ML072220295

Relief Request No. RR-04

ML072220295
Person / Time
Site:	Indian Point
Issue date:	09/26/2007
From:	Mark Kowal NRC/NRR/ADRO/DORL/LPLI-1
To:	Balduzzi M Entergy Nuclear Operations
Boska J, NRR, 301-415-2901
References
RR-04, TAC MD4699
Download: ML072220295 (17)

Text

September 26, 2007 Mr. Michael A. Balduzzi Sr. Vice President & COO Regional Operations, NE Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 - RELIEF REQUEST NO. RR-04 (TAC NO. MD4699)

Dear Mr. Balduzzi:

By letter dated February 28, 2007, as supplemented by letter dated June 4, 2007, Entergy Nuclear Operations Inc., (the licensee) submitted a relief request for the fourth 10-year Inservice Inspection (ISI) Interval and Containment ISI Program Plan for Indian Point Nuclear Generating Unit No. 2. The proposed alternative will use the dissimilar metal weld qualification criteria administered by the Electric Power Research Institute's Performance Demonstration Initiative program in lieu of selected American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, Appendix VIII, Supplement 10 requirements.

Inservice inspection of ASME Code Class 1, 2, and 3 components is performed in accordance with Section XI of the ASME Code and applicable addenda as required by Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(g), except where specific relief has been granted by the Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 50.55a(g)(6)(i).

Also, 10 CFR 50.55a(a)(3) states that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if: (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Based on the enclosed safety evaluation, the NRC staff concludes that, in accordance with 10 CFR 50.55a(a)(3)(i), the proposed alternative program will provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the proposed alternative under relief request No. RR-04, for the duration of the fourth 10-year ISI interval.

M. Balduzzi If you have any questions regarding this approval, please contact the Indian Point Project Manager, John Boska, at (301) 415-2901.

Sincerely,

/RA/

Mark G. Kowal, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-247

Enclosure:

Safety Evaluation cc w/encl: See next page

ML072220295 *See memo dated June 26, 2007 OFFICE LPL1-1/PM LPL1-1/LA CPNB/BC OGC LPL1-1/BC NAME JBoska SLittle JTsao for MKowal TChan* STurk DATE 8/29/07 8/30/07 6/26/07 9/15/07 9/26/07 Indian Point Nuclear Generating Unit No. 2 cc:

Mr. Michael R. Kansler Mr. John A. Ventosa President & CEO / CNO GM, Engineering Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.

1340 Echelon Parkway 440 Hamilton Avenue Jackson, MS 39213 White Plains, NY 10601 Mr. John T. Herron Mr. John F. McCann Sr. Vice President Director, Nuclear Safety & Licensing Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.

1340 Echelon Parkway 440 Hamilton Avenue Jackson, MS 39213 White Plains, NY 10601 Sr. Vice President Ms. Charlene D. Faison Engineering & Technical Services Manager, Licensing Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.

1340 Echelon Parkway 440 Hamilton Avenue Jackson, MS 39213 White Plains, NY 10601 Mr. Fred R. Dacimo Mr. Ernest J. Harkness Site Vice President Director, Oversight Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.

Indian Point Energy Center 1340 Echelon Parkway 450 Broadway, GSB Jackson, MS 39213 P.O. Box 249 Buchanan, NY 10511-0249 Mr. Patric W. Conroy Director, Nuclear Safety Assurance Mr. Anthony Vitale - Acting Entergy Nuclear Operations, Inc.

General Manager, Plant Operations Indian Point Energy Center Entergy Nuclear Operations, Inc. 450 Broadway, GSB Indian Point Energy Center P.O. Box 249 450 Broadway Buchanan, NY 10511-0249 P.O. Box 249 Buchanan, NY 10511-0249 Mr. T.R. Jones - Acting Manager, Licensing Mr. Oscar Limpias Entergy Nuclear Operations, Inc.

Vice President Engineering Indian Point Energy Center Entergy Nuclear Operations, Inc. 450 Broadway, GSB 1340 Echelon Parkway P. O. Box 249 Jackson, MS 39213 Buchanan, NY 10511-0249 Mr. Joseph P. DeRoy Mr. William C. Dennis Vice President, Operations Support Assistant General Counsel Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.

