ML033500392

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Requests for Relief from ASME Code,Section XI, Appendix Viii, Supplement 10, Qualification Requirements for Dissimilar Metal Piping Welds
ML033500392
Person / Time
Site: Harris, Brunswick, Crystal River, Robinson  Duke Energy icon.png
Issue date: 12/05/2003
From: Hinnant C
Progress Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
PE&RAS 03-0102
Download: ML033500392 (29)


Text

C. S. Hinnant CJ Progress Energy Sr. Vice President and Chief Nuclear Officer Progress Energy, Inc.

December 5, 2003 10 CFR 50.55a(a)(3)(i)

SERIAL: PE&RAS 03-0102 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324/LICENSE NOS. DPR-71 AND DPR-62 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400 / LICENSE NO. NPF-63 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 / LICENSE NO. DPR-23 CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT DOCKET NO. 50-302 / LICENSE NO. DPR-72 REQUESTS FOR RELIEF FROM ASME CODE, SECTION XI. APPENDIX VIII.

SUPPLEMENT 10. "QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS" Ladies and Gentlemen:

Progress Energy Carolinas, Inc. (PEC) and Progress Energy Florida, Inc. (PEF) submit the following Relief Requests for the Progress Energy plants listed in Table 1 below. We request approval by April 1, 2004 to support our Robinson Plant refueling outage.

PEC is the principal licensee for the H. B. Robinson Steam Electric Plant, Unit No. 2; the Brunswick Steam Electric Plant, Unit Nos. 1 and 2; and the Shearon Harris Nuclear Power Plant, Unit No. 1. PEF is the principal licensee for the Crystal River Unit 3 Nuclear Generating Plant.

4+VJV P.O.

Box 1551 PEB 1323 Raleigh, NC 27602 T> 919.546.4222 F> 919.546.5473

'T Document Control Desk PE&RAS 03-0102 / Page 2 TABLE I List of plants, type, ISI 10-year interval, ASME Code of record, and Relief Request number.

ISI ASME ISI START ISI END PLANT/TYPEIRR #

INTERVAL EDITION DATE DATE DOCKET #

Brunswick Steam Third 1989 Edition, May II, May 10, 50-325 Electric Plant, no addenda 1998 2008 Unit 1, BWR, RR-32 Brunswick Steam Third 1989 Edition, May 11, May 10, 50-324 Electric Plant, no addenda 1998 2008 Unit 2, BWR, RR-32 Crystal River Nuclear Third 1989 Edition, August 14, August 13, 50-302 Generating Plant, no addenda 1998 2008 Unit 3, PWR, RR-03-001-11 Shearon Harris Nuclear Second 1989 Edition, February 2, May 1, 50400 Power Plant, no addenda 1998 2007 Unit 1, PWR, RR-2R1-014 H.B. Robinson Steam Fourth 1995 Edition, February February 50-261 Electric Plant, 1996 addenda 19, 2002 18, 2012 Unit 2, PWR, R R -19 This Relief Request is submitted in accordance with 10 CFR 50.55a(a)(3)(i), and applies to the program required by 10 CFR 50.55a(g)(6)(ii)(C) to implement Supplement 10 to Appendix VIII of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI (i.e., referred to hereafter as Supplement 10).

Relief is requested to use an alternative program for implementation of Supplement 10 requirements, as presented in the enclosed Relief Request. The alternative program will be implemented through the Performance Demonstration Initiative (PDI) Program.

The final rule published in the Federal Register on September 22, 1999 (i.e.,

64 FR 51370), requires implementation of a program, by November 22, 2002, to comply with Supplement 10. Supplement 10 contains the qualification requirements for procedures, equipment, and personnel involved with examining dissimilar metal welds using ultrasonic techniques. This scope is commonly known as performance-based criteria to improve the ability of an examiner to detect and characterize flaws during examination of components to provide more reliable examination results.

Document Control Desk PE&RAS 03-0102 / Page 3 The industry has implemented a PDI program and has developed an alternative program to implement Supplement 10. The alternative program is based on forthcoming ASME Code changes and was generated from a PDI model prepared by the Electric Power Research Institute (EPRI). The alternative program has been submitted to the ASME Code organization for consideration and, as of December 2002, has been approved by the non-destructive examination (NDE) subcommittee. PEC has been a participant in the industry-sponsored program through the Nuclear Energy Institute (NEI) and EPRI. PEC and PEF plants will implement the alternative program when approved by the applicable ASME Code and regulatory actions.

