ML18093B433
| ML18093B433 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 02/01/1989 |
| From: | Miltenberger S Public Service Enterprise Group |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NLR-N89013, NUDOCS 8902090482 | |
| Download: ML18093B433 (36) | |
Text
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.I Public Service Electric and Gas Company Steven E. Miltenberger Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4199 Vice President and Chief Nuclear Officer FEB 0 l ag NLR-N89013 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION INSERVICE INSPECTION PROGRAM SALEM GENERATING STATION UNIT NO. 1 DOCKET NO. 50-272 Public Service Electric and Gas Company (PSE&G) is in receipt of the subject request for additional information (RAI) regarding the Salem Unit 1 Inservice Inspection Program for the Second 10-year Interval dated November 9, 1988.
The responses to those items presented in Section 2 of the RAI are presented in the Attachment to this letter.
Should you have any further questions with regard to this submittal, please do not hesitate to contact us.
Sincerely,
~E~
Attachment
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- - *9902090482. *990201 PDR ADOCK 05000272 Q
PNU
Document Control Desk c
Mr. J. c. Stone Licensing Project Manager Ms. K. Halvey Gibson Senior Resident Inspector 2
Mr. w. T. Russell, Administrator Region I Ms. J. Moon, Interim Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 FEB O 1 1989
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ATTACHMENT
,J., l, ___ I RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION INSERVICE INSPECTION PROGRAM SALEM GENERATING STATION, UNIT NO. 1 The NRC Staff has requested additional information and/or clarification regarding certain scheduled inservice examinations and requests for relief presented in the Inservice Inspection Program Plan for the Salem Unit 1 Second 10-Year ISI Interval.
The questions posed by the Staff and the accompanying PSE&G responses are presented below.
RAI ITEM 2.A The Staff notes that the Containment Spray System has been completely exempted from Inservice Examinations during t~e Second 10-Year Interval and only 5.3% of the Class 2 piping welds in the Residual Heat Removal (RHR) System are scheduled for examination.
Paragraph 10CFR50.55a(b) (2) (iv) requires that ASME Code Class 2 piping welds in the RHR, Emergency Core Cooling, and Containment Heat Removal systems shall be examined.
These systems should not be completely exempted from inservice examination based on Section XI exclusion criteria contained in IWC-1220.
The staff has previously determined that a 7.5 % augmented volumetric sample constitutes an acceptable resolution at similar plants.
A volumetric examination should be performed on at least a 7.5%
sample of the Class 2 piping welds in the Containment Spray, Chemical and Volume Control, Safety Injection and RHR Systems.
PSE&G RESPONSE TO RAI ITEM 2.A A review of the Salem Unit 1 Boundary Tables (Appendix D to the Long-Term Examination Plan for the Second 10-Year ISI Interval) indicates that approximately 50 percent of the lines in the Containment Spray System are shown as exempt under Code Case N-408, Paragraphs (a) (1) or (a) (6).
The remaining 50 percent, although not exempt, all contain welds in line~ whose wall thickness is less than 3/8 inch.
Therefore, in accordance with the footnotes to Table 1, Category C-F-1 of Code Case N-408, no welds were selected for examination.
The 184 nonexempt welds were however, included in the overall count for Class 2 piping welds.
In order to satisfy the Staff's concerns, 14 welds in the Containment Spray System have been selected and included in the
I
'I PSE&G RESPONSE TO RAI ITEM 2.A (continued)
Long-Term Plan for volumetric and surface examinations.
This meets the 7.5% requirement of the Code Case.
PSE&G concurs with the Staff assessment that only 5.3% of the Class 2 piping welds in the RHR System are scheduled for examin~tion.
As such, five additional welds have been selected for examination bringing the total number of welds to be examined in the system to 15, which is approximately 8%.
RAI ITEM 2.B Request for Relief No.1:
Relief is requested from performing the inservice examination.for the inaccessible portions of the Examination Category B-F, B-H, B-J, C-A, C-B, C-C, C-F-1, AND C-G welds listed in Attachment 5-13 of the ISI Program Plan.
This relief request has not been supported by adequate descriptive and detailed technical information.
Therefore, the Staff requests the following information:
(1)
For each of the welds listed, provide a detailed description of the obstructions or limitations which will be encountered during the course of the examination{s) {e.g., drawings or sketches may be helpful when describing weld/component configurations, interferences, etc.);
(2)
Provide an estimate of the percentage.of the Code-required examination{s) that can be performed for each of the welds listed; (3)
State the extent to which the examination sample has been increased to make up for the portions of the welds not examined; and (4)
With regard to the following nozzle-to-safe end welds listed as Examination Category B-F, Item B5.130, should these welds be listed as Item B5.40 as they are pressurizei nqzzle-to
-safe end welds?
6-PR-1105-1 6-PR-1104-1 6-PR-1103-1 4-PR-1100~1
RAI ITEM 2.B (continued)
The Staff considers inservice examinations of the pressure
-retaining dissimilar metals welds such as the subject safe-end welds crucial to plant safety.
Therefore, the licensee should provide adequate descriptive and detailed technical information to support the relief request.
PSE&G RESPONSE TO RAI ITEMS 2.B(l), 2.B(2) AND 2.B(3)
Upon receipt of this RAI, PSE&G contacted Mr. Jim Stone, The NRR Project Manager for the Salem Units to discuss the potential for employment of ASME Section XI Code Case N-460, "Alternative Examination Coverage for Class 1 and Class 2 Welds" so as to reduce the large amount of information which would have to be generated in order to respond to RAI Items 2.B(l) and 2.B(2).
Employment of this ASME Code Case would allow a reduction in examination coverage ~n any Class 1 or Class 2 weld provided the reduction in coverage for that weld is less than 10%.
Mr. Stone indicated that future Staff approval of this Code Case on a generic ~asis is anticipated but that formal NRC ~pproval was not available at this time.
For this reason, PSE&G has recently submitted (on January 26, 1989) a request to permit the use of ASME Section XI Code Case N-460.
PSE&G has employed Code Case N-460 in its response to RAI Items 2.B(l) and 2.B(2) in anticipation of a concurrent Staff approval for both the use of the Code Case and the RAI response.
Should the Staff respond alternatively, PSE&G will. address any additional information required for the response to the RAI at that time.
Examination coverages for all areas have been calculated, and the examination areas where 90% or more of the required coverage can be obtained (per Code Case N-460) have not been addressed in this response.
The following additional explanations are provided:
EXAMINATION CATEGORY B-F REMARKS All B-F welds have been selected for examination, therefore a sample increase cannot be realized.
Coverage will be maximized on the pressurizer dissimilar metal welds, but only 30-50 percent of the examination area can be volumetrically examined, and that volume only on the weld for reflectors perpendicular to the weld.
PSE&G RESPONSE TO RAI ITEMS 2.B(l), 2.B(2) AND 2.B(3) (continued)
B-J C-A C-B c-c The initial weld allocation included the welds required by Note(l) of Table IWB-2500 1 for B-J welds.
The second emphasis was placed on adherence to Note(2) and welds selected which had been examined during the first ISI interval.
Since all Class 1 welds have been examined during preservice, alternate Class 1 B-J welds have been selected which will not incur limitations and the originally selected limited examination areas deleted from the "Component and Piping Limitations" Table.
In one instance where substitution is not a viable option, an additional weld on the line will be examined to increase overall coverage of the system.
This has been noted on the "Component and Piping Limitations Table (see Table 1 attached to this response).
The limitations in this category occur in the regenerative heat exchanger and the RHR heat exchanger and are caused by permanent attachments and component geometry.
As in the B-F Category, there is no latitude for expansion beacuse all applicable examination areas have been selected in these "one-of
-a-kind" vessels.
Examination areas will be evaluated to determine where augmented surf ace examination can be applied to improve coverage and surf ace examinations performed on accessible portions of the welds.
Although only limited volumetric examinatibn is possible, full surface coverage can be obtained.
Previous ISI data and available drawings do not allow computation of the weld volume coverage obtainable.
Measurements will be taken during this ISI interval to allow the percentage of weld volume coverage to be accurately calculated.
Substitute examination areas are not available.
Magnetic particle (MT) examinations are the recommended examination arid have been accomplished during the first ISI interval on these ferritic lugs and supports.
Since MT examinations inherently
PSE&G RESPONSE TO RAI ITEMS 2.B{l), 2.B{2) AND 2.B{3) {continued)
C-F-1 C-G require more space to perform, each area will be carefully analyzed to determine if augmented liquid
- penetrant examinations can be performed to minimize the limitations and maximize coverage.
The limited-coverage examination areas in this category are terminal ends of systems and therefore, substitutions cannot be made since all terminal ends must be selected.
The best possible examination coverage will be obtained to ensure the integrity of the system.
Additional welds on the affected lines have been selected for examination to improve overall coverage of the systems and are noted in the "Component and Piping Limitations" Table (see Table 1 attached).
The C-G examination listed was improperly categorized and has been redesignated as C-F-1.
. PSE&G RESPONSE TO RAI ITEM 2.B(4)
- -.:s;rii_c;;~ the Summer 197 8 Addenda to Seqtion XI were issued, several options existed for assigning dissimilar metal welds to an examination category.
In previous Code editions, the examination requirements for dissimilar metal welds were different than for normal piping welds, i.e., they required both volumetric and surface examination, whereas norm.al piping welds required either volumetric or surface examination.
More recent Code editiops have imposed identical examination requirements on both dissimilar metal and similar metal piping welds.