1340 Echelon Parkway 440 Hamilton Avenue Jackson, MS 39213 White Plains, NY 10601

Indian Point Nuclear Generating Unit No. 2 cc:

Mr. Michael Balboni Mr. William DiProfio Deputy Secretary for Public Safety PWR SRC Consultant State Capitol, Room 229 48 Bear Hill Road Albany, NY 12224 Newton, NH 03858 Mr. John P. Spath Mr. Garry Randolph New York State Energy, Research, and PWR SRC Consultant Development Authority 1750 Ben Franklin Drive, 7E 17 Columbia Circle Sarasota, FL 34236 Albany, NY 12203-6399 Mr. William T. Russell Mr. Paul Eddy PWR SRC Consultant New York State Department 400 Plantation Lane of Public Service Stevensville, MD 21666-3232 3 Empire State Plaza Albany, NY 12223-1350 Mr. Jim Riccio Greenpeace Regional Administrator, Region I 702 H Street, NW U.S. Nuclear Regulatory Commission Suite 300 475 Allendale Road Washington, DC 20001 King of Prussia, PA 19406 Mr. Phillip Musegaas Senior Resident Inspectors Office Riverkeeper, Inc.

Indian Point 2 828 South Broadway U. S. Nuclear Regulatory Commission Tarrytown, NY 10591 P.O. Box 59 Buchanan, NY 10511 Mr. Mark Jacobs IPSEC Mr. Charles Donaldson, Esquire 46 Highland Drive Assistant Attorney General Garrison, NY 10524 New York Department of Law 120 Broadway New York, NY 10271 Mr. Raymond L. Albanese Four County Coordinator 200 Bradhurst Avenue Unit 4 Westchester County Hawthorne, NY 10532 Mayor, Village of Buchanan 236 Tate Avenue Buchanan, NY 10511

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR RELIEF NO. RR-04 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NO. 50-247

1.0 INTRODUCTION

By letter dated February 28, 2007, Agencywide Documents Access and Management System (ADAMS) Accession No. ML070640101, as supplemented by letter dated June 4, 2007, ADAMS Accession No. ML071620216, Entergy Nuclear Operations, Inc. (the licensee),

submitted the Indian Point Nuclear Generating Unit No. 2 (IP2) Fourth 10-year Interval Inservice Inspection (ISI) and Containment Inservice Inspection Program (CISI) plan. The application proposed relief request RR-04, alternatives to selected American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI requirements that relate to the ultrasonic examination of dissimilar metal welds at IP2. The request would authorize the use of the proposed alternative as administered by the Electric Power Research Institute's (EPRI's) Performance Demonstration Initiative (PDI) program in lieu of selected dissimilar metal weld qualification requirements of the ASME Code,Section XI, Appendix VIII, Supplement 10, for the fourth 10-year ISI interval, which began on March 1, 2007. IP2's current operating license will expire on September 28, 2013, approximately 3 years before the end of the fourth 10-year ISI interval, although a license renewal application is under review by the Nuclear Regulatory Commission (NRC).

2.0 REGULATORY REQUIREMENTS Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure test conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) twelve months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The ASME Code of record for IP2's fourth ISI interval is the 2001 Edition with the 2003 Addenda of Section XI of the ASME Code.

Enclosure

In accordance with 10 CFR 50.55a(g)(6)(ii)(c), the implementation of Supplements 1 through 8, 10 and 11 of Appendix VIII to Section XI, 1995 Edition with the 1996 Addenda of the ASME Code is required on a phased schedule ending on November 22, 2002. Supplement 10 was required to be implemented by November 22, 2002. Additionally, 10 CFR 50.55a(g)(6)(ii)(C)(2) requires licensees implementing the 1989 Edition and earlier editions of Section XI of the ASME Code to implement the 1995 Edition with the 1996 Addenda of Appendix VIII and supplements to Appendix VIII of Section XI of the ASME Code.