The inability to meet the 10 CFR 50.55a(g)(6)(ii)(C) required schedule of November 22, 2002, to have a Supplement 10 program in place has not impacted the safe operation of PEC and PEF plants, because the program is intended for use during an outage for dissimilar metal weld examinations. As described in NRC Regulatory Issue Summary 2003-01, "Examination of Dissimilar Metal Welds, Supplement 10 to Appendix VIII of Section XI of the ASME Code," dated January 21, 2003, until regulatory compliance is achieved, any system operability issues arising from the inability to comply with Supplement 10 will be addressed consistent with NRC Generic Letter 91-18.

The proposed alternative program described in the enclosed Relief Request follows the scope of Supplement 10, with the enhancements, clarifications, and refinements approved by the ASME Code Non-Destructive Examination (NDE) subcommittee, and provides an acceptable level of quality and safety as required by 10 CFR 50.55a(a)(3)(i). Approval is requested by April 1, 2004.

There are no new commitments made in this letter. Please refer any questions regarding this submittal to Mr. Tony Groblewski, at (919) 546-4579.

Sincerely, C. S. Hinnant Senior Vice President and Chief Nuclear Officer CSH/kmh

Document Control Desk PE&RAS 03-0102 / Page 4

Enclosures:

1.

Relief Request, "Examination of Dissimilar Metal Welds"

2.

Supplemental Information Provided by the Performance Demonstration Initiative (PDI) cc (with enclosures):

U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Luis A. Reyes, Regional Administrator, 23 T85 Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Atlanta, GA 30303-8931 U. S. Nuclear Regulatory Commission ATTN: Mr. Eugene M. Dipaolo - NRC Senior Resident Inspector Brunswick Steam Electric Plant 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission ATTN: Senior Resident Inspector Crystal River Nuclear Power Plant 6745 N. Tallahassee Rd.

Crystal River, FL 34428 U. S. Nuclear Regulatory Commission ATTN: NRC Senior Resident Inspector H. B. Robinson Steam Electric Plant 2112 Old Camden Road Hartsville, SC 29550 U. S. Nuclear Regulatory Commission ATTN: NRC Senior Resident Inspector Shearon Harris Nuclear Power Plant 5413 Shearon Harris Rd.

New Hill, NC 27562-9300 U. S. Nuclear Regulatory Commission (Electronic Copy Only)

ATTN: Ms. Brenda L. Mozafari (Mail Stop OWFN 8G9) 11555 Rockville Pike Rockville, MD 20852-2738

Document Control Desk PE&RAS 03-0102 / Page 5 U. S. Nuclear Regulatory Commission (Electronic Copy Only)

ATTN: Mr. Chandu P. Patel (Mail Stop OWFN 8H12) 11555 Rockville Pike Rockville, MD 20852-2738 Ms. Jo A. Sanford Chair - North Carolina Utilities Commission 4325 Mail Service Center Raleigh, NC 276994325 Division of Boiler and Pressure Vessel North Carolina Department of Labor ATTN: Mr. Jack Given, Bureau Chief 1101 Mail Service Center Raleigh, NC 27699-1101

PE&RAS 03-0102 Page 1 of 7 RELIEF REQUEST: Examination of Dissimilar Metal Welds Revision 0 COMPONENTS FOR WHICH RELIEF IS REOUESTED The relief requested applies to pressure-retaining piping welds subject to examination using procedures, personnel, and equipment qualified to American Society of Mechanical Engineers (ASME) Code,Section XI, Appendix VIII, Supplement 10 criteria.

APPLICABLE CODE EDITION AND ADDENDA ASME Boiler and Pressure Vessel Code,Section XI, Edition and Addenda are listed in Table 1 of the cover letter.

APPLICABLE CODE REQUIREMENT The following paragraphs or statements are from ASME Code,Section XI, Appendix VIII, 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.

PE&RAS 03-0102 Page 2 of 7 Item 7 - Paragraph 2.2(b) states in part - The regions containing a flaw to be sized shall be identified to the candidate.

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

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

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

Item 11 - Table 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.

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

As provided by the PDI in Enclosure 2, a copy of the proposed revision to Supplement 10 is attached. It identifies the proposed alternatives and allows them to be viewed in context. Enclosure 2 also identifies additional clarifications and enhancements, for information.

