ML060550423

Uni 2, Third Ten-Year Inservice Inspection (ISI) Interval Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques,

ML060550423
Person / Time
Site:	San Onofre
Issue date:	02/22/2006
From:	Scherer A Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML060550423 (34)

Text

SOUTHERN CALIFORNIA A. Edward Scherer EDISON`4 Manager of Nuclear Regulatory Affairs An EDISON INTERNATIONALS Company February 22, 2006 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Docket Nos. 50-361 Third Ten-Year Inservice Inspection (ISI) Interval Relief Request ISI-3-18 Use cof Structural Weld Overlay and Associated Alternative Repair Techniques.

San Onofre Nuclear Generating Station, Unit 2

Dear Sir or Madam:

Pursuant to 10 CFR 50.55a(a)(3)(i), Southern California Edison (SCE) requests approval to use alternatives to the requirements of the American Society of Mechanical Engineers (ASME) Code, Section Xl, 1995 Edition through 1996 Addenda, IWA-4000, for repair/replacement activities related to the performance of structural weld overlay repairs at San Onofre Nuclear Generating Station (SONGS) Unit 2 for the third 10-year inservice inspection (ISI) interval.

SONGS Unit 2 is now in its Cycle 14 refueling outage and ISI Ultrasonic (UT) examinations were performed in accordance with the SONGS Risk-informed Inservice Inspection (RI-ISI) program, SONGS response to NRC Bulletin 2004-01, Material Reliability Program, Primary System Piping Butt Weld Inspection and Evaluation Guideline (MRP 139), and ASME Section XI Code.

These examinations included 4 high safety significant (HSS) Class 1 reactor coolant system (RCS) pressurizer, dissimilar metal, nozzle to safe end welds.

These welds are ISI Designation Numbers 02-005-027, 02-005-028, 02-005-029, and 02-005-030, which are three safety valve line nozzles and the pressurizer spray line nozzle, respectively. The pressurizer spray line weld inspection met the requirements of Appendix VIII, Supplement 10, as modified by the Performance Demonstration Initiative (PDI) Program. However, the material of the three, safety valve line safe ends is cast austenitic stainless steel. SCE performed the qualified Appendix Vil, Supplement 10, as modified by the PDI Program UT exam, on the Alloy 82/182 welds from the nozzle side, which is ferritic steel. Appendix Vil, Supplement 9 "Qualification Requirements for Cast Austenitic Piping Welds" is in course of preparation P.O. Box 128 }O -

San Clemente, CA 92672 949-368-7501 Fax 949-368-7575

Document Control Desk February 22, 2006 and is not required by 10CFR50.55a(g)(6)(ii)(C). Therefore, to meet the RI-IS I UT examination requirement of the safety valve lines, SCE has performed the UT examination from the cast austenitic stainless steel side in accordance with ASME Section Xl, Appendix IlIl.

Although axial indications were identified in ISI Designation Numbers 02-005-027 and 02-005-028, these indications were dispositioned as not being attributed to primary water strauss corrosion cracking (PWSCC) as discussed below. Nevertheless, SCE has decided to perform a structural weld overlay on all four welds to eliminate dependence on the Alloy 82/182 welds as a pressure boundary weld and to mitigate any potential PWSCC in the future.

The axial indications identified in 02-005-027 and 02-005-028 were found in the Alloy 82/182 weld. SCE requested the EPRI NDE Center to review these axial indications and SCE performed eddy current examinations on these welds. Through these supplemental! examinations and the evaluation SCE concluded that the identified axial indications are not surface connected and therefore are not PWSCC. There is evidence that the indications are related to fabrication flaws that were created during the fabrication of the welds. The detaills of the EPRI evaluation are provided as Enclosure 1 to this letter.

Although there is evidence that these indications are acceptable fabrication flaw indications, SCE will be performing a structural weld overlay repair instead of evaluating them as flaws in accordance with ASME Section Xl Code requirements SONGS Unit 2 is in its third 10-year ISI interval, which started on August 18, 2003 and is scheduled to end on August 17, 2013. The 1995 Edition through 1996 Addenda of Section Xl applies to the ISI program, the RI-ISI program, the Repair/Replacement program activities, and the requirements associated with Appendix Vil, Performance Demonstration for Ultrasonic Examination Systems.

ASME approved Code Cases N-504-2 and N-638-1 are listed as acceptable for use in NRC Regulatory Guide 1.147, Revision 14, with the following conditions that will be met for the purposes of this request:

N-504-2: The provisions of Section Xl, Nonmandatory Appendix Q, "Weld Overlay Repair of Class 1, 2, and 3 Austenitic Stainless Steel Piping Weldments," must also be met. (This appendix is now published in the 2005 Addenda of ASME Section Xl.)

Document Control Desk February 22, 2006 N-638-1: UT examinations shall be demonstrated for the repaired volume using representative samples that contain construction type flaws. The acceptance criteria of NB-5330 of Section III edition and addenda approved in 10 CFR 50.55a apply to all flaws identified within the required volume.

These Code Cases and the 1995 Edition through 1996 Addenda of Section Xl contain some of the criteria needed to apply a structural weld overlay repair in dissimilar metal piping welds with Alloy 82/182 weld material including the use of temper bead welding without preheat or post weld heat treatment.

Alternatives to these ASME Code requirements and modifications to the methodologies contained in Code Case N-504-2 and Code Case N-638-1, however, will be used to apply an acceptable structural weld overlay repair with NRC approval of this request. Additionally for SONGS Unit 2, SCE is required in accordance with 10 CFR 50.55a(g)(6)(ii)(C) to implement Appendix V\ll of the ASME Code, Section Xl, 1995 Edition with the 1996 Addenda, which contains ultrasonic examination performance qualification requirements under Supplement 11 for a completed structural weld overlay repaiir. In lieu of these ASME Code ultrasonic requirements, SCE proposes to use alternative techniques for the ultrasonic examination of the structural weld overlay repair, and the examination of the dissimilar metal welds.