Alternatives to requirements may be authorized or relief granted by the NRC pursuant to 10 CFR 50.55a(a)(3)(i), 10 CFR 50.55a(a)(3)(ii), or 10 CFR 50.55a(g)(6)(i). In proposing alternatives or requesting relief, the licensee must demonstrate that: (1) the proposed alternatives provide an acceptable level of safety; (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety; or (3) conformance is impractical for the facility. Pursuant to 10 CFR 50.55a(g)(4)(iv), ISI items may meet the requirements set forth in subsequent editions and addenda of the ASME Code that are incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed therein, and subject to Commission approval. Portions of editions and addenda may be used provided that requirements of the respective editions and addenda are met.

Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee submitted the request as a proposed alternative to selected ASME Code,Section XI, Appendix VIII, Supplement 10 requirements for the fourth 10-year ISI interval at IP2 which began on March 1, 2007, and ends April 3, 2016.

3.0 EVALUATION 3.1 Applicable Code Requirements The licensees applicable ISI code of record is the 2001 Edition, with the 2003 Addenda, of the ASME Code,Section XI, Appendix VIII, Supplement 10, of which the implementation is required in accordance with 10 CFR 50.55a(g)(6)(ii)(c).

The licensee proposed alternatives to the following Supplement 10 requirements: 1.1(b), 1.1(d),

1.1(d)(1), 1.2(b), 1.2(c)(1), 1.3(c), 1.4(b), 2.0, 2.2(b), 2.2(c), 2.3(a), 2.3(b), and Table VIII-S2-1.

3.1.1 Applicable Systems/Components The requested relief from the Supplement 10 requirements is applicable to pressure-retaining dissimilar metal welds in vessel nozzles subject to ultrasonic examination using procedures, personnel, and equipment qualified to the ASME Code,Section XI, Appendix VIII, Supplement 10 criteria.

3.2 Licensees Proposed Alternative and Bases Pursuant to the alternative provisions in 10 CFR 50.55a(a)(3)(i), the licensee proposed the following for the duration of the fourth 10-year ISI interval at IP2. The proposed alternative will be implemented through the PDI program.

Paragraph 1.1(b) proposed alternative:

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

(610 mm) shall be considered to be flat. When a range of thicknesses is to be examined, a thickness tolerance of +/-25% is acceptable."

Technical Basis - The change in the minimum pipe diameter tolerance from 0.9 times the diameter to the nominal diameter minus 0.5-inch provides tolerances more in line with industry practice. Though the alternative is less stringent for small pipe diameters, they typically have a thinner wall thickness than larger diameter piping. A thinner wall thickness results in shorter sound path distances that reduce the detrimental effects of the curvature. This change maintains consistency between Supplement 10 and the recent revision to Supplement 2.

Paragraph 1.1(d) proposed alternative:

"At least 60% of the flaws shall be cracks, the remainder shall be alternative flaws. Specimens with intergranular stress corrosion cracking (IGSCC) shall be used when available. Alternative flaws, if used, shall provide crack-like reflective characteristics and shall be limited to the case where implantation of cracks produce spurious reflectors that are uncharacteristic of actual flaws. Alternative flaw mechanisms shall have a tip width of less than or equal to 0.002 in.

(.05 mm). Note, to avoid confusion, the proposed alternative modifies instances of the term cracks or cracking to the term flaws because of the use of alternative flaw mechanisms.

Technical Basis - As illustrated by the licensees submittal, implanting a crack requires excavation of the base material on at least one side of the flaw. While this may be satisfactory for ferritic materials, it does not produce a useable axial flaw in austenitic materials because the sound beam, which normally passes only through base material, must now travel through weld material on at least one side, producing an unrealistic flaw response. In addition, it is important to preserve the dendritic structure present in field welds that would otherwise be destroyed by the implantation process. To resolve these issues, the proposed alternative allows the use of up to 40% fabricated flaws as an alternative flaw mechanism under controlled conditions. The fabricated flaws are isostatically compressed which produces ultrasonic reflective characteristics similar to tight cracks.

Paragraph 1.1(d)(1) proposed alternative:

"At least 80% of the flaws shall be contained wholly in weld or buttering material. At least one, and a maximum of 10% of the flaws shall be in ferritic base material. At least one, and a maximum of 10% of the flaws shall be in austenitic base material."