BASIS FOR RELIEF In accordance with 10 CFR 50.55a(a)(3)(i), in lieu of the requirements of the ASME Code,Section XI, 1995 Edition with 1996 Addenda, Appendix VIII, Supplement 10, the proposed alternative discussed below shall be used. Compliance with the proposed alternative will provide an acceptable level of quality and safety for examination of the affected welds.

Item I - The proposed alternative to Paragraph 1.1 (b) is:

"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 inch (13 mm) of the nominal diameter shall be considered equivalent. Pipe diameters larger than 24 inch (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

PE&RAS 03-0102 Enclosure I Page 3 of 7 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 Intergranular Stress Corrosion Cracking (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 service induced flaws. Alternative flaw mechanisms shall have a tip width of less than or equal to 0.002 inch (.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. 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."

]~~u~tion 4

l fMechanical fatigue crack Item 3 -The proposed alternative to Paragraph l.l(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 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.

PE&RAS 03-0102 Page 4 of 7 Item 4 - The proposed alternative to Paragraph 1.2(b) states:

"Detection sets shall be selected from Table VIII-S1O-1. The number of unflawed grading units shall be at least one and a half times the number of flawed grading units."

Technical Basis - New Table VIII-S 10-1 provides a statistically based ratio between the number of unflawed grading units and the number of flawed grading units. Based on information provided by the PDI, the proposed alternative reduces the ratio to 1.5 times to reduce the number of test samples to a more reasonable number. 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 bases are in Table VIII-S 10-1.

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 Number

(% Wall Thickness) of Flaws 10 to 30%

20%

31 to 60%

20%

61 to 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'."

PE&RAS 03-0102 Page 5 of 7 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.,

Pressurized Water Reactor nozzle to safe end welds) impractical. The proposed alternative differentiates between Inside Diameter (ID) and Outside Diameter (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 of ASME Code Section XI, Division 1, Appendix XIII, "Qualification Requirements for Wrought Austenitic Piping Welds."

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"). 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 of ASME Code Section XI, Division 1, Appendix XIII, "Qualification Requirements for Wrought Austenitic Piping Welds."

Items 9 and 10 - The proposed alternatives 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 of ASME Code Section XI, Division 1, Appendix XIII, "Qualification Requirements for Wrought Austenitic Piping Welds." It also incorporates terminology from length sizing for additional clarity.

PE&RAS 03-0102 Page 6 of 7 Item 11 -The proposed alternative modifies the acceptance criteria of Table VHI-S2-1 as follows:

Table VIII-S-2-10-1 PERFORMANCE DEMONSTRATION DETECTION TEST ACCEPTANCE CRITERIA Detection Test False Call Test Acceptance Criteria Acceptance Criteria No. of Minimum No. of Maximum Flawed Detection Unflawed Number Grading Criteria Grading of False Units Units Calls 4-I 4--

