ML23096A237

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Request to Use a Provision of a Previous Edition of the ASME Boiler and Pressure Vessel Code,Section XI, for Non-Destructive Examinations
ML23096A237
Person / Time
Site: Summer, Surry  Dominion icon.png
Issue date: 04/06/2023
From: James Holloway
Dominion Energy Services, Dominion Energy South Carolina, Dominion Energy Virginia
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
23-013
Download: ML23096A237 (1)
v • d • e


Text

Dominion Energy Services, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 ~ Dominion Dominion Energy.com ~ Energy~

April 6, 2023 10 CFR 50.55a Attn: Document Control Desk Serial No.: 23-013 U.S. Nuclear Regulatory Commission NRA/GDM: R1 Washington, DC 20555-0001 Docket Nos.: 50-280/281 50-395 License No.: DPR-32/37 NPF-12 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION ENERGY VIRGINIA)

DOMINION ENERGY SOUTH CAROLINA, INC. (DESC)

SURRY POWER STATION UNITS 1 AND 2 VIRGIL C. SUMMER NUCLEAR STATION UNIT 1 REQUEST TO USE A PROVISION OF A PREVIOUS EDITION OF THE ASME BOILER AND PRESSURE VESSEL CODE, SECTION XI, FOR NON-DESTRUCTIVE EXAMINATIONS Pursuant to 10 CFR 50.55a(z)(1), Dominion Energy Virginia and DESC (collectively, "Dominion Energy") request approval of a proposed alternative for the performance of non-destructive examinations (NOE) for Surry Power Station (SPS) Units 1 and 2 and V. C. Summer Nuclear Station (VCSNS) Unit 1. SPS and VCSNS are currently in the fifth and fourth inservice inspection (ISi) intervals, respectively. The-sixth 10-year ISi intervals for SPS Units 1 and 2 and the fifth 10-year ISi interval for VCSNS Unit 1 will be based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV)

Code,Section XI, 2019 Edition. The remaining Dominion Energy nuclear fleet plants (i.e., North Anna and Millstone Power Stations) are currently standardized on the 2013 Edition of the ASME BPV Code for the performance of NOE activities. Therefore, to promote fleet commonality, Dominion Energy proposes the use of the 2013 Edition of the ASME Section XI Code for the performance of NOE activities subject to the applicable conditions contained in 10 CFR 50.55a(b)(2) for SPS Units 1 and 2 and VCSNS Unit 1.

The alternative would be applicable to the sixth 10-year ISi intervals for SPS Units 1 and 2 and the fifth 10-year ISi interval for VCSNS Unit 1. The proposed alternative request is provided in the attachment.

The SPS Unit 1 sixth 10-year inservice inspection (ISi) interval begins on October 14, 2023 and ends on October 13, 2033. The SPS Unit 2 sixth 10-year ISi interval begins on May 10, 2024 and ends on May 9, 2034. The VCSNS fifth 10-year ISi interval begins on January 1, 2024 and ends on December 31, 2033. Since the SPS Unit 1 sixth 10-year ISi interval begins on October 14, 2023, Dominion Energy requests approval of the proposed alternative by September 30, 2023.

Serial No.23-013 Docket Nos. 50-280/281/395 NDE Alternative Request Page 2 of 2 Should you have any questions or require additional information, please contact Mr. Gary D. Miller at (804) 273-2771.

Res~ .~

James Holloway Vice President - Nuclear Engineering and Fleet Support Virginia Electric and

Commitments made in this letter: None.

cc: U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, Georgia 30303-1257 Mr. L. John Klos - Surry NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 E-3 11555 Rockville Pike Rockville, Maryland 20852 Mr. G. Edward Miller NRC Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 E-3 11555 Rockville Pike Rockville, Maryland 20852-2738 NRC Senior Resident Inspector Surry Power Station NRC Senior Resident Inspector V. C. Summer Nuclear Station Mr. G. J. Lindamood Santee Cooper - Nuclear Coordinator

Serial No.23-013 Docket Nos. 50-280/281/395 Attachment PROPOSED ALTERNATIVE TO PERMIT APPLICATION OF CERTAIN ASME SECTION XI 2013 EDITION NOE REQUIREMENTS FOR FLEET CONSISTENCY Virginia Electric and Power Company (Dominion Energy Virginia)

Surry Power Station Units 1 and 2 Dominion Energy South Carolina, Inc.

