ML032660317

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Request for Alternative to ASME Section XI, Appendix Viii, Supplement 10
ML032660317
Person / Time
Site: Monticello, Palisades, Kewaunee, Point Beach, Prairie Island, Duane Arnold  Entergy icon.png
Issue date: 09/17/2003
From: Weinkam E
Nuclear Management Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MB9023, TAC MB9024, TAC MB9025, TAC MB9026, TAC MB9027, TAC MB9028
Download: ML032660317 (25)


Text

y il iI Committed to Nuclear Exce 5

s Nuclear Management Company, LLC September 17, 2003 10 CFR 50.55a(a)(3)(i)

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 DUANE ARNOLD ENERGY CENTER DOCKET 50-331 LICENSE No. DPR-49 MONTICELLO NUCLEAR GENERATING PLANT DOCKET 50-263 LICENSE No. DPR-22 PRAIRIE ISLAND NUCLEAR GENERATING PLANT UNITS I AND 2 DOCKETS 50-282 AND 50-306 LICENSE Nos. DPR-42 AND DPR-60 REQUEST FOR ALTERNATIVE TO ASME SUPPLEMENT 10 KEWAUNEE NUCLEAR POWER PLANT DOCKET 50-305 LICENSE No. DPR-43 POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 DOCKETS 50-266 AND 50-301 LICENSE Nos. DPR-24 AND DPR-27 PALISADES NUCLEAR PLANT DOCKET 50-255 LICENSE No. DPR-20 SECTION Xi. APPENDIX Vill.

Supplement 10 to ASME Section XI, Appendix Vil, "Performance Demonstration for Ultrasonic Examination Systems," contains qualification requirements for procedures, equipment, and personnel involved with examining dissimilar metal welds using ultrasonic techniques. Pursuant to 10 CFR 50.55a(a)(3)(i), Nuclear Management Company, LLC (NMC) requests NRC approval to use an alternative in lieu of certain of these requirements.

Approval is requested for the above-identified plants to use a technical alternative developed by the Performance Demonstration Initative (PDI). Use of the proposed alternative will provide an acceptable level of quality and safety, as described in the attached request.

By letter dated August 6, 2003, the NRC Staff authorized the use of a similar alternative for Edwin I. Hatch Nuclear Plant, Units 1 and 2; Joseph M. Farley Nuclear Plant, Units 1 and 2; and Vogtle Electric Generating Plant, Units 1 and 2 (TAC Nos. MB9023, MB9024, MB9025, MB9026, MB9027 and MB9028).

700 First Street

  • Hudson, Wisconsin 54016 Telephone: 715.377.3300 O

September 17, 2003 Page 2 provides information regarding inservice inspection intervals and applicable ASME Code Editions for the NMC plants. Attachment 2 provides the 10 CFR 50.55a(a)(3)(i) request. NMC requests approval of the request by July 1, 2004, to support planning and scheduling activities for upcoming refueling outages.

This letter contains no new commitments.

d. Weinkam Diredt> Regulatory Services Nuclear Management Company, LLC cc:

Regional Administrator, USNRC Region IlIl Project Managers, Office of Nuclear Reactor Regulation (Duane Arnold Energy Center, Kewaunee Nuclear Power Plant, Monticello Nuclear Generating Plant, Palisades Nuclear Plant, Point Beach Nuclear Plant, Prairie Island Nuclear Generating Plant)

NRC Resident Inspectors (Duane Arnold Energy Center, Kewaunee Nuclear Power Plant, Monticello Nuclear Generating Plant, Palisades Nuclear Plant, Point Beach Nuclear Plant, Prairie Island Nuclear Generating Plant)

Yv -

ATTACHMENT I NUCLEAR MANAGEMENT COMPANY, LLC DUANE ARNOLD ENERGY CENTER DOCKET 50-331 MONTICELLO NUCLEAR GENERATING PLANT DOCKET 50-263 PRAIRIE ISLAND NUCLEAR GENERATING PLANT UNITS I AND 2 DOCKETS 50-282 AND 50-306 KEWAUNEE NUCLEAR POWER PLANT DOCKET 50-305 POINT BEACH NUCLEAR PLANT, UNITS I AND 2 DOCKETS 50-266 AND 50-301 PALISADES NUCLEAR PLANT DOCKET 50-255 September 17, 2003 APPLICABLE CODE AND ADDENDA i page follows

i i

1 APPLICABLE CODE AND ADDENDA ASME EDITION/

SI INTERVAL INTERVAL PLANT ADDENDA INTERVAL START DATE END DATE Duane Arnold Energy Center 1989 Edition/

Third Nov. 1, 1996 Nov. 1, 2005 50-331 No Addenda Monticello Nuclear 1995 Edition!

