ML051160176

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Proposed Alternative to the ASME Code,Section XI, Repair Requirements
ML051160176
Person / Time
Site: Cook American Electric Power icon.png
Issue date: 04/15/2005
From: Fadel D
Indiana Michigan Power Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP:NRC:5055-03
Download: ML051160176 (24)


Text

Indiana Michigan Power INDIA NA Cook Nuclear Plant MICHIGAN One Cook Place POWER PVMRIAEP~com Bridgman,MI 49106 A unit of American Electric Power April 15, 2005 AEP:NRC:5055-03 10 CFR 50.55a Docket No. 50-315 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1-17 Washington, DC 20555-0001 Donald C. Cook Nuclear Plant Unit I PROPOSED ALTERNATIVE TO THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS CODE, SECTION XI REPAIR REQUIREMENTS Pursuant to 10 CFR 50.55a(a)(3)(i), Indiana Michigan Power Company (I&M) is proposing an alternative to the requirements of the American Society of Mechanical Engineers Code,Section XI requirements. Specifically, I&M is proposing the use of the Electric Power Research Institute Performance Demonstration Initiative (PDI) Program for implementation of Appendix VIII, Supplement 11 requirements. Attachment I to this letter provides the proposed alternative. provides a comparison of Appendix VIII, Supplement 11, requirements to the PDI alternative.

This letter contains no new commitments. Should you have any questions, please contact Mr. John A. Zwolinski, Director of Safety Assurance at (269) 466-2428.

Sincerely, aninel P. Fadel Engineering Vice President RGV/jen Attachments: 1. 10 CFR 50.55a Relief Request - ISIR-16 Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)

2. Revised Appendix VIII, Supplement 11 Comparison to the PDI Alternative

U. S. Nuclear Regulatory Commission AEP:NRC:5055-03 Page 2 C: R. Aben - Department of Labor and Economic Growth J. L. Caldwell - NRC Region III K. D. Curry - AEP Ft. Wayne, w/o attachments J. T. King - MPSC, w/o attachments C. F. Lyon - NRC Washington DC MDEQ - WHMD/HWRPS, w/o attachments NRC Resident Inspector

Attachment 1 to AEP:NRC:5055-03 10 CFR 50.55a Relief Request - ISIR-16 Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)

SYSTEM/COMPONENT(S) FOR WHICH RELIEF IS REQUESTED 1-PRZ Pressurizer Safety Nozzle to Safety Valve Inlet Line Weld CODE REQUIREMENTS The Code requirements for which relief is requested are all contained within Appendix VIII, Supplement 11. For example, Paragraph 1.I(d)(1), requires that all base metal flaws be cracks.

Paragraph 1.1(e)(1) requires that at least 20 percent but less than 40 percent of the flaws shall be oriented within +20 degrees of the pipe axial direction. Paragraph 1. (e)(1) also requires that the rules of IWA-3300 shall be used to determine whether closely spaced flaws should be treated as single or multiple flaws. Paragraph l.1(e)(2)(a)(1) requires that a base grading unit shall include at least 3 inches of the length of the overlaid weld. Paragraph 1.1(e)(2)(b)(1) requires that an overlay grading unit shall include the overlay material and the base metal-to-overlay interface of at least 6 square inches. The overlay grading unit shall be rectangular, with minimum dimensions of 2 inches. Paragraph 3.2(b) requires that all extensions of base metal cracking into the overlay material by at least 0.1 inch are reported as being intrusions into the overlay material.

RELIEF REQUESTED Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested to use the enclosed Performance Demonstration Initiative (PDI) Program for implementation of Appendix VIII, Supplement 11 requirements.

BASIS FOR RELIEF Paragraph l.1(d)(1), requires that all base metal flaws be cracks. As illustrated below, implanting a crack requires excavation of the base material on at least one side of the flaw.

While this may be satisfactory for ferritic materials, it does not produce a useable axial flaw in austenitic materials because the sound beam, which normally passes only through base material, must now travel through weld material on at least one side, producing an unrealistic flaw response. To resolve this issue, the PDI program revised this paragraph to allow use of alternative flaw mechanisms under controlled conditions. For example, alternative flaws shall be limited to when implantation of cracks precludes obtaining an effective ultrasonic response, flaws shall be semi-elliptical with a tip width of less than or equal to 0.002 inches, and at least 70 percent of the flaws in the detection and sizing test shall be cracks and the remainder shall be alternative flaws.

