NLS2004009, Inservice Inspection Relief Requests PR-03, RC-06, RC-07, R1-17, R1-31, R1-32, and R1-33

Inservice Inspection Relief Requests PR-03, RC-06, RC-07, R1-17, R1-31, R1-32, and R1-33

ML040490589
Person / Time
Site:	Cooper
Issue date:	02/12/2004
From:	Edington R Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NLS2004009
Download: ML040490589 (38)

Text

, Z Nebraska Public Power District Always there when you need us I OCFR50.55a NLS2004009 February 12, 2004 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

Inservice Inspection Relief Requests PR-03, RC-06, RC-07, RI-17, RI-31, RI-32 and RI-33 Cooper Nuclear Station, NRC Docket 50-298, DPR-46 The purpose of this letter is to request that the Nuclear Regulatory Commission (NRC) grant the Nebraska Public Power District (NPPD) relief from certain Inservice Inspection (ISI) code requirements for the Cooper Nuclear Station pursuant to IOCFR50.55a.

Relief requests PR-03, Rl-17, RI-31, RI-32 and RI-33 are applicable to the third ten-year ISI interval, which ends February 28, 2006. Relief requests RC-06 and RC-07 are applicable to the first ten-year interval of the Containment Inspection Program, which ends April 8, 2007. Attachment I provides a summary listing of the relief requests NPPD is submitting to address examination techniques. Attachment 2 contains the individual ISI relief requests.

NPPD expects to submit an additional relief request to address the Risk Informed ISI Program in the near future.

NPPD requests NRC approval of these relief requests by October 15, 2004. Approval of the relief requests, where noted in Attachment 1, is needed by that date to accommodate performance of inspections during the Cycle 22 Refueling Outage scheduled to begin in January 2005.

If you should have any questions concerning this matter, please contact Paul V. Fleming at (402) 825-2774.

Sincerely, Randall K. Edington Vice President - Nuclear and Chief Nuclear Officer

/rar Attachments COOPERNUCLEARSTATION P.O. Box 98/ Brownville, NE 68321-0098 Jc74-7 Telephone: (402) 825-3811 / F3x: (402) 825-5211 www.nppd.com

NLS2004009 Page 2 of 2 cc: Regional Administrator w/attachments USNRC - Region IV Senior Project Manager vv/attachments USNRC - NRR Project Directorate IV-I Senior Resident Inspector xv/attachments USNRC NPG Distribution w/o attachments CNS Records w/attachments

NLS2004009 Attachment I Page 1 of I Listing of Inservice Inspection (ISI) Relief Requests Cooper Nuclear Station Nebraska Public Power District Relief Subject / Description Approval Attachment 2 Request No. Needed by RE22 Page Numbers PR-03 Eliminate the removal of bolting, VT-3 visual examination for corrosion, No 1-2 and IWA-3 100 evaluation, on leaking bolted connections.

RC-06 Perform a VT-I or VT-3 visual examination in lieu of a VT-2 visual Yes 3-4 examination following a repair or replacement.

RC-07 In lieu of using the acceptance criteria provided in IWE-3515.1, use the No 5-6 acceptance criteria in Subarticle IWB-3517.1 RI-17 Eliminate disassembling pipe clamp or restraint to examine welded Yes 7-8 attachments. Examine to maximum extent possible in accordance with applicable Code requirements.

RI-31 Austenitic welds that are not accessible from both sides for Yes 9-11 inspection will be inspected from the one side that is accessible.

RI-32 Cooper Nuclear Station will use a depth sizing requirement of 0.15 inch Yes 12-13 Root Mean Square as an acceptance criteria in lieu of the requirement in Subparagraph 3.2(c) of Supplement 4 of Appendix VIII.

RI-33 Alternatives are proposed to the qualification requirements for Yes 14-34 dissimilar metal piping welds of ASME Section Xl, 1995 Edition, 1996 Addenda, Appendix VIII, Supplement 10.

NLS2004009 Page I of 34 RELIEF REQUEST NUMBER: PR-03, REVISION 2 COMPONENT IDENTIFICATION Code Classes: 1, 2, and 3

References:

IWA-5250 Examination Categories: B-P, C-H, and D-A Item Numbers: B15.10 through B15.71, C7.10 through C7.80, and DIl 0

==

Description:==

Alternate corrective measures for bolted connections.

Component Numbers: All Class 1, 2, and Class 3 pressure retaining components subject to system pressure testing.

APPLICABLE CODE EDITION AND ADDENDA 1989 Edition, No Addenda CODE REQUIREMENT IWA-5250(a)(2) requires, if leakage occurs at a bolted connection, that the bolting be removed, examined by VT-3 visual examination for corrosion, and evaluated in accordance with WA-3100.

BASIS FOR RELIEF In the event of a bolted connection leak detected during the conduct of a system pressure test, current ASME Section XI requirements specify that all bolting must be removed for the purpose of a VT-3 visual examination and evaluation. This requires removing the component or piping system from service, which could result in a plant shutdown, a delay of plant startup or, for continued operation, a reduction in plant safety.

Nebraska Public Power District's (NPPD) proposed alternative to requirements of the 1989 Edition of the Code was approved by the Nuclear Regulatory Commission (NRC). Specifically, NPPD would evaluate the bolting to determine its susceptibility to corrosion, perform a more in-depth evaluation as applicable and remove the bolt closest to the source of leakage and evaluate the bolt in accordance with IWNA-3 100(a).

Since the granting of the above relief, the Section XI Code requirements have changed, making clear the purpose of the examination is to detect degradation of bolting due to leakage from borated systems. The ASME Code Section XI, 1998 Edition, 1999 Addenda, revised Subsubarticle IWA-5250 (a)(2) as follows:

"If leakage occuts at a bolted connection in a system boratedforthe pupose ofcontrolling reactivity one ofthe bolts shall be removed JVT-3 examined, and evluated in accordancewith IWA-3100. Tle bolt selected shall be one closest to the source of leakage. flen the removed

NLS2004009 Page 2 of 34 RELIEF REQUEST NUMBER: PR-03, REVISION 2 (Continued) bolt has evidence of degradation,all remainingbolts in te connection shall be removed, VT-3 examined, and evaluated in accordancewith IVA-3100."

Under the revised subsubarticle, this examination is applicable to code piping of borated water systems. Cooper Nuclear Station (CNS) is a boiling water reactor and does not use borated water to control reactivity during normal plant operation. This examination requirement would not be necessary under the 1999 Addenda.

Moreover, CNS experience with bolted connections has not identified any such failures directly attributed to corrosion of the bolting. The majority of leakage identified during testing is from packing leaks but a small percentage is attributed to flange connections and other pressure retaining bolted connections. Usually this leakage is arrested as the plant heats up or other corrective measures are performed to stop the leakage. In those cases where leakage is not arrested based on the above actions, an evaluation is performed and, when necessary, corrective measures are taken.

Compliance with the requirement to remove bolting to perform a VT-3 examination when corrosion is not a factor could unnecessarily subject CNS personnel to additional exposure and the plant to additional outage time. Removal and examination of bolting can also result in a system or portion of a system being placed in an inoperable or degraded condition. In summary, performing Code Requirement would constitute a higher level of risk, unnecessary personnel exposure, and a hardship on the plant without a compensating increase in the level of quality and safety.