Fourth May 1, 2003 May 31, 2012 Generating Plant 1996 Addenda 50-263 Prairie Island Nuclear 1989 Edition!

Third Dec. 17, 1993 Dec. 16, 2003*

Generating Plant, Unit 1 No Addenda 50-282 Prairie Island Nuclear 1989 Edition/

Third Dec. 21, 1994 Dec. 20, 2004 Generating Plant, Unit 2 No Addenda 50-306 Kewaunee Nuclear Power 1989 Edition/

Third June 16, 1994 June 16, 2005**

Plant No Addenda 50-305 Point Beach Nuclear Plant, 1998 Edition/

Fourth July 1, 2002 June 30, 2012 Units 1 And 2 2000 Addenda 50-266 And 50-301 Palisades Nuclear Plant 1989 Edition/

Third May 12,1995 Dec. 12, 2006 50-255 No Addenda

  • By letter dated January 24, 2003, NMC requested approval to use an alternative that would extend the Third Ten-Year Interval for Prairie Island Nuclear Generating Plant, Unit 1. Upon approval of that request, the Third Ten-Year Interval for Prairie Island Nuclear Generating Plant, Unit 1 will end on December 20, 2004.
    • Kewaunee Nuclear Power Plant's Third Ten-Year Interval is being extended as allowed by ASME Section Xl, IWA-2430(d).

ATTACHMENT 2 NUCLEAR MANAGEMENT COMPANY, LLC DUANE ARNOLD ENERGY CENTER DOCKET NO. 50-331 MONTICELLO NUCLEAR GENERATING PLANT DOCKET NO. 50-263 PRAIRIE ISLAND NUCLEAR GENERATING PLANT UNITS AND 2 DOCKET NOS. 50-282 AND 50-306 KEWAUNEE NUCLEAR POWER PLANT DOCKET NO. 50-305 POINT BEACH NUCLEAR PLANT, UNITS I AND 2 DOCKET NOS. 50-266 AND 50-301 PALISADES NUCLEAR PLANT DOCKET NO. 50-255 September 17, 2003 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(1)

APPENDIX Vill-SUPPLEMENT 10 20 pages follow

PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

APPENDIX Vil - SUPPLEMENT 10 SYSTEMICOMPONENT(S) FOR WHICH RELIEF IS REQUESTED:

Pressure Retaining Piping Welds subject to examination using procedures, personnel, and equipment qualified to ASME Section Xl, Appendix Vill, Supplement 10 criteria.

CODE REQUIREMENTS:

The following statements or paragraphs are from ASME Section Xl, Appendix Vil, Supplement 10 and identify the specific requirements that are included in this request for relief.

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

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

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

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

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

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

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

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

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

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

Item 11 - Table 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.

RELIEF REQUESTED Relief is requested to use the following alternative requirements for implementation of Appendix Vil, Supplement 10 requirements. They will be implemented through the Performance Demonstration Initiative (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 September 2002 had been approved by the NDE Subcommittee.

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

"The specimen set shall include the minimum and maximum pipe diameters and thicknesses for which the examination procedure is applicable. Pipe diameters within 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 within 1/2 inch of the nominal diameter 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:

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I 1;

"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, shall meet the following requirements:

(1) Alternative flaws, if used, shall provide crack-like reflective characteristics and shall only be used when implantation of cracks would produce spurious reflectors that are uncharacteristic of service-induced flaws.

