WM 05-0013, 10CFR50.55a Requests Regarding Implementation of ASME Section XI Requirements for Examination of the Reactor Pressure Vessel and Connecting Loop Piping Welds; 10CFR50.55a Requests 12R-29, 12R-30, 12R-31, and 12R-32

10CFR50.55a Requests Regarding Implementation of ASME Section XI Requirements for Examination of the Reactor Pressure Vessel and Connecting Loop Piping Welds; 10CFR50.55a Requests 12R-29, 12R-30, 12R-31, and 12R-32

ML050950356
Person / Time
Site:	Wolf Creek
Issue date:	03/25/2005
From:	Muench R Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
WM 05-0013
Download: ML050950356 (40)

Text

WLF CREEK 'NUCLEAR OPERATING CORPORATION Richard A. Muench President and Chief Executive Officer Mardh 25, 2005 WM 05-0013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Docket No. 50-482: 10 CFR 50.55a Requests Regarding Implementation of ASME Section Xi Requirements for Examination of the Reactor Pressure Vessel and Connecting Loop Piping Welds; 10 CFR 50.55a Requests 12R-29, 12R-30, 12R-31, and 12R-32 Gentlemen:

Pursuant to 10 CFR 50.55a(a)(3)(i), Wolf Creek Nuclear Operating Corporation (WCNOC) hereby requests NRC approval for use of alternatives to the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code, Section Xl requirements for examination of the reactor pressure vessel (RPV) and connecting loop piping welds for the second 10-year interval of WCNOC's Inservice Inspection (ISI) Program.

Attachment I provides 10 CFR 50.55a Request 12R-29 to the WCNOC Second Interval ISI Program Plan. It requests an alternative from the qualification requirements of ASME Section Xi Appendix Vil, Supplement 10 for supporting examination of dissimilar metal piping welds (i.e., for RPV piping welds examined from the inside surface of the RPV). The proposed alternative would allow use of alternative requirements that have been developed by the industry (to be implemented through the Performance Demonstration Initiative (PDI) program) and which are contained in a proposed revision to Supplement 10. A summary of the proposed revision to Supplement 10 is included as Enclosure I to support request 12R-29. 1provides 10 CFR 50.55a Request 12R-30 to the WCNOC Second Interval ISI Program Plan. It requests an alternative from the qualification requirements of Supplements 2 and 10 of ASME Section XI Appendix VIII to permit use of the industry's PDI program for implementation of the applicable qualification requirements associated RO. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNVET

WM 05-0013 Page 2 of 2 with the examination of Class 1 pressure-retaining piping (safe-end) welds from the inside surface. The alternate program proposed by the industry as Supplement 14 to Appendix Vil would be used for this purpose.

Attachment III provides 10 CFR 50.55a Request 12R-31 to the WCNOC Second Interval ISI Program Plan. It would allow use of a PDI-qualified procedure to complete the ultrasonic examination of the RPV shell-to-flange weld from the vessel inside diameter surface in accordance with Appendix Vil Supplements 4 and 6 in lieu of ASME Section V, Article 4 (as directed by ASME Section Xi, 1989 Edition, Subsection IWA-2232 and Appendix I, Subparagraph 1-2110).

Attachment IV provides 10 CFR 50.55a Request 12R-32 to the WCNOC Second Interval ISI Program Plan. It requests use of the alternative examination volume requirements shown in Figure 1 of Code Case N-613-1 for examination of the RPV nozzle to vessel welds in lieu of the requirements of ASME Section Xi, Figure IWB-2500-7(a).

NRC Safety Evaluation dated April 7, 2004, to the AmerenUE Callaway Plant, approved the alternatives for which WCNOC is seeking approval in the attached 10 CFR 50.55a Requests 12R-29, 12R-30 and 12R-31 listed above.

NRC Safety Evaluation dated October 7, 2004, to Duke