Use of the proposed alternative is based on the Performance Demonstration Initiative (PDI) approved techniques and procedures also contained in this request. The detailed relief request ISI-3-18 is provided as Enclosure 2 to this letter. It contains a comprehensive set of criteria that includes three tables that outline the proposed SONGS Unit 2 structural weld overlay repair criteria for the welds with ISI Designation Numbers 02-005-027, 02-005-028, 02-005-029, and 02-005-030. None of the stainless steel safe end to pipe welds adjacent to the welds designated above needed to be included in the structural weld overlay repair. The size of the structural weld overlay repair on each of the four welds is limited to the designated weld. The three tables provide alternatives and modifications to the ASME Code requirements and Code Cases N-504-2 and N-638-1 that SCE has determined will be necessary to perform this repair to provide an acceptable level of quality and safety. SCE will also use Code Case N-460, which is listed as acceptable for unconditional use in NRC Regulatory Guide 1.147, Revision 14.

Similar relief requests have been previously approved for AmerGen Energy Company for its Three Mile Island Nuclear Station, Unit 1 on July 21, 2004, for Susquehanna Steam Electric Station, on Unit 1,June 22, 2005, for Indiana Michigan Power Company for Donald C. Cook Nuclear Plant, Unit 1 on June 27, 2005, for Constellation Energy's Calvert Cliffs Nuclear Power Plant, Unit 2

Document Control Desk February 22, 2006 on July 20, 2005, and for Dominion Nuclear Connecticut for Millstone Power Station Unit 3, on January 20, 2006.

Please note that Attachment 3 of the enclosed relief request is considered proprietary information and contains the affidavit required by 10 CFR 2.390 requesting that Attachment 3 be withheld from public disclosure.

The relief request does not include the stress analysis that is being performed to support the structural weld overlay repair. Considering the weld overlay implemented is a full structural replacement of the existing piping material, i.e.,

the resulting stresses in the piping material will be decreased. The current stress report, which covers the weld with no overlay, is sufficiently conservative to justify the weld with the overlay. The analysis is not expected to be completed until some time after the Unit 2 return to service. SCE will submit a summary report of the analysis and its conclusion as soon as they become available.

SCE requests approval of this relief request to support the return to service of SONGS Unit 2 from the current Cycle 14 refueling outage. As of now the schedule shows the need by March 21, 2006, but it could occur earlier.

Should you have any questions, please contact Mr. Jack Rainsberry at (949) 368-7420 Sincerely,

Enclosures:

1. EPRI Report "Review of Ultrasonic Examinations Performed at SONGS Unit 2 on the Pressurizer Safety Nozzle During Unit 2 C14"

2. Relief Request 1';1-3-18, "Use of Structural Weld Overlay and Associated Alternative Repair Techniques" cc: e. S. Mallett, Regional Administrator, NRC Region IV N. Kalyanam, NRC Project Manager, San Onofre Units 2 and 3 C;. C. Osterholtz, NRC Senior Resident Inspector, San Onofre Units 2 and 3

Proprietary Information Submitted Under 10 CFR 2.390 Contained in Attachment 3 of this Document Southern California Edison (SCE)

San Onofre Nuclear Generating Station (SONGS), Unit 2 Docket No. 50-361 Enclosure 2 Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques

Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques Proprietary Information submitted Under 10 CFR 2.390 Contained in Attachment 3 of this Document CONTENTS 1.0 REASON FOR THE REQUEST .................................................... 2 2.0 CODE COMPONENTS FOR WHICH RELIEF IS REQUESTED .............. 2 3.0 (CODE REQUIREMENTS FOR WHICH RELIEF IS REQUESTED .......... 4 4.0 PROPOSED ALTERNATIVES AND SUPPORTING INFORMATION ...... 4 5.0 DURATION OF THE PROPOSED RELIEF REQUEST ............................... 6 6.0 PRECEDENTS ................................................... 7

7.0 REFERENCES

................................................... 8 8.0 CVONCLUSION .................................................... 8 ATTACHMENT 1 Table 1: Modifications To Code Case N-504-2 and Corresponding Nonmandatory Appendix Q Requirements Table 2: Alternatives To Appendix VIII. Supplement 11 Table 3: Modification To Code Case N-638-1 ATTACHMENT 2 Chemical Analyses of Incremental Milling of Weldment ATTACHMENT 3 Structural Weld Overlay Design Drawings (Proprietary Information Submitted Under 10 CFR 2.390)

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Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques Proposed Altemative In Accordance with 10 CFR 50.55a(a)(3)(i)

- Altemative Provides Acceptable Level of Quality and Safety -

1.0 REASON FOR THE REQUESr Currently, there are no comprehensive criteria for a licensee to apply a structural weld overlay repair to a dissimilar metal weld that is constructed of Alloy 82/182 weld material, which is susceptible to primary water stress corrosion cracking (PWSCC). Although the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel Code, Section Xl, 1995 Edition through 1996 Addenda, IWA4000 (Reference 1), is used for the San Onofre Nuclear Generating Station (SONGS) Unit 2 Section Xl repair/replacement program, it does not have the needed requirements for this type of repair. The latest Nuclear Regulatory Commission (NRC) approved ASME Code also does not have the needed requirements for this type of repair. Repair/replacement activities associated with a structural wield overlay repair of this type are required to address the materials, welding parameters, ALARA concerns, operational constraints, examination techniques, and procedure requirements. Thus, this is the reason for this relief request.

2.0 CODE COMPONENTS FOR WHICH RELIEF IS REQUESTED Group: High safety significant (HSS) Class 1 dissimilar metal piping welds with Alloy 82/182 weld metal are believed to be susceptible to PWSCC.

a) Name of Components:

1. Pressurizer S21201ME087 safety nozzle to safe end HSS dissimilar metal weld (ISI Designation Number 02-005-027) with Alloy 82/182 weld material subject to PWSCC. This weld contains five axial flaw indications that were confirmed not surface connecting by supplemental eddy current examination (ECT).

2. Pressurizer S21201ME087 safety nozzle to safe end HSS dissimilar metal weld (ISI Designation Number 02-005-028) with Alloy 82/182 weld material subject to PWSCC. This weld contains one axial flaw indication that was confirmed not surface connecting by supplemental ECT and visual examination.