(2) Alternative flaw mechanisms shall have a tip width no more than 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.

r/xavati n

Mechanical fatigue crack

]

ti in Base material Item 3 - The proposed alternative to Paragraph 1.1 (d)(1) states:

uAt least 80% of the flaws shall be contained wholly in weld or buttering material. At least one and no more than 10% of the flaws shall be in ferritic base material. At least one and no more than 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.

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

"Personnel performance demonstration detection test sets shall be selected from Table VilI-S10-1. The number of unflawed grading units shall be at least 1-1/2 times the number of flawed grading units."

Technical Basis - Table VIII-S1 0-1 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. This reduces 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-SI0-1.

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 4 of 7

pipe (e.g., PWR nozzle to safe end welds) impractical. The proposed alternative differentiates between ID and OD scanning surfaces, requires that they be conducted separately, and requires that flaws be concealed from the candidate.

This is consistent with the recent revision to Supplement 2.

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

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

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

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

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

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

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

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TABLE VIII-S -1E 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 6

6 12 7

6 14 1

8 7

6l 2

9 7

10 2

10 8

15 3

2 11 9

2-17 3-3 12 9

2 18 3

13 10 2n-2 0 4-3 14 10 2 21 3

15 11 3-23 3

16 12 H 24 4

17 12 3e 26 4

18 13 27 4

19 13 e 29 E

4 20 14 40- 30 5

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

ALTERNATIVE EXAMINATION In lieu of the requirements of ASME Section X, Appendix Vil, Supplement 10, the proposed alternative shall be used. The proposed alternative is described in the enclosure.

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

IMPLEMENTATION SCHEDULE This technical alternative will be used at Duane Arnold Energy Center; Monticello Nuclear Generating Plant; Point Beach Nuclear Plant, Units 1 And 2; Prairie Island Nuclear Generating Plant, Units 1 And 2; Kewaunee Nuclear Power Plant; and Palisades Nuclear Plant during each plant's present Ten-Year Interval of the Inservice Inspection Program. (See Attachment I for Interval dates.)

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hig SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning 1.0 SCOPE Supplement 10 is applicable to dissimilar A scope statement provides added clarity metal piping welds examined from either regarding the applicable range of each the inside or outside surface.

individual Supplement. The exclusion of Supplement 10 is not applicable to piping CRC provides consistency between welds containing supplemental corrosion Supplement 10 and the recent revision to resistant clad (CRC) applied to mitigate Supplement 2 (Reference BC 00-755).

Intergranular Stress Corrosion Cracking Note, an additional change identifying CRC (IGSCC).

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 limitations stated in the scope of specific limitations stated in the scope of the examination procedure (e.g., pipe size, the examination procedure (e.g., pipe size, weld joint configuration, access weld joint configuration, access limitations). The same specimens may be limitations). The same specimens may be used to demonstrate both detection and used to demonstrate both detection and sizing qualification.

sizing qualification.

1.1 General. The specimen set shall 2.1 General.

Renumbered conform. to the following requirements.

The specimen set shall conform to the following requirements.

(a) The minimum number of flaws in a New, changed minimum number of flaws to specimen set shall be ten.

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

(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 pipe Page 1 ofl3 Enclosure

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

diameter shall be considered equivalent.

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

thickness tolerance of +25% is acceptable.

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

examples of the following fabrication "conditions" 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 geometric counterbore or weld root conditions, (e.g., counterbore or weld root conditions, conditions. Weld repair areas were added cladding, weld buttering, remnants of cladding, weld buttering, remnants of as a result of recent field experiences.

previous welds, adjacent welds in close previous welds, adjacent welds in close proximity);

proximity, weld repair areas);

(2) typical limited scanning surface (2) typical limited scanning surface Differentiates between ID and OD scanning conditions (e.g., diametrical shrink, single-conditions shall be included as follows:

surface limitations. Requires that ID and side access due to nozzle and safe end (a) for outside surface examination, weld OD qualifications be conducted external tapers).

crowns, diametrical shrink, single-side independently (Note, new paragraph 2.0 access due to nozzle and safe end external (identical to old paragraph 1.0) provides for tapers alternatives when "a set of specimens is (b) for inside surface examination, designed to accommodate specific internal tapers, exposed weld roots, and limitations stated in the scope of the cladding conditions for inside surface examination procedure.").

examinations.