¶e to AEP:NRC:5055-03 Page 2 a io Mechanicalfatigue crack Ipj~c~aIin Base rnaterial Relief is requested to allow closer spacing of flaws provided they didn't interfere with detection or discrimination. The existing specimens used to date for qualification to the tri-party (NRC/BWROG/EPRI) agreement have a flaw population density greater than allowed by the current Code requirements. These samples have been used successfully for all previous qualifications under the tri-party agreement program. To facilitate their use and provide continuity from the tri-party agreement program to Supplement 11, the PDI Program has merged the tri-party test specimens into their weld overlay program. For example: the requirement for using IWA-3300 for proximity flaw evaluation in Paragraph l.1(e)(1) was excluded. Instead, indications will be sized based on their individual merits; Paragraph 1.1(d)(l) includes the statement that intentional overlay fabrication flaws shall not interfere with ultrasonic detection or characterization of the base metal flaws; Paragraph 1.l(e)(2)(a)(1) was modified to require that a base metal grading unit include at least 1 inch of the length of the overlaid weld, rather than 3 inches; Paragraph l.l(e)(2)(a)(3) was modified to require sufficient unflawed overlaid weld and base metal to exist on all sides of the grading unit to preclude interfering reflections from adjacent flaws, rather than the 1-inch requirement of Supplement 11; Paragraph 1.1(e)(2)(b)(1) was modified to define an overlay fabrication grading unit as including the overlay material and the base metal-to-overlay interface for a length of at least 1 inch, rather than the 6 square inch requirement of Supplement 11; and Paragraph 1.1(e)(2)(b)(2) states that overlay fabrication grading units designed to be unflawed shall be separated by unflawed overlay material and unflawed base metal-to-overlay interface for at least 1 inch at both ends, rather than around its entire perimeter.

Additionally, the requirement for axially oriented overlay fabrication flaws in Paragraph 1.l(e)(l) was excluded from the PDI Program as an improbable scenario. Weld overlays are typically applied using automated gas tungsten arc welding techniques with the filler metal being applied in a circumferential direction. Because resultant fabrication-induced discontinuities would also be expected to have major dimensions oriented in the circumferential direction axial overlay fabrication flaws are unrealistic.

The PDI Program revised Paragraph 2.0 allowing the overlay fabrication and base metal flaw tests to be performed separately. The requirement in Paragraph 3.2(b) for reporting all extensions of cracking into the overlay is omitted from the PDI Program because it is redundant to the root mean square calculations performed in Paragraph 3.2(c) and its presence adds confusion and ambiguity to depth sizing as required by Paragraph 3.2(c). This also makes the weld overlay program consistent with the Supplement 2 depth sizing criteria.

These changes are contained in Code Case N-653. A comparison between the 95 Edition and 96 Addenda of Supplement 11, Code Case N-653, and the PDI Program is enclosed as to AEP:NRC:5055-03 Page 3 supporting documentation. The first column identifies the Code requirements, while the second (middle) column identifies the changes made by the Code Case.

There are, however, some additional changes that were inadvertently omitted from the Code Case. The most important change is Paragraph 1.1(e)(2)(a)(1) where the phrase "and base metal on both sides, " was inadvertently included in the description of a base metal grading unit. The PDI Program intentionally excludes this requirement because some of the qualification samples include flaws on both sides of the weld. To avoid confusion, several instances of the term "cracks" or "cracking" were changed to the term "flaws" because of the use of alternative flaw mechanisms. Additionally, to avoid confusion, the overlay thickness tolerance contained in Paragraph 1.1(b) last sentence, was reworded and the phrase "and the remainder shall be alternativeflawvs" was added to the next to last sentence in Paragraph l.1(d)(1). Additional editorial changes were also made to the PDI Program. The above changes are identified by bold print in the third column of Attachment 2.

ALTERNATIVE EXAMINATION In lieu of the requirements of ASME Section XI, 1995 Edition, 1996 Addenda, Appendix VIII, Supplement 11, the PDI Program shall be used.

DURATION OF THE RELIEF The relief is requested for the remaining service life of the component.