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Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques

3. Pressurizer S21201 ME087 safety nozzle to safe end HSS dissimilar metal weld (ISI Designation Number 02-005-029) with Alloy 82/182 weld material subject to PWSCC. This weld contains no reportable indications.

4. Pressurizer S21201 ME087 spray nozzle to safe end HSS dissimilar metal weld (ISI Designation Number 02-005-030) with Alloy 82/182 weld material subject to PWASCC. This weld contains no reportable indications.

The size of the weld overlay repair on each of the four welds is limited to cover only the designated weld. The adjacent welds were Ultrasonic Testing (UT) examined per the Risk Informed Inservice Inspection (RI-ISI) program, with no reportable indications.

b) ASME Code Class:

These welds are all ASME Code Class I welds located within the reactor coolant pressure boundary and subject to the steam space environment of the pressurizer.

c) System:

Reactor Coolant System (RCS) d) Code Category:

Examination Category B-F, "Risk-Informed Piping Examinations" e) Code Item No. B5.40

'Welds subject to PWSCC" (ISI Designation Numbers 02-005-027, 02-005-028, 02-005-029, 02-005-0 30)

"Welds subject to Thermal Fatigue" (ISI Designation Numbers 02-005-027, 02-005-028, 02-005-029, 02-00'5-030) 3.0 CODE REQUIREMENTS FOR WHICH RELIEF IS REQUESTED 1995 Edition through the 1996 Addenda of the ASME Code Section Xl, (Reference 1), IWA-4610(a).

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Relief Request ISI-3-18 Use of Structural Weld Overlay and Aissociated Alternative Repair Techniques 1995 Edition with the 1996 Addenda, of the ASME Code, Section Xl, Appendix VIII, Supplement 11 (Reference 2).

Modification to the Nuclear Regulatory Commission (NRC) approved Code Case N-504-2 with the 2005 Addenda, Nonmandatory Appendix Q (Reference 3).

Code Case N-638-1 (Reference 4).

Attachment 1,Tables 1, 2, and 3 provide details of relief requested from each of the above requirements.

4.0 PROPOSED ALTERNATIVES AND SUPPORTING INFORMATION A structural weld overlay repair is proposed for the pressurizer S21201 ME087 safety nozzles to safe end HSS dissimilar metal welds (ISI Designation Numbers 02-005-027, 02-005-028, and 02-005-029) and the spray nozzle to safe end weld (ISI Designation Number 02-005-030). The material of the above four nozzles is ferritic steel (P3). The pipe safe ends are austenitic stainless steel (P8). The spray nozzle material is SA-508 Class 2 and the safe end material is SA-1 82 F 316. The safety nozzles material is SA-508 Class 2 and the safe end material is SA-351 CF8M. The existing weld filler material is Alloy 82/182 (F43 equivalent to P43). The overlay will be designed as a structural weld overlay in accordance with ASME Section Xl Code Case N-504-2 and Nonmandatory Appendix Q (Reference 3). The temper bead welding technique will be implemented in accordance with ASME Section Xl Code Case N-638-1 (Reference 4) for that portion of the overlay applied over the ferritic base material for which the Construction Code requires post-weldl heat treatment. Temperature monitoring requiirements contained within this Ccde Case will be performed using contact pyrometers in lieu of thermocouples required by IWA-4610(a) of the ASME Code, Section Xl 1995 Edition through 1996 Addenda (Reference 1).

This structural weld overlay is sized to satisfy the ASME Section III requirements without crediting the existing pipe. See Attachment 2 for the chromium content information of the weld material being used and Attachment 3 for a design drawing of each of the four structural weld overlays associated with this relief request. This structural weld overlay (weld reinforcement) will completely cover the existing Alloy 82/182 weld metal and will extend onto the ferritic and austenitic stainless steel material on each end of the weld. To avoid stress risers, the weld material is extended and tapered across the pipe and nozzle side. The end slope is required to be no steeper than 45 degrees to minimize stress concentration. Sufficient overlay length is provided to allow for adequate transfer of axial loads between the pipe and the weld overlay. Therefore, the length of the actual structural weld overlay exceeds the minimum length required Page 4 of 8

Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques by ASME Code Case N-504-2 and Section Xi Appendix Q for load redistribution and inspection purposes. The thickness of the overlay is determined by the general Section Xl requirement that no flaw of depth greater than 75% through-wall is acceptable, along with the consideration of applied loading. It is important to note that inspection requirements are a controlling factor in the structural weld overlay repair design. The length of the structural weld overlay must be sufficient for inspection of an area that is 1/2 inch beyond the required repair length and the outer 25% of the original wall thickness. It should be noted that the length of the structural weld overlay was extended and blended into the low alloy steel nozzle outer diameter taper to permit UT inspection of the weld and minimize stress concentration on the nozzle outer diameter. Since the outside diameter of the nozzle is larger than that of the safe end, the structural weld overlay thickness on the safe end is increased to allow a smooth transition surface for UT inspection. Therefore, the final structural weld overlay length and thickness after taking into consideration the UT inspection requirements will exceed the length required for a structural weld overlay repair in accordance with the ASME Code Case N-504-2 and Section Xl Appendix Q.

In summary, the combination of deposition of PWSCC resistant weld reinforcement on the outside surface of the dissimilar metal weld, with favorable axiall and hoop residual compressive stress produced on the inside diameter due to shrinkage will bear acceptable assurance for long term crack mitigation. In addition, inservice inspection is facilitated because of the enhanced ability to inspect the joint.