(e) Qualification requirements shall be satisfied separately for outside surface Page 2 ofl3 Enclosure

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning 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 "alternative flaws" in lieu of cracks.

(1) At least 50% of the cracks shall be in 2.2 Flaw Location.

Renumbered and re-titled. Flaw location austenitic material. At least 50% of the At least 80% of the flaws shall be percentages redistributed because field cracks in austenitic material shall be contained wholly in weld or buttering experience indicates that flaws contained in contained wholly in weld or buttering material. At least one and no more than weld or buttering material are probable and material. At least 10% of the cracks shall be 10% of the flaws shall be in ferritic base represent the more stringent ultrasonic in ferritic material. The remainder of the material. At least one and no more than detection scenario.

cracks may be in either austenitic or ferritic 10% of the flaws shall be in austenitic material.

base material.

(2) At least 50% of the cracks in austenitic 2.3 Flaw Type.

Renumbered and re-titled. Alternative base material shall be either IGSCC or (a) At least 60% of the flaws shall be flaws are required for placing axial flaws in thermal fatigue cracks. At least 50% of the cracks, and 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 shall meet the following unrealistic ultrasonic response. This is requirements:

consistent with the recent revision to (1) Alternative flaws, if used, shall Supplement 2 (Reference BC 00-755).

provide crack-like reflective characteristics and shall only be used The 40% limit on alternative flaws is when implantation of cracks would needed to support the requirement for up to produce spurious reflectors that are 70% axial flaws. Metricated uncharacteristic of service-induced flaws.

(2) Alternative flaws shall have a tip width no more than 0.002 in. (.05 mm).

(3) At least 50% of the cracks shall be (b) At least 50% of the flaws shall be Renumbered. Due to inclusion of coincident with areas described in (c) coincident with areas described in 2.1(d)

"alternative flaws", use of "cracks" is no above.

above.

longer appropriate.

Page 3 of 13 Enclosure

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning 2.4 Flaw Depth.

All flaw depths shall be greater than 10% of Moved from old paragraph 1.3(c) and 1.4 the nominal pipe wall thickness. Flaw and re-titled. Consistency between depths shall exceed the nominal clad detection and sizing specimen set thickness when placed in cladding. Flaws requirements (e.g., 20% vs. 1/3 flaw depth in the sample set shall be distributed as increments, e.g., 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). No units. Each grading unit shall include at 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 Page 4 of 13 Enclosure

or SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning pipe specimen.

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

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

(c) Flawed grading units shall meet the Flaw depth requirements moved to new following criteria for flaw depth, paragraph 2.4, flaw orientation orientation, and type.

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

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

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

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

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

circumferentially.

shall be oriented axially. The 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 izing new paragraph 3.2 p

Page 5 of 13 Enclosure

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

1.4 Depth Sizing Specimens. The Moved, included in new paragraphs 2. 1, specimen set shall include depth sizing 2.3,2.4 specimens that meet the following requirements.

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

(b) Flaws in the sample set shall not be Moved, potential conflict with old wholly contained within cladding and shall paragraph 1.2(c)(1); "However, flaw 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 Page 6 ofl3 Enclosure

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning Moved, included in paragraph 2.4 for Flaw Depth Minimum consistent applicability to detection and

(% Wall Thickness)

Number of Flaws sizing samples.

10-30%

20%

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

(2) Depth sizing flaws shall be oriented as Included for clarity. Previously addressed in 2.5(a).

by omission (i.e., length, but not depth had a specific exclusionary statement) 2.0 CONDUCT OF 3.0 CONDUCT OF Renumbered PERFORMANCE DEMONSTRATION PERFORMANCE DEMONSTRATION The specimen inside surface and Personnel and procedure performance Differentiate between qualifications identification shall be concealed from the demonstration tests shall be conducted conducted from the outside and inside candidate. All examinations shall be according to the following requirements.

surface.

completed prior to grading the results and (a) For qualifications from the outside presenting the results to the candidate.

surface, the specimen inside surface and Divulgence of particular specimen results or identification shall be concealed from the candidate viewing of unmasked specimens candidate. When qualifications are after the performance demonstration is performed from the inside surface, the prohibited.

flaw location and specimen identification shall be obscured to maintain a "blind test". All examinations shall be completed prior to grading the results and presenting 11' I

Page 7 of 13 Enclosure

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS A,

Current Requirement Proposed Change Reasoning 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.