-~~~~

142-4-1

~~~ 6-4--

4-10 8

20 15 2

1 1 9

222 1 7 3

12 9

18 3

13 10 20 3

14 10 21 3

15 11 23 3

16 12 24 4

17 12 26

-6 4

18 13 27 4

19 13 29 4

20 14 40-30 4-8 5

PE&RAS 03-0102 Page 7 of 7 Technical Basis - The proposed alternative adds new Table VIII-S 10-1 above. It is a modified version of Table VIII-S2-1 to reflect the reduced number of unflawed grading units and allowable false calls. As provided by the PDI, as part of ongoing ASME Code activities, Pacific Northwest National Laboratories has reviewed the statistical significance of these revisions and offered the new Table VIII-SI 0-1.

ALTERNATIVE EXAMINATION In accordance with the alternative provisions of 10 CFR 50.55a(a)(3)(i), Progress Energy Carolinas, Inc. and Progress Energy Florida, Inc. propose that in lieu of the requirements of the ASME Code,Section XI, 1995 Edition with 1996 Addenda, Appendix VIII, Supplement 10, the required examinations will be implemented through the Electric Power Research Institute (EPRI) PDI Program. The proposed alternative is described in.

IMPLEMENTATION SCHEDULE The proposed alternative is applicable for the remainder of the ten year inservice inspection interval.

PRECEDENTS Letter from James W. Clifford (USNRC) to Mr. Mike Bellamy (Entergy Nuclear Operations, Inc., Pilgrim Nuclear Power Station) dated May 6, 2003, "Pilgrim Nuclear Power Station - Pilgrim Relief Request No. 30, Relief From ASME Code,Section XI, Appendix VIII, Supplement 10, 'Performance Demonstration for Ultrasonic Examination Systems' (TAC No. MB7949)." [ADAMS Accession Number ML0312701490]

REFERENCES None.

PE&RAS 03-0102 Page I of 17 Supplemental Information Provided by the Performance Demonstration Initiative (PDI)

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

both detection and sizing qualification.

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

to the following requirements.

PE&RAS 03-0102 Page 2 of 17 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (a) The minimum number of flaws in a test set New, changed minimum number of flaws to shall be ten.

ten 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 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 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 within revision to Supplement 2 (Reference within a range of 0.9 to 1.5 times a nominal a range of 1/2 inch (13 mm) of the nominal BC 00-755).

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

tolerance of +25% is acceptable.

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

of the following fabrication conditions:

"conditions."

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

adjacent welds in close proximity);

previous welds, adjacent welds in close proximity, and weld repair areas);

PE&RAS 03-0102 Page 3 of 17 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (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 shall be included as follows:

surface limitations. Requires that ID and OD due to nozzle and safe end external tapers).

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

tapers, exposed weld roots, and cladding conditions Qualification requirements shall be satisfied 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 "alternative flaws" in lieu of cracks.

(I) 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 no more than 10%

experience indicates that flaws contained in wholly in weld or buttering material. At least of the flaws shall be in ferritic base material.

weld or buttering material are probable and 10% of the cracks shall be in ferritic material.

At least one and no more than 10% of the represent the more stringent ultrasonic The remainder of the cracks may be in either flaws shall be in austenitic base material.

detection scenario.

austenitic or ferritic material.

PE&RAS 03-0102 Page 4 of 17 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 flaws base material shall be either IGSCC or are required for placing axial flaws in the thermal fatigue cracks. At least 50% of the (a) At least 60% of the flaws shall be cracks, HAZ of the weld and other areas where cracks in ferritic material shall be the remainder shall be alternative flaws.

implantation of a crack produces mechanically or thermally induced fatigue Specimens with IGSCC shall be used when metallurgical conditions that result in an cracks.

available. Alternative flaws shall meet the unrealistic ultrasonic response. This is following requirements consistent with the recent revision to (1) Alternative flaws, if used, shall provide Supplement 2 (Reference BC 00-755).

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

uncharacteristic of service induced flaws. (2)

Alternative flaws shall have a tip width of no more than 0.002 inch (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 "alternative coincident with areas described in (c) above.

coincident with areas described in 2.1(d) flaws," use of "cracks" is no longer above.

appropriate.

PE&RAS 03-0102 Page 5 of 17 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 and greater than 10% of the nominal pipe wall re-titled. Consistency between detection and thickness. Flaw depths shall exceed the sizing specimen set requirements (e.g., 20%

nominal clad thickness when placed in vs. 1/3 flaw depth increments, e.g., original cladding. Flaws in the sample set shall be paragraph 1.3(c)).

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 set Renumbered and re-titled and moved to shall include detection specimens that meet paragraph 3.1(a). No other changes.

the following requirements.

PE&RAS 03-0102 Page 6 of 17 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). No other units. Each grading unit shall include at least changes.

3 inch of weld length. If a grading unit is designed to be unflawed, at least 1 inch 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 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."

PE&RAS 03-0102 Page 7 of 17 SUPPLEMENT 10- QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (1) 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 detection and depth sizing.

number, shall be oriented axially. The (a) For other than sizing specimens, at least Paragraph 2.5(b)(1) requires that all length-remainder of the flaws shall be oriented 30% and no more than 70% of the flaws, sizing flaws be oriented circumferentially.

circumferentially.

rounded to the next higher whole number, shall be oriented axially. The remainder of the 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.

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