(DESC)

V. C. Summer Nuclear Station Unit 1

Serial No.23-013 Docket Nos. 50-280/281/305 ISi Alternative Request Attachment PROPOSED ALTERNATIVE TO PERMIT APPLICATION OF CERTAIN ASME SECTION XI 2013 EDITION NDE REQUIREMENTS FOR FLEET CONSISTENCY Surry Power Station Units 1 and 2 V. C. Summer Nuclear Station Unit 1 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) -

" Acceptable Level of Quality and Safety"

1. ASME Code Component{s) Affected Code Class Class 1, 2, and 3 ASME Section XI, 2013 Edition and Reference ASME Section XI, 2019 Edition Components Class 1, 2, and 3 Examinations Examination All, as related to NOE Methods and Requirements Cateqories Item Numbers All, as related to NOE Methods and Requirements
2. Applicable Code Edition The sixth 10-year interval of the Surry Power Station (SPS) Units 1 and 2 lnservice Inspection (ISi) Program and the fifth 10-year interval of the Virgil C. Summer Nuclear Station (VCSNS) Unit 1 ISi Program will be based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code,Section XI, 2019 Edition. The remaining Dominion Energy nuclear fleet plants (i.e.,

North Anna and Millstone Power Stations) are currently standardized on the 2013 Edition of the ASME BPV Code for performance of non-destructive examination (NOE) activities.

The SPS Unit 1 sixth 10-year ISi interval begins on October 14, 2023 and ends on October 13, 2033. The SPS Unit 2 sixth 10-year ISi interval begins on May 10, 2024 and ends on May 9, 2034. The VCSNS fifth 10-year ISi interval begins on January 1, 2024 and ends on December 31, 2033.

3. Applicable Code Requirements SPS and VCSNS are requesting approval to use the 2013 Edition of ASME Section XI for NOE activities associated with inservice inspections for the SPS Units 1 and 2 sixth and VCS Unit 1 fifth 10-year ISi intervals.

Page 1 of 15

Serial No.23-013 Docket Nos. 50-280/281/305 ISi Alternative Request Attachment

4. Reason for Request The SPS Unit 1, sixth 10-year ISi interval is currently scheduled to begin on October 14, 2023. The SPS Unit 2, sixth 10-year ISi interval is currently scheduled to begin on May 10, 2024. The VCSNS Unit 1, fifth 10-year ISi interval is currently scheduled to begin on January 1, 2024. At the beginning of these 10-year ISi intervals, the ISi Programs for these plants will update to the 2019 Edition of ASME Section XI as required by 10 CFR 50.55a.

The remaining Dominion Energy nuclear fleet plants currently use a common Code Edition for the implementation of NOE requirements such that ISi related NOE activities across the fleet are performed in accordance with a standardized fleet program. The standardized NOE requirements and procedures are currently based on the 2013 Edition of the ASME Section XI Code. The current NOE program is controlled through common corporate procedures that are implemented across the entire Dominion Energy nuclear fleet.

Due to the difference in interval start dates for SPS and VCSNS as compared to the other Dominion Energy sites, the upcoming 10-year ISi interval updates for SPS and VCSNS would require development and implementation of a separate NOE Program with unique supporting procedures affecting multiple organizations.

Additionally, Dominion Energy would be required to create a unique skill set and training applicable specifically to SPS and VCSNS. This minimizes the ability to share resources across Dominion Energy sites, presents human performance concerns when applying different criteria, and precludes the use of common site and fleet procedures.

Therefore, pursuant to 10 CFR 50.55a(z)(1), Dominion Energy request authorization to utilize the NOE requirements in the 2013 Edition of ASME Section XI for SPS Units 1 and 2 and VCSNS Unit 1 for the SPS Units 1 and 2 sixth 10-year ISi intervals and the VCSNS Unit 1 fifth 10-year ISi interval. The use of the 2013 Edition of the ASME Section XI Code will be limited to the performance of NOE activities and is subject to the applicable conditions contained in 10 CFR 50.55a(b)(2).