Technical Basis - Under the current ASME Code, as few as 25% of the flaws are contained in austenitic weld or buttering material. Recent experience has indicated that flaws contained within the weld are the likely scenario. The metallurgical structure of austenitic weld material is ultrasonically more challenging than either ferritic or austenitic base material. The proposed alternative is, therefore, more challenging than the current ASME Code.

Paragraph 1.2(b) proposed alternative:

"Detection sets shall be selected from Table VIII-S10-1. The number of unflawed grading units shall be at least one and a half times the number of flawed grading units."

Technical Basis - New Table VIII-S10-1 provides a statistically based ratio between the number of unflawed grading units and the number of flawed grading units. The proposed alternative reduces the ratio to 1.5 times. This reduces the number of test samples to a more reasonable number from the human factors perspective. However, the statistical basis used for screening personnel and procedures is still maintained at the same level with competent personnel being successful and less skilled personnel being unsuccessful. The acceptance criteria for the statistical basis are in Table Vlll-S10-1.

Paragraph 1.2(c)(1) and 1.3(c) proposed alternative:

The proposed alternative to the flaw distribution requirements of Paragraph 1.2(c)(1) (detection) and 1.3(c) (length) is to use the Paragraph 1.4(b) (depth) distribution table (see below) for all qualifications.

Flaw Depth Minimum Number

(% Wall Thickness) of Flaws 10-30% 20%

31-60% 20%

61-100% 20%

Technical Basis - The proposed alternative uses the depth sizing distribution for both detection and depth sizing because it provides for a better distribution of flaw sizes within the test set.

This distribution allows candidates to perform detection, length, and depth-sizing demonstrations simultaneously utilizing the same test set. The requirement that at least 75% of the flaws shall be in the range of 10% to 60% of wall thickness provides an overall distribution tolerance. The distribution uncertainty decreases the possibilities for testmanship that would be inherent to a uniform distribution. It must be noted that it is possible to achieve the same distribution utilizing the present requirements, but it is preferable to make the criteria consistent.

Paragraph 2.0 first sentence proposed alternative:

"For qualifications from the outside surface, the specimen inside surface and identification shall be concealed from the candidate. When qualifications are performed from the inside surface, the flaw location and specimen identification shall be obscured to maintain a "blind test".

The current Code requires that the inside surface be concealed from the candidate. This makes qualifications conducted from the inside of the pipe (e.g., pressurized-water reactor nozzle to safe end welds) impractical. The proposed alternative differentiates between inner diameter (ID) and outer diameter (OD) scanning surfaces, requires that they be conducted separately, and requires that flaws be concealed from the candidate.

Paragraph 2.2(b) and 2.2(c) proposed alternative:

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

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

Paragraph 2.3(a) and 2.3(b) proposed alternative:

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

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

Table VIII-S2-1 acceptance criteria proposed alternative:

Table VIII-S2 10-1 PERFORMANCE DEMONSTRATION DETECTION TEST ACCEPTANCE CRITERIA Detection Test False Call Test Acceptance Criteria Acceptance Criteria No. of Minimum No. of Maximum Flawed Detection Unflawed Number Grading Units Criteria Grading of False Calls 5 5 10 0 6 6 12 1 7 6 14 1 8 7 16 2 9 7 18 2 10 8 20 15 3 2 11 9 22 17 3 3 12 9 24 18 3 3 13 10 26 20 4 3 14 10 28 21 5 3 15 11 30 23 5 3 16 12 32 24 6 4 17 12 34 26 6 4 18 13 36 27 7 4 19 13 38 29 7 4 20 14 40 30 8 5 Technical Basis - The proposed alternative is identified as new Table VIII-S10-1. It was modified to reflect the reduced number of unflawed grading units and allowable false calls. As a part of ongoing ASME Code activities, Pacific Northwest National Laboratory (PNNL) has reviewed the statistical significance of these revisions and offered the revised Table VIII-S10-1.

3.3 Staff Evaluation The licensee proposed the use of the examination program developed by PDI. The NRC staffs evaluation of the PDI program is discussed below.