Tables 1, 2, and 3, when used with the ASME Code, Section Xl, 1995 Edition through 1996 Addenda, Article IWA4000 (Reference 1), provide a comprehensive package of proposed detailed criteria with requirements, proposed altematives, methodologies, modifications, and the bases for these differences, to support this relief request. This SONGS Unit 2 structural weld overlay repair of a piping weld with Alloy 82/182 weld material will be performed as a repair/replacement activity in accordance with IWA-4000 of the 1995 Edition, through 1996 Addenda, of AS;ME Section Xl (Reference 1) with the exception of the requirements in IWA-461 0(a). In lieu of the weld-attached thermocouple requirements and recording instruments in IWA-4610(a), contact pyrometers and manual recording of the process temperatures will be used at SONGS Unit 2. These contact pyrometers will be calibrated in accordance with the measuring and test equipment program and will be capable of monitoring the process temperatures from 50 0F, minimum preheat temperature to 350'F, maximum interpass temperature. Additionally, the methodology of Code Case N-504-2 (Reference 2), as modified and shown in Table 1,will be used. The ultrasonic examination of the completed structural weld overlay will be accomplished in accordance with ASIME Section Xl, 1995 Edition with the 1996 Addenda, Appendix VilI, Supplement 11 (Reference 2) with the alternatives used to comply with the Performance Demonstration Initiative (PDI) program as shown Page 5 of 8

Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques in Table 2. The temper bead weld technique requirements in accordance with Code Case N-638-1 (Reference 4) will be applied to the ferritic nozzle base material with the modifications described in Table 3. Any applicable requirements not addressed by Tables 1,2, and 3 will be met as described in Section Xl, 1995 Edition through 1996 Addenda, IWA-4000 (Reference 1);

Appendix Vill, Supplement 11 (Reference 2); Code Case N-504-2 (Reference 3);

and Code Case N-638-1 (Reference 4).

Code Case N-504-2 (Reference 3) is approved for use for austenitic stainless steel material in NRC Regulatory Guide 1.147, Revision 14, August 2005, provided it is used with Nonmandatory Appendix Q, of ASME Section Xl, 2005 Addenda. Provided in Table I are SCE's proposed modifications for structural weld overlay repair of nickel based and ferritic materials due to the specific construction of the SONGS Unit 2 dissimilar metal welds. Therefore, SCE intends to follow the methodology of Code Case N-504-2 (Reference 3), except for the modifications identified in Table 1.

5.0 DURATION OF PROPOSED RELIEF REQUEST This request will be applied for the remainder of the current SONGS Unit 2 third 10-year ISI interval that started on August 18, 2003. Once these structural weld overlays are installed they will remain in place for the design life of the repair that is defined by the evaluation required in paragraph (g) of Code Case N-504-2 and corresponding requirements in Nonmandatory Appendix Q (Reference 3). The structural weld overlays are also subject to the satisfactory examination requirements of Article Q-4000 for inservice inspection. Those requirements include adding any installed structural weld overlay repairs into the SONGS Unit 2 ISI plan per Subarticle Q4300 for at least one inservice examination to be completed within the next 2 refueling cycles.

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Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques 6.0 PRECEDENTS

1. Letter from Richard J. Laufer, NRC, to Christopher M. Crane, AmerGen, "Three Mile Island Nuclear Station, Unit 1 (TMI-1) Request for Relief from Flaw Removal, Heat Treatment, and Nondestructive Examination Requirements for the Third 10-year Inservice Inspection (ISI) Interval (TAC.No. MC1201)," Accession Number ML041670510, dated July 21, 2004.

2. Letter from Richard J. Laufer, NRC, to Bryce L. Shriver, PPL Susquehanna, "Susquehanna Steam Electric Station, Unit 1 - Relief from American Society of Mechanical Engineers, Boiler and Pressure Vessel Code (ASME Code), Section Xl, Appendix VilI, Supplement 11, Requirements and Code Cases N-504-2 and N-638 Requirements (TAC Nos. MC2450, MC2451 and MC2594)," Accession Number ML051220568, dated June 22, 2005.

3. Letter from L. Raghavan, NRC, to Mano K. Nazar, I&M, "Donald C. Cook Nuclear Plant, Unit I - Alternative to Repair Requirements of Section Xl of the American Society of Mechanical Engineers Code (TAC No.

MC06751)," Accession Number ML051720006, dated June 27, 2005.

4. Letter from Richard J. Laufer, NRC, to George Vanderheyden, Calvert Cliffs, "Calvert Cliffs Nuclear Power Plant, Unit No. 2 - Relief Request for Use Weld Overlay and Associated Alternative Inspection Techniques (TAC Nos. MC6219 and MC62'20)," Accession Number ML051930316, dated July 20, 2005.

5. Letter from Leslie N. Darrell J. Roberts, NRC, to David A. Christian Dominion Nuclear Connecticut, Inc., "Millstone Power Station, Unit No. 3-Issuance of Relief from Code Requirements (TAC No. MC8609),"

Accession Number ML053260012, dated January 20, 2006.

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Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques

7.0 REFERENCES

(1) 1995 Edition through 1996 Addenda, ASME Code, Section Xi, IWA-4000.

(2) 1995 Edition, ASME Code, Section Xl, with the 1996 Addenda, Appendix VIII, Supplement 11.

(3) ASME Code Case N-504-2, Alternative Rules for Repair of Class 1,2, and 3 Austenitic Stainless Steel Piping Section Xl, Division 1, March 12, 1997, including ASME Code Section Xl, 2005 Addenda, Nonmandatory Appendix Q,Weld Overlay Repair of Class 1 , 2, and 3 Austenitic Stainless Steel Piping Weldments.

(4) ASME Code Case N-638-1, Similar and Dissimilar Metal Welding Using Ambient Temperature Machine GTAW Temper Bead Technique Section Xl, Division I , February 13, 2003.

8.0 CONCLUSION

SCE has determined that the approach described in this relief request includes available operating experience (OE) related to previously approved NRC requirements that have been used to produce acceptable structural weld overlay repairs when applied to a dissimilar metal weld with Alloy 82/182 weld material.

The basis for this determination is the application of this same type of structural weld overlay repair at Three Mile Island, Donald C. Cook, Calvert Cliffs, and Millstone. Those structural weld overlay repairs were based on, and this relief request includes, the NRC approved ASME Code requirements and Code Cases. SCE believes that the use of this relief request for a structural weld overlay repair at SONGS Unit 2 will result in an acceptable level of quality and safely that meets the requirements of 10 CFR 50.55a(a)(3)(i).