Consequently, ASME Section XI, through Code Interpretation XI-1-83-15, has allowed utilities to consider these welds in either category, as long as they received the same examinations.
As reflected in the Salem Unit 1 Second 10-Year ISI Long-Term Plan, these four welds are shown as piping welds {B-F BS.130) rather then B-F BS.40.
Both item numbers contain the same examination requirements.
'~
Table 1 Page 1of8 COMPONENT AND PIPING LIMITATIONS Class Summary Category Identification of Alternate No.
Item No.
Limitation Basis for Relief Examinations Remarks 022200 1
6-PR-UOS-1 Complete volumetric ex:ami-Due to the nozzle and safe None.
As performed during the first B-F N~o-Safo End nation of the Code volume is end configuration, scanning inspection interval, complete -
BS.130 not obtainable. 100% of the from the base material is not surface c:xamination coverage and Surface and Volumetric weld length can be scanned possible.
a ~egree and 4S-degree ultra-from the weld surface.
sonic examination from the weld surface is obtainable.
023400 1
6-PR-1104-1 Complete volumetric exami-Due to the nozzle and safe None.
As performed during the first B-F Nozzlc--to-Safe End nation of the Code volume is end configuration, scanning inspection
- inte1Val, complete BS.130 not obtainable. 100% of the from the base material is not surface examination coverage and Surface and Volumetric weld length can be scanned possable.
a 0-degree and 4S-degree ultra-from the weld surface.
sonic examination from the weld surface is obtainable.
024600 1
6-PR-1103-1 Complete volumetric exami-Due* to the nozzle and safe None.
As performed during the first B-F Nozzle-to-Safe End nation of lhe Code volume is end configuration, scanning inspection interval, complete BS.130 not obtainable. 100% of the from lhe base maaerial is not surface examination coverc1ge and Surface and Volumetric weld length can be scanned pouible.
a 0-degree and 4S-degree ultra-from lhe weld wrface.
sonic cxamination from the weld surface is obtainable.
025900 1
4-PR-1100-1 Complete volumetric exami-Due to lhe nozzle and safe None.
As performed during the first e B-F Nozzle-10-Safe End na1ion of the Code volume is end configuration, scanning inspection
- inlerval, complele BS.130 noa obtainable. 100% of 1he from the base material is not surface examination coverage and Surface and Volumetric weld length can be scanned powble.
a 0-degree and 4S-degree ultra-from the weld surface.
sonic examination from the weld surface is obtainable.
033500 1
4-PS-1131-29 Complete volumetric exami-Due to the nozzle and safe None.
As performed during the first B-F Safe End-to-Nozzle nation oflhe Code volume is end configuration, scanning inspection interval, complete BS.40 not obtainable. 100% of the from the base material is not surface ecarnination coverage and Sur.face and Volumetric weld length can be scanned pouible.
a 0-degree and 4S-degree ultra-from the weld surface.
sonic examination from the weld surface is obtainable.
Class Summary Category No.
Item No.
117000 No Sub5litute Terminal End (Add Weld)
- 17 116900 20SQIJ5 205135 205140 1
B-J 89.11 2
C-A Cl.JO 2
C-A Cl.JO 2
C-A Cl.30 2
C-A Cl.JO 6-SJ..1141-18 Blbow-to-Branc:h Coonecdoa Surfaco and Volumetric 1-RHE-2 Shell-to-Tube Sheet Volumetric 1-RHE-3 Tube Sheet-to-Shell Volumetric 1-RHE-11 Shell-to-Tube Sheet Volumetric 1-RHE-12 Tube Sheet-to-Shell Volumetric Table 1 COMPONENT AND PIPING LIMITATIONS Identification of Limitation Complete volumetric exami-nation of the Code volume ii not obtainable. 1004ll of the weld length can be scanned from the weld aurface.
Complete volumetric exami-nation of the Code volume ii not obtainable.
Complete coverage is obtained for apprmimately 20% of the cumination area.
Complete volumetric exami-nation of the Code volume is not obtainable. 100% of the weld length can be IC8Rllcd from tho base material.
Basis for Relief Due to the elbow and branch connection configuratfon, 1Canning from the base mate-rial is not posstble.
Due to the inaccesstbility of 24" of the weld, scanning of the complete weld is not pos.-
11ble.
Due to a aupport bracket extending 1/4* to each aide of the weld, IC8nning on the weld with @.degree and 45-degrcc is not possible..
Volumetric coverage ii not Duo to pennanent restraint obtainable.
and insulation interference, examination of the Code examination \\folume. is not possible.
Volumetric coverage is not Due to permanent restraint obtainable.
interference, examination of the Code caunination volume is not possable.
Alternate Examinations None.
None.
None.
None.
None.
Page 2 of 8 Remarks As performed during the first inspection interval, complete surface examination coverage and a 0-degrec and 45-degree ultra-sonic examination from the weld surface is obtainable. Additional weld on this line will be exam-ined.
As performed during the first inspection interval, a limited examination of the Code area is obtainable.
As performed during the first inspection interval, a complete 45-degree and 60-degree ultra-sonic examination from the base material is obtainable.
None.
None.
Table 1 Page 3 of 8 COMPONENT AND PIPING LIMITATIONS Class Summary Category Examination Area/
Identification of Alternate No.
Item No.
Eumilultion Requirement Limitation Basis for Relief Examinations Remarks 205163 2
11-RHRHBX-IN Complete volumetric exami-Due to permanent support None.
As performed during the first C-8 Nozzlo-al>Sbcll nation of the Code volume is lugs from 11 1/2"-22" and inspection interval, complete e C2.21 not obtainable. Ul0% of the 44" -54" and due to closeness surface examination coverage and Surface and Volumetric weld length can be scanned of welds 1 and 2 in the areas a 0-degree and 45-degree ultra-from the weld surface.
S'r-7' and 36"-4Cr' L, scanning sonic examination from the weld is limited. Bxamination from surface is obtainable.
nozzle side is not obtainable due to configuration.
205168 2
11-RHRHBX-OUf Complete volumetric cxami-Due to permanent support None.
As performed during the first C-B Shell-to-Nozzle nation of the Code volume is lugs from 11 1/2"-22" and inspection interval, complete C2.21 not obtainable. 100% of the 44"-54" and due to closeness surface examination coverage and Surface and Volumetric weld length can be scanned of welds 1 and 2 in the areas a ~egree and 45-degree ullra-from the weld surface.
S'J'-7' and 36"-4Cr' L, scanning sonic examination from the weld is limited. Examination from surface is obtainable.
nozzle side is not obtainable due to configuration.
205210 2
12-RHRHBX-2 Complete volumetric cxami-Due to nozzle configuration, None.
As performed during the first C-A Shell-to-Flange nation of the Code volume is scanning is limited to a "W" inspection interval, complete Cl.10 not obtainable. 100% of the of 1-3" from 4"-7' and Sl"-54" surface examination C011erage and Volumetric weld length can be scanned Land a "W" of 1/2"-3" from a 0-degree and 45-dt.-gree ultra-e from the weld surface.
62"-65 1/2" L. Scanning is sonic examinalion from the weld not possible on flange side surface is obtainable.
due to configuration.
Ir Table 1 Page 4 of 8 COMPONENT AND PIPING LIMITATIONS Class Summal)'
Categol)'
Examiulion Area/
Identification of Alternate No.
Item No.
Examil\\alion Requirement Limitation Basis for Relief Examinations Remarks 205220 2
12-RHRHEX-IN Complete volumetric exami-Due to nozzle configuration, None.
As performed during the first C-8 Nozzlc.to-Sbcll nation of the Code volume is IC8J1lling from the nozzle is inspection interval,. complete C2.21 not obtainable. 100% of the not possible. Due to adjacent surface examination ooverage and Surface and Volumetric weld length can be scanned weld interference, scanning is a 0-degree and 4S-degree ultra-from the weld surface.
limited to a *w-of 7/8*-3*
sonic examination from the weld from ss*-TL and a *w-of surface is obtainable.
l/2*-3* from is*-39" L. Due to support interference, scan-ning is limited to *w-of l/?9-3* from 11 l/2*-22* Land a
- w-of l/2*-3* from 111/2"-
22*L and a "W" of 1 1/8"-3*
from 42 1/2*-SJ 1/4" L.
205230 2
12-RHRHEX-OlJf Complete volumetric exami-Due to nozzle configuration, None.
As performed during the first C-8 Shell-lo-Nozzle nation of the Code volume is scanning from the nozzle side inspection interval, complete C2.21 not obtainable. 100% of the is not possible. Due to adja-surface ccaminalion coverage and Surface and Volumetric weld length can be scanned cent weld interference, scan-a ~degree and 45-degree ultra-from the weld surface.
ning is limited to a *w-of sonic examination from the weld 3/S--3* from 58 1/X'-7" Land surface is obtainable.
a *w-of 0"-3* from 25*-40*.
Due to support interference, scanning is limited to *w-of 1 3/8*-1*
from 113/4"-
21 3 /'34* L and a "W" of 1 1/4-3.
from 45 3/8*-
S4 1/4" L.
227750 2
32-MS-2141-2WPA Surface examination coverage This examination area is None.
See Figure 1.
C-C Lugs 1 through 4 is not obtainable.
within the penetration and is CJ.20 inaccessible.
228750 2
32-MS-2131-2WPA Surface examination ooverage This examination area is None.
See Figure 1.
C-C Lugs 1 through 4 is not obtainable.
within the penetration and is CJ.20 Surface inaccessible.
Table 1 Page 5 of 8 COMPONENT AND PIPING LIMITATIONS Class Summary Category
~emioarion Area/
Identification of Alternate No.
hem No.