Paragraph 1.1(b):

The ASME Code requirement that 0.9 to 1.5 times the nominal diameter are equivalent was established for a single nominal diameter. When applying the ASME Code-required tolerance to a range of diameters, the tolerance rapidly expands on the high side. Based on the current requirements, a 5-inch outer diameter pipe would be equivalent to a range of 4.5-inch to 7.5-inch diameter pipe. Under the proposed PDI guidelines, the equivalent range would be reduced to 4.5-inch to 5.5-inch diameter pipe. Additionally, with the current ASME Code requirements, a 16-inch nominal diameter pipe would be equivalent to a range of 14.4-inch to 24-inch diameter pipe. The proposed PDI guidelines would significantly reduce the equivalent range to between 15.5-inch and 16.5-inch diameter pipe. The difference between the ASME Code and the proposed PDI program for diameters less than 5 inches is not significant because of a shorter metal path and beam spread associated with smaller diameter piping.

The NRC staff reviewed the licensees technical basis for the proposed alternative and agrees with the licensees assessment that the alternative provides tolerances more in-line with industry practice. Based on the discussion as presented above, the staff finds the proposed alternative will provide more conservative tolerance results for a range of piping diameters in comparison to the current ASME Code requirements. The staff also finds that the differences in tolerance results for smaller diameter piping are not significant. Therefore, the NRC staff finds the proposed alternative acceptable.

Paragraph 1.1(d):

The ASME Code requires all flaws to be cracks. Manufacturing test specimens containing cracks free of spurious reflections and telltale indicators is extremely difficult in austenitic material. To overcome these difficulties, the EPRI developed a process for fabricating flaws that produce ultrasonic acoustic responses similar to the responses associated with actual cracks. EPRI presented its process at public meetings held June 12 through 14, 2001, and January 31 through February 2, 2002, at EPRIs Non-Destructive Examination Center located in Charlotte, North Carolina.

The NRC staff attended the meetings and determined that the process parameters used for manufacturing fabricated flaws demonstrated the ability to produce acoustic responses similar to those associated with actual cracks. In addition, the staff reviewed the licensees technical basis and agrees with the licensees assessment. Therefore, the NRC staff concludes that the proposed alternative adequately demonstrates that ASME Code requirements are met.

Paragraph 1.1(d)(1):

The ASME Code requires that at least 50% of the flaws be contained in austenitic material and at least 50% of the flaws in the austenitic material shall be contained fully in weld or buttering material. This means that at least 25% of the total flaws must be located in the weld or buttering material. Industry experience shows that flaws identified during ISI of dissimilar metal welds are more likely to be located in the weld or buttering material. The grain structure of austenitic weld and buttering material represents a much more stringent ultrasonic scenario than that of a ferritic or austenitic base material. Flaws in austenitic base material that are free of spurious reflectors and telltale indicators are difficult to create.

The NRC staff finds the proposed alternative that at least 80% of the flaws be contained in the weld metal or buttering material provides a testing scenario reflective of industry experience and minimizes difficulties associated with telltale reflectors common to placing flaws in austenitic base material. Therefore, the NRC staff finds the proposed alternative provides a more rigorous inspection than that required by the ASME Code and, therefore, is acceptable.

Paragraph 1.2(b):

The ASME Code requires that detection sets meet the requirements of Table VIII-S2-1, which specify the minimum number of flaws in a test set to be five with 100% detection. The ASME Code also requires the number of unflawed grading units to be two times the number of flawed grading units. The proposed alternative would follow the detection criteria of the table beginning with a minimum number of flaws in a test set being 10, reducing the number of false calls to one and a half times the number of flawed grading units.

The NRC staff reviewed the licensees technical basis and finds that the proposed alternative satisfies the pass/fail objective established in ASME Code,Section XI, Appendix VIII for performance demonstration acceptance criteria.

Paragraph 1.2(c)(1), Paragraph 1.3(c):

The ASME Code requires, for detection and length sizing, that at least 1/3 of the flaws be located between 10-30% through the wall thickness and 1/3 located greater than 30% through the wall thickness. The remaining 40% would be located randomly throughout the pipe wall thickness. The proposed alternative sets the distribution criteria for detection and length sizing to be the same as the depth sizing distribution, which stipulates that at least 20% of the flaws be located in each of the increments of 10-30%, 31-60%, and 61-100%. The remaining 40%

would be located randomly throughout the wall thickness. With the exception of the 10-30%

increment, the proposed alternative is a subset of the ASME Code requirements. The 10-30%

increment would be in the subset if it contained at least 30% of the flaws.