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Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques Attachment 1 San Onofre Nuclear Generating Station, Unit 2, Comprehensive Criteria For Structural Weld Overlay of Welds Contains Modifications and Alternatives for the Use Of Relief Request ISI-3-18 Tables 1, 2, and 3

Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques Table I Modifications To Code Case N-504-2 and Corresponding Non-Mandatory Appendix Q Requirements Code Case N-504-2 Modiflcation/Basis Reply: It is the opinion of the Committee that, in lieu of the Modification. Code Case N-504-2 will be used for weld overlay requirements of IWA-4120 in Editions and Addenda up to and repairs to the ferritic (P3) and nickel alloy (F43/P43) base including the 1989 Edition with the 1990 Addenda, in IWA- material as well as the austenitic stainless steel (P8) base 4170(b) in the 1989 Edition with the 1991 Addenda up to and material.

including the 1995 Edition, and in IWA-4410 in the 1995 Edition Basis: Code Case N-504-2 is accepted for use along with with the 1995 Addenda and later Editions and Addenda, defect Nonmandatory Appendix Q in the current NRC Regulatory in austenitic stainless steel piping may be reduced to a flaw of Guide 1.147 Rev. 14. For the weld overlay of the identified acceptable size in accordance with IWB-3640 from the 1983 welds at SONGS Unit 2 the base material will be ferritic material Edition with the Winter 1985 Addenda, or later Editions and (P3) with existing nickel alloy weld metal (F43/P43) to which an Addenda, by deposition at weld reinforcement (weld overlay) austenitic stainless steei (PB) safe end is weided. industry on the outside surface of the pipe, provided the following operational experience has shown that PWSCC in Alloy 82/182 requirements are met. [Essentially same as Scope of will blunt at the interface with stainless steel base metal, ferritic Appendix Q]: base metal, or Alloy 52/52M weld metal, SONGS Unit 2 plans to apply a 3600 structural weld overlay to control growth in any PWSCC crack and maintain weld integrity. The weld overlay will induce compressive stress in the weld, thus impeding growth of any reasonably shallow cracks. Furthermore, the overlay will be sized to meet all structural requirements independent of the existing weld.

(b)Reinforcement weld metal shall be low carbon (0.035% Modification. In lieu of austenitic stainless steel filler material, max.) austenitic stainless steel applied 3600 around the the reinforcement weld metal will be a nickel alloy.

circumference of the pipe, and shall be deposited in Basis: The weld metal used may be ERNiCrFe-7A (Alloy 52M, accordance with a qualified welding procedure specification UNS N06054) or ERNiCrFe-7 (Alloy 52 UNS N06052). This identified in the Repair Program. [Same as Q-2000(a)] weld metal is assigned F43 by ASME per Code Case 2142-2.

The requirements ofASME Section III, NB-2400 will be applied to all filler material. The chromium content of Alloy 52M is 28-3 1.5Yo, identical to that of Alloy 52. The main difference in Alloy 52 vs. Alloy 52M is a higher Niobium content (0.5- 1%). The Page 1 of 2

Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques Table I Modifications To Code Case N-504-2 and Corresponding Non-Mandatory Appendix Q Requirements difference in chemical composition between Alloy 52 and Alloy 52M improves the weldability of the material and pins the grain boundaries thus preventing separation between the grains and hot tearing during weld puddle solidification. These filler materials were selected for their improved resistance to PWSCC. Alloys 52 and 52M contain about 30% chromium that imparts excellent corrosion resistance. The existing Alloy 82/182 weld and the Alloy 52/52M overlay are nickel base and have ductile properties and toughness similar to austenitic stainless steel piping welds at pressurized water reactor operating temperature. These filler materials are suitable for welding over the ferritic nozzle or pipe Alloy 82/182 weld and the austenitic stainless steel pipe or safe ends.

(e) The weld reinforcement shall consist of a minimum of two Modification: Delta ferite (FN) measurements will not be weld layers having as-deposited delta ferrite content of at least performed for weld overlay repairs made of Alloy 52/52M weld 7.5 FN. The first layer of weld metal with delta ferrite content of metal.

least 7.5 FN shall constitute the first layer of the weld Basis: Welds of Alloy52/52M are 100% austenitic and contain reinforcement design thickness. Alternatively, first layers of at no delta ferrite due to the high nickel composition least 5 FN may be acceptable based on evaluation. [Same as (approximately 60% nickel).

Q-2000(d)]

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Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques Table 2 Alternatives to Appendix Vill, Supplement 11 Appendix Vil of Section Xl cannot be used for NDE of a structural weld overlay repair. Relief is requested to use the PD1 program implementation of Appendix VIII. A detailed comparison of Appendix V\II and PDI requirements is summarized below.

Relief is requested to allow closer spacing of flaws provided they don't interfere with detection or discrimination. The specimens used to date for qualification to the Tri-party (NRC/BWROG/EPRI) agreement have a flaw population density greater than allowed by current Code requirements. These samples have been used successfully for all previous qualifications under the Tn-party agreement program. To facilitate their use and provide continuity from the Tn-party agreement program to Supplement 11, the PDI program has merged the Tri-party test specimens into their structural weld overlay program.

SUPPLEMENT 11 - QUALIFICATION REQUIREMENTS PDI PROGRAM:

FOR FULL STRUCTURAL OVERLAID WROUGHT The Proposed Alternative to Supplement 11 AUSTENITIC PIPING WELDS Requirements 1 0 SPECIMEN REQUIREMENTS 1.1 General. The specimen set shall conform to the following requirements.

(b)The specimen set shall consist of at least three specimens Alternative: (b)The specimen set shall include specimens with having different nominal pipe diameters and overlay overlays not thicker than 0.1 in.more than the minimum thicknesses. They shall include the minimum and maximum thickness, nor thinner than 0.25 in.of the maximum nominal nominal pipe diameters for which the examination procedure is overlay thickness for which the examination procedure is applicable. Pipe diameters within a range of 0.9 to 1.5 times a applicable.

nominal diameter shall be considered equivalent. If the Basis: To avoid confusion, the overlay thickness tolerance procedure is applicable to pipe diameters of 24 in.or larger, the contained in the last sentence was reworded and the phrase specimen set must include at least one specimen 24 in. or "and the remainder shall be alternative flaws" was added to the larger but need not include the maximum diameter. The next to last sentence in paragraph 1.1 (d)(1).

specimen set must include at least one specimen with overlay thickness within -0.1 in.to +0.25 in.of the maximum nominal overlay thickness for which the procedure is applicable.