PRECEDENTS This relief has previously been granted for the Edwin I. Hatch Nuclear Plant (Reference 1), Nine Mile Point Nuclear Station, Unit 2 (Reference 2), and Pilgrim Nuclear Power Station (Reference 3). It is Indiana Michigan Power Company's understanding that the proposed alternative has been verbally approved for the Hope Creek Nuclear Plant.

REFERENCE

1. Letter from John A. Nakoski, Nuclear Regulatory Commission (NRC), to H. L. Sumner, Jr.,

Southern Nuclear Operating Company, "Relief Request for the Third 10-Year Inservice Inspection Program Re: Edwin I. Hatch Nuclear Plant, Units 1 and 2 (TAC Nos. MB3875 and MB3876)," dated January 14, 2003.

2. Letter from Richard J. Laufer, NRC, to J. T. Conway, Nine Mile Point Nuclear Station, LLC, "Nine Mile Point Nuclear Station, Unit No. 2 - Authorization of Alternative, Inservice Inspection (ISI) Relief Request ISI-23B (TAC No. MB5732)," dated May 6, 2003.

Attachment I to AEP:NRC:5055-03 Page 4

3. Letter from Darrell Roberts, NRC, to M. Kansler, Entergy Nuclear Operations, Inc.,

"Pilgrim Nuclear Power Station - Pilgrim Relief Request No. 38, Relief from ASME Code,Section XI, Appendix VII, Supplement 11, "Qualification Requirements for Full Structural Overlaid Wrought Austenitic Piping Welds" (TAC No. MC0961)," dated February 26, 2004.

Attachment 2 to AEP:NRC:5055-03 Revised Appendix VIII, Supplement 11 Comparison to the PDI Alternative

Attachment 2 to AEP:NRC:5055-03 Page I RPvisPd Annendiy VTTI II.Runniment 11 Comnqriqnn to the PDT Alternative Supplement 11 - Qualification PDI Program:

Requirements for Full Structural Code Case N-653 The Proposed Alternative to Overlaid Wrought Austenitic Piping Supplement 11 Requirements Welds (Provided for Information Only) (Differences are in bold type) 1.0 SPECIMEN REQUIREMENTS Qualification test specimens shall meet the No Change No Change requirements listed herein, unless a set of specimens is designed to accommodate specific limitations stated in the scope of the examination procedure (e.g., pipe size, weld joint configuration, access limitations). The same specimens may be used to demonstrate both detection and sizing qualification.

1.1 General. The specimen set shall No Change No Change conform to the following requirements.

(a) Specimens shall have sufficient volume No Change No Change to minimize spurious reflections that may interfere with the interpretation process.

Attachment 2 to AEP:NRC:5055-03 Page 2 Revised Appendix VIII. Supplement 11 Comparison to the PDI Alternative Supplement 11 - Qualification PDI Program:

Requirements for Full Structural Code Case N-653 The Proposed Alternative to Overlaid Wrought Austenitic Piping Supplement 11 Requirements Welds (Provided for Information Only) (Differences are in bold type)

(b) The specimen set shall consist of at No Change (b) The specimen set shall consist of at least three specimens having different least three specimens having different nominal pipe diameters and overlay nominal pipe diameters and overlay thicknesses. They shall include the thicknesses. They shall include the minimum and maximum nominal pipe minimum and maximum nominal pipe diameters for which the examination diameters for which the examination procedure is applicable. Pipe diameters procedure is applicable. Pipe diameters within a range of 0.9 to 1.5 times a nominal within a range of 0.9 to 1.5 times a nominal diameter shall be considered equivalent. If diameter shall be considered equivalent. If the procedure is applicable to pipe the procedure is applicable to pipe diameters of 24 inches or larger, the diameters of 24 inches or larger, the specimen set must include at least one specimen set must include at least one specimen 24 inches or larger but need not specimen 24 inches or larger but need not include the maximum diameter. The include the maximum diameter.

specimen set must include at least one The specimen set shall include specimens specimen. with overlay thickness within with overlays not thicker than 0.1 inches

-0.1 inches to +0.25 inches of the more than the minimum thickness, nor maximum nominal overlay thickness for thinner than 0.25 inches of the maximum which the procedure is applicable. nominal overlay thickness for which the examination procedure is applicable.