Eumlllldon Requirement Limitation Basis for Relier Examinations Remarks 229850 2
32-MS-2121-2WPA Surface examination awerage This examination area is None.
See Figure 1.
cc I.up 1 through 4 is not obtainable.
within the penetration and is Cl.20 Surface inacceuible.
231050 2
32-MS-2111-2WPA Surface examination coverage This examination area is None.
Sec Figure 1.
C-C Lugs 1 through 4 is not obtainable.
within the penetration and is Cl.20 Surface inaccessible.
230000 2
32-MS-2121-2PS-2 Complete surfcwe eiaunination Due to weld lugs at 0"-19",
None.
As performed during the first cc Pipe Support coverage is not attainable.
22"-ll", 36 1/2"-38 1/2", 42 inspection interval, a limited Cl.20 Approximately 20% of the 1/2-67", 72-104~ L, complete examination of the Code area is Surface examination area is aaies.Wlc surface examination coverage obtainable.
for examination.
is not obtainable.
263304 2
14-RH-2114-18 Complete volumetric c:xami-Due to flange and pump con-None.
As performed during the first Add C-F-1 Flange-to-Pump nation of the Code volume is figuration, scanning from the inspection
- interval, complete Weld#l4 CS.11 not obtainable. 100% of the base material is not possible.
surface ciamination coverage and 263284 Surface and Volumetric weld length can be scanned a 0-degree and 45-degree ultra-from the weld surface.
sonic examination from the weld surface is obtainable. Substitution not allowed. Additional weld will be examined.
e 263508 2
8-RH-2126-1 Complete volumetric exami-
- Due to pump and valve con-None.
As performed during the fust Add C-F-1 Pump-to-Valve nation of the Code volume is figuration, scanning from the inspection interval, complete
- 2 CS.11 not obtainable. 100% or the base material is not possible.
surface examination coverage and 263510 Surface and Volumetric weld length can be scanned a 0-degree and 45-degrec ultra-from the weld surface.
sonic examination from the weld surface is obtainable. Substitution no1 allowed. Additional weld will be examined.
Summary No..
2.64206 Add
- 2 2.64202 277940 271960 278200 Class Category Item No.
2 C-F-1 C5.ll 2
C-C Cl.40 2
C-C Cl.40 2
- c-e Cl.40
~11iu1ion Area/
Examlnaltoa Requirement
.s.1-2104-4 Safe Bnd-lo-Noulc Surface and Volumc&ric 12-MS-167-VS-lA Valve Support at 90 Degrees Surface 12-MS-167-VS-lB Valve Support at 90 Degrees Surface 1.1-MS-167-VS-2 Valve Suppoft at 270 Degrees Surface Table 1 COMPONENT AND PIPING LIMITATIONS Identification of Limitation Complete volumetric exami-nation of the Code volume is not obtainable. 100% of the weld length can be scanned from the weld surface.
Complete surface examination coverage is not obtainable.
Complete surfaa: aamination coverage is not obtainable.
Complete surface cramination coverage is not obtainable.
Basis for Relief Due to weld #3 and the noz-zle configuration, scanning from the base material is not poasable.
Due to support structure interference, examination is not possible from CCW side.
Complete examination surface coverage is not obtainable from l 7/8*-6 l/r Land 9 1/4*-lJ* L due to proximity of lugs l and lB.
Due to lug lA interference, examination ii not poasable from CCW side.
Due to lug 2A, interference, eumination is not possible from CCW side.
Alternate Examinations None.
None.
None.
None.
Page 6 of 8 Remarks As performed during the first inspection interval, a complete Cklegreie and 45-0egrec ullrasonic examination from the weld sur-face is obtainable.
A surface examination was performed as a supplemental examination. Sub-stitution not allowed. Additional weld will be examined.
As performed during the first inspection interval, a limited eomination of the Code area is obtainable. MT examination will be augmented with P'f if possible to improve coverage. See Fig-ure 2.
As performed during the first inspection interval, a limited examination of the Code area is obtainable. MT examination will be augmented with P'f if possible to improve coverage. See Fig-ure.2.
As performed during the first inspection interval, a limited examination of the Code area is obtainable. MT examination will be augmented with P'f if possible 10 improve coverage. See Fig-ure 2.
Summary No.
278240 278260 278400 278440 Class Ca1egory llem No.
2 C-C CJ.40 2
C-C CJ.40 2
C-C CJ.40 2
C-C CJ.40 Examination Area/
Examination Requirement 13-MS-167-VS-2A Valve Support at 270 Dcgrcca Surface 13-MS-167-VS-28 Valve Suppon at 270 Degrees Surface 14-MS-167-VS-2 Valve Suppon at 270 Degrees Surface 14-MS-167-VS-2A Valve Support at 270 Degrees Surface Table 1 COMPONENT AND PIPING LIMITATIONS ldentificalion of Limilalion Complete surface examination is not obtainable.
Comple1e surface examination is not oblainable.
Complete surface examination is not oblainable.
Complele surface examinalion of the Code area is not obtainable.
Basis for Relief Due to support structure interference, e:xaminalion is not obtainable on CCW side.
Compleie surface examination coverage is not obtainable from 17 7/8'-22 1/2*, 25*_29 1/2* due to lugs 28 and 2.
Due to valve support Lug 2A, surf ace examination coverage is not oblainable on CCW side.
Due to Lug 2A interference, surface examination coverage is not oblainable on CCW side.
Due to valve support lug 2A and 28, surface examina1ion is 001 possible from lT-20 1/2* and 24 1/2*-28 5/8" L, and on lhe CCW side.
Alternate Examina1ions None.
None.
None.
None.
Page 7 of 8 Remarks As performed during the firsl inspection inlerval, a limited examinalion of lhe Code area is oblainable. MT examination will be augmenled wilh PT if possible 10 improve coverage. See Fig-ure 2.
As performed during lhe first inspection inlerval, a limi1ed examinalion of lhe Code area is ob1ainable. MT examination will be augmenled wilh PT if possible 10 improve coverage. See Fig-ure 2.
As performed during the firsl inspection imerval, a limi1ed examina1ion of the Code area is ob1ainable. MT examina1ion will be augmen1ed wilh PT if possible
- 10 improve coverage. See Fig-ure 2.
As performed during 1he first inspection interval, a limited examination of the Code area is obtainable. MT examination will be augmented wilh PT if possible 10 improve coverage. See Fig-ure 2.
Class Summary Category No.
Item No.
278460 2
C-C Cl.40 Examinalion Arca/
Examiution Requirement 14-MS-167-VS-28 Valve Suppon at 210 Dcgrca Surfac:c Table l COMPONENT AND PIPING LIMITATIONS Identification of Limitation Complete surfaa: examination of the Code area. is not obtainable.
Basis for Relief Due to support Lug iitterfer-encc, surface examination is not obtainable on CCW side.
Alternate Examinations None.
Page 8 of 8 Remarks As performed during the first inspection interval, a limited examination of the Code area is obtainable. MT examination will be augmented with PT if possible to improve coverage. See Fig-ure 2.
PIPING/
CONTAINMENT WALL PENETRATION SLEEVE DEPICTION OF LUG LOCATIONS WITHIN PENETRATION WHICH ARE INACCESSIBLE FOR EXAMINATION FIGURE 1
I 1
B
~
tf
- 1 OR z
~
l_..i
~
~
I I
I I
I I
I I
I I -,
~
TYPICAL 167 MAIN STEAM VALVE SUPPORT Figure 2
,RAI ITEM 2.C Request for Relief No. 4:
Relief is requested from performing the Code-required hydrostatic pressure tests of portions of the 3/4 in. Class 2 piping in the RHR and Safety Injection Systems at the r.equired test pressures of 565 PSI and 750 PSI.
As a proposed alternative, the subject lines will be pressurized to the nominal operating pressure (80-90 PSI) of the demineralized water system.
Provide information with regard to the hydrostatic pressure testing of the piping adjacent to the portions of piping for which relief is requested.
Discuss the possibility of including the subject portions of piping in the hydrostatic tests of the adjacent piping.
PSE&G RESPONSE TO RAI ITEM 2.C Relief Request No. 4 was submitted because of piping configuration restraints.
The lines are 3/4 in. Class 2 piping but with check valves preventing flow to the system isolation valves from the demineralized water system used.to make-up and flush the RHR System.
All the piping is welded with welded capped check valves.
Without breaching the system to remove the check valve internals or the demineralized water system upstream of the isolation valves, testing of this piping would not be obtainable.
A hydrostatic pressure test to 751-770 psig was performed on the portions of the system on the RHR side of the check valves as specified and required by ASME Section XI.
The total length of piping tested at the nominal pressure of the demineralized water system (between 80-90 psig) is 6 fe~t.
RAI ITEM 2.D Request for Relief No. 5:
Relief is requested from performing the Code-required inservice VT-3 and VT-4 visual examination* and inservice (furictional) testing of Class l, 2 and 3 snubbers.
As a proposed alternative, visual examinations and ~unctional testing will be performed in accordance with the-plant Technical Specifications.
.--RAI ITEM 2.D (continued)
Discuss the extent to which the proposed alternative visual examination meets the intent of the Code-required VT-3 and VT-4 visual examinations.
How will the proposed alternative examination result in an increase in the overall level of plant quality and safety, as stated in the relief request?
PSE&G RESPONSE TO RAI ITEM 2.D Section XI of the ASME Code 1983 Edition through Summer 1983 Addenda, Article IWF-2000 requires VT-3 and VT-4 inservice visual examinations of mechanical and hydraulic snubbers.