Page 1 of 7

Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques Table 2 Alternatives to Appendix Vill, Supplement 11 (d) Flaw Conditions (1) Base metal flaws. All flaws must be cracks in or near the - Alternative: (1) ... must be in or... intentional overlay butt weld heat-affected zone, open to the inside surface, and fabrication flaws shall not interfere with ultrasonic detection or extending at least 75% through the base metal wall. Flaws may characterization of the base metal flaws. Specimens containing extend 100% through the base metal and into the overlay intergranular stress corrosion cracking shall be used when material; in this case, intentional overlay fabrication flaws shall available. At least 70% of the flaws in the detection and sizing not interfere with ultrasonic detecton or characterization of the tests shall be cracks and the remainder shall be alternative cracking. Specimens containing IGSCC shall be used when flaws. Alternative flaw mechanisms, if used, shall provide crack-available. like reflective characteristics and shall be limited by the following:

(a) The use of alternative flaws shall be limited to when the implantation of cracks produces spurious reflectors that are uncharacteristic of actual flaws.

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

Basis: This paragraph requires that all base metal flaws be cracks. 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% of the flaws in the detection and sizing test shall be cracks and the remainder shall be alternative flaws. To avoid confusion, the overlay thickness tolerance contained in paragraph 1.1(b) last sentence, was Page 2 of 7

Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques Table 2 Alternatives to Appendix VIII, Supplement 11 reworded and the phrase "and the remainder shall be alternative flaws" was added to the next to last sentence.

Paragraph 1.1 (d)(1) includes the statement that intentional overlay fabrication flaws shall not interfere with ultrasonic detection or characterization of the base metal flaws.

(e) Detection Specimens (1) At least 20% but less than 40% of the flaws shall be oriented Alternative: (1) At least 20% but less than 40% of the base within +/-20° of the pipe axial direction. The remainder shall be metal flaws shall be oriented within +/-20° of the pipe axial oriented circumferentially. Flaws shall not be open to any direction. The remainder shall be oriented circumferentially.

surface to which the candidate has physical or visual access. Flaws shall not be open to any surface to which the candidate The rules of IWA-3300 shall be used to determine whether has physical or visual access.

closely spaced flaws should be treated as single or multiple Basis: The requirement for axially oriented overlay fabrication flaws. flaws was excluded from the PDI Program as an improbable scenario. Weld overlays are typically applied using automated GTA W techniques with the filler metal applied in a circumferential direction. Because resultant fabrication induced discontinuities would also be expected to have major dimensions oriented in the circumferential direction axial overlay fabrication flaws are unrealistic. The requirement for using IWA-3300 for proximity flaw evaluation was excluded, instead indications will be sized based on their individual merits.

(2) Specimens shall be divided into base and overlay grading Alternative: (2) Specimens shall be divided into base metal units. Each specimen shall contain one or both types of grading and overlay fabrication grading units. Each specimen shall units. contain one or both types of grading units. Flaws shall not interfere with ultrasonic detection or characterization of other flaws.

(a)(1) A base grading unit shall include at least 3 in. of the Alternative: (a)(1) A base metal grading unit includes the length of the overlaid weld. The base grading unit includes the overlay material and the outer 25% of the original overlaid outer 25% of the overlaid weld and base metal on both sides. weld. The base metal grading unit shall extend circumferentially The base grading unit shall not include the inner 75% of the for at least I in. and shall start at the weld centerline and be overlaid weld and base metal overlay material, or base metal wide enough in the axial direction to encompass one half of the Page 3 of 7

Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques Table 2 Alternatives to Appendix VI1I, Supplement 11 to-overlay interface. original weld crown and a minimum of 0.50" of the adjacent base material.

Basis: The phrase "and base metal on both sides," was inadvertently included in the description of a base metal grading unit, The PDl 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. Modified to require that a base metal grading unit include at leastl in. of the length of the overlaid weld, rather than 3 inches.

(a)(2) When base metal cracking penetrates into the overlay Altemative: (a)(2) When base metal flaws penetrate into the material, the base grading unit shaii inciude the overlay metal avelay material, the base metal grading unit shall nv.I Use within 1 in. of the crack location. This portion of the overlay as part of any overlay fabrication grading unit.

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

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

length used in one base grading unit shall not be used in Modified to require sufficient unflawed overlaid weld and base another base grading unit. Base grading units need not be metal to exist on all sides of the grading unit to preclude uniformly spaced around the specimen. interfering reflections from adjacent flaws, rather than the 1 inch requirement.

(b)(1) An overlay grading unit shall include the overlay material Altemative: (b)(1) An overlay fabrication grading unit shall and the base metal-to-overlay interface of at least 6 in2. The include the overlay material and the base metal-to-overlay overlay grading unit shall be rectangular, with minimum interface for a length of at least 1 in.

dimensions of 2 in. Modified to require sufficient unflawed overlaid weld and base metal to exist on all sides of the grading unit to preclude interfering reflections from adjacent flaws, rather than the I inch requirement (b)(2) An overlay grading unit designed to be unflawed shall be Altemative: (b)(2) Overlay fabrication grading units designed Page 4 of 7

Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques Table 2 Alternatives to Appendix VIII, Supplement 11 surrounded by unflawed overlay material and unflawed base to be unflawed shall be separated by unflawed overlay material metal-to-overlay interface for at least 1 in. around its entire and unflawed base metal-to-overlay interface for at least 1 in.

perimeter. The specific area used in one overlay grading unit at both ends. Sufficient unflawed overlaid weld and base metal shall not be used in another overlay grading unit. Overlay shall exist on both sides of the overlay fabrication grading unit grading units need not be spaced uniformly about the to preclude interfering reflections from adjacent flaws. The specimen. specific area used in one overlay fabrication grading unit shall not be used in another overlay fabrication grading unit. Overlay fabrication grading units need not be spaced uniformly about the specimen.