Attachment 2 to AEP:NRC:5055-03 Page 3 Revised Appendix VIII, Supplement II Comparison to the PDT Alternative Supplement 11 - Qualification PDI Program:

Requirements for Full Structural Code Case N-653 The Proposed Alternative to Overlaid Wrought Austenitic Piping Supplement 11 Requirements Welds (Provided for Information Only) (Differences are in bold type)

(c) The surface condition of at least two No Change No Change specimens shall approximate the roughest surface condition for which the examination procedure is applicable.

(d) Flaw Conditions

Attachment 2 to AEP:NRC:5055-03 Page 4 Revised Appendix VIII, Supplement 11 Comparison to the PDI Alternative Supplement 11 - Qualification PDI Program:

Requirements for Full Structural Code Case N-653 The Proposed Alternative to Overlaid Wrought Austenitic Piping Supplement 11 Requirements Welds (Provided for Information Only) (Differences are in bold type)

(1) Base metal flaws. All flaws must be (1) Base metal flaws. All flaws must be in (1) Base metal flaws. All flaws must be in cracks in or near the butt weld heat- or near the butt weld heat-affected zone, or near the butt weld heat-affected zone, affected zone, open to the inside surface, open to the inside surface, and extending at open to the inside surface, and extending at and extending at least 75 percent through least 75 percent through the base metal least 75 percent through the base metal the base metal wall. Flaws may extend wall. Intentional overlay fabrication flaws wall. Intentional overlay fabrication flaws 100 percent through the base metal and into shall not interfere with ultrasonic detection shall not interfere with ultrasonic detection the overlay material; in this case, or characterization of the cracking. or characterization of the base metal flaws.

intentional overlay fabrication flaws shall Specimens containing IGSCC shall be used Specimens containing IGSCC shall be used not interfere with ultrasonic detection or when available. when available. At least 70opercent of the characterization of the cracking. (a) At least 70 percent of the flaws in the flaws in the detection and sizing tests shall Specimens containing IGSCC shall be used detection and sizing tests shall be cracks. be cracks and the remainder shall be when available. Alternative flaw mechanisms, if used, shall alternative flaws. Alternative flaw provide crack-like reflective characteristics mechanisms, if used, shall provide crack-and shall be limited by the following: like reflective characteristics and shall be limited by the following:

(I) Flaws shall be limited to when implantation of cracks precludes obtaining (a) The use of Alternative flaws shall be a realistic ultrasonic response. limited to when the implantation of cracks produces spurious reflectors that are (2) Flaws shall be semielliptical with a tip uncharacteristic of actual flaws.

width of less than or equal to 0.002 inches.

(b) Flaws shall be semielliptical with a tip width of less than or equal to 0.002 inches.

Attachment 2 to AEP:NRC:5055-03 Page 5 Revised Appendix VIII, Supplement 11 Comparison to the PDT Alternative Supplement 11 - Qualification PDI Program:

Requirements for Full Structural Code Case N-653 The Proposed Alternative to Overlaid Wrought Austenitic Piping Supplement 11 Requirements Welds (Provided for Information Only) (Differences are in bold type)

(2) Overlay fabrication flaws. At least No Change No Change 40 percent of the flaws shall be non-crack fabrication flaws (e.g., sidewall lack of fusion or laminar lack of bond) in the overlay or the pipe-to-overlay interface. At least 20 percent of the flaws shall be cracks. The balance of the flaws shall be of either type.

(e) Detection Specimens  :

(1) At least 20 percent but less than (1) At least 20 percent but less than (1) At least 20 percent but less than 40 percent of the flaws shall be oriented 40 percent of the base metal flaws shall be 40 percent of the base metal flaws shall be within +20 degrees of the pipe axial oriented within +20 degrees of the pipe oriented within +20 degrees of the pipe direction. The remainder shall be oriented axial direction. The remainder shall be axial direction. The remainder shall be circumferentially. Flaws shall not be open oriented circumferentially. Flaws shall not oriented circumferentially. Flaws shall not to any surface to which the candidate has be open to any surface to which the be open to any surface to which the physical or visual access. The rules of candidate has physical or visual access. candidate has physical or visual access.

IWA-3300 shall be used to determine whether closely spaced flaws should be treated as single or multiple flaws.