The inspection program as stated in the Code is:
(a)
Inservice examination shall be performed either during normal system operation or plant outages, and (b)
The required examinations shall be completed in accordance with the inspection schedule established for components under IWB, IWC, IWD amd IWE.
The examinations scheduled per the Salen Unit 1 ISI Program Plan were scheduled in accordance with Inspection Program B, as described in IWA-2400 for Class 1, 2 and 3 components and component supports.
Inspection periods are presently scheduled in accordance with the provisions of IWA-2400; IWB-2400, IWC-2400, IWD-2400 and IWF-2400 as follows:
First Period
- Three calendar years following the completion of the first inspection interval.
Second Period - Next four calendar years of plant service.
Third Period
- Next three calendar years of plant service.
IWF-5000 requires inservice tests to be performed on mechanical and hydraulic snubbers.
For snubbers of less than 50 kips, (a) inserv1ce tests shall be performed either during normal system operation or plant outages, and (b) a* representative sample of 10% of the total number of nonexempt (IWF-1230) snubbers whose load rating is less than 50 kips shall be tested each inspection period.
PSE&G RESPONSE TO RAI ITEM 2.D (continued)
Relief is requested from performing the inservice VT-3 and VT-4 visual examination and inservice (functional) testing to the requirements of the Code.
Visual examinations and functional testing will be performed on the Class 1, 2, and 3 (and other) snubbers in compliance with Salem Unit 1 Technical Specification (TS) 4.7.9.
Performance of examinations and testing to the requirements of the TS referenced above meets or exceeds all the require~ents of the Code.
As an example, the Code specifies that examinations will be scheduled per the inspection period established.
TS 4.7.9 requires that visual examinations be performed on all snubbers every 18 months +/- 25% based on zero (0) inoperable snubbers.
Thus, inspections are performed more frequently and usually twice as often as specified.in the Code.
Visual inspections shall verify (1) that there are no visible indications of damage or impaired operability,* (2) that attachments to the foundation or supporting structure are secure, and (*3) that in those locations where snubber movement can be manually induced without disconnection of the snubber, that the snubber has fredom of movement and is not frozen up.
Functional testing of mechanical and hydraulic snubbers in accordance with the TS is required at least once per 18 months during shutdown.
This testing frequency is over and*above that specified by the Code.
Also, the Code only specifies functional testing requirements for snubbers less than 50 kips.
The TS specify the requirement to perform testing on all mechanical and hydraulic sn~bbers including those with a rated capacity of greater than or equ~l to 50 kips.
The 10% sample selection, additional sample selection, and functional test acceptance criteria in the TS for both mechanical and hydraulic snubbers meet or exceed all Code requirements.
In summary, PSE&G believes that snubber testing in accordance with the Salem Unit 1 TS results in an increase in the overall level of plant quality and safety since the examination and functional testing requirements meet or exceed Code req.uirements and since the inspections are performed on a more frequent basis than that ~pecified by the Code.
RA! ITEM 2.E Plans for inservice examination of the Reactor Pressure Vessel welds should address the degree of compliance with Regulatory Guide 1.150, "Ultrasonic Testing of Reactor Vessel Welds During Preservice and Inservice Examinations.
Discuss the near-surface examination and resolution with regard to finding service induced flaws and the use of electronic gating as related to the volume of material near the surface that is not being examined.
PSE&G RESPONSE TO RA! ITEM 2.E Plans for inservice examination of the Salem Unit 1 reactor pressure vessel welds incorporate the use of Southwest Research Institute (SwRI) Fast PaR and Enhanced Data Acquisition System (EDAS).
SwRI has developed a broad range of technology to address near-surface examination.
The field technology is based on search units using multiple piezoelectric elements to extract information relative to flaws from compression waves of transducers.
as multibeam inspection tehcnology the interactive shear and
~his procedure is referred to (MIT).
Detection of near-surface cracks using the SwRI 50/70 transducer is an application of MIT.
This specially constructed transducer is extremely effective for detection of flaws close to the near surface.
Additionally, the technique and transducers used are effective to a depth of approximately 2 1/2 inches in the vessel wall.
To support the use of the SwRI 50/70 detection system, appropriate reactor pressure vessel inner radius and piping calibration blocks have been modified, prior to the last mechanized vessel examiantions by the additi6n of 1/16 inch diameter holes starting at the clad-bese metal interface at 1/2 inch intervals to the depth of the first 1/4-T Section XI Code reflector.
In addition, the EDAS proposed for use does not electronically gate out any areas.
All wave form data from Time Zero are digitized and recorded for use in B-and C-scan presentations.
Indications will be sized with the use of multibeam tip diffraction transducers.
SwRI has prepared a transcript of Appendix A to NRC Regulatory Guide 1.150, Revision 1, annotated with SwRI's comments.
. Comments are provided relative to the Regulatory Position portion of the Reg. Guide and indicate SwRI's technical methods of implementing Regulatory Guide 1.150.
The transcript is attached for your review.
SOUilJWESI RESEABCH INSTITUTE IMPLEMEN"fATION OF REGUl.ATORY GUIDE 1.150 REOUJREMENTS APPENDIX A Ultrasonic examination of reactor vessel welds should be performed according to the requirements of Section XI of the ASME B&PV Code, as referenced in the Safety Analysis Report (SAR) and its amendments, supplemented by the following:
- 1.
INSPECDON SYSTEM PERFORMANCE CHECKS The conduct of a quality examination requires that the performance characteristics of the inspection system used be well defined and documented.
This is particularly true for situations which require comparisons of examination results generated during succcWve examinations on the same components.
A system comprises:
- a.
a transducer;
- b.
a single-channel instrument or each channel of a multichannel instrument; and
- c.
a given cable type and length.
The chec:b descnbcd in paragraphs 1.1 and 1.2 should be made for any UT system used for inspection of reactor pressure vessel (RPV) welds.
The field performance checks described in 1.2 (with the possible exception of 1.2.c) should be conducted on a basic calibration block that represents the thickness range to be examined.
SwRI 9fJG Mlh IM n<<tl to tJqiM tlllll doalnlent tlw pofonnilna dulructeristia of ur ~
""",..,,... bml dailtf so far many -yet11S.
Mad of tJw dll!da identified hlnin NIN,,_. """""1d opaudnf Jlf<<lia for SwRL SwRI applia these
~
to "" IWlt:/t/r ~
wf!/4 ~
whdMr tlw cmminatioru art:
~
"""""""" ftvm tlw iluiM sulf11a, "' """"""*" from tM ouJ.ritl4 surfaa.
Sina llw tallllr of llw jiGl pa/Otmlllfa daa:G daai1Jed in L2 tllfl inMpmdDlt of
~
lllat:k...... SwRI ptflUdula allow dw u.w of 111'1 Cll/ibnltian blodc that will~ IM,._ laJJOlllG nMtMtl/ar tlN pei/"""'11ta clr<<:k.
1.1
'PrHpm Perfonpang; Checks
- a.
Freqpens;y of Checks These checks should be verified within 6 months before reactor pressure vessel examinations performed during one outage.
Pulse shape and noise suppression c:Ontrols should remain at the same settings during calibration and examination.
- b.
RF Waycfonn A record of the RF (radiofrequency) pulse wavcfonn from a reference reflector should be obtained for each search unit used in the examination in a manner which will provide frequency amplitude infonnation.
At the highest amplitude portion of the beam, the RF return signal should be recorded before it has been rectified or conditioned for display.
The reflector used in generating the RF return signal as well as the electronic system (i.e.,
the basic ultrasonic instrument, gating, and form of gated signal) should be documented.
These records should be used for comparison with previous and future records.
SwRI petfomu " compld4 lllbonlloty analyrir of eWf11 sellldl unit in inwntory at least nay 6 months.
77U.r ll1llllyAr induda not only m:anling the RF pulse wavefonn identifkd abow, but abo detl!lminalion of tM frequent:y spectrum and distJlna ampliluM auw: for ut:Js sellldl unit.
&an:h uniU dult do not meet strict petf"""'111U kJ/enznt:a ate dist:arrMd or lllbellJd a.r not aa:eplllbk /<1' field use.
Docunwnllltion of thb ll1Ullym i.r provitJ,ed to SwRI c&na prior to du: job and i.r also iMbuW in the final aaminlllian 1q10tt.
In qtltfjtim to du: lllbonlloty Wll'dl unit ~
SwRI photof/aph.r the RF wavefonn in lhll jfGd tJunnr inililll 111111 final caJibnzdOlu.
77U.r pmvida " rw:ord of the RF waveform obtJlined ming the spedJic.sy.rton camponena (""1Udlu:el; inst1unMn4 and Cllb/4) dult tn usedforca/ibnllion and aamination.
1.2 field Performance Checks
- a.
Fregvcncy of Cbecb As a minimum, these chccb should be verified on site before and after examining all the welds that need to be examined in a reactor pressure ~l during one outage.
Pulse shape and noise suppression controls should remain at the same setting during examination and cahlxation.
- b.
Jgstrument Sensitiyity Purina Linearity Chec:ks The initial instrument sensitivity during the performance of 1.2.e should be such that it falls at the calibration sensitivity or at some point between the calibration sensitivity and the scanning sensitivity.
- c.
RPWe;fgrm A record of the RF (radiofrequency) pulse waveform from a reference reflector should be obtained and recorded in a manner that will permit extraction of frequency amplitude information.
At the highest amplitude portion of the beam, the RP return signal should be recorded before it has been rectified or conditioned for display.