Relief is requested in accordance with I OCFR50.55a(a)(3)(ii).

PROPOSED ALTERNATE PROVISIONS In lieu of the requirements contained in Relief Request PR-03, Revision 1, NPPD vill quantify and evaluate bolted connection leakage in accordance with site procedures and provide necessary corrective action. This corrective action may involve rework of the connection.

APPLICABLE TIME PERIOD Relief is requested for the third ten-year interval of the ISI Program for CNS, which ends on February 28, 2006.

PR-03, Revision I was approved by the NRC on October 23, 1997 (TAC No. M94000).

A NLS2004009 Attachment 2 Page 3 of 34 RELIEF REQUEST NUMBER: RC-06, REVISION I COMPONENT IDENTIFICATION Code Class: MC

Reference:

IWE-5240 Examination Category: E-P Item

Description:

VT-2 Visual Examination Component Numbers: All APPLICABLE CODE EDITION AND ADDENDA 1992 Edition, 1992 Addenda CODE REQUIREMENT IWE-5240 states that the requirements of IWA-5240 are applicable following repair, replacement, or modification. IWA-5240 requires a VT-2 visual examination in conjunction with the pressure test.

BASIS FOR RELIEF Subsubarticle IWE-52 10 states that except as noted in Subsubarticle IWE -5240, the requirements of Article IWA-5000 are not applicable to Class MC or Class CC components.

Subsubarticle IWE-5240 states that the requirements of Paragraph IWA-5246 (corrected to IWA-5240 in the 1993 Addenda) for visual examinations are applicable. Subsubarticle IWA-5240 identifies requirements for the performance of a VT-2 visual examination. VT-2 visual examinations are conducted to detect evidence of leakage from pressure-retaining components with or without leakage collection systems, during the conduct of a system pressure test. In addition, personnel performing VT-2 visual examination are required to be qualified in accordance with Subarticle IWA-2300 of ASME Section XI.

Table IWE-2500-1, Examination Category E-P, Item E9.10, identifies the examination method of I OCFR50 Appendix J and does not identify a VT-2 visual examination. I CFR5O, Appendix J provides requirements for testing, as well as acceptable leakage criteria. These tests are performed by qualified Appendix J test personnel using calibrated equipment to determine leak rate acceptability.

The 1998 Edition of Section XI, Subsubarticle IWE-5240, requires a detailed visual examination (IWE-23 10) be performed on areas affected by repair/replacement activities. The requirement was amended by I OCFR50.55a (b)(2)(ix)(F) to require a VT- I or VT-3 examination.

NLS2004009 Page 4 of 34 RELIEF REQUEST NUMBER: RC-06, REVISION 1 (Continued)

Repairs and replacements, including modification, to the containment pressure-retaining boundary and to integral attachments, must be performed in accordance with Article IWA-4000.

This article requires, among other things, preparation of a repair and replacement plan; requires repairs and installation of replacement, including performance of nondestructive examinations, to be performed in accordance with the original edition of the Construction Code or Section XI; and requires performance of preservice inspection in accordance with Subsection IWE. The program specifies the repair methods and nondestructive examinations necessary to ensure that the original quality and construction requirements of the containment vessel are met.

Performance of the Appendix J testing will detect leakage that may exist in the containment pressure-retaining boundary. In accordance with the requirements of the 1998 Edition of Section XI, Subsubarticle IWE-5240, performance of a VT-I or VT-3 examination (instead or a VT-2 examination) and compliance with Article IWA-4000 will provide assurance of the structural integrity of the containment pressure-retaining boundary.

Relief is requested in accordance with IOCFR50.55a(a)(3)(i).

ALTERNATIVE EXAMINATIONS In lieu of performing a VT-2 examination for repair or replacement, a VT-I or VT-3 examination, as appropriate, will be performed.

APPLICABLE TIME PERIOD Relief is requested for the first ten-year interval of the Containment Inspection Program at CNS, which ends on April 8, 2007.

PRECEDENT A similar relief request to perform a VT-I examination in lieu of performing a VT-2 examination was approved for Sequoyah, Units I and 2 (TAC NOS. MA5912 and MA5915) on February 3, 2000.

NLS2004009 Page 5 of 34 RELIEF REQUEST NUMBER: RC-07, REVISION 0 COMPONENT IDENTIFICATION Code Class: MC

Reference:

]WE-3515.1 Examination Category: E-G Item

Description:

Bolted Connections Component Numbers: All APPLICABLE CODE EDITION AND ADDENDA 1992 Edition, 1992 Addenda.

CODE REQUIREMENT IWE-3515.1 requires that "bolting material shall be examined in accordance with the material specification for defects which may cause the bolted connection to violate either the leak-tight or structural integrity. Defective items shall be replaced."

BASIS FOR RELIEF Bolting material specifications provide requirements relative to the base material properties and related fabrication discontinuities. Material specification requirements are generally associated with the chemical composition, mechanical strength, test specimens and dimensional requirements. These qualities provide little or no guidance for the examination of the bolted connection for service-induced degradation. For inservice bolting, examination guidelines and acceptance criteria must be specific to discontinuities which are relevant to continued service.

In lieu of using the acceptance criteria provided in IWE-35 15.1, NPPD proposes to use the acceptance criteria for Class I pressure retaining bolting. Subparagraph WB-3517.1, "Standards for Examination Category B-G-1, Pressure Retaining Bolting Greater Than 2 in. in Diameter, and Examination Category B-G-2, Pressure Retaining Bolting 2 in. and Less in Diameter."

"The following relevant conditions shall require correction to meet the requirements of IWB-3122 prior to service or IWB-3142 prior to continued service; a) crack-like flaws that exceed the allowable liner flaw standards of IWB-3515.5; b) more than one deformed or sheared thread in zone of thread engagement of bolts, studs or nuts; c) localized general corrosion that reduces the bolt or stud cross-sectional area by more than 5%;

NLS2004009 Page 6 of 34 RELIEF REQUEST NUMBER: RC-07, REVISION 0 (Continued) d) bending, twisting, or deformation of bolts or studs to the extent that assembly or disassembly is impaired; e) missing or loose bolts, studs, nuts, or washers; f) fractured bolts, studs, or nuts; g) degradation of protective coatings on bolting surfaces; or h) evidence of coolant leakage near bolting."

Relief is requested in accordance with I OCFR50.55a(a)(3)(i).

ALTERNATIVE EXAMINATIONS Bolting material will be examined in accordance with the inservice standards of the 1992 Edition, with 1992 Addenda of ASME Section XI, Subparagraph IWB-3517.1 APPLICABLE TIM1IE PERIOD Relief is requested for the first ten-year interval of the Containment Inspection Program at CNS, which ends on April 8. 2007.

PRECEDENT Relief from examining bolting materials in accordance with the material specification in accordance with IWE-3515.1 was approved for Brunswick, Units I and 2 (TAC NOS. MA4166 and MA4167) on August 10, 1999.