Attachment 2 to AEP:NRC:5055-03 Page 6 Revised Appendix VIII, Supplement 11 Comparison to the PDI Alternative Supplement 11 - Qualification PDI Program:

Requirements for Full Structural Code Case N-653 The Proposed Alternative to Overlaid Wrought Austenitic Piping Supplement 11 Requirements Welds (Provided for Information Only) (Differences are in bold type)

(2) Specimens shall be divided into base (2) Specimens shall be divided into base (2) Specimens shall be divided into base and over-lay grading units. Each specimen metal and overlay fabrication grading units. metal and overlay fabrication grading units.

shall contain one or both types of grading Each specimen shall contain one or both Each specimen shall contain one or both units. types of grading units. Flaws shall not types of grading units. Flaws shall not interfere with ultrasonic detection or interfere with ultrasonic detection or characterization of other flaws. characterization of other flaws.

(a)(J) A base grading unit shall include at (a)(l) A base metal grading unit shall (a)(1)A base metal grading unit includes least 3 inches of the length of the overlaid include at least I inch of the length of the the overlay material and the outer.

weld. The base grading unit includes the overlaid weld. The base metal grading unit 25 percent of the original overlaid weld.

outer 25 percent of the overlaid weld and includes the outer 25 percent of the The base metal grading unit shall extend base metal on both sides. The base grading overlaid weld and base metal on both sides. circumferentially for at least 1 inch and unit shall not include the inner 75 percent The base metal grading unit shall not shall start at the weld centerline and be of the overlaid weld and base metal overlay include the inner 75 percent of the overlaid wide enough in the axial direction to material, or base metal-to-overlay interface. weld and base metal overlay material, or encompass one half of the original weld base metal-to-overlay interface. crown and a minimum of 0.50 inch of the adjacent base material.

(a)(2) When base metal cracking penetrates (a)(2) When base metal cracking penetrates (a)(2) When base metal flaws penetrate into the overlay material, the base grading into the overlay material, the base metal into the overlay material, the base metal unit shall include the overlay metal within grading unit shall not be used as part of any grading unit shall not be used as part of any I inch of the crack location. This portion overlay fabrication grading unit. overlay fabrication grading unit.

of the overlay material shall not be used as part of any overlay grading unit.

Attachment 2 to AEP:NRC:5055-03 Page 7 Revised Appendix VIII, Supplement 11 Comparison to the PDI Alternative Supplement 11 - Qualification PDI Program:

Requirements for Full Structural Code Case N-653 The Proposed Alternative to Overlaid Wrought Austenitic Piping Supplement 11 Requirements Welds (Provided for Information Only) (Differences are in bold type)

(a)(3) When a base grading unit is designed (a)(3) Sufficient unflawed overlaid weld (a)(3) Sufficient unflawed overlaid weld to be unflawed, at least 1 inch of unflawed and base metal shall exist on all sides of the and base metal shall exist on all sides of the overlaid weld and base metal shall exist on grading unit to preclude interfering grading unit to preclude interfering either side of the base grading unit. The reflections from adjacent flaws. reflections from adjacent flaws.

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

(b)(1) An overlay grading unit shall include (b)(1) An overlay fabrication grading unit (b)(l) An overlay fabrication grading unit the overlay material and the base metal-to- shall include the overlay material and the shall include the overlay material and the overlay interface of at least 6 square inches base metal-to-overlay interface for a length base metal-to-overlay interface for a length The overlay grading unit shall be of at least 1 inch. of at least I inch.

rectangular, with minimum dimensions of 2 inches.

Attachment 2 to AEP:NRC:5055-03 Page 8 Revised Appendix VIII, Supplement 11 Comparison to the PDI Alternative Supplement 11 - Qualification PDI Program:

Requirements for Full Structural Code Case N-653 The Proposed Alternative to Overlaid Wrought Austenitic Piping Supplement 11 Requirements Welds (Provided for Information Only) (Differences are in bold type)