This should be determined on the same reflector as that used in 1.1.b above. This record should be retained for future reference.
e e
- d.
Sqccn Hei&ht Linearity Screen height linearity of the ultrasonic instrument should be det.ermined according to the mandatory Appendix I to Article 4, Seetion V of the ASME Code or Appendix I to Section XI of the ASME Code.
- e.
Amplitude Control Linearity Amplitude control linearity should be determined according to the mandatory Appendix II of Article 4,Section V, of the ASME Code or Appendix I of Section XI of the ASME Code.
- f.
Anile-Beam Profile Characterization The vertical beam profile should be determined for each search unit used during the examination by a procedure similar to that outlined in nonmandatory Appendix B-60, Article 4,Section V, of the ASME Code or Appendix I to Section XI of the ASME Code.
Beam profile curves should be determined at different depths to cover the thicknesses of materials to be examined.
Interpolation may be used to obtain beam profile correction for assessing flaws at intermediate depths for which beam profile has not been determined.
- Beam profile measurements should be made at the sensitivity required for sizing.
For
'IM~
pafonnana ch<<Ja daaibetl abow tn pafomwl by SwRI a follows:
- 1)
RF Wawfann - SwRI photof1'flplu thlJ RF wtl'Jefonn in tlul ~
dllling each inililll llNl jinlll clllibnltion.
77m pnwida a m:ard of tlul RF wavefomz obtmMd u.rinr tlul sp<<iJi& -.syston ~
{lnlnsducer, instrument, and Cllblil) thllt tn uud for adibtrltilJn llNl alll1liMtian.
- 2)
Sams Heit/II Linearity - Sams hei;rt 1inurity ch<<Ja tn pofomwl /Ot' eodl in.rtnlnMnt in <<:t:anlana Miii tlul Ref Guide ~
7Mse dl<<lcr tn Jltllfomwl imml!tJialay before llNl after completicn of tlul auminGdGn.r.
- 3)
.Anrp/illMlc Canl10I Linetriy -.AmplilluJe canllOl liMlll'ity duJt:1a estllblish "
.... 1*IJan.rhip bdwan "" adjwtmt!nt of tlul pr, "' ~
conJrols (boiar "' 6Witdta) llNl thlJ conaponding si,,al ~
change observed anllMCRT.
In IM am of """""11 mllJlinatiaru, thlJ pn cantmb tn used to ddermine the lllrqllibuM "' a pen:Dllllfe of thlJ Di.rtJlna Amplitude Corra:tial (DAC)
Ouw by adju.rting tlul CIJlllrol.f until thlJ sifl'lll m.a tlul D.A.C aow llNl azlroitrtinr the indkation tarqJlilude ba.re4 upon tlul """""" of gain adjustmml.
Since tlul gain cantmb tn med to indirectly calmfak indication 11111plihvk, it ii impotfllnt for thlJ rdatianship bdMWn control tUJiu.rlmenl.J llNl conaponding sipll duznga to be linear regardlas of how 1a1f6 or sm4lll tlul iNlialtion. ii prior to tlul canllOl adjwtmmL In tlul case
(1,Jf(li ~11~:1* ll(j:J:(J~l:IJ: j:~l,.j:~~IJ 1*'1*J'
- l. r :
~. 'I i f ~ r ! r J f I. ~ ~ t j "i *
~ I :Ii. H* I !. r c* l
- l !.
i I 1, i ~ h. t *. I ~ l I f. ' J 1
- ~ i ' ~
~
Ira t Jt ra 1 b I 1111.
.,~i"i l Sri 1l1::1r l~r:I~~ fl~t;!tlr !!~ ~~ff ti"!: tf !1
.g_J*i" Ji l
~i:Jlt rh:,lc.~ric*tl ~ le.hhr..hf IJ~ltl~ :~i~I~
i11~~IJl11t *~
~a.~u~-J,!~
l 1* 11 ~ ~ ~
~ E. ~ $ l i
~ ~ r l: l l ~ l l l ~ ~ ~
J* r ~ l J* J* ~ ~
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- 2.
CAL1BRATION System calibration should be performed to establish the DAC curve and the sweep range cali"bration in accordance with Article 4,Section V, of the ASME Code or Appendix I to Section XI.
Cahbration should be confirmed before and after each RPV examination, or each week in which the system is in use, whichever is less.
Where possible, the same calibration block should be used for successive inscrvice examinations of the RPV.
System calibtfltion i.r pofomUJd on.ril4 by SwRI in oa:onJance with Reg GuUJe
~
Oft the applicable ba.ric caJibnztion block.
Calibrlllion confimullion during """""" emminatioM i.r pafonned prior to the emminadon; at least nay four houn during the a.amination.r; with any substitution of surr:h unit, cable, "'power source; """upon completion of the ~
FOi' m<<:luznized t!Zlllnbulliau, SwRI petfomu calibnltion confimullion prior to the stmt of " seria of f!Zllmi1uztiotu (11 series i.r consUlam to IM similllr a.aminations pafonned u.ring the lll7M cmmination l<<:hniqua and the SlllM equipment configunzdon); with any
.rubstiti1don of uan:h unit, Cllble, "' power source; ~
the deviu i.r rmrotled from the a.amination '1lm; "' led nay Mck tluliw the emminalions; and at the completion of " seria of a.aminlltion.r.
WMe thi.r Cllli1mllion confimullion frequency i.r *consistenl with the ~
Guide, it sometima doa not CDmply with tM 12-haur frequmi:y ~
of Patuwuph T-432.1.2 of S<<:lian Y.
&caw. of the inMmtt slllbility and telUlbility of the SwRI d<<llOnit: ~
hoMwo; SwRI 1ul8 M'IO' aperienad pmblmu mating calibnllian confimullion aitllia,..,,.,. going beyond the 12-haur time period.
'IM ot:t:qJlllbiJit of au.edinr the S<<lian y 12-houT Cll6b1rltion ch<<Jc can IM detnonstrrlUd as allowtul in Pat'fl/IOllla IW.A.-2240 of S<<tion XL
- 2.1 Calibration for Manual Scannin&
For manual sizing of flaws, static calibration may be used if sizing is performed using a static transducer.
When signals arc ma-rimized during calibration, they should also be maximized during sizing.
For manual scanning for the detection of flaws, reference hole detection should be shown at scanning speed and detection level set accordingly.
Ar ~
abtMr, SwRI rua skllk caJibnllilJn and sllllil; sizing t<<hniqua /OI' manual
~
~
'boda colibnltion """ jllzw sipll.r.
Reftnna: hok drt:Don i.r Wfli/illtl ~.scanninl tllltl' the c"1ilmltion blodc at tM 1IUIJdmwn scanning sp<<d and
~"""the sip lrtMtf "'ar:ad.r tM 1f!CIJnlini lePd.
2.2 Calibration for Mei;hanjp;d Sgnnin1 When flaw detection is to be done by mechanized equipment, the calibration should be performed using the following guidelines:
- a.
The DAC curve should be established using either a moving transducer mounted on the mechanism that will be used for examination of the component or a mechanism that duplicates the critical factors (e.g., transducer mounting, weight,
pivot points, couplant) present in the scanning mechanism.
- b.
Cah"bration speed should be at or higher than the scanning speed, except when correction factors established in 2.2.d are used.
- c.
The direction of transducer movement (forward or backward) during calibration to establish the DAC curve should be the same direction during scanning unless it can be shown that a change in scanning direction docs not reduce flaw detection capability.
- d.
One
- of the following alternative guidelines should be followed to establish correction factors if static calibration is used:
(1)
Correction factors between dynamic and static response should be established using the basic cah"bration block or, (2)
Correction factors should be established using models and taking scaling factors into consideration (assumed scaling relationship should be verified) or, (3)
Correction factors should be established using full-scale mock-ups.
SwRI camplia Mtla thac ~
for caJibnllian for medulnized.raznning in oa:onlllna witll 2.2.d(J) in that M luwtl ~
demanstra/etl equiva/au:y bdwm scanning wit11 the SwRI PaR dlvka or tnld: """"*" St:lll'llll!IS llNl our st.adc Clllibration t<<:hniqua.
SwRI 1f1llliMJy pnwida " '9fJ'I to its automen documenting thi.r equiva/au:y using the etpipmmt pertinent to each Cll:J/DnWs app/iD1lion..
2.3 Cah"bration Confirmation Cah"bration confirmation performed as mid.shift or interim confirmation between onsite calibrations should comply with stability requirements in T-433, Article 4,Section V, of the ASMECodc.
When an electronic simulator is used for onsite cah"bration confirmation after a Code-required block cah"bration performed off site, the following should apply.
- a.
Complete system performance should be maintained stable prior to offsite calibrations and onsite calibration confirmation by use of target reflectors.
The target reflectors should be mounted with identical physical displacement in both the offsite calibration facilities and the onsite me.chaniud equipment.
Each onsite periodic calibration should be preceded by complete system performance verification using a minimum of two (2) target reflectors separated by a distance representing 75 percent of maximum thickness to be examined.
- b.
Written records of cah'brations should be established for both target reflector responses and Code calibration block DAC curves for each transducer.
These written records may be used to monitor drift since the original recorded calibration.
- c.
Measures should be taken to ensure that the different variables such as temperature, Vibration, and shock limits are minimized by controlling packaging, handling, and storage.
SwRI calibffltion conjimumons are performed al the fmluency sp<<ijied in paragraph 2 above and are in complillna with the stllbilUy ~
of the &g GuidL SwRI calibnzdon conjimultions are perfonned onsilll using the lHuic azJibnzlion block, not an d<<troni& blocJc silrruJilta.