NLS2004009 Page 7 of 34 RELIEF REQUEST NUMBER: RI-17, REVISION 2 COMPONENT IDENTIFICATION Code Class: I and 2

References:

Code Case 509 ASME Section XI, 1995 Edition, 1995 Addenda Examination Category: B-K, C-C, and D-A Item Numbers: B 10.10, B 10.20, B 10.30, B 10.40, C3.10, C3.20, C3.30, C3.40, DI.10, D1.20, D1.30 and D1.40

==

Description:==

Integrally Welded Attachments Component Numbers: Various APPLICABLE CODE EDITION AND ADDENDA 1989 Edition, No Addenda CODE REQUIREMENT Code Case N-509 states that Class I integrally welded attachments shall be examined and tested as specified in ASME Section XI, Table WB-2500-1, Examination Category B-K.

Code Case N-509, Table 2500-1, Examination Category B-K, requires a surface examination for a 10% sample of welded attachments.

Code Case N-509 states that Class 2 integrally welded attachments shall be examined and tested as specified in ASME Section XI, Table 2500-1, Examination Category C-C.

Code Case N-509, Table 2500- 1, Examination Category C-C, requires a surface examination for a 0% sample of welded attachments.

Code Case N-509 states that Class 3 integrally welded attachments shall be examined and tested as specified in ASME Section XI, Table 2500-1, Examination Category D-A.

Code Case N-509, Table 2500-l, Examination Category D-A, requires a visual VT-I examination fro a 10% sample of welded attachments.

BASIS FOR RELIEF In Revision 0 of Relief Request Rl-17 NPPD requested relief from removing piping clamps to achieve the required 100% examination coverage for integrally welded attachments (shear lugs).

The NRC staff concluded that the proposed alternative, in conjunction with the reduction in number of integrally welded attachments examinations allowed by Code Case N-509, did not provide an acceptable level of quality and safety. The relief request was denied. In Relief

A NLS2004009 Attachment 2 Page 8 of 34 RELIEF REQUEST NUMBER: RI-17, REVISION 2 (Continued)

Request RI- 17, Revision 1, NPPD requested relief from removing pipe clamps to achieve required examination coverage for four (4) integrally welded attachments. This relief request was granted with the condition that an additional integrally welded attachment be examined.

Revision I of RI-17 was submitted on April 23, 1998 and approved by the NRC on March 1, 1999. At that time IOCFR50.55(a) referenced ASME Section Xl, Division 1, and included addenda through the 1988 Addenda and editions through the 1989 Edition for Class 1, 2 and 3 components. The 1989 Edition did not contain any provisions to allow examination of integrally welded attachments without removing component support members. In the 1995 Edition, 1995 Addenda, Figures IWB-2500-15, WC-2500-5 and IWD-2500-1 for welded attachments were modified to add the following note: "Examination of surface areas may be limited to the portions of these areas that are accessible without removal of support members". The 1995 Edition through the 1996 Addenda of ASME Section Xl was approved for use in OCFR50.55a(b)(2) on November 22, 1999 (after relief was granted for RI-17, Revision 1). The 1995 Edition, 1995 Addenda of ASME Section XI incorporates the examination percentages as given in Code Case N-509. These provisions incorporated in the 1995 Edition, 1995 Addenda have remained in the code through the 2001 Edition, 2003 Addenda. Therefore, NPPD requests approval to use the 1995 Edition, 1996 Addenda of ASME Section XI for the examination of welded attachments.

The acceptance criteria of the 1995 Edition, 1996 Addenda of Section XI will also be used since it is a related requirement.

Approval is requested under I OCFR50.55a(g)(4)(iv) to use ASME Section XI, 1995 Edition, 1996 Addenda, for the examination and acceptance of Class I, Class 2 and Class 3 welded attachments.

PROPOSED ALTERNATIVE POSITIONS NPPD will use ASME Section Xl, 1995 Edition, 1996 Addenda, for the examination and acceptance of Class I, Class 2 and Class 3 welded attachments.

APPLICABLE TIME PERIOD Relief is requested for the third ten-year interval of the Inservice Inspection Program for CNS, which ends on February 28, 2006.

RI-1 7, Revision 0 was denied by the NRC on October 23, 1997 (TAC No. M94000).

RI-17, Revision I was approved by the NRC on March 11, 1999 (TAC No. MA2138)

4 NLS2004009 Attachment 2 Page 9 of 34 RELIEF REQUEST NUMBER: RI-31 COMPONENT IDENTIFICATION Code Class: I

Reference:

IWB-2500-1 Examination Category: B-F, B-J Item

Description:

Single Side Volumetric Examination Component Numbers: See Table RI-3 1 APPLICABLE CODE EDITION AND ADDENDA 1995 Edition, 1996 Addenda CODE REQUIREMENT I OCFR50.55a (b)(2)(xv)(A), requires, in part, the following examination coverage when applying Supplement 2 to ASME Section XI, Appendix VIII:

1. Piping must be examined in two axial directions and when examination in the circumferential direction is required, the circumferential examination must be performed in two directions, provided access is available.

2. Where examination from both sides is not possible, full coverage credit may be claimed for a single side for ferritic welds. Where examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single sided Appendix VIII demonstration using a flaw on the opposite side of the weld.

3. I OCFR50.55a(b)(2)(xvi)(B) requires that examinations performed from one side of a ferritic or stainless steel pipe weld must be conducted with equipment, procedures, and personnel that have demonstrated proficiency with single side examinations. To demonstrate equivalency to two sided examinations, the demonstration must be performed to the requirements of Appendix VIII as modified by this paragraph and 50.55a(b)(2)(xv)(A).

BASIS FOR RELIEF IOCFR50.55a(b)(2)(xvi)(A) requires that if access is available, the weld shall be scanned in each of the four directions (parallel and perpendicular to the weld) where required. Coverage credit may be taken for single side exams on ferritic piping. However, for austenitic piping, a procedure must be qualified with a flaw on the inaccessible side of the weld. There are currently no qualified single side examination procedures that demonstrate equivalency to two-sided examination procedures on austenitic piping welds. Current technology is not capable of reliably

NLS2004009 Page 10 of 34 RELIEF REQUEST NUMBER: RI-31 (Continued) detecting or sizing flaws on the far side of an austenitic weld for configurations common to domestic commercial nuclear application.

The Electric Power Research Institute Performance Demonstration Initiative (PDI) Program conforms with the rule regarding single side access for piping. PDI Performance Demonstration Qualification Summary (PDQS) certificates for austenitic piping list the limitation that single side examination is performed on a best effort basis. The best effort qualification is provided in place of a complete single side qualification to demonstrate that the examiner qualification and the subsequent weld examination is based on application of the best available technology.

When the examination area is limited to one side of an austenitic weld, examination coverage does not comply with IOCFR50.55a(b)(2)(xv)(A) and proficiency demonstration does not comply with I OCFR50.55a(b)(2)(xvi)(A) full coverage credit may not be claimed.

Pursuant to I OCFR50.55a(g)(6)(i), relief is requested from the examination coverage and qualification demonstration requirements for austenitic piping welds with single sided access based on the requirements being impractical. A list of the affected welds is provided in Table RI-31-1.

ALTERNATIVE EXAMINATIONS The best available techniques, as qualified through the PDI for Supplement 2 with demonstrated best effort for single side examination, will be used from the accessible side of the weld.

APPLICABLE TIME PERIOD Relief is requested for the third ISI ten-year interval at CNS, which ends February 28, 2006.