(b)(2) An overlay grading unit designed to (b)(2) Overlay fabrication grading units (b)(2) Overlay fabrication grading units be unflawed shall be surrounded by designed to be unflawed shall be separated designed to be unflawed shall be separated unflawed overlay material and unflawed by unflawed overlay material and unflawed by unflawed overlay material and unflawed base metal-to-overlay interface for at least base metal-to-overlay interface for at least base metal-to-overlay interface for at least 1 inch around its entire perimeter. The 1 inch at both ends. Sufficient unflawed 1 inch at both ends. Sufficient unflawed specific area used in one overlay grading overlaid weld and base metal shall exist on overlaid weld and base metal shall exist on unit shall not be used in another overlay both sides of the overlay fabrication both, sides of the overlay fabrication grading unit. Overlay grading units need grading unit to preclude interfering grading unit to preclude interfering not be spaced uniformly about the reflections from adjacent flaws. The reflections from adjacent flaws. The specimen. specific area used in one overlay specific area used in one overlay fabrication grading unit shall not be used in fabrication grading unit shall not be used in another overlay fabrication grading unit. another overlay fabrication grading unit.

Overlay fabrication grading units need not Overlay fabrication grading units need not be spaced uniformly about the specimen. be spaced uniformly about the specimen.-

Attachment 2 to AEP:NRC:5055-03 Page 9 Revised Appendix VIII, Supplement 11 Comparison to the PDI Alternative Supplement 11 - Qualification PDI Program:

Requirements for Full Structural Code Case N-653 The Proposed Alternative to Overlaid Wrought Austenitic Piping Supplement 11 Requirements Welds (Provided for Information Only) (Differences are in bold type)

(b)(3) Detection sets shall be selected from (b)(3) Detection sets shall be selected from (b)(3) Detection sets shall be selected from Table VIH-S2-1. The minimum detection Table VIII-S2-1. The minimum detection Table VIII-S2-1. The minimum detection sample set is five flawed base grading sample set is five flawed base metal sample set is five flawed base metal units, ten unflawed base grading units, five grading units, ten unflawed base metal grading units, ten unflawed base metal flawed overlay grading units, and ten grading units, five flawed overlay grading units, five flawed overlay unflawed overlay grading units. For each fabrication grading units, and ten unflawed fabrication grading units, and ten unflawed type of grading unit, the set shall contain at overlay fabrication grading units. For each overlay fabrication grading units. For each least twice as many unflawed as flawed type of grading unit, the set shall contain at type of grading unit, the set shall contain at grading units. least twice as many unflawed as flawed least twice as many unflawed as flawed grading units. For initial procedure grading units. For initial procedure qualification, detection sets shall include qualification, detection sets shall include the equivalent of three personnel the equivalent of three personnel qualification sets. To qualify new values qualification sets. To qualify new values of essential variables, at least one personnel of essential variables, at least one personnel qualification set is required. qualification set is required.

Attachment 2 to AEP:NRC:5055-03 Page 10 Revised Appendix VIII, Supplement 11 Comparison to the PDI Alternative Supplement 11 - Qualification PDI Program:

Requirements for Full Structural Code Case N-653 The Proposed Alternative to Overlaid Wrought Austenitic Piping Supplement 11 Requirements Welds (Provided for Information Only) (Differences are in bold type)

(ftSizing Specimen (1) The minimum number of flaws shall be (1) The minimum number of flaws shall be (1) The minimum number of flaws shall be ten. At least 30 percent of the flaws shall ten. At least 30 percent of the flaws shall ten. At least 30 percent of the flaws shall be be overlay fabrication flaws. At least be overlay fabrication flaws. At least overlay fabrication flaws. At least 40 percent of the flaws shall be cracks open 40 percent of the flaws shall be cracks open 40 percent of the flaws shall be open to the to the inside surface. to the inside surface. For initial procedure inside surface. Sizing sets shall contain a qualification, sizing sets shall include the distribution of flaw dimensions to assess equivalent of three personnel qualification sizing capabilities. For initial procedure sets. To qualify new values of essential qualification, sizing sets shall include the variables, at least one personnel equivalent of three personnel qualification qualification set is required. sets. To qualify new values of essential variables, at least one personnel qualification set is required.

(2) At least 20 percent but less than No Change No Change 40 percent of the flaws shall be oriented axially. The remainder shall be oriented circumferentially. Flaws shall not be open to any surface to which the candidate has physical or visual access.