5. Proposed Alternative and Basis for Use

The proposed alternative would allow SPS Units 1 and 2 and VCSNS Unit 1 to utilize the 2013 Edition of ASME Section XI for NOE activities related to performing inservice inspections during the sixth 10-year ISi intervals for SPS Units 1 and 2 and the fifth 10-year ISi interval for VCSNS Unit 1. In implementing this proposed alternative, SPS and VCSNS will comply with all applicable NRC conditions and Page 2 of 15

Serial No.23-013 Docket Nos. 50-280/281 /305 ISi Alternative Request Attachment limitations related to the NOE requirements of the 2013 Edition of the ASME Section XI Code specified in 10 CFR 50.55a(b)(2).

Specifically, SPS and VCSNS are requesting the use of the provisions in the 2013 Edition of ASME Section XI for NOE activities associated with inservice inspections. These NOE activities are driven by the ASME Code,Section XI, Subsection IWA, Articles IWA-1000 and IWA-2000, and Mandatory Appendices I, Ill, IV, VI, VII, and VIII as shown in Table 1.

Table 2 provides a summary of the significant differences between the 2013 and 2019 Editions of ASME Section XI that have an impact on NOE activities. This table provides an analysis of these changes and the impact of maintaining the 2013 Edition of ASME Section XI for the application of NOE activities for the specified 10-year ISi intervals. SPS and VCSNS will comply with all related NOE requirements of the 2013 Edition of ASME Section XI as they interface with the Subsection IWA General Requirements of Articles IWA-1000 and IWA-2000, as well as the applicable Mandatory Appendices.

This request will allow SPS and VCSNS NOE requirements to remain standardized with the rest of the Dominion Energy nuclear fleet.

It is important to note that this request does not apply to the balance of the ISi Programs including the selection, planning, and scheduling of ISi examinations and tests as defined in IWB-, IWC-, IWD-, and IWF-2500 or NRC approved ISi alternatives. Therefore, ISi examinations and tests will be selected, planned, and scheduled in accordance with the 2019 Edition of ASME Section XI, which is the Code of Record for the SPS Units 1 and 2 sixth, and VCSNS Unit 1 fifth, 10-year ISi Intervals. Further, this proposed alternative request will have no effect on any prior relief or alternative requests previously approved by the NRC.

Continued application of the 2013 Edition of ASME Section XI specifically for NOE requirements (consistent with the other Dominion Energy nuclear sites) will provide an acceptable level of quality and safety and will enhance the effective management and implementation of the NOE activities. Approval of this request supports Dominion Energy's ability to maximize efficiencies, minimize human performance and procedure error traps, and optimize the use of internal operating experience, as the entire Dominion Energy nuclear fleet will continue to utilize common procedures, processes, training, and knowledge for NOE implementation.

6. Duration of Proposed Alternative

This alternative is requested for the sixth 10-year ISi interval for SPS Units 1 and 2, and for the fifth 10-year ISi interval for VCSNS Unit 1.

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Serial No.23-013 Docket Nos. 50-280/281/305 ISi Alternative Request Attachment

7. Precedents

  • Exelon Generation Company Fleet Letter Request RS-19-089 (JAFP 0084), "Byron Station, Unit Nos. 1 and 2; Dresden Nuclear Power Station, Units 2 and 3; James A Fitzpatrick Nuclear Power Plant; Lasalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; and Quad Cities Nuclear Power Station, Units 1 and 2 - Request to Use Provisions in the 2013 Edition of the ASME Boiler and Pressure Vessel Code for Performing Non-Destructive Examinations (EPID L-2019-LLR-0080)," approved by NRC Safety Evaluation (SE) dated April 17, 2020 (ADAMS Accession No. ML20099D955).
  • Arkansas Nuclear One, Unit 2 (ANO-2), Relief Request ANO2-ISl-021, "Arkansas Nuclear One, Unit 2 - Request for Alternative ANO2-ISl-021 to Permit Continued Application of the 2007 Edition through the 2008 Addenda of the ASME Code (EPID L-2018-LLR-0122)," approved by NRC SE dated June 11, 2019 (ADAMS Accession No. ML19156A400).

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Serial No.23-013 Docket Nos. 50-280/281/305 ISi Alternative Request Attachment Table 1 Proposed Section XI, 2013 Edition Implementation for NDE Activities1* 2* 4 Code Provision Article IWA-1000 Subsection !WA-General Requirements Article IWA-2000 Mandatory Appendices I Ill IV VI VII Vlll 3 Notes:

1. Dominion Energy will use the Articles and Mandatory Appendices of the ASME Code,Section XI, 2013 Edition as shown in this table for NOE related activities.
2. Dominion Energy will comply with all NRC conditions, limitations, and restrictions specified in 10 CFR 50.55a(b)(2) for the applicable ASME Section XI Code Edition referenced.
3. Dominion Energy will implement the 2013 Edition of ASME Section XI, Appendix VIII, or the latest approved edition and addenda as allowed by 10 CFR 50.55a(g)(4)(ii).
4. NOE activities for the Repair Replacement of Class 3 Polyethylene Piping will use the 2019 Edition of Section XI.