NLS2004009 Page I I of 34 RELIEF REQUEST NUMBER: RI-31 (continued)

TABLE RI-31-1 ESTIMATED UT EXAMINATION COVERAGE

'WELD ID CONFIGURATION SIZE ISO SYSTEM A PERIOD CERCENT RAS-BJ-9 Tee to Elbow 20 CNS-RR-37 RR 1 50 RAS-BJ-5 P90 to Valve* 28 CNS-RR-37 RR N/A 50 RAS-13J-6 Valve to Pipe 28 CNS-RR-37 RR N/A 50 RAS-13J-8 Elbow to Pump 28 CNS-RR-37 RR N/A 50 RAD-BJ-1 Pump to Pipe 28 CNS-RR-37 RR 3 50 RAD-BJ-2 Pipe to Valve 28 CNS-RR-37 RR 3 50 RAD-BJ-3 Valve to Pipe 90* 28 CNS-RR-37 RR 3 50 RAD-BJ-6 Tee to Pipe 24 CNS-RR-37 RR 3 50 RAH-BJ-I Cross to Header 22 CNS-RR-37 RR N/A 50 RAH-BJ-2 Cross to Header 22 CNS-RR-37 RR N/A 50 RRG-BJ-3 Header to Pipe 12 CNS-RR-37 RR N/A 50 RRK-BJ-3 Header to Pipe 12 CNS-RR-37 RR N/A 50 RBS-BJ-5 P90 to Valve* 28 CNS-RR-38 RR N/A 50 RBS-BJ-6 Valve to Pipe 28 CNS-RR-38 RR N/A 50 RBS-BJ-8 Elbow to Pump 28 CNS-RR-38 RR N/A 50 RBD-BJ-1 Pump to Pipe 28 CNS-RR-38 RR N/A 50 RBD-BJ-2 Pipe to Valve 28 CNS-RR-38 RR N/A 50 RBD-BJ-3 Valve to Pipe 28 CNS-RR-38 RR N/A 50 RBD-BJ-6 Tee to Pipe 24 CNS-RR-38 RR 2 50 RBH-BJ-I Cross to Header 22 CNS-RR-38 RR N/A 50 RBH-BJ-2 Cross to Header 22 CNS-RR-38 RR N/A 50 RRB-BJ-3 Header to Pipe 12 CNS-RR-38 RR N/A 50 RRD-BJ-3 Header to Pipe 12 CNS-RR-38 RR N/A 50 CSA-BJ-14 Valve to Pipe 6 2502-1 CS N/A 50 CSB-BJ-13 Valve to Pipe 6 2502-1 CS N/A 50 CWA-BJ-4 P90 to Valve* 6 2503-1 RWCU 3 50 CNVA-BJ-5 Valve to P90* 6 2503-1 RWCU 3 50 CWA-BJ-17 P90 to Valve* 6 2503-1 RWCU N/A 50 CWA-BJ-18 Valve to Pipe 6 2503-1 RWCU N/A 50 CWA-BJ-16 Pipe to Valve 6 2503-1 RWCU N/A 50

• - "P90" indicates a section of piping bent during fabrication

NLS2004009 Page 12 of 34 RELIEF REQUEST NUMBER: RI-32 COMPONENT IDENTIFICATION Code Class: I

Reference:

ASME Section XI, Appendix VIII Examination Category: B-F Item Numbers: B5. 0

==

Description:==

Appendix VIII, Supplement 4 Component Numbers: All APPLICABLE CODE EDITION AND ADDENDA 1989 Edition, No Addenda and 1995 Edition, 1996 Addenda CODE REQUIREMENT Appendix VIII, Supplement 4, Subparagraph 3.2(c), requires that performance demonstration results when plotted on a two-dimensional plot with the depth estimated by ultrasonics plotted along the ordinate and the true depth plotted along the abscissa, satisfy the following statistical parameter:

1. the slope of the linear regression line is not less than 0.7;

2. the mean deviation of flaw depth is less than 0.25 in.;

3. correlation coefficient is not less than 0.70.

BASIS FOR RELIEF The linear regression line (Subparagraph 3.2(c)(1)) is the difference between measured and true value plotted along a through-wall thickness. For Supplement 4 performance demonstration, a linear regression line of the data is not applicable because the performance demonstrations are performed on test specimens with flaws located in the inner 15 percent of wall thickness. The differences between measured versus true value produce a tight grouping of results which resemble a shotgun pattern. The slope of a regression line from such data is extremely sensitive to small variations, thus making the parameter of Subparagraph 3.2(c)(1) a poor and inappropriate acceptance criteria. The second parameter, 3.2(c)2, pertains to the mean deviation of the flaw depth. The value used in the Code is too lax with respect to evaluating flaw depths within the inner 15 percent of wall thickness. Therefore, the Electric Power Research Institute Performance Demonstration Initiative Program proposes to use the more appropriate criterion of 0.15 inch Root Mean Square (RMS) of IOCFR50.55a(b)(2)(xv)(C)(I), which modifies Subparagraph 3.2(a), as the acceptance criterion. The third parameter, 3.2(c)(3), pertains to a correlation coefficient. The value of the correlation coefficient in Subparagraph 3.2(c)(3) is

NLS2004009 Page 13 of 34 RELIEF REQUEST NUMBER: RI-32 (Continued) inappropriate for this application since it is based on the linear regression from Subparagraph 3.2(c)(1).

Relief is requested in accordance with I OCFR50.55a(a)(3)(i).

ALTERNATIVE EXAMINATIONS NPPD will use 0.15 inch RMS as an acceptance criteria rather than Subparagraph 3.2(c) of Supplement 4 of Appendix VIII.

APPLICABLE TIME PERIOD Relief is requested for the third ten-year ISI interval at CNS, which ends on February 28, 2006.

PRECEDENT A similar relief request was approved for Salem and Hope Creek, Units I and 2 (TAC NOS.

MB1399, MB1400 and MB1401) on March 26, 2001.

NLS2004009 Page 14 of 34 RELIEF REQUEST NUMBER: RI-33 COMPONENT IDENTIFICATION Code Class: I

Reference:

ASME Section XI, Appendix VIII Examination Category: B-F Item Number: B5.10

==

Description:==

Appendix VIII, Supplement 10 Component Numbers: All APPLICABLE CODE EDITION AND ADDENDA 1989 Edition, No Addenda and 1995 Edition, 1996 Addenda CODE REQUIREMENT The following paragraphs or statements are from ASME Section XI, Appendix VIII, Supplement 10 and identify the specific requirements that are included in this request for relief.

Item I - Paragraph 1. (b) states in part - Pipe diameters within a range of 0.9 to 1.5 times a nominal diameter shall be considered equivalent.

Item 2 - Paragraph l. (d) states - All flaws in the specimen set shall be cracks.

Item 3 - Paragraph . l (d)(I) states - At least 50% of the cracks shall be in austenitic material. At least 50% of the cracks in austenitic material shall be contained wholly in weld or buttering material. At least 10% of the cracks shall be in ferritic material. The remainder of the cracks may be in either austenitic or ferritic material.

Item 4 - Paragraph 1.2(b) states in part - The number of unflawed grading units shall be at least twice the number of flawed grading units.

Item 5 - Paragraph 1.2(c)(1) and 1.3(c) state in part - At least 1/3 of the flaws, rounded to the next higher whole number, shall have depths between 10% and 30% of the nominal pipe wall thickness. Paragraph 1.4(b) distribution table requires 20% of the flaws to have depths between 10% and 30%.