Attachment 2 to AEP:NRC:5055-03 Page I I Revised Appendix VIII, Supplement 11 Comparison to the PDI Alternative Supplement 11 - Qualification PDI Program:

Requirements for Full Structural Code Case N-653 The Proposed Alternative to Overlaid Wrought Austenitic Piping Supplement fl Requirements Welds (Provided for Information Only) (Differences are in bold type)

(3) Base metal cracking used for length No Change (3) Base metal flaws used for length sizing sizing demonstrations shall be oriented demonstrations shall be oriented circumferentially. circumferentially.

(4) Depth sizing specimen sets shall (4) Depth sizing specimen sets shall include at least two distinct locations where No Change include at least two distinct locations where cracking in the base metal extends into the a base metal flaw extends into the overlay overlay material by at least 0.1 inch in the material by at least 0.1 inch in the through-through-wall direction. wall direction.

2.0 CONDUCT OF PERFORMANCE DEMONSTRATION The specimen inside surface and The specimen inside surface and The specimen inside surface and identification shall be concealed from the identification shall be concealed from the identification shall be concealed from the candidate. All examinations shall be candidate. All examinations shall be candidate. All examinations shall be completed prior to grading the results and completed prior to grading the results and completed prior to grading the results and presenting the results to the candidate. presenting the results to the candidate. presenting the results to the candidate.

Divulgence of particular specimen results Divulgence of particular specimen results Divulgence of particular specimen results or candidate viewing of unmasked or candidate viewing of unmasked or candidate viewing of unmasked specimens after the performance specimens after the performance specimens after the performance demonstration is prohibited. demonstration is prohibited. The overlay demonstration is prohibited. The overlay fabrication flaw test and the base metal fabrication flaw test and the base metal flaw test may be performed separately. flaw test may be performed separately.

Attachment 2 to AEP:NRC:5055-03 Page 12 Revised Appendix VIII, Supplement 11 Comparison to the PDI Alternative Supplement 11 - Qualification PDI Program:

Requirements for Full Structural Code Case N-653 The Proposed Alternative to Overlaid Wrought Austenitic Piping Supplement 11 Requirements Welds (Provided for Information Only) (Differences are in bold type) 2.1 Detection Test.

Flawed and unflawed grading units shall be Flawed and unflawed grading units shall be Flawed and unflawed grading units shall be randomly mixed. Although the boundaries randomly mixed. Although the boundaries randomly mixed. Although the boundaries of specific grading units shall not be of specific grading units shall not be of specific grading units shall not be revealed to the candidate, the candidate revealed to the candidate, the candidate revealed to the candidate, the candidate shall be made aware of the type or types of shall be made aware of the type or types of shall be made aware of the type or types of grading units (base or overlay) that are grading units (base metal or overlay grading units (base metal or overlay present for each specimen. fabrication) that are present for each fabrication) that are present for each specimen. specimen.

2.2 Length Sizing Test (a) The length sizing test may be conducted No Change No Change separately or in conjunction with the detection test.

(b) When the length sizing test is No Change No Change conducted in conjunction with the detection test and the detected flaws do not satisfy the requirements of 1.1(f), additional specimens shall be provided to the candidate. The regions containing a flaw to be sized shall be identified to the candidate.

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

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Requirements for Full Structural Code Case N-653 The Proposed Alternative to Overlaid Wrought Austenitic Piping Supplement 11 Requirements Welds (Provided for Information Only) (Differences are in bold type)

(c) For a separate length sizing test, the No Change No Change regions of each specimen containing a flaw to be sized shall be identified to the candidate. The candidate shall determine the length of the flaw in each region.

(d) For flaws in base grading units, the (d) For flaws in base metal grading units, (d) For flaws in base metal grading units, candidate shall estimate the length of that the candidate shall estimate the length of the candidate shall estimate the length of part of the flaw that is in the outer that part of the flaw that is in the outer that part of the flaw that is in the outer 25 percent of the base wall thickness. 25 percent of the base metal wall thickness. 25 percent of the base metal wall thickness.

