimen set shall include the (c) The specimen set shall include the Renumbered, metricated, the change in minimum and maximum pipe diameters minimum and maximum pipe diameters and pipe diameter tolerance provides and thicknesses for which the examination thicknesses for which the examination consistency between Supplement 10 and procedure is applicable. Pipe diameters procedure is applicable. Pipe diameters the recent revision to Supplement 2.

within a range of 0.9 to 1.5 times a nominal within a range of 112 In. (13 mm) of the (Reference BC 00-755) diameter shall be considered equivalent.

nominal diameter shall be considered Pipe diameters larger than 24 in. shall be equivalent. Pipe diameters larger than 24 considered to be flat. When a range of in. (610 mm) shall be considered to be flat.

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

examined, a thickness tolerance of +25% is acceptable.

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

conditions:

(1) geometric conditions that normally (1) geometric and material conditions that Clarification, some of the items listed relate require discrimination from flaws (e.g.,

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

proximity);

proximity, and weld repair areas);

Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

- Alternative Provides Acceptable Level of Quality and Safety -

Page 2 of 15

Document Control Desk LR-N03-0396 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (2) typical limited scanning surface (2) typical limited scanning surface Differentiates between ID and OD conditions (e.g., diametrical shrink, single-conditions (e.g., weld crowns, diametrical scanning surface limitations. Requires that side access due to nozzle and safe end shrink, single-side access due to nozzle ID and OD qualifications be conducted external tapers).

and safe end external tapers for outside independently (Note, new paragraph 2.0 surface examinations; and Internal (identical to old paragraph 1.0) provides for tapers, exposed weld roots, and alternatives when "a set of specimens is cladding conditions for inside surface designed to accommodate specific examinations). Qualification limitations stated in the scope of the requirements shall be satisfied examination procedure.").

separately for outside surface and inside surface examinations.

(d) All flaws in the specimen set shall be Deleted this requirement, because new cracks.

paragraph 2.3 below provides for the use of nalternative flaws' in lieu of cracks.

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

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

material.

Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

- Alternative Provides Acceptable Level of Quality and Safety -

Page 3 of 15

Document Control Desk LR-N03-0396 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (2) At least 50% of the cracks in austenitic 2.3 Flaw Type.

Renumbered and re-titled. Alternative base material shall be either IGSCC or (a) At least 60% of the flaws shall be flaws are required for placing axial flaws in thermal fatigue cracks. At least 50% of the cracks, the remainder shall be the HAZ of the weld and other areas where cracks in ferritic material shall be alternative flaws. Specimens with implantation of a crack produces mechanically or thermally induced fatigue IGSCC shall be used when available.

metallurgical conditions that result in an cracks.

Alternative flaws, if used, shall provide unrealistic ultrasonic response. This is crack-like reflective characteristics and consistent with the recent revision to shall be limited to the case where Supplement 2 (Reference BC 00-755).

implantation of cracks produces spurious reflectors that are The 40% limit on alternative flaws is uncharacteristic of actual flaws.

needed to support the requirement for up Alternative flaw mechanisms shall have to 70% axial flaws. Metricated a tip width of less than or equal to 0.002 In. (0.05 mm).

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

above.

longer appropriate.

Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

- Alternative Provides Acceptable Level of Quality and Safety -

Page 4 of 15

Document Control Desk LR-N03-0396 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning 2.4 Flaw Depth. All flaw depths shall be Moved from old paragraph 1.3(c) and 1.4 greater than 10% of the nominal pipe wall and re-titled. Consistency between thickness. Flaw depths shall exceed the detection and sizing specimen set nominal clad thickness when placed in requirements (e.g., 20% vs. 1/3 flaw depth cladding.

increments, e.g., original paragraph 1.3(c))

Flaws In the sample set shall be distributed as follows:

Flaw Depth Minimum

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

20%

31-60%

20%

61-100%

20%

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

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

Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

- Alternative Provides Acceptable Level of Quality and Safety -

Page 5of15

Document Control Desk LR-N03-0396 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (a) Specimens shall be divided into grading Renumbered to paragraph 3.1(a)(1).

units. Each grading unit shall include at No other changes.

least 3 in. of weld length. If a grading unit is designed to be unflawed, at least 1 in. of unflawed material shall exist on either side of the grading unit. The segment of weld length used in one grading unit shall not be used in another grading unit. Grading units need not be uniformly spaced around the pipe specimen.