Ar mi:h, the additional ~
identifi4d in this parawuph for the 11.ut of an d<<tronil: blocJc simuJIJta do not apply.
Ill addition to periodk caJibnztion conjirmation.r, functional ch<<Ja of the ur instnunentr and the TCG.systan are typil:lllJy perfat'fned at shift cluzn~.
Tlu!se cht!da utiliu eJectmnil: signal gf!IU!nltOn to monitor fOI' cluzngu in sweep and amplilllM display&
TM Slllbility critoiJI of Pw,.uph T 433 of Artide 4 are used for aa:eplllbilily of~
functional ch<<:la.
For PJf2I full va."11 talll'ltituJdau using SwR1'1 Ftl.ft PaR..sy.ston, two DalJZ Acquisition S-ystenu tn utilized in ptll'lllll!L While OM.sy.stan ii used for saznning and dala aapifition, the othll q:Wm ii bcinr Clllibnlll!tl for the nat saia of emmination.r.
Ill ejfa:t, two ~
cllbltl.S}'StoU tn u.re4 OM for caJibnrlion and another for atlminlldon.
SwRI'1 Remot6 Olbll: ClllibnllDr.sy.rtan allolln camparisan of the di/len!ltCe in cable per/"""'11tU and alro prtWUla el<<lmnil: signal generation f 01' ptJriodic ~
dUlt the Jlt!'/"""'1111% of the two t:llbk.1}'Stml.r lul3 not cluznged.
77tae cllbltl Jlt!'ftlmllllll:tJ ch<<la (ft Jlt!'forrrrbl "' the.,,.. time. and usinr the SIZ1M ail6ill, as IM d<<l1'0nic functional cht!da ~
abowr..
2.4 Calibration Blocks Calibration blocks should comply with Appendix I to Section XI or Article 4,Section V, of the ASME Code.
When an alternative calibration block or a new conventional block is used, a ratio between the DAC curves obtained from the original block and from the new block should be noted (for reference) to prOYide for a meaningful comparison of previous and current data.
The cahbration side-drilled holes in the basic calibration block and the block surface should be protected so that their characteristics do not change during storage.
These side-drilled holes or the block surface should not be modified in any way (e.g., by polishing) between successive examinations. If the block surface or the cahbration reflector holes have been polished by any chemical or mechanical means, this fact should be recorded.
SwRI ~
,_,,. the w of Clllibnlliotl bloda thlll tn fabtit:llWl in accotdance with IM R6f Guidll ~
for slilllllllrd Code t<<hniqua.
When sp<<illl t<<hniqua tllS ""1hwf,.mdl a
"""1,....,. IMmn amnination of the.,_, rwfaa w:Jllmw or lp<<ial "'1ZZl6 illnlr 1lldilU amninatio1, SwRI ~
modijicatian of aJmlf!lflianal bloda in ordl!r to ~
the ~
of the specilll technique.
Wht!newr ~
abtinw Code ~
tn used a gui"'1na for the SwRI
~
It ii SwRr1 rrx:ommendtztio th/It the sanw calibffltion block be uud for ~
t!Z1D11i1u1tioM Howew!t', * ~
calibffltion bloda are* cJusngm, SwRI also
e e
recommend.r dult "
condlllioft ~ pafomwl if possible to aid in comparison of indiClltion.r if n<<a.rary.
- 3.
EXAMINATION The scope and extent of the ultrasonic examinations should comply with IWA-2000,Section XI, of the ASME Code.
If electronic gating is used to define the examination volume within which indications are recorded, the start and stop control points should include the entire required thickness including the material near each surface.
If a single gate is used, it should be capable of recording multiple indications appearing in the gate.
Alternative mealiS of recording may be used providing they do not reduce flaw detection and recording capability.
Enmination should be done with a minimum 25-perccnt scan overlap based on the transducer element size.
Tlul lt:OfM """ alent of """""" allnlilraliotu lllf! ""'1nmed in tM emmbuztion p/lln llNl aamintztion proutJura in llCt:Onlllna with IWA-2<<n In °"'1!i' to ~
that the scope llNl allnl of tllllDtnlllal emminllliau comply with IWA-2000 of Sa:lian XI. SwRI pepo;a a detmW San Pl4ln for each lllllDmllted aamintztion llCIMly in lllldilim to lypiall miminlzlion pmatlwa.
ThU plan addn!ssa devia conjigurrllian. SCllll1ling parrzmelln, clllibnzlion parrzmelln,,_ Sdlinp, and oth6 sp<<:iJic infomtlllion nade4 to pofonn the wari:. ~
of tM SwRI
.rcon p/lln, m ptqJtn4 for 11 sp<<:i/ic app/iallian, will ensure that the full wKu1ne of IM ASME t!JfZZlftilullW 111m i.r a:amine4 to IM allnl allowt!d by that vase/
ainfiguration. ~
i.r aaompli.rMll mini II combinlldon of saaaJ beam angles llNl cmmination tedrniqua "'spa:iJW in tM St:ll1I p/aM.
'IM el<<:lranit: gtlli1rr.f)'StOn ulilizal by SwRI doa not limit IM aamintztion wHu1M within MUdl illdialiotu lllf! ff!Cl1'daL W1tas IM SwRI llJlndJzrd dlltll acqui.rition system i.r "'"" 11 W"'1o tmlfdin1 i.r 1llllde of the lldlllll UT ~
CRT Jll'l'llllion.r with tM Xtll'Ch unit polilionaJ infomtlllion superimposed in rml tim&
SwRl's *.si.a of IM tllt" enJulnt:etl dlltll acquirjtjon.sysmn luu twalllpping electronic
..,,, for each UT dullrMl suds that II full w1'unw aambultiota i.r di~ ~
and ~
77w SwRI mlulnud dlll/J ~
..,mon ~
i.r CllpOble of di -1'htl. -=--*.. -~-- :-.1:--:--
~- *.......,_.~~
.All tmninllliam pofannol in """'*"" with thi.J ~
Guidil lllf! pafOIT1Wl rainr /1 lSjlGr:mt OMrilp, 1111/a;f "gtr!lll6 mwlilp i.r ~
3.1 Internal Surface The
- capability to effectively detect defects at the internal clad/base metal interface shall be considered acceptable if the examination procedure(s) or tcclmique(s)
- meet the requirements of Section 6.0 of this document and demonstrate the following:
- a.
- b.
- c.
Procedures for examination from the outer swface, or when using full vee from the inside surface, should include the usc of the 2-percent notch which penetrates the internal (clad) surface of the calibration blocks, defined by Section XI, Appendix I, F'igure 1-3131, or Section V, Article 4, F'igure T-434-1.
Procedures for examination from the internal surface when not using the full vee should conform to paragraph 3.1.b below.
An alternate reflector, other than the 2-percent notch described above, may be used provided:
(1) that it is located at the clad/base metal interface or at an equivalent distance from the swface, (2) that it does not exceed the maximum allowable defect size, and (3) that equivalent or superior results can be demonstrated.
The examination procedure(s) should provide for volumet.oic examination of at least 1-inch of metal as measured perpendicular to the nominal location of the base metal cladding interface.
SwRI pmUdura for aaminlldon from IM oubiM Slllfaa of the vasd wall u.M IM 2-par:l!llt natdl for refet'tilla a sp<<:iffe!tl in JIGl"W¥ 3.1(11).
7'hae pmcedura also iN:JuM 11 1lalf wre Clllibralion with the notdl u.d for rad*aon of all indkalion.r wllidl llpllf!tlr tit IM insiM Slllfou of IM aaminotior1 --.
SwRI proutillla for "1ndml bans cmminadan from IM iMillll suzface 1lliliz.e 1/16-inda dianwl6 ~
ho/a Ill IM dad/kw mdlll inlltface as dacribed in JIOlll#UPh 3.l(b).
In bods CAJO, SwRI proadllla ]lffMM for WJlutMbit: mzminlllion of ~
than 1-inda depth below tM dlllldinf inll!lface a 1f1qUin:d by JXllUl!jupla 3.l(c)-
SwRI 1uu dt!manslnllMl dull tM tefoaa MtUilivity Glllblislu!d an IM 1/16-indl dillmeteT
~
ho/a mM!b or ar:#lb tlult sped/il!d in S<<liDn XI of tM ASME Code.
77lb t<<hnique lua abo IMol denransltrBd to hllWl tM CllptlbiJily of det<<ting f1llws with good signal-llHUJUe di.raimbulliDn Ill dqtJu of Ill lea.rt 2-3/4 int:ha below the
~
mdlll inll!lfoa, Ihm ~
- tlln1u;rwaJJ ZDtlll of calibrated sensitivity of duJ ~
lllUl ~
barn.r.
Usbw IM tandem bairn transducen, SwRI lua.,_.,.,, jlaR of mi1llli. sirJI in tlw.,,. bdlWl!n IM ~
metal intet/111% lllld duJ ftnt 4~
lllUl ~
DAC paint.
SwRI lua al.ro u.d ~
"""1 (~
1llOll1llMI piezod<<1rk elsnenls) surr:h 1lllia for 'llNlat:llld aamilullioM; hoMwo; IM useful 1flltgll i.r limiWl to appmDmately 1-int:ll of dqda below IM dlllldinf with no ~
impnwonent DW!r' the tandem
,,_,..-a llnil Ill duJ ~
mdlll inlaface.
3.2. Sranninr Weld-Metal Interface The beam anglca used to scan welds should be based on the geometry 9f the weld/parent metal interface.