Basis: Paragraph 1.1 (e)(2)(b)(2) states that overlay fabrication grading units designed to be unflawed shall be separated by unflawed overlay material and unflawed base metal-to-overlay interface for at least 1 in. at both ends, rather than around its entire perimeter.

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

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

(3) Base metal cracking used for length sizing demonstrations Altemative: (3) Base metal flaws used ...circumferentially.

Page 5 of 7

Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques Table 2 Alternatives to Appendix VIII, Supplement 11 shall be oriented circumferentially.

(4) Depth sizing specimen sets shall include at least two distinct Alternative: (4) Depth sizing specimen sets shall include at locations where cracking in the base metal extends into the least two distinct locations where a base metal flaw extends overlay material by at least 0.1 in. in the through-wall direction. into the overlay material by at least 0.1 in. in the through-wall direction.

2.0 Conduct of Performance Demonstration The specimen inside surface and identification shall be Alternative: The specimen ...prohibited. The overlay concealed from the candidate. All examinations shall be fabrication flaw test and the base metal flaw test may be completed prior to grading the results and presenting the results performed separately.

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 grading units shall be randomly mixed. Alternative: Flawed ... (base metal or overlay Although the boundaries of specific grading units shall not be fabrication)... each specimen.

revealed to the candidate, the candidate shall be made aware of the type or types of grading units (base or overlay) that are present for each specimen.

2.2 Length Sizing Test (d) For flaws in base grading units, the candidate shall estimate Alternative: (d) For.. . base metal grading.. . base metal wall the length of that part of the flaw that is in the outer 25% of the thickness.

base wall thickness.

2.3 Depth Sizing Test.

For the depth sizing test, 80% of the flaws shall be sized at a Alternative: (a) The depth sizing test may be conducted specific location on the surface of the specimen identified to the separately or in conjunction with the detection test.

candidate. For the remaining flaws, the regions of each (b) When the depth sizing test is conducted in conjunction with specimen containing a flaw to be sized shall be identified to the the detection test and the detected flaws do not satisfy the candidate. The candidate shall determine the maximum depth requirements of 1.1 (f), additional specimens shall be provided of the flaw in each region. 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 Page 6 of 7

Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques Table 2 Alternatives to Appendix VIII, Supplement 11 candidate. The candidate shall determine the maximum depth of the flaw in each region.

3.0 ACCEPTANCE CRITERIA 3.1 Detection Acceptance Criteria .

Examination procedures, equipment, and personnel are _

Alternative: Examination procedures are qualified for detection qualified for detection when the results of the performance when:

demonstration satisfy the acceptance criteria of Table VlIl-S2-1 a. All flaws within the scope of the procedure are detected and for both detection and false calls. The criteria shall be satisfied the results of the performance demonstration satisfy the separately by the demonstration results for base grading units acceptance criteria of Table VII-S2-1 for false calls.

and for overlay grading units. b. At least one successful personnel demonstration has been performed meeting the acceptance criteria defined in (c).

c. 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.

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

3.2 Sizing Acceptance Criteria (a) The RMS error of the flaw length measurements, as Altemative: (a) The ...base metal flaws is... position.

compared to the true flaw lengths, is less than or equal to 0.75 inch. The length of base metal cracking is measured at the 75%

through-base-metal position.

(b) All extensions of base metal cracking into the overlay Alternative: This requirement is omitted.

material by at least 0.1 in. are reported as being intrusions into Basis: The requirement for reporting all extensions of cracking the overlay material. into the overlay is omitted from the PDI Program because it is redundant to the RMS calculations performed in paragraph 3.2(c) and its presence adds confusion and ambiguity to depth sizing as required by paragraph 3.2(c). This also makes the weld overlay program consistent with the supplement 2 depth sizing criteria Page 7 of 7

Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques Table 3 Modification To Code Case N-638-1 Code Case N-638-1 Modification/Basis (Referenced below in 4.0(b) para. 1.0(d) Prior to welding the Modification: In lieu of the required ultrasonic examination of area to be welded and a band around the area of at least 11/2 4.0(b) only the required liquid penetrant examination will be times the component thickness or 5in., whichever is less shall performed. The ultrasonic examination will be in accordance be at least 500 F.) with N-504-2 and Appendix Q.

Basis: For the application of the weld overlay repair addressed 4.0(b) The final weld surface and a band around the area in this request it is not possible to perform a meaningful defined in para. 1.0 (d) shall be examined using a surface and ultrasonic examination of the required band of base material ultrasonic methods when the completed weld has been at because of the existing nozzle configurations shown in the ambient temperature for at least 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. The ultrasonic design drawings contained in attachmens 3 and 4. This Code examination shall be in accordance with Appendix 1.3 Case applies to any type of welding where a temper bead technique is to be employed and is not specifically written for a weld overlay repair. However, it is believed that for this type of 3Refer to the 1989 Edition with the 1989 Addenda and later repair that any major base material cracking would take place in Editions and Addenda the HAZ directly below the weld overlay or in the underlying Inconel 82/182 weld deposit and not in the required band of material out beyond the overlay. Therefore, it is assumed that if this cracking were to occur it would be identified by the ultrasonic examination of the weld overlay and not performing the required base material ultrasonic examination should be considered acceptable.

4.0(c) requires temperature monitoring by welded Modification: Preheat and interpass temperatures for the weld thermocouples per IWA-4610(a) pad will be measured using a contact pyrometer. Interpass temperature will be monitored for the first three layers at each repair location. On the first repair location, the interpass temperature measurements will be taken every three to five passes. After the first three layers, interpass temperature measurements will be taken every six to ten passes for the subsequent layers. The heat input from layers beyond the third layer will not have a metallurgical affect on the low alloy steel HAZ Basis: Due to the location of the repair and area radiation dose rate, the placement of welded thermocouples for monitoring weld interpass temperature is determined to be not beneficial Page 1 of 2

Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques Table 3 Modification To Code Case N-638-1 based on dose savings. Therefore, welueu ihennocUupfles areI not planned for use to monitor interpass temperature during welding.