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Serial No.23-013 Docket Nos. 50-280/281/305 ISi Alternative Request Attachment Table 2 Significant Changes in Code Editions that Impact NOE Description of Analysis of Paragraph 2013 Edition 2019 Edition Change Change Related to NOE Table Referenced Referenced Table revised in This change has IWA-1600-1 Standards and Standards and its entirety. For no effect. The Specifications Specifications NDE the use of the 1995 reference to edition of CP-ANSI/ASNT CP- 189 provides an 105 the 2006 acceptable edition has been written practice added. The for the edition of CP-189 qualification and has been updated certification of from the 1995 NDE personnel.

edition to the 2006 The 1995 edition edition. of CP-189 contains appropriate training outlines.

The proposed alternative to implement the 2013 Edition, including all applicable 10CFR 50.55a(b)(2) conditions will ensure an acceptable level of quality and safety.

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Serial No.23-013 Docket Nos. 50-280/281/305 ISi Alternative Request Attachment Table 2 Significant Changes in Code Editions that Impact NDE Description of Analysis of Paragraph 2013 Edition 2019 Edition Change Change Related to NOE IWA-2200 EXAMINATION EXAMINATION Subparagraph (d) This change has METHODS METHODS has been added. no impact as this (d) When Section V is the standard is referenced for practice for the examination Dominion Energy methodology, the nuclear fleet Edition and NOE Program.

Addenda of Section The use of the V shall be the same 2013 Edition or as that of Section later Editions of XI. Alternatively, the ASME Articles from later Section V Code Editions and will be Addenda of Section implemented V may be used, through the provided related written NOE requirements of procedures, those Articles are when Section V met. The Section V is referenced for Edition and the examination Addenda shall be methodology.

referenced in the inspection plan or procedure.

IWA-2210 VISUAL VISUAL Subarticle revised This change has EXAMINATION EXAMINATION as shown. no effect as this Visual examination Visual examination change is less shall be conducted shall be conducted restrictive.

in accordance with in accordance with the requirements the requirements of of Section V, Section V, Article 9, Article 9, except except that the that the angle of view illumination shall requirements for be in accordance direct visual only with IWA-2211 and apply to VT-1, and the demonstration the requirements for shall be in illumination, accordance with distance, and Table IWA-2211-1. resolution demonstration shall be in accordance with Table IWA-2211-1.

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Serial No.23-013 Docket Nos. 50-280/281/305 ISi Alternative Request Attachment Table 2 Significant Changes in Code Editions that Impact NOE Description of Paragraph 2013 Edition Analysis of 2019 Edition Change Change Related to NOE IWA-2212 NIA VT-2 Examination Subparagraph (c) This change has (c) As indicated in added. no effect as this Table IWA-2211 -1, change is less there are no restrictive.

illumination, distance, and resolution demonstration requirements for VT-2.

IWA-2310 GENERAL GENERAL Subparagraph (a) The proposed (a) Personnel (a) Personnel revised as shown. alternative to performing performing implement the nondestructive nondestructive 2013 Edition, examinations examinations (NOE) including all (NOE) shall be shall be qualified applicable qualified and and certified using a 10 CFR certified using a written practice 50.55a(b)(2) written practice prepared in conditions will prepared in accordance with ensure an accordance with ANSI/ASNT acceptable level ANSI/ASNT CP-189, Standard of quality and CP 189, Standard for Qualification and safety.

for Qualification Certification of and Certification of Nondestructive Nondestructive Testing Personnel, Testing Personnel, and ANSI/ASNT as amended by the CP-105, Standard requirements of for Topical Outlines this Division . for Qualification of Certifications Nondestructive based on Testing Personnel, SNT-TC-1A, ANSI as amended by the N45.2.6, or earlier requirements of this editions of Division.

ANSI/ASNT Certifications based CP-189 are valid ... on earlier editions of ANSI/ASNT CP-189 are valid ...