circumferentially.

PE&RAS 03-0102 Page 8 of 17 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (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 Moved, potential conflict with old wholly contained within cladding and shall be paragraph 1.2(c)(1); "However, flaw depths distributed as follows:

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

PE&RAS 03-0102 Page 9 of 17 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 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 by in 2.5(a).

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

PE&RAS 03-0102 Page 10 of 17 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning 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: (a) surface.

completed prior to grading the results and For qualifications from the outside surface, presenting the results to the candidate.

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

identification shall be obscured to maintain a "blind test." All examinations shall be completed prior to grading the results and presenting the results to the candidate.

Divulgence of particular specimen results or candidate viewing of unmasked specimens after the performance demonstration is prohibited.

2.1 Detection Test. Flawed and unflawed 3.1 Detection Qualification.

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

(a) The specimen set shall include detection Renumbered, moved from old paragraph 1.2.

specimens that meet the following requirements.

PE&RAS 03-0102 Page 11 of 17 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 units.

paragraph 1.2(a). Metricated. No other changes.

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

(b) The end of each flaw shall be separated from an unflawed grading unit by at least 1 inch (25 mm) of unflawed material. A flaw may be less than 3 inch 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 Table revised to reflect a change in the minimum VIII-S10-1. The number of unflawed grading sample set to 10 and the application of units shall be at least 1-1/2 times the number equivalent statistical false call parameters to of flawed grading units.

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.

PE&RAS 03-0102 Page 12 of 17 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 criteria demonstrations satisfy the acceptance criteria of procedures versus personnel and of Table VIH-S 10- 1 for both detection and equipment contained in new paragraph 4.0 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 the Provides consistency between Supplement 10 separately or in conjunction with the detection detection test shall be length sized.

and the recent revision to Supplement 2 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 samples, in conjunction with the detection test, and less in conjunction with the detection test, and less consistent with the recent revision to than ten circumferential flaws are detected, than ten circumferential flaws are detected, Supplement 2 (Reference BC 00-755).

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

flaw in each region.

equal or interchangeable.

PE&RAS 03-0102 Page 13 of 17 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 samples, regions of each specimen containing a flaw to regions of each specimen containing a flaw to consistent with the recent revision to be sized shall be identified to the candidate.

be sized may be identified to the candidate.

Supplement 2 (Reference BC 00-755).

The candidate shall determine the length of The candidate shall determine the length of the flaw in each region.

the flaw in each region.

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

the RMS error of the flaw length measurements, as compared to the true flaw Metricated.

lengths, do not exceed 0.75 inch (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.

PE&RAS 03-0102 Page 14 of 17 4,.

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 conducted in Change made to be consistent with the recent each specimen containing a flaw to be sized conjunction with the detection test, and less 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 consistent with the recent revision to be sized may be identified to the candidate.

Supplement 2 (Reference BC 00-755).

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

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

personnel are qualified for depth sizing when Metricated.

the RMS error of the flaw depth measurements, as compared to the true flaw depths, do not exceed 0.125 inch (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 S 10 from S2 because of the personnel are qualified for detection when the change in the minimum number of flaws and results of the performance demonstration the reduction in unflawed grading units from satisfy the acceptance criteria of Table 2X to 1.5X.

VIII-S2-1 for both detection and false calls.

PE&RAS 03-0102 Page 15 of 17 II SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning 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 when 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 inch

PE&RAS 03-0102 Page 16 of 17

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

procedure. Combining successful Successful personnel performance demonstrations allows a variety of examiners demonstrations may be combined to satisfy to be used to qualify the procedure.

these requirements.

Detectability of each flaw within the scope of the procedure is required to ensure an (b) Detectability of all flaws in the procedure acceptable personnel pass rate. The last qualification test set that are within the scope sentence is equivalent to the previous of the procedure shall be demonstrated.

requirements and is satisfactory for expanding Length and depth sizing shall meet the the essential variables of a previously requirements of paragraph 3.1, 3.2, and 3.3.

qualified procedure.

(c) At least one successful personnel demonstration shall be performed.

(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.

PE&RAS 03-0102 Page 17 of 17

.4..

4..

TABLE VIII-S/-1 PERFORMANCE DEMONSTRATION DETECTION TEST ACCEPTANCE CRITERIA Detection Test False Call Test Acceptance Critera Acceptance Criteria No. of No. of Maximum Flawed Minimum Unflawed Number Grading Detection Grading of False Units Criteria Units Calls e10

° 6

6 12 1

7 6

14 1

87 1

2 9

7

-1 2

10 8

2-15 3

2 11 9

2-17 3-3 12 9

24-18 3

3 13 10 26-20 4-3 14 10 26-21 5-3 15 11 3e-23 5-3 16 12 32 24 6

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

19 13 3&-29 4

20 14 4-30 8-5