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

Table Vill-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 and type.

requirements moved to new paragraph 2.5, flaw type requirements moved to new paragraph 2.3, "Flaw Type".

Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

- Alternative Provides Acceptable Level of Quality and Safety -

Page 6 of 15

Document Control Desk LR-N03-0396 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (1) All flaw depths shall be greater than Deleted, for consistency in sample sets the 10% of the nominal pipe wall thickness. At depth distribution is the same for detection least 1/3 of the flaws, rounded to the next and sizing.

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

(2) At least 30% and no more than 70% of 2.5 Flaw Orientation.

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

circumferentially.

remainder of the flaws shall be oriented circumferentially.

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

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

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

above Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

- Alternative Provides Acceptable Level of Quality and Safety -

Page 7 of 15

Document Control Desk LR-N03-0396 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (c) All flaw depths shall be greater than Moved, included in new paragraph 2.4 10% of the nominal pipe wall thickness. At above after revision for consistency with least V3 of the flaws, rounded to the next detection distribution higher whole number, shall have depths between 10% and 30% of the nominal pipe wall thickness. However, flaw depth shall exceed the nominal clad thickness when placed in cladding. At least 1/3 of the flaws, rounded to the next whole number, shall have depths greater than 30% of the nominal pipe wall thickness.

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

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

Proposed Alternative In Accordance with 10 CFR 50.55a(a) (3) (i)

- Alternative Provides Acceptable Level of Quality and Safety -

Page 8 of 15

Document Control Desk LR-N03-0396 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (b) Flaws in the sample set shall not be Moved, potential conflict with old wholly contained within cladding and shall paragraph 1.2(c)(1); "However, flaw depths be distributed as follows:

shall exceed the nominal clad thickness when placed in cladding.". Revised for clarity and included in new paragraph 2.4 epth Minimum Moved, included in paragraph 2.4 for

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

20%

sizing samples.

31-60%

20%

61-100%

20%

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

(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 Included for clarity. Previously addressed as in 2.5(a).

by omission (i.e., length, but not depth had a specific exclusionary statement)

Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

- Alternative Provides Acceptable Level of Quality and Safety -

Page 9 of 15

Document Control Desk LR-N03-0396 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning 2.0 CONDUCT OF PERFORMANCE 3.0 CONDUCT OF PERFORMANCE Renumbered DEMONSTRATION DEMONSTRATION The specimen inside surface and For qualifications from the outside Differentiate between qualifications identification shall be concealed from the surface, the specimen Inside surface and conducted from the outside and inside candidate. All examinations shall be identification shall be concealed from surface.

completed prior to grading the results and the candidate. When qualifications are presenting the results to the candidate.

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

prior to grading the results and presenting the results to the candidate. Divulgence of particular specimen results or candidate viewing of unmasked specimens after the performance demonstration is prohibited.

2.1 Detection Test Flawed and unflawed 3.1 Detection Qualification.

Renumbered, moved text to paragraph grading units shall be randomly mixed 3.1 (a)(3)

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

requirements.

Proposed Altemative In Accordance with 10 CFR 50.55a(a)(3)(i)

- Altemative Provides Acceptable Level of Quality and Safety -

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Document Control Desk LR-N03-0396 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (1) Specimens shall be divided into grading Renumbered, moved from old paragraph units. Each grading unit shall include at 1.2(a). Metricated. No other changes.

least 3 in. (76 mm) of weld length. If a grading unit is designed to be unflawed, at least 1 in. (25 mm) of unflawed material shall exist on either side of the grading unit.

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

(2) Detection sets shall be selected from Moved from old paragraph 1.2(b). Table Table Vill-S10-1. The number of unflawed revised to reflect a change in the minimum grading units shall be at least one and a sample set to 10 and the application of half times the number of flawed grading equivalent statistical false call parameters units.

to the reduction in unflawed grading units.

Human factors due to large sample size.

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

(b) Examination equipment and personnel Moved from old paragraph 3.1. Modified to are qualified for detection when personnel reflect the 100% detection acceptance demonstrations satisfy the acceptance criteria of procedures versus personnel and criteria of Table Vil S10-1 for both detection equipment contained in new paragraph 4.0 and false 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.