Page 2 of 2

Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques ATTACHMENT 2 CHEMICAL ANALYSES OF INCREMENTAL MILLING OF WELDMENT SONGS Unit 2

Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques The data shown below are typical of several mockups that WSI has performed that are representative of the weld overlays to be installed. These data are from an overlay on carbon steel base material and testing has confirmed that the chromium content of overlays on stainless steel base materials is similar. The data supports the current overlay design, which specifies a single sacrificial layer that is not credited in the structural analysis of the overlay.

Chromium Content (wt. %)

For Orbital Welding Utilizing Alloy 52M Alloy 52M 2n" Layer Is Layer 1It Layer 0.035" wire by X-ray by X-ray by Electron Diffraction from CMTR Fluoroscope Fluoroscope Spectroscopy Element! SFA 5.14 Near Quadrant ER NiCrFe- Near Surface Near Surface Surface layer Base 7A SraelyrMetal Chromium ID - 28.8 26.3 27.3 27.4 27.5 Chromium S0 - 29.5 26.9 29.1 28.0 27.4 Chromium 1130 - 29.1 26.6 28.0 27.5 27.5 Chromium 270' - 29.4 27.0 26.7 26.9 26.4 Avg. % Cr 29.3 29.2 26.7 27.8 27.5 27.2 NOTE: These data are representative of the alloy 52M structural weld overlay repair to be deposited on the SONGS Unit 2 Pressurizer Safety and Spray Nozzles. Subsequent layers will have %Cr equal to or greater than the 2nd layer Page 1 of 1

Relief Request ISI-3-18 Use of Structural Weld Overlay and Associated Alternative Repair Techniques Proprietarv Information Submitted Under 10 CFR 2.390 ATTACHMENT 3 Structural Weld Overlay Design Drawings Application for Withholding Proprietary Information from Public Disclosure Affidavit in Conformance with 10 CFR 2.390 Safety Valve Nozzle Assembly Spare: Drawing Number 41011 Sheet 1 Rev. 0 Safelty Nozzle to 2PSV200 Assembly: Number 41011 Sheet 2 Rev. 0 Safely Nozzle to 2PSV201 Assembly: Drawing Number 41011 Sheet 3 Rev. 0 Spray Nozzle Assembly: Drawing Number 41011 Sheet 4 Rev. 0

Structural Integrity Associates, Inc.

6855 S. Havana Street Suite 350 Centennial, CO 80112-3868 Phone: 303-792-0077 Fax: 303-792-2158 www.structint.com pnccardella~strucUnt.com February 22, 2006 PCR-06-004 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

Proprietary Information The Application for Withholding is submitted by Structural Integrity Associates ("SI") pursuant to the provisions of Paragraph (b)(1) of Section 2.390 of the Commission's regulations. It contains commercial strategic information proprietary to SI and customarily held in confidence.

The drawings which are being requested to be withheld since they are considered to be proprietary in their entirety are further identified in the attached affidavit. In conformance with 10 CFR Section 2.390, the Affidavit accompanies this Application far Withholding, setting forth the basis on which the identified proprietary information may be withheld from public disclosure.

Accordingly, it is respectfully requested that the subject information which is proprietary to SI be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Correspondence with respect to this Applicalion for Withholding or the accompanying affidavit should be addressed to Peter C. Riccardella.

Very tiuly yours, Peter C. Riccardella Sr. Associate and Chief Technology Officer Enclosure Austin, TX Charlotte, NC N.Stonington, CT San Jose, CA Silver Spring, MD Sunrise, FL Uniontown, OH Whittier, CA 512-533-9191 704-597-5554 860-599-6050 408-978-8200 301-445-8200 954-572-2902 330-899-9753 562-944-8210

(1) I am the Chief Technology Officer of STRUCTURAL INTEGRITY ASSOCIATES ("Sr'), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of SI.

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commissiion's regulations and in conjunction with the SI "Application for Withholding"' accompanying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by SI in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

i. The information sought to be withheld from public disclosure is owned and has been held in confidence by SI.

ii. The information is of a type customarily held in confidence by SI and not customarily disclosed to the public. SI has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes SI's policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.)

where prevention of its use by any of SI's competitors without license from SI constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a

competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of SI, its customers or suppliers.

(e) It reveals aspects of past, present, or future SI or customer funded development plans and programs of potential commercial value to SI.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the SI system which include the following:

(a) The use of such information by SI gives SI a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the SI competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the SI ability to sell products and services involving the use of the information.

(c) Use by our competitor would put SI at a competitive disadvantage by reducing his expenditure of resources at our expense.

(d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving SI of a competitive advantage.

(e) The SI capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

iii. The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

iv. The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

v. The proprietary information sought to be withheld in this submittal is that in SCE Drawing 41011. The proprietary information is submitted as part of an SCE relief request for weld overlay activities at San Onofre Nuclear Generating Station, Unit 2.

This information is part of that which will enable the plant to apply weld overlays as mitigation against stress corrosion cracking in susceptible weldments.

Further this information has substantial commercial value as follows:

(a) SI can sell the use of similar information to its customers for purposes of addressing stress corrosion cracking issues.

(b) The information requested to be withheld reveals the distinguishing aspect of a methodology which was developed by SI.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of SI because it would enhance the ability of competitors to provide similar services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRCI requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive SI effort and the expenditure of a considerable sum of money.

In order for competitors of SI to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

I declare under penalty of perury under the laws of the State of Colorado that the foregoing is true and correct. The above facts are within my personal knowledge and if sworn to testify to them, I could. and would competently tei thereto.

Chief Technology Officer

Slate of Colorado )

)ss.

County of Arapahoe )

On SJC/'5 o ' beforeme, c ,ef-7 c.. OLu02-,a Notary Public in and for said State, personally appeared Peter C.

Riccardella , personally known to me (or proved to me on the basis of satisfactory evidence) to be the person(s) whose name is subscribed to the within instrument and acknowledged before me that he/she/they executed the same in his/her/their authorized capacity(ies) and that by his/her/their signature(s) on the instrument the person(s) or the entity(ies) on behalf of which the person(s) acted executed the same.

WITNESS my hand and official seal.

NOTARY PUBLIC

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