Where feasible for 'W'Clds such as those identified in Section T-441.4.2 of Article 4,Section V, of the ASME Code, at least one *ang1e should be such that the beam is perpendicular (+/- 15 degrees to perpendicular) to the weld/parent metal interface, or it should be demonstrated that unfavorably oriented planar flaws can be detected by the UT technique being used. If this is not feasible, usc of alternative volumetric NDE techniques, as permitted by the ASME Code, should be considered.
For RPY sM/l seam welds, SwRI wes thi! nominal Code-specified 0-Ugree, 45-degree, and ~
beanU to aaniW the full volume of the wail section except for the WJllune of ""1lerial nar the beam entry point, for whil:h we use the previously mmlioned tandem search units.
Section T-441.4.2 (or T-441.3.2.2 of the 1986 F.didon) of Artick 4,Section V states that beam angla otho lhlln ~
45-degrea, and ~
should be wed for the emmination of (a) j1llnge weJd.r when the aamiNztion is conducted from the flange faa, (b) nozZla and no:rzk weld.r Mien the aamiruztion is conducted from the nozzle lHn, (c) lllladunent and support weldr, and (d) aamiNztion of double taper junctions.
SwRI has employed this apptOQCh for mmry yean.
SwRI pmudura, howwl; often pmviM nun than code specified coverage where.
feasible.
Eada of the uniqw wield conjiprrztiolu notl!d above is ewrh<<<rted to determine
- the bat and mo.st comprdlensiw COW!lfl/ll atlllinable.
Whe1e necessary, other angle and straight beam emmination.r tn pafomred to ~
comp/de ~
of
~sM/l, ~
and allllchment wdd.r.
Prmously mentioned tandem beam l<<hniqua 111e also ulilized to ptr1WM the ~
1ll!llr surfaa COtla'tlge when 1llTZz.l4 baN aJllllilullions In pafomu!IL
- 4.
BEAM PROFILE Delete entire paragraph. This section included in Recommended Change 1.21, Angle Beam Profile Characterization.
- 5.
SCANNING WELD-METAL INTERFACE Delete entire paragraph.
This section included in Recommended Change 3.2, Scanning Weld-Metal Interface.
- 6.
RECORPING AND SIZING The capability to detect, record, and size the flaws delineated by Section XI, IWB-3500, should be demonstrated.
The measurement tolerance established should be applied when sizing flaws detected and recorded during scanning (see paragraph 7.a).
TM ~
to Mnqnsqptc the Cllpllbility to del<<t, ~
and me /llltft Cl11I be
~
~
MIJ&
A libaal inl6pn!llllit1n mifllt be that yan of industry apa;.a ""' ~
that Code t<<hniqua In capabk of det<<:tint, m:otding and...., Jlllw&.
A ~
inlDptdlllian might be that a modalp of every calG!iN6lr Mil4 ctJlf/iprlJion should be fabrit:lll<<l containing implllnted flaM and t!%llllrint#I ill "'*" to dmlamtnlt,e and document the capability.
SwRI feds that the rml natl;,,~ in bdMwn.
We hJWe ~
aperienu and documenlation to show that the 45-tleppe and 60-
.,,_ Code t:Zllmination.r and thou II.Jing the tlllUl.em proba tn effective for dd<<ting and r<<:anling f"1M in Wl1ll wdd.r wllal SClllf1ling from either the inside OI' OUUiM sueftlt:IJ of the vauL Our a:petienu also ~
that beam angla that tn
~
to be asenlilllly """""' to the wield lll'e effeclive in detl!ctinf and l'f!COl'ding flaM in the norzle..t&.sludl weJd.r from the nazzk bar&
By Wtue of aclUlll flaw
tJd<<tim ming aurmt t<<hniqua, SwRI':s UT proadzlres an well qualified.
AJtJwu;a IM capabilitia of SwRI ~
to de/<<t and m:ord /ll1M luu been
~
on " :signiJit:llnt wzridy of tat :sp<<imen.r and in mlCllJr Vfml!l.r during acllUll ~
and praervia aaminlltion.r, it Cllll1IOt be ptaCliazl1y dernonstraled duzt tlu: t<<hniqua and equipment have tlu: azpabilily to size jlaw:s. with any predictable to/enlna.
Many raearch studia throughoul IM hi.rtmy of tlu: nudur indu.rDy have 1111.Dnpted to qruznJify tlu: sizing ability of Wl1iow NDE appliclllion.r, 1IOfle have es111b1i.s1W11 uniwna1Jy aaeptl.tl resu/l.J.
TM dif/enmt joint ccnfiguration.s, plate thidcna:su, f1llw locadons within tlu:
'Nf!ld, flaw orimtations, and acoustic cJuzracteristia of tlu: componenl mlllDilll all ~
to the inherent wzriabilily of sizing t<<hniques.
Ar ~
SwRI will conlinw to ~
to our QISlomels the thorough evaluation of any j1mn that an dd<<:led and ff!t:Ol*'1 during our aszmituztiolu.
1'heu recommerullllio lulw included, and will ctJNi1rw to include, Code and non-Code sizing t<<:hniqua, the use of mpplementlll NDE t<<hniqua if pnldial/, construction of modc-up.t of tlu: ptllfiallllr confiprllion in quation, raelllCh of dallJ from similar mzminlllion.r and :studia, and calling in can.rultllntr with ptllfiallllr erpatiM in tlu:
~ of ptab/l!ln (from t1llUiM SwRI if ~)
to fully ewzlu.1114 the emmination and IM talla.
We will obo tmirt our clienU in ft't!IY way poa.ribk with NRC ewiJuatians of report.able indil:lltion.r and in IM 1ISll of Fnll:IU18 M<<:luznia l<<hniqua, if 1l<<GSlllY-6.1 Geometric Indications Indications determined to be from geometric sources need not be sized.
Recording of these indications should be at SO-percent DAC. When indications are evaluated as geometric in
- origin, the basis for. that determination should be dcsc:ribcd.
After recording sufficient information to identify the origin of the geometric indication, further recording and evaluation arc not required.
Indication lllUllym and :sizini ;,, pofomwd 111 an indqoulmt onsit6 llCtivity by SwRI.
.All of the ailminalim """' ;,, mWwtJ by Leva o "' Lewi m e:r.aminas to t1u:
alent MCaSlllY to dt!lmniM the origin of""' 1ffCIJnlBl indialliotu.
lndialtiolu thol tn llfll1IMllk in Drip lft 1f!t:l1t'de4 Ill 50 pm:mt DAC and tlu: 1UlllW of mda llldl indication;,,~
6.2 Indic;ations with Chapgjmi Metal Path
- a.
Indications that change metal path distances (indicating throughwall dimension),
when scanned *in accordance with the requirements of ASME Section XI for a distance greater than that recorded from the calibration reflector, should be recorded.
- b.
Reflectors which are at metal paths representing 25 percent and greater of the throughwall thickness of the vessel wall measured from the inner swfacc should be recorded in accordance with the requirements of ASME Section XI and
,.I characterized at SO-percent DAC.
- c.
Reflectors which are within the inner. 25-pcrcent of the throughwall thickness should be recorded at 20-pcrcent DAC.
Characterization should be in accordance with the demonstrated methods under paragraph 6.0. When the indication is sized at 20-pcrcent DAC, the size may be corrected by subtracting the beam width in the through-thickness direction obtained from the calibration hole (between 20-perccnt DAC points) which is at a depth similar to the flaw depth.
If the indication ex.cccds SO-percent DAC, the length should be recorded by measuring the distance between SO-percent DAC levels.
The determined size should be the larger of the two.
SwRI bdoa duzt dul intmt of this
- JJUl"llupla i.r to ~
duzt dul all1f&ina' attempt to deU!nrriM """ docwnenl tM 1llOd ~
of " ~
luwing throupall dimauion.
To dul allnl ~
SwRI "'1lll tllllllym of tnwelling indiazdon.r is pofonMll in oa:onlllnu wiJh tJu:u ~
SwRI typiallly perfomu 'both '1J.petr:etrt and 50-paunl Hain spnllll ~
al dul W. of clllibtrllian in ca. dul in[otrnlllion i.r 1IMdal during diJta analy.rir.
HOMM!r, sizing with baltn spnllll canet:lion at 20-paunt IM.C sJrouJd not be gotmllly app&4 withaul cllUliDn a this apJWooda J1'°dlu:a ~
WIMd sizing dill.a, induding nepiw flaw sir.a in catllin cara..
Far tllndon bans &etllf:h unitr, dul au of balln S/JlfJ'1ll canedion far sizing i.r not 1UJtlna/ly ~
J....mcq of tM raUqu4 beaJn pro/il6 ~
Whm Miii' suefaa indklldolu tn ~
dutinf " wmd emminlltion, SwRI 1fJllliMJy applia OM or mote sp<<:illl sizinr t<<hniqua in onJ6' to obtain tM bat GlimaW of tM flaw me be/ant comparing tlul m to dul aa:qJllllta aill!M of S<<lian XL In general, SwRI ClJtlt:ll1I with dul sp<<iJial apJWtMO\\ but obo tet:ammeNb t1J1Plkadon of Hl<<Jetl tlllenuzt4 sizing tM:hniquo wlMlll wa.wry bared upon " ~
pqh<<dion to ~
wldt:h l<<hniqw i.r ~
1llOd ~
'for dul lll'tidpa'M flaw ~
and orlenJadon.
6.3 Indications W"ttbout Chan&inr Metal Patb
- a.