Proposed Altemative In Accordance with 10 CFR 50.55a(a)(3)(i)

- Alternative Provides Acceptable Level of Quality and Safety -

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Document Control Desk LR-N03-0396 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning 2.2 Length Sizing Test 3.2 Length Sizing Test Renumbered (a) The length sizing test may be (a) Each reported circumferential flaw in Provides consistency between Supplement conducted separately or in conjunction with the detection test shall be length sized.

10 and the recent revision to Supplement 2 the detection test.

(Reference BC 00-755).

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

provided to the candidate such that at least provided to the candidate such that at least ten flaws are sized. The regions containing ten flaws are sized. The regions containing Note, length and depth sizing use the term a flaw to be sized shall be identified to the a flaw to be sized may be identified to the "regions" while detection uses the termn candidate. The candidate shall determine candidate. The candidate shall determine "grading units". The two terms define the length of the flaw in each region.

the length of the flaw in each region.

different concepts and are not intended to be equal or interchangeable.

Proposed Alternative In Accordance with 10 CFR 50.55a(a) (3) (i)

- Alternative Provides Acceptable Level of Quality and Safety -

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Document Control Desk LR-N03-0396 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (c) For a separate length sizing test, the (c) For a separate length sizing test, the Change made to ensure security of regions of each specimen containing a flaw regions of each specimen containing a flaw samples, consistent with the recent to be sized shall be identified to the to be sized may be identified to the revision to Supplement 2 (Reference BC candidate. The candidate shall determine candidate. The candidate shall determine 00-755).

the length of the flaw in each region.

the length of the flaw in each region.

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

when the RMS error of the flaw length Metricated.

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

(19 mm).

2.3 Depth Sizing Test 3.3 Depth Sizing Test Renumbered (a) For the depth sizing test, 80% of the (a) The depth sizing test may be Change made to ensure security of flaws shall be sized at a specific location conducted separately or In conjunction samples, consistent with the recent on the surface of the specimen identified to with the detection test. For a separate revision to Supplement 2 (Reference BC the candidate.

depth sizing test, the regions of each 00-755).

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

Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i7

- Alternative Provides Acceptable Level of Quality and Safety -

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Document Control Desk LR-N03-0396 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (b) For the remaining flaws, the regions of (b) When the depth sizing test Is Change made to be consistent with the each specimen containing a flaw to be conducted in conjunction with the recent revision to Supplement 2 sized shall be identified to the candidate.

detection test, and less than ten flaws (Reference BC 00-755).

The candidate shall determine the are detected, additional specimens shall maximum depth of the flaw in each region.

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

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

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

and personnel are qualified for depth sizing Metricated.

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. (3 mm).

3.0 ACCEPTANCE CRITERIA Delete as a separate category. Moved to new paragraph detection (3.1) and sizing 3.2 and_3.3 3.1 Detection Acceptance Criteria.

Moved to new paragraph 3.1(b), reference Examination procedures, equipment, and changed to Table S10 from S2 because of personnel are qualified for detection when the change in the minimum number of the results of the performance flaws and the reduction in unflawed demonstration satisfy the acceptance grading units from 2X to 1.5X.

criteria of Table Vill-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 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

- Alternative Provides Acceptable Level of Quality and Safety -

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Document Control Desk LR-N03-0396 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS t.

Current Requirement Proposed Change Reasoning (a) Examination procedures, equipment, Moved to new paragraph 3.2(d), included and personnel are qualified for length sizing word "when" as an editorial change.

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

(b) Examination procedures, equipment, 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.

4.0 PROCEDURE QUALIFICATION New Procedure qualifications shall Include New. Based on experience gained in the following additional requirements.

conducting qualifications, the equivalent of (a) The specimen set shall include the 3 personnel sets (i.e., a minimum of 30 equivalent of at least three personnel flaws) is required to provide enough flaws sets. Successful personnel to adequately test the capabilities of the demonstrations may be combined to procedure. Combining successful satisfy these requirements.

demonstrations allows a variety of (b) Detectability of all flaws within the examiners to be used to qualify the scope of the procedure shall be procedure. Detectability of each flaw demonstrated. Length and depth sizing within the scope of the procedure is shall meet the requirements of required to ensure an acceptable paragraph 3.2 and 3.3.

personnel pass rate. The last sentence is (c) At least one successful personnel equivalent to the previous requirements demonstration has been performed.

and is satisfactory for expanding the (d) To qualify new values of essential essential variables of a previously qualified variables, at least one personnel procedure qualification set Is required.

Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(1)

- Altemative Provides Acceptable Level of Quality and Safety -

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