The NRC staff reviewed the licensees technical basis for the proposed alternative. The staff finds the change simplifies the assembly of test sets for detection and sizing qualifications and, based on industry experience, is more indicative of actual conditions in the field. In addition, the staff finds the proposed alternative does not significantly deviate from, or reduce the level of, detection and length sizing from that required in the ASME Code. Therefore, the NRC staff finds the alternative is acceptable.

Paragraph 2.0:

The current ASME Code requires that the inside surface be concealed from the candidate. This makes qualifications conducted from the inside of the pipe impractical. The proposed alternative differentiates between ID and OD scanning surfaces, requires that they be conducted separately, and requires that flaws be concealed from the candidate. The NRC staff concludes that the intent behind the concealment of the ID is to assure that tests conducted from the outside are blind examinations that do not provide location information to the examiner. The NRC staff concludes that the licensees alternative to conceal the OD surface from the candidate for examinations performed from the ID meets the same intent to perform a blind examination and is, therefore, acceptable.

Paragraph 2.2(b) and 2.2(c):

The ASME Code requires that the region of flaws added to the test set for length sizing be identified to the candidate. The proposed alternative would make identifying the location of additional flaws an option.

The NRC staff finds that the proposed alternative will provide an additional element of difficulty to the testing process, since the candidate would be expected to demonstrate the skill of detecting and sizing flaws over a larger area in comparison to a specific region. The NRC staff finds the alternative, if utilized, would require the demonstration of a higher level of skill than that currently required by the ASME Code and is, therefore, acceptable.

Paragraph 2.3(a):

The ASME Code requires that 80% of the flaws be sized in a specific location that is identified to the candidate. The proposed alternative permits detection and depth sizing to be conducted separately or concurrently. In order to maintain a blind test, the location of flaws cannot be shared with the candidate. For depth sizing that is conducted separately, allowing the test administrator the option of not identifying flaw locations makes the testing process more difficult.

The NRC staff finds that the proposed alternative will provide an additional element of difficulty to the testing process, since the candidate would be expected to demonstrate the skill of detecting and sizing flaws in an unknown location. The NRC staff finds the alternative, if utilized, would require the demonstration of a higher level of skill than that currently required by the ASME Code and is, therefore, acceptable.

Paragraph 2.3(b):

The ASME Code requires that the region of flaws added to the test set for depth sizing shall be identified to the candidate. The proposed alternative would make identifying the region of flaws an option.

The NRC staff finds that the proposed alternative will provide an additional element of difficulty to the testing process since the candidate would be expected to demonstrate the skill of finding and sizing flaws in an area larger than a specific location. The NRC staff finds the alternative, if utilized, would require the demonstration of a higher level of skill than that currently required by the ASME Code and is, therefore, acceptable.

Table VIII-S2-1 acceptance criteria:

The ASME Code requirements, discussed in Paragraph 1.2(b) above, are based on statistical parameters for screening personnel. The proposed alternative increases the minimum number of flawed grading units and reduces the number of unflawed grading units while maintaining the same statistical parameters as the ASME Code. The NRC staff finds that the proposed alternative provides the same pass/fail screening criteria used to develop the test size tables in Appendix VIII are also used to create the PDI alternative Supplement 10, Table VIII-S10-1.

Therefore, the NRC staff determined that the alternative does not significantly impact the false call criteria established in the table and, therefore, is acceptable.

4.0 CONCLUSION

S The NRC staff has reviewed the licensees submittal and determined that, in accordance with 10 CFR 50.55a(a)(3)(i), the proposed alternative program will provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the proposed alternative under relief request No. RR-04 for the duration of the fourth 10-year ISI interval, which began on March 1, 2007.

All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in this request remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.

Principal Contributor: Isaac A. Anchondo Date: September 26, 2007