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Serial No.23-013 Docket Nos. 50-280/281/305 ISi Alternative Request Attachment Table 2 Significant Changes in Code Editions that Impact NOE Description of Analysis of Paragraph 2013 Ed ition 2019 Edition Change Change Related to NOE IWA-2318 N/A Qualification for New paragraph The proposed Pneumatic IWA-2318 added. alternative to Pressure Test implement the Personnel 2013 Edition, including all applicable 10 CFR 50.55a(b)(2) conditions will ensure an acceptable level of quality and safety.

IWA-2324 N/A Practical New paragraph The proposed Examination IWA-2324 added. alternative to Techniques for implement the CP-189 2013 Edition, including all applicable 10CFR 50.55a(b)(2) conditions will ensure an acceptable level of quality and safety.

Table N/A Practical New The proposed IWA-2324-1 Examination NDE Table IWA-2324-1 alternative to Techniques added. implement the 2013 Edition, including all applicable 10CFR 50.55a(b)(2) conditions will ensure an acceptable level of quality and safety.

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Serial No.23-013 Docket Nos. 50-280/281/305 ISi Alternative Request Attachment Table 2 Significant Changes in Code Editions that Impact NOE Description of Analysis of Paragraph 2013 Edition 2019 Edition Change Change Related to NOE IWA-2350 LIMITED LIMITED Paragraph revised This change has CERTIFICATION CERTIFICATION as shown. no effect.

Limited certification Limited certification in a method is provisions of permitted for ANSI/ASNT CP-189 personnel who are do not apply.

restricted to Limited certification performing in a method is examinations of permitted for limited scope, i.e., personnel who are limited operations restricted to or limited performing techniques within examinations of the method. Topics limited scope, i.e.,

that are not limited operations or relevant to the limited techniques limited certification within the method.

may be deleted Topics that are not from the relevant to the ANSI/ASNT limited certification CP-189, may be deleted from Appendix VI, or the applicable Appendix VI I training outline and training outline and may be may be accompanied ...

accompanied ...

IWA-2360 LEVELi AND LEVEL I AND Subparagraph (c) The proposed LEVEL II LEVEL II TRAINING added. alternative to TRAINING AND AND EXP ERIENCE implement the EXPERIENCE (c) Experience is 2013 Edition, work time in an NDE including all N/A method. Classroom applicable and laboratory 10CFR training time shall 50.55a(b)(2) not be credited as conditions will experience. ensure an acceptable level of quality and safetv.

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Serial No.23-013 Docket Nos. 50-280/281/305 ISi Alternative Request Attachment Table 2 Significant Changes in Code Editions that Impact NOE Description of Analysis of Paragraph 2013 Edition 2019 Edition Change Change Related to NOE Appendix I PIPI NG PIPING Subparagraph This change has 1-3200 (c) Dissimilar metal (c) Dissimilar metal revised as shown . no effect as this welds shall be welds shall be change is less examined in two examined in two restrictive.

axial and two axial and two circumferential circumferential directions. directions. If Procedures and examination from personnel qualified both sides of the solely from the weld is not possible, austenitic side of procedures and the weld may be personnel qualified used to perform for singleside examinations from examination in either side of the accordance with weld. When Mandatory examination from Appendix VIII, both sides is not Supplement 10, possible, shall be used to procedures and examine the personnel qualified required volume.

for singleside examination in accordance with Appendix VIII, Supplement 10, with all flaws on the opposite side of the weld, shall be used to examine the reauired volume.

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Serial No.23-013 Docket Nos. 50-280/281/305 ISi Alternative Request Attachment Table 2 Significant Changes in Code Editions that Impact NDE Description of Analysis of Paragraph 2013 Edition 2019 Ed ition Change Change Related to NDE Appendix Ill GENERAL GENERAL Subparagraph (b) The proposed 111-1100 (b) The (b) The revised as shown. alternative to requirements of requirements of implement the Supplement 1 Supplement 1 apply 2013 Edition, apply to to examination of including all examination of welds in wrought applicable austenitic and austenitic materials 10 CFR dissimilar metal and dissimilar metal 50.55a(b)(2) welds. welds from the conditions will outside surface. The ensure an requirements of acceptable level Supplement 2 apply of quality and to welds in safety.

centrifugally and statically cast austenitic materials examined from the outside surface.