(1) Specimens shall be divided into grading Renumbered, moved from old paragraph units.

1.2(a). Metricated. No other changes.

(a) Each grading unit shall include at least 3 in. (76 mm) of weld length.

(b)The end of each flaw shall be separated from an unflawed grading unit by at least 1 in. (25 mm) of unflawed material. A flaw may be less than 3 in. (76 mm) in length.

(c) The segment of weld length used in one grading unit shall not be used in another grading unit.

(d) Grading units need not be uniformly spaced around the pipe specimen.

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

the reduction in unflawed grading units.

Human factors due to large sample size.

V Page 8 of 13 Enclosure

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS 1J Current Requirement Proposed Change Reasoning (3) Flawed and unflawed grading units shall Moved from old paragraph 2.1 be randomly mixed.

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

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 Provides consistency between Supplement separately or in conjunction with the the detection test shall be length-sized.

10 and the recent revision to Supplement 2 detection test.

(Reference BC 00-755).

Page 9 of 13 Enclosure

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change I

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

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

be equal or interchangeable.

the length of the flaw in each region.

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

to be sized shall be identified to the candidate. The candidate shall determine candidate. The candidate shall determine 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, do not exceed 0.75 in. (19 mm).

3.3 Depth Sizing Test Renumbered 2.3 Depth Sizing Test (a) For the depth sizing test, 80% of the (a) The depth-sizing test may be Change made to ensure security of samples, flaws shall be sized at a specific location on conducted separately or in conjunction consistent with the recent revision to the surface of the specimen identified to the with the detection test. For a separate Supplement 2 (Reference BC 00-755).

candidate.

depth-sizing test, the regions of each specimen containing a flaw to be sized may be identified to the candidate. The candidate shall determine the maximum Page 10 of 13 Enclosure

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning depth of the flaw in each region.

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

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

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

may be identified to the candidate. 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, do not exceed 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 flaws the results of the performance and the reduction in unflawed grading units demonstration satisfy the acceptance from 2X to 1.5X.

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

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

Page 11 of 13 Enclosure

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning the RMS error of the flaw length measurements, as compared to the true flaw lengths, is less than or equal to 0.75 inch.

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

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

conducting qualifications, the equivalent of (a) The specimen set shall include the 3 personnel sets (i.e., a minimum of 30 equivalent of at least three personnel flaws) is required to provide enough flaws performance demonstration test sets.

to adequately test the capabilities of the Successful personnel performance procedure. Combining successful demonstrations may be combined to demonstrations allows a variety of satisfy these requirements.

examiners to be used to qualify the (b) Detectability of all flaws in the procedure. Detectability of each flaw procedure qualification test set that are within the scope of the procedure is within the scope of the procedure shall be required to ensure an acceptable personnel demonstrated. Length and depth sizing pass rate. The last sentence is equivalent to shall meet the requirements of paragraph the previous requirements and is 3.1, 3.2, and 3.3.

satisfactory for expanding the essential (c) At least one successful personnel variables of a previously qualified demonstration shall be performed.

procedure (d) To qualify new values of essential variables, at least one personnel qualification set is required. The acceptance criteria of 4.0(b) shall be met.

Page 12 of13 Enclosure

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement I

Proposed Change I

Reasoning TABLE VIII-S F

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

676 1

1 7 ~

~ ~

lb 2e 9

7 16 2

10 8

20-15 3-2 11 9

2t-17 3-3 12 9

24-18 3-3 13 10 2-20 4-3 14 10 2&-21 5-3 15 11 3"

23 5-3 16 12 32-24 4

17 12 34-26 6-4 18 13 36-27 4

19 13 29 7

4 20 14 40'30 8-5 Page 13 of 13 Enclosure