Item 6 - Paragraph 2.0 first sentence states - The specimen inside surface and identification shall be concealed from the candidate.

Item 7 - Paragraph 2.2(b) states in part - The regions containing a flaw to be sized shall be identified to the candidate.

- , f .

NLS2004009 Attachment 2 Page 15 of 34 RELIEF REQUEST NUMBER: RI-33 (Continued)

Item 8 - Paragraph 2.2(c) states in part - For a separate length sizing test, the regions of each specimen containing a flaw to be sized shall be identified to the candidate.

Item 9 - Paragraph 2.3(a) states - For the depth sizing test, 80% of the flaws shall be sized at a specific location on the surface of the specimen identified to the candidate.

Item 10 - Paragraph 2.3(b) states - For the remaining flaws, the regions of each specimen containing a flaw to be sized shall be identified to the candidate. The candidate shall determine the maximum depth of the flaw in each region.

Item I I - Table VIII-S2-1 provides the false call criteria when the number of unflawed grading units is at least twice the number of flawed grading units.

BASIS FOR RELIEF Item I - Proposed alternative to Paragraph 1.1(b):

The specimen set shall include the minimum and maximum pipe diameters and thicknesses for which the examination procedure is applicable. Pipe diameters within 1/2 in. (13 mm) of the nominal diameter shall be considered equivalent. Pipe diameters larger than 24 in. (610 mm) shall be considered to be flat. When a range of thicknesses is to be examined, a thickness tolerance of +25% is acceptable.

Technical Basis - The change in the minimum pipe diameter tolerance from 0.9 times the diameter to within 1/2 inch of the nominal diameter provides tolerances more in line with industry practice. Though the alternative is less stringent for small pipe diameters they typically have a thinner wall thickness than larger diameter piping. A thinner wall thickness results in shorter sound path distances that reduce the detrimental effects of the curvature. This change maintains consistency between Supplement 10 and the recent revision to Supplement 2.

Item 2 - Proposed alternative to Paragraph 1.1(d):

At least 60% of the flaws shall be cracks, the remainder shall be alternative flaws. Specimens with Intergranular Stress Corrosion Cracking (IGSCC) shall be used when available. Alternative flaws, shall meet the following requirements:

(I) Alternative flaws, if used, shall provide crack-like reflective characteristics and shall only be used when implantation of cracks would produce spurious reflectors that are uncharacteristic of service-induced flaws.

(2) Alternative flaw mechanisms shall have a tip width no more than 0.002 in. (.05 mm).

T rI NLS2004009 Attachment 2 Page 16 of 34 RELIEF REQUEST NUMBER: RI-33 (Continued)

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

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

IE1atsion Mechanical fatigue crack in Base material Item 3 - Proposed alternative to Paragraph .l(d)(l):

At least 80% of the flaws shall be contained wholly in weld or buttering material. At least one and no more than 10% of the flaws shall be in ferritic base material. At least one and no more than 10% of the flaws shall be in austenitic base material.

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

Item 4 - Proposed alternative to Paragraph 1.2(b):

Personnel performance demonstration detection test sets shall be selected from Table VIII-S 10-1.

The number of unflawed grading units shall be at least 1-1/2 times the number of flawed grading units.

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

NLS2004009 Page 17 of 34 RELIEF REQUEST NUMBER: RI-33 (Continued) and less skilled personnel being unsuccessful. The acceptance criteria for the statistical basis are in Table VIII-S10-1.

Item 5 - The proposed alternative to the flaw distribution requirements of Paragraph .2(c)(1)

(detection) and 1.3(c) (length) is to use the Paragraph 1.4(b) (depth) distribution table (see below) for all qualifications.

Flaw Depth Minimum

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

31-60% 20%

61-100% 20%

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

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

Item 6 - Proposed alternative to Paragraph 2.0 first sentence:

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

Technical Basis - The current Code requires that the inside surface be concealed from the candidate. This makes qualifications conducted from the inside of the pipe (e.g., PWR nozzle to safe end welds) impractical. The proposed alternative differentiates between ID and OD scanning surfaces, requires that they be conducted separately, and requires that flaws be concealed from the candidate. This is consistent with the recent revision to Supplement 2.

Items 7 and 8 - Proposed alternatives to Paragraph 2.2(b) and 2.2(c):

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

Technical Basis - The current Code requires that the regions of each specimen containing a flaw to be length sized shall be identified to the candidate. The candidate shall determine the length of the flaw in each region (Note, that length and depth sizing use the term "regions" while detection uses the term "grading units" - the two terms define different concepts and are not intended to be equal or interchangeable). To ensure security of the samples, the proposed alternative modifies

'SI NLS2004009 Attachment 2 Page 18 of 34 RELIEF REQUEST NUMBER: RI-33 (Continued) the first "shall" to a "may" to allow the test administrator the option of not identifying specifically where a flaw is located. This is consistent with the recent revision to Supplement 2.

Items 9 and 10 - Proposed alternative to Paragraph 2.3(a) and 2.3(b):

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

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

Item 11 - The proposed alternative modifies the acceptance criteria of Table VIII-S2-1 as follows:

TABLE VIII-S7-1 PERFORMANCE DEMONSTRATION DETECTION TEST ACCEPTANCE CRITERIA Detection Test False Call Test Acceptance Critera Acceptance Criteria No. of No. of Maximum Flawed Minimum Unflawed Number Grading Detection Grading of False Units Criteria Units Calls 5 5 10 o 6 6 12 1 7 6 14 1 8 7 16 2 9 7 10 2 10 8 s- 15 2 11 9 2L- 17 3-3 12 9 24- 18 3 13 10 26-20 4-3 14 10 28-21 3 15 11 3-23 3 16 12 32- 24 64 17 12 3 26 6 4 18 13 36-27 4 19 13 3 29 7-4 20 14 40 30 8 5

NLS2004009 Page 19 of 34 RELIEF REQUEST NUMBER: RI-33 (Continted)

Technical Basis - The proposed alternative is identified as new Table S 10- 1 above. It was modified to reflect the reduced number of unflawed grading units and allowable false calls. As a part of ongoing Code activities, Pacific Northwest National Laboratory has reviewed the statistical significance of these revisions and offered the revised Table S 10- 1.

Pursuant to I OCFR50.55a(a)(3)(i), approval is requested to use the proposed alternative described herein and outlined in Table RI 1.

ALTERNATIVE EXAMINATIONS In lieu of the requirements of ASME Section Xl, 1995 Edition, 1996 Addenda, Appendix VIII, Supplement 10, the proposed alternative shall be used. A copy of the proposed alternative is contained in Table RI-33-1.

APPLICABLE TIME PERIOD Relief is requested for the third ten-year ISI interval at CNS, which ends on February 8, 2006.

PRECEDENT A similar relief request was approved for Edwin I. Hatch, Units I and 2, Joseph M. Farley, Units I and 2 and Vogtle, Units I and 2 (TAC NOS. MB9023, M19024, MB9025, MB9026, MB9027 and MB9028) on August 6,2003.