Appendix Ill AUSTENITIC AND AUSTENITIC AND Supplement 1 The proposed Supplement 1 DISSIMILAR DISSIMILAR revised in its alternative to METAL WELDS. METAL WELDS entirety to remove implement the cast materials. 2013 Edition, including all applicable 10CFR 50.55a(b)(2) conditions will ensure an acceptable level of quality and safety.

Appendix Ill NIA WELDS IN CAST Supplement 2 The proposed Supplement 2 AUSTENTIC added to address alternative to MATERIALS welds in cast implement the austenitic 2013 Edition, materials. including all applicable 10CFR 50.55a(b)(2) conditions will ensure an acceptable level of quality and safetv.

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Serial No.23-013 Docket Nos. 50-280/281/305 ISi Alternative Request Attachment Table 2 Significant Changes in Code Editions that Impact NDE Description of Analysis of Paragraph 2013 Edition 2019 Edition Change Change Related to NDE Appendix IV Table IV-3110-1 Table IV-3110-1 Added The proposed Table IV-3110-1 Component Type alternative to "Piping (Inside implement the Surface)" and 2013 Edition, Applicable including all Supplement "4" to applicable the table. 10 CFR 50.55a(b)(2) conditions will ensure an acceptable level of quality and safetv.

Appendix IV 1.0 SPECIMEN 1.0 SPECIMEN Subparagraph This change has Supplement 2 REQUIREMENTS REQUIREMENTS (d)(2) revised as no effect as this (d)(2) The length of (2015 Edition) shown. change is less cracks or notches (d)(2) The length of restrictive.

open to the surface cracks or notches shall not exceed open to the surface the allowable shall be either (a) length specified in 1/16 in. (1.5 mm) or IWB-3514 and less, or (b) less than IWC-3514 for or equal to the inservice surface allowable length flaws for piping or specified in Table IWB-3510-3 IWB-35 14 and and IWC-3514 for Table IWC-3510-3 inservice surface for vessels. flaws for piping or Tables IWB-3510-3 and IWC-3510-3 for vessels Page 13 of 15

Serial No.23-013 Docket Nos. 50-280/281/305 ISi Alternative Request Attachment Table 2 Significant Changes in Code Editions that Impact NDE Description of Analysis of Paragraph 2013 Edition 2019 Edition Change Change Related to NOE Appendix IV 1.0 SPECIMEN 1.0 SPECIMEN Subparagraphs The proposed Supplement 2 REQUIREMENTS REQUIREMENTS (d)(2), (d)(2) (-a), alternative to (2015 Edition) (d)(2) The length of and (d)(2) (-b) implement the (d)(2) The length of cracks or notches revised as shown. 2013 Edition, cracks or notches open to the surface including all open to the surface shall (-a) not exceed applicable shall be either (a) 1/16 in. (1.5 mm) for 10CFR 1/16 in. (1.5 mm) any austenitic 50.55a(b)(2) or less, or stainless steels, or conditions will (b) less than or nickel alloys UNS ensure an equal to the N06600, N06082, acceptable level allowable length W86182, W86152, of quality and specified in and N06054. safety.

IWB-3514 and (-b) for ferritic IWC-3514 for material be less inservice surface than or equal to the flaws for piping or allowable length Tables IWB-35 10-3 specified in and IWC-3510-3 IWB-3514 and for vessels IWC-3514 for inservice surface flaws for piping or Tables IWB-3510-3 and IWC-3510-3 for vessels.

Appendix IV NIA QUALIFICATION New Supplement The proposed Supplement 4 REQUIREMENTS 4 added. alternative to FOR implement the COMPLEMENTARY 2013 Edition, EDDY CURRENT including all EXAMINATION OF applicable INSIDE SURFACES 10CFR OF PIPING 50.55a(b)(2) conditions will ensure an acceptable level of quality and safetv.

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Serial No.23-013 Docket Nos. 50-280/281/305 ISi Alternative Request Attachment Table 2 Significant Changes in Code Editions that Impact NDE Description of Analysis of Paragraph 2013 Edition 2019 Edition Change Change Related to NDE Appendix VIII Performance Performance NIA The proposed Demonstration Demonstration For alternative to For Ultrasonic Ultrasonic implement the Examination Exam ination 2013 Edition, Systems Systems including all applicable 10 CFR 50.55a(b)(2) conditions will ensure an acceptable level of quality and safety.

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