2.3 Depth Sizing Test. .

For the depth sizing test, 80 percent of the The candidate shall determine the depth of (a) The depth sizing test may be flaws shall be sized at a specific location on the flaw in each region. conducted separately or in conjunction the surface of the specimen identified to the with the detection test.

candidate. 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.

to AEP:NRC:5055-03 Page 14 Revised Appcn ix VIII, Supplement 11 Comparison to the PDI Alternative Supplement 11 - Qualification PDI Program:

Requirements for Full Structural Code Case N-653 The Proposed Alternative to Overlaid Wrought Austenitic Piping Supplement 11 Requirements Welds (Provided for Information Only) (Differences are in bold type)

(b) When the depth sizing test is conducted in conjunction with the detection test and the detected flaws do not satisfy the requirements of 1.1(f),

additional specimens shall be provided to the candidate. The regions containing a flaw to be sized shall be identified to the candidate. The candidate shall determine the maximum depth of the flaw in each region.

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

Attachment 2 to AEP:NRC:5055-03 Page 15 1 Revised Appendix VIII, Supplement 11 Comparison to the PDI Alternative Supplement 11 - Qualification PDI Program:

Requirements for Full Structural Code Case N-653 The Proposed Alternative to Overlaid Wrought Austenitic Piping Supplement 11 Requirements Welds (Provided for Information Only) (Differences are in bold type) 3.0 ACCEPTANCE CRITERIA 3.1 Detection Acceptance Criteria.

Examination procedures, equipment, and Examination procedures are qualified for a) Examination procedures are personnel are qualified for detection when detection when all flaws within the scope qualified for detection when; the results of the performance of the procedure are detected and the demonstration satisfy the acceptance results of the performance demonstration criteria of Table VHI-S2-1 for both satisfy the acceptance criteria of Table detection and false calls. The criteria shall VHI-S2-1 for false calls. Examination be satisfied separately by the demonstration equipment and personnel are qualified for results for base grading units and for detection when the results of the overlay grading units. performance demonstration satisfy the acceptance criteria of Table VIII-S2-1 for both detection and false calls. The criteria shall be satisfied separately by the demonstration results for base metal grading units and for overlay fabrication grading units.

to AEP:NRC:5055-03 Page 16 Revised Appendix VIII, Supplement 11 Comparison to the PDI Alternative Supplement 11 - Qualification PDI Program:

Requirements for Full Structural Code Case N-653 The Proposed Alternative to Overlaid Wrought Austenitic Piping Supplement 11 Requirements Welds (Provided for Information Only) (Differences are in bold type)

1) All flaws within the scope of the procedure are detected and the results of the performance demonstration satisfy the acceptance criteria of Table VIII-S2-1 for false calls.

(a) At least one successful personnel demonstration has been performed meeting the acceptance criteria defined in (b).

(b)Examination equipment and personnel are qualified for detection when the results of the performance demonstration satisfy the acceptance criteria of Table VIII-S2-1 for both detection and false calls.

(c) The criteria in (a), (b) shall be satisfied separately by the demonstration results for base metal grading units and for overlay fabrication grading units.

Attachment 2 to AEP:NRC:5055-03 Pag~e 17 Revised Appen ix VIII, Supplement 11 Comparison to the PDI Alternative Supplement 11 - Qualification PDI Program:

Requirements for Full Structural Code Case N-653 The Proposed Alternative to Overlaid Wrought Austenitic Piping Supplement 11 Requirements Welds (Provided for Information Only) (Differences are in bold type) 3.2 Sizing Acceptance Criteria.

Examination procedures, equipment, and No Change No Change personnel are qualified for sizing when the results of the performance demonstration satisfy the following criteria.

(a) The RMS error of the flaw length No Change (a) The RMS error of the flaw length measurements, as compared to the true measurements, as compared to the true flaw lengths, is less than or equal to flaw lengths, is less than or equal to 0.75 inch. The length of base metal 0.75 inch. The length of base metal flaws is cracking is measured at the 75 percent measured at the 75 percent through-base-through-base-metal position. metal position.

(b) All extensions of base metal cracking This requirement is omitted. This requirement is omitted.,

into the overlay material by at least 0.1 inch are reported as being intrusions into the overlay material.

(c) The RMS error of the flaw depth (b) The RMS error of the flaw depth (b) The RMS error of the flaw depth measurements, as compared to the true measurements, as compared to the true measurements, as compared to the true flaw depths, is less than or equal to flaw depths, is less than or equal to flaw depths, is less than or equal to 0.125 inch. 0.125 inch. 0.125 inch.