NLS2004009 Page 20 of 34 RELIEF REQUEST RI-33 (Continued)

TABLE RI-33-1 APPENDIX VIII, SUPPLEMENT 10 ALTERNATIVE BASIS 1.0 SCOPE Supplement 10 is applicable to dissimilar A scope statement provides added clarity metal piping welds examined from either regarding the applicable range of each the inside or outside surface. Supplement individual Supplement. The exclusion of 10 is not applicable to piping welds CRC provides consistency between containing supplemental corrosion resistant Supplement 10 and the recent revision to clad (CRC) applied to mitigate Supplement 2 (Reference BC 00-755).

Intergranular Stress Corrosion Cracking Note, an additional change identifying CRC (IGSCC). as "in course of preparation" is being processed separately.

1.0 SPECIMEN REQUIREMENTS 2.0 SPECIMEN REQUIREMENTS Renumbered Qualification test specimens shall meet the Qualification test specimens shall meet the No Change requirements listed herein, unless a set of requirements listed herein, unless a set of specimens is designed to accommodate specimens is designed to accommodate specific limitations stated in the scope of specific limitations stated in the scope of the examination procedure (e.g., pipe size, the examination procedure (e.g., pipe size, weld joint configuration, access weld joint configuration, access limitations). The same specimens may be limitations). The same specimens may be used to demonstrate both detection and used to demonstrate both detection and sizing qualification. sizing qualification.

1.I General. The specimen set shall 2.1 General. Renumbered conform to the following requirements. The specimen set shall conform to the following requirements.

(a) The minimum number of flaws in a New, changed minimum number of flaws to specimen set shall be ten. 10 so sample set size for detection is consistent with length and depth sizing.

NLS2004009 I Page 21 of 34 RELIEF REQUEST RI-33 (Continued)

TABLE RI-33-1 APPENDIX VIII, SUPPLEMENT 10 ALTERNATIVE BASIS (a) Specimens shall have sufficient volume (b) Specimens shall have sufficient volume Renumbered to minimize spurious reflections that may to minimize spurious reflections that may interfere with the interpretation process. interfere with the interpretation process.

(b) The specimen set shall include the (c) The specimen set shall include the Renumbered, metricated, the change in pipe minimum and maximum pipe diameters and minimum and maximum pipe diameters and diameter tolerance provides consistency thicknesses for which the examination thicknesses for which the examination between Supplement 10 and the recent procedure is applicable. Pipe diameters procedure is applicable. Pipe diameters revision to Supplement 2 (Reference BC within a range of 0.9 to 1.5 times a nominal within 1/2 in. (13 mm) of the nominal 00-755).

diameter shall be considered equivalent. diameter shall be considered equivalent.

Pipe diameters larger than 24 in. shall be Pipe diameters larger than 24 in. (610 mm) considered to be flat. When a range of shall be considered to be flat. When a range thicknesses is to be examined, a thickness of thicknesses is to be examined, a tolerance of +25% is acceptable. thickness tolerance of +25% is acceptable.

(c) The specimen set shall include examples (d) The specimen set shall include examples Renumbered, changed "condition" to of the following fabrication condition: of the following fabrication conditions: "conditions" (1) geometric conditions that normally (I) geometric and material conditions that Clarification, some of the items listed relate require discrimination from flaws (e.g., normally require discrimination from flaws to material conditions rather than geometric counterbore or weld root conditions, (e.g., counterbore or weld root conditions, conditions. Weld repair areas were- added cladding, weld buttering, remnants of cladding, weld buttering, remnants of as a result of recent field experiences.

previous welds, adjacent welds in close previous welds, adjacent welds in close proximity); proximity, weld repair areas);

I NLS2004009 Page 22 of 34 RELIEF REQUEST RI-33 (Continued)

TABLE RI-33-1 APPENDIX VIII, SUPPLEMENT 10 ALTERNATIVE BASIS (2) typical limited scanning surface (2) typical limited scanning surface Differentiates between ID and OD scanning conditions (e.g., diametrical shrink, single- conditions shall be included as follows: surface limitations. Requires that ID and side access due to nozzle and safe end (a) for outside surface examination, weld OD qualifications be conducted external tapers). crowns, diametrical shrink, single-side independently (Note, new paragraph 2.0 access due to nozzle and safe end external (identical to old paragraph 1.0) provides for tapers alternatives when "a set of specimens is (b) for inside surface examination, internal designed to accommodate specific tapers, exposed weld roots, and cladding limitations stated in the scope of the conditions for inside surface examinations). examination procedure.").

(e) Qualification requirements shall be satisfied separately for outside surface and inside surface examinations.

(d) All flaws in the specimen set shall be Deleted this requirement, because new cracks. paragraph 2.3 below provides for the use of "alternative flaws" in lieu of cracks.

(I) At least 50% of the cracks shall be in 2.2 Flaw Location. Renumbered and re-titled. Flaw location austenitic material. At least 50% of the At least 80% of the flaws shall be contained percentages redistributed because field cracks in austenitic material shall be wholly in weld or buttering material. At experience indicates that flaws contained in contained wholly in weld or buttering least one and no more than 10% of the weld or buttering material are probable and material. At least 10% of the cracks shall be flaws shall be in ferritic base material. At represent the more stringent ultrasonic in ferritic material. The remainder of the least one and no more than 10% of the detection scenario.

cracks may be in either austenitic or ferritic flaws shall be in austenitic base material.

material.

Iz NLS2004009 Page 23 of 34 RELIEF REQUEST RI-33 (Continued)

TABLE RI-33-1 APPENDIX VIII, SUPPLEMENT 10 ALTERNATIVE BASIS (2) At least 50% of the cracks in austenitic 2.3 Flaw Type. Renumbered and re-titled. Alternative base material shall be either GSCC or (a) At least 60% of the flaws shall be flaws are required for placing axial flaws in thermal fatigue cracks. At least 50% of the cracks, and the remainder shall be the HAZ of the weld and other areas where cracks in ferritic material shall be alternative flaws. Specimens with GSCC implantation of a crack produces mechanically or thermally induced fatigue shall be used when available. Alternative metallurgical conditions that result in an cracks. flaws shall meet the following unrealistic ultrasonic response. This is requirements: consistent with the recent revision to (1) Alternative flaws, if used, shall provide Supplement 2 (Reference BC 00-755).

crack-like reflective characteristics and shall only be used when implantation of The 40% limit on alternative flaws is cracks would produce spurious reflectors needed to support the requirement for up to that are uncharacteristic of service-induced 70% axial flaws. Metricated flaws.

(2) Alternative flaws shall have a tip width no more than 0.002 in. (.05 mm).

(3) At least 50% of the cracks shall be (b) At least 50% of the flaws shall be Renumbered. Due to inclusion of coincident with areas described in (c) coincident with areas described in 2.1 (d) "alternative flaws", use of "cracks" is no above. above. longer appropriate.

NLS2004009 I Page 24 of 34 RELIEF REQUEST RI-33 (Continued)

TABLE RI-33-1 APPENDIX VIII, SUPPLEMENT 10 ALTERNATIVE BASIS 2.4 Flaw Depth.

All flaw depths shall be greater than 10% of Moved from old paragraph 1.3(c) and 1.4 the nominal pipe wall thickness. Flaw and re-titled. Consistency between depths shall exceed the nominal clad detection and sizing specimen set thickness when placed in cladding. Flaws in requirements (e.g., 20% vs. 1/3 flaw depth the sample set shall be distributed as increments, e.g., original paragraph 1.3(c)).

follows:

Flaw Depth Minimum

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

31-60% 20%

61-100% 20%

At least 75% of the flaws shall be in the range of 10 to 60% of wall thickness.

1.2 Detection Specimens. The specimen set Renumbered and re-titled and moved to shall include detection specimens that meet paragraph 3.1 (a). No other changes.

the following requirements.

NLS2004009 a Page 25 of 34 RELIEF REQUEST RT-33 (Continued)

TABLE RI-33-1 APPENDIX VIII, SUPPLEMENT 10 ALTERNATIVE BASIS (a) Specimens shall be divided into grading Renumbered to paragraph 3.1 (a)( 1). No units. Each grading unit shall include at other changes.

least 3 in. of weld length. If a grading unit is designed to be unflawed, at least I in. of unflawed material shall exist on either side of the grading unit. The segment of weld length used in one grading unit shall not be used in another grading unit. Grading units need not be uniformly spaced around the pipe specimen.

(b) Detection sets shall be selected from Moved to new paragraph 3.1 (a)(2).

Table VIII-S2- 1.The number of unflawed grading units shall be at least twice the number of flawed grading units.

(c) Flawed grading units shall meet the Flaw depth requirements moved to new following criteria for flaw depth, paragraph 2.4, flaw orientation orientation, and type. requirements moved to new paragraph 2.5, flaw type requirements moved to new paragraph 2.3, "Flaw Type".

NLS2004009 I Page 26 of 34 RELIEF REQUEST RI-33 (Continued)

TABLE RI-33-1 APPENDIX VIII, SUPPLEMENT 10 ALTERNATIVE BASIS (1) All flaw depths shall be greater than Deleted, for consistency in sample sets the 10% of the nominal pipe wall thickness. At depth distribution is the same for detection least 1/3 of the flaws, rounded to the next and sizing.

higher whole number, shall have depths between 10% and 30% of the nominal pipe wall thickness. However, flaw depths shall exceed the nominal clad thickness when placed in cladding. At least 1/3 of the flaws, rounded to the next whole number, shall have depths greater than 30% of the nominal pipe wall thickness.

(2) At least 30% and no more than 70% of 2.5 Flaw Orientation. Note, this distribution is applicable for the flaws, rounded to the next higher whole (a) For other than sizing specimens at least detection and depth sizing. Paragraph number, shall be oriented axially. The 30% and no more than 70% of the flaws, 2.5(b)(1) requires that all length- sizing remainder of the flaws shall be oriented rounded to the next higher whole number, flaws be oriented circumferentially.

circumferentially. shall be oriented axially. The remainder of the flaws shall be oriented circumferentially.

1.3 Length Sizing Specimens. The Renumbered and re-titled and moved to specimen set shall include length sizing new paragraph 3.2.

specimens that meet the following requirements.

(a) All length sizing flaws shall be oriented Moved, included in new paragraph 3.2(a).

circumferentially.

(b) The minimum number of flaws shall be Moved, included in new paragraph 2.1 ten. above.

NLS2004009 I Page 27 of 34 RELIEF REQUEST RI-33 (Continued)

TABLE RI-33-1 APPENDIX VIIT, SUPPLEMENT 10 ALTERNATIVE BASIS (c) All flaw depths shall be greater than Moved, included in new paragraph 2.4 10% of the nominal pipe wall thickness. At above after revision for consistency with least 1/3 of the flaws, rounded to the next . detection distribution higher whole number, shall have depths between 10% and 30% of the nominal pipe wall thickness. However, flaw depth shall exceed the nominal clad thickness when placed in cladding. At least 1/3 of the flaws, rounded to the next whole number, shall have depths greater than 30% of the nominal pipe wall thickness.

1.4 Depth Sizing Specimens. The specimen Moved, included in new paragraphs 2. 1, set shall include depth sizing specimens that 2.3, 2.4.

meet the following requirements.

(a) The minimum number of flaws shall be Moved, included in new paragraph 2. 1.

ten.

(b) Flaws in the sample set shall not be Moved, potential conflict with old wholly contained within cladding and shall paragraph 1.2(c)(1); "However, flaw depths be distributed as follows: shall exceed the nominal clad thickness when placed in cladding.". Revised for clarity and included in new paragraph 2.4.

NLS2004009 I Page 28 of 34 RELIEF REQUEST RI-33 (Continued)

TABLE RI-33-1 APPENDIX VIII, SUPPLEMENT 10 ALTERNATIVE BASIS Moved, included in paragraph 2.4 for Flaw Depth Minimum consistent applicability to detection and

(% Wall Thickness) Number of Flaws sizing samples.

10-30% 20%

3 1-60% 20%

61-100% 20%

The remaining flaws shall be in any of the above categories.

(b) Sizing Specimen sets shall meet the Added for clarity.

following requirements.

(1) Length-sizing flaws shall be oriented Moved from old paragraph 1.3(a).

circumferentially.

(2) Depth sizing flaws shall be oriented as Included for clarity. Previously addressed in 2.5(a). by omission (i.e., length, but not depth had a specific exclusionary statement).

NLS2004009 Page 29 of 34 RELIEF REQUEST RI-33 (Continued)

TABLE RI-33-1 APPENDIX VIII, SUPPLEMENT 10 ALTERNATIVE BASIS 2.0 CONDUCT OF PERFORMANCE 3.0 PERFORMANCE Renumbered DEMONSTRATION DEMONSTRATION The specimen inside surface and Personnel and procedure performance Differentiate between qualifications identification shall be concealed from the demonstration tests shall be conducted conducted from the outside and inside candidate. All examinations shall be according to the following requirements. surface.

completed prior to grading the results and (a) For qualifications from the outside presenting the results to the candidate. surface, the specimen inside surface and Divulgence of particular specimen results or identification shall be concealed from the candidate viewing of unmasked specimens candidate. When qualifications are after the performance demonstration is performed from the inside surface, the flaw prohibited. location and specimen identification shall be obscured to maintain a "blind test". All examinations shall be completed prior to grading the results and presenting the results to the candidate. Divulgence of particular specimen results or candidate viewing of unmasked specimens after the performance demonstration is prohibited.

2.1 Detection Test. Flawed and unflawed 3.1 Detection Test. Renumbered, moved text to paragraph grading units shall be randomly mixed. 3.1 (a)(3).

(a) The specimen set shall include detection Renumbered, moved from old paragraph specimens that meet the following 1.2.

requirements.

I NLS2004009 Page 30 of 34 RELIEF REQUEST RI-33 (Continued)

TABLE RI-33-1 APPENDIX VIII, SUPPLEMENT 10 ALTERNATIVE BASIS (I) Specimens shall be divided into grading Renumbered, moved from old paragraph units. 1.2(a). Metricated. No other changes.

(a) Each grading unit shall include at least 3 in. (76 mm) of weld length.

(b) The end of each flaw shall be separated from an unflawed grading unit by at least I in. (25 mm) of unflawed material. A flaw may be less than 3 in. in length.

(c) The segment of weld length used in one grading unit shall not be used in another grading unit.

(d) Grading units need not be uniformly spaced around the pipe specimen.

(2) Personnel performance demonstration Moved from old paragraph 1.2(b). Table detection test sets shall be selected from revised to reflect a change in the minimum Table VIII-S I0-1. The number of unflawed sample set to 10 and the application of grading units shall be at least 1-1/2 times equivalent statistical false call parameters to the number of flawed grading units. the reduction in unflawed grading units.

Human factors due to large sample size.

(3) Flawed and unflawed grading units shall Moved from old paragraph 2.1.

be randomly mixed.

NLS2004009 W Page 31 of 34 RELIEF REQUEST RI-33 (Continued)

TABLE RI-33-1 APPENDIX VIII, SUPPLEMENT 10 ALTERNATIVE BASIS (b) Examination equipment and personnel Moved from old paragraph 3.1. Modified are qualified for detection when personnel to reflect the 100% detection acceptance demonstrations satisfy the acceptance criteria of procedures versus personnel and criteria of Table VIII S 10-1 for both equipment contained in new paragraph 4.0 detection and false calls. and the use of 1.5X rather than 2X unflawed grading units contained in new paragraph 3.1 (a)(2). Note, the modified table maintains the screening criteria of the original Table VIII-S2-1.

2.2 Length Sizing Test 3.2 Length Sizing Test Renumbered (a) The length sizing test may be conducted (a) Each reported circumferential flaw in Provides consistency between Supplement separately or in conjunction with the the detection test shall be length-sized. 10 and the recent revision to Supplement 2 detection test. (Reference BC 00-755).

(b) When the length sizing test is conducted (b) When the length-sizing test is conducted Change made to ensure security of samples, in conjunction with the detection test, and in conjunction with the detection test, and consistent with the recent revision to less than ten circumferential flaws are less than ten circumferential flaws are Supplement 2 (Reference BC 00-755).

detected, additional specimens shall be detected, additional specimens shall be provided to the candidate such that at least provided to the candidate such that at least Note, length and depth sizing use the term ten flaws are sized. The regions containing ten flaws are sized. The regions containing "regions" while detection uses the term a flaw to be sized shall be identified to the a flaw to be sized may be identified to the "grading units". The two terms define candidate. The candidate shall determine candidate. The candidate shall determine different concepts and are not intended to the length of the flaw in each region. the length of the flaw in each region. be equal or interchangeable.

(c) For a separate length sizing test, the (c) For a separate length-sizing test, the Change made to ensure security of samples, regions of each specimen containing a flaw regions of each specimen containing a flaw consistent with the recent revision to to be sized shall be identified to the to be sized may be identified to the Supplement 2 (Reference BC 00-755).

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

NLS2004009 .

Page 32 of 34 RELIEF REQUEST RI-33 (Continued)

TABLE RI-33-1 APPENDIX VIII, SUPPLEMENT 10 ALTERNATIVE BASIS (d) Examination procedures, equipment, Moved from old paragraph 3.2(a) includes and personnel are qualified for length-sizing inclusion of "when" as an editorial change.

when the RMS error of the flaw length Metricated.

measurements, as compared to the true flaw lengths, do not exceed 0.75 in. (19 mm).

2.3 Depth Sizing Test 3.3 Depth Sizing Test Renumbered (a) For the depth sizing test, 80% of the (a) The depth-sizing test may be conducted Change made to ensure security of samples, flaws shall be sized at a specific location on separately or in conjunction with the consistent with the recent revision to the surface of the specimen identified to the detection test. For a separate depth-sizing Supplement 2 (Reference BC 00-755).

candidate. test, the regions of each specimen containing a flaw to be sized may be identified to the candidate. The candidate shall determine the maximum depth of the flaw in each region.

(b) For the remaining flaws, the regions of (b) When the depth-sizing test is conducted Change made to be consistent with the each specimen containing a flaw to be sized in conjunction with the detection test, and recent revision to Supplement 2 (Reference shall be identified to the candidate. The less than ten flaws are detected, additional BC 00-755).

candidate shall determine the maximum specimens shall be provided to the depth of the flaw in each region. candidate such that at least ten flaws are . Changes made to ensure security of sized. The regions of each specimen samples, consistent with the recent revision containing a flaw to be sized may be to Supplement 2 (Reference BC 00-755).

identified to the candidate. The candidate shall determine the maximum depth of the flaw in each region.

NLS2004009 I Page 33 of 34 RELIEF REQUEST RI-33 (Continued)

TABLE RI-33-1 APPENDIX VIII, SUPPLEMENT 10 ALTERNATIVE BASIS (c) Examination procedures, equipment, Moved from old paragraph 3.2(b).

and personnel are qualified for depth sizing Metricated.

when the RMS error of the flaw depth measurements, as compared to the true flaw depths, do not exceed 0.125 in. (3 mm).

3.0 ACCEPTANCE CRITERIA Delete as a separate category. Moved to new paragraph detection (3.1) and sizing 3.2 and 3.3 3.1 Detection Acceptance Criteria. Moved to new paragraph 3.1(b), reference Examination procedures, equipment, and changed to Table S10 from S2 because of personnel are qualified for detection when the change in the minimum number of flaws the results of the performance and the reduction in unflawed grading units demonstration satisfy the acceptance from 2X to .5X.

criteria of Table VIII-S2-1 for both detection and false calls.

3.2 Sizing Acceptance Criteria Deleted as a separate category. Moved to new paragraph on length 3.2 and depth 3.3 (a) Examination procedures, equipment, Moved to new paragraph 3.2(d), included and personnel are qualified for length sizing word "when" as an editorial change.

the RMS error of the flaw length measurements, as compared to the true flaw lengths, is less than or equal to 0.75 inch.

(b) Examination procedures, equipment, Moved to new paragraph 3.3(c) and personnel are qualified for depth sizing when the RMS error of the flaw depth measurements, as compared to the true flaw depths, is less than or equal to 0.125 in.

NLS2004009 Page 34 of 34 RELIEF REQUEST RI-33 (Continued)

TABLE RI-33-1 APPENDIX VIII, SUPPLEMENT 10 ALTERNATIVE BASIS 4.0 PROCEDURE QUALIFICATION New Procedure qualifications shall include the New. Based on experience gained in following additional requirements. conducting qualifications, the equivalent of (a) The specimen set shall include the 3 personnel sets (i.e., a minimum of 30 equivalent of at least three personnel flaws) is required to provide enough flaws performance demonstration test sets. to adequately test the capabilities of the Successful personnel performance procedure. Combining successful demonstrations may be combined to satisfy demonstrations allows a variety of these requirements. examiners to be used to qualify the (b) Detectability of all flaws in the procedure. Detectability of each flaw procedure qualification test set that are within the scope of the procedure is within the scope of the procedure shall be required to ensure an acceptable personnel demonstrated. Length and depth sizing pass rate. The last sentence is equivalent to shall meet the requirements of paragraph the previous requirements and is 3.1, 3.2, and 3.3. satisfactory for expanding the essential (c) At least one successful personnel variables of a previously qualified demonstration shall be performed. procedure (d) To qualify new values of essential variables, at least one personnel qualification set is required. The acceptance criteria of 4.0(b) shall be met.

I ATTACHMENT 3 LIST OF REGULATORY COMMITMENTSl Correspondence Number: NLS2004009 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing & Regulatory Affairs Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITTED DATE COMMITMENT OR OUTAGE None

.4 PROCEDURE 0.42 REVISION 13 PAGE 14 OF 16