Indications which do not change metal path distance when scanned in accordance with the requirements of ASME Section XI and are within the outer 75-percent of the througbwall dimension should be recorded when any continuous dimension c=eeds 1-incb.
- b.
If the indiC:ation falls within the inner 25-perccnt of the throughwall dimensions, it should be recorded at 20-perccnt DAC and evaluated at SO-percent DAC.
- c.
Precautionary note:
Indications lying parallel to welds may appear as nontraveling (without manging metal path) when scanned by parallel moving transducers whose beams arc aimed normal to the weld, i.e., at 90-degrces. Multiple scans, however, may reveal that these indications arc traveling indications.
H so, recording and sizing arc to be done in accordance with paragraph 6.2
'J.
To IM almt praclialble, SwRI dlllll tllUl/y:rU of nontnzvelling indiclltianf i.r pafonned in aaonlllna Mt/I lhl!.W requirrmenl;J, along with IM use of addilion.al sizing llX:hniqua MteN appt'Oflriatl!.
TM ~
note of Pwaguph 6.3.c. i.r ~
To allevillte thi.r conam, SwRI pafomu SClllllling in the dilmion of the beam component whowa' possible.
In those in.rtlllu:a wnos thi.r prefarm mode of saznning cannot be
- 1m1tret1, SwRI pmudllra ~
thi.r conam by ~g llllditionllJ St:111U of (along the sound beam dim:lion) of wry nongmnrelric ang/Hellm indication obsetwd during scans made poralleJ to the wcl4.
'1Mu addidonllJ scans an pafonned using Sl'1lll/l scan i:nat!rnerll.r (or "1t1JI trrlnsdul:er' owrlap) in order to dew1Jop " l'O)' tlCCll1'l1t6 dlllll set.
This dlllll set allows 11 ddDminlllion Of whether the indication i.r 11 lnlvding or nontravding indication and also pmvida ~
dlllll for sizingJIUl1KXIG if fl<<GllZ'Y*
6.4 Additional Rccordiur Criteria The following information should also be recorded for indications that arc reportable ac:c:ording to this regulatory position:
- a.
Indications should be recorded at scan intervals no greater than 1/ 4-inch.
- b.
The recorded information should include the indication travel (metal path distance) and the transducer position for 20-percent (where applicable),
SO-percent, and 100-percent DAC and the maximum amplitude of the signal.
- c.
When multiclwmel equipment is used in the examination system such that all examination displays arc not available for simultaneous viewing, an electronic gating system should be used which will provide on-line, reproducible, recorded information regarding metal path, amplitude, and position of all indications aa:eding a present level The represent level should be the minimum recording level required. To ensure that all recordable indications arc recorded, a preferred method would incorporate multigates in each channel or a single gate for each channel with multi-indication recording capability.
Ill refl!l'l!llOI to P111uwupla 6.~ SwRI typial1y pafamu inililll.running ming " 25%
owrlllp a speciJilll in P*Uflupla.1 Howwr, dlllll to be 'llli1ir.ed for sp<<ifie sizing or imlatiPon of indiatiaru dult aual thll ~
1imil.J of S<<lian. XI i.r lll:l[Uirm
- 1/4-indl.... inlowllr.
11lll illJatnulliat _,,;,wl in PG1Ujjjupla 6.4.b i.r typialJly ret:"'*4 by SwRI for all wmd
~
whdlw tM cmmintltion i.r pafomtlltl 1'UlllllllJly OI' using tllllomllWl
~
Ill re/t!lf!lla to PwutJupla 6.4.c whidl ~
th/I use of nallli-dulnnl!l equipment, th/I SwRI slllndJlrd dlllll ~
~
Sllli.rfia thi.r ~
by vi1tluJ of the vi1MJo ~
of the in.rlnlnrmt sawm.
- Sina IM entire.roan praenlJ1lion i.r 1't!t:Otda, sim1IJlaMolu l'lfUllipM siFflb an 1't!i:anW if ~
TM dlllll analysi.r
~
abo int:buJo mUw of all of the Wtlto
- dlllll thetdly ensuring that etlCh
~
sipl i.r mVtwd and analyr.<<l.
- 7.
~~----------
iNliMdwll1y m:ord sinwJtllMom muJtipk indiazliau by digitizing and storing tM entire Mlln'eform, tJru.r ~
st1mmlining and aculDrding tM """' acquUition and tlllll/yAr ]ll'tJQm.
REPORTING OF RESULTS Records obtained while following the recommendations of regulatory positions 1.2, 3, and 6, along with discussions and explanations, if any, should be kept available at the site.
II the size of an indication, as determined in regulatory positions 6.2 or 6.3, exceeds the allowable limits of Section XI of the ASME Code, the indications should be reported as abnormal degradation of reactor pressure boundary in accordance with the recommendation of regulatory position 2.a(3) of Regulatory Guide 1.16.
Along with the report of ultrasonic cnmination test results, the following information should also be included:
- a.
The best estimate of the tolerances in sizing of flaws at the sensitivity required m Section 6 and the basis for this estimate.
This estimate may be determined in part by the use of additional reflectors in the basic cah"bration block.
- b.
A description of the technique used to qualify the effectiveness of the examination procedure, including, as a minimum, material, section thickness, and reflectors.
- c.
The best estimates of the portion of the volume required to be examined by the ASME Code that bas not been effectively examined such as volumes of material near each surface because of near-field or other effects, volumes near interfaces between cladding and parent metal, geometry, volumes inaccessible to the transducer, volumes affected by electronic gating. and volumes near the surface opposite the transducer.*
Sketches and/or descriptions of the tools, fixtures, and component geometry which contribute to incomplete c:overagc should be included.
- d.
Provide sketches of equipment (i.e., samning mechanism and transducer holders) with reference points and neccuary dimensions to allow a reviewer to follow the equipment's indication location scheme.
- e.
When other \\'Olumetric techniques are used, a description of the techniques used should be included in the report.
- It should-be noted that the licensee is required to apply for relief from impractical ASME Code requirements according to 50.SSa of 10CFR. II the licensee is committed to examine a weld as per the inspecdon plan in the plant SAR, the licensee is required to file an amendment when the commitments made in the SAR cannot be met In tefamu to P"""Wupla 1-4 SwRI f<<b tilllt IM sir.a obtllin<<l u.rin6 Cod4 sizing t<<hniquG shauJil lM used ~
/OI' carrpadsan lo Cod4 ~
stllruJards
~
pombl&
.&Jud as SwRI ~
Cod4.rizi1w t<<hniqua appetl" to lM sOmewMt ~
hOMWO; dwn i.r /iJtl4 evidt:nl:e lo SllJ1PO'I tM fa.Jibility of dew/opinf sp<<:i/k tolenl1u:a OI' coner:lion fot:tDn /OI' Cod4 mini t<<Jrniqua.
Nor i.r
- e.
thee siwsifiaznt evidena of improw!d ac...'wat:y and consistmcy raulling from tlu! use of lllfY OM 8'"""* sizing ~
Altmu#.e sizing methods must k uwJ azrefu/]y and, in effect, shauld k used only when it can k determined dull the CoM sizing t<</rniqua 4ft.
for S<<M
- 1mra1, inappropria2 for the sped/k t)fM of f/lzw
~
'1'1ta. lllltl!nu!nlz do point. out dull flaw ma based on ur ~ estimllta.
We, of
~
have WDying degrea of confidma in flaw si2 atinuzta dqJouling on patiMnl amnination varillbla.
Sina the ramijiclltiotu of our flaw siu estimaDon.r
~ wry ~
SwRI will typically 1'!t:IJIJllJVNl Cl!ltJlin octiotu to our customl!r which can ~
our confillena in f/lzw sm atimatian.
'1'lta. ~
may indu.tM octiotu such as:
- 11) placing additional ho/a in the Clllibnzdon blodc
,, )
constnu:ting mode~ of the a:amiluzdon (lff!ll c) using other' NDE equipment d)
"Pfllying ~
NDE 1Mlhotb
- )
pafonning ""6in """1n1loty tGU n
calling in sp<<ia6m wilh ptlTtialJllr' apaiena in similllr problenu.
In tef~ to Pwuwupla 7.b, the ""* for all SwRI Jl'OUllure quali/ialliDn.r i.r doal1neltli!tl and "'1lliJabk for llllllit l1y cJimt or **""°'Y ~Ill any tim&
In teftnna to P111qupla 7.c; SwRI Jl'flflida a ddin"hd limilllliatu ntpart for all n!llCIDr vasel aaminlltiotu.
TM limitlllialu rt!J1011 i.r a combinlllion of tllbla and sla!tdla dull depict """ qlllllllify 11111 Wl1imr limillllilJlu to the °""' 1flqUinld ~
'1'lta. rqortr compik "" of tht: Wl1ioul pftMnt """' ilrlD " concire, lllUlent.andtlbk fom&lll and can k 11.Md a the ba.m for Relief~ if waiary.
TM infomullian iMntiJiM in P*uwupla 7.d i.r mudndy ptOVid<<l in the SwRI Sam Pllln prior to pa/"""'11ta of alllftinlltiau.
In tlddilion, " COflY of the ** ermtffd" Sam 1'11111 iJ 1qroduad tlNl indMMtl in IM SwRI FllUll Rqa<<.
In teferrtnaJ to P...
upla 7:.,
wh4'I ~
t<<:hniqua ~ *rti~e4 eidl6 for miminlllion or sizbfr Jlll1IJOIG, a campla daaiplian of the llJ1Pliation and rauJa i.r indlUIMl in IM SwRI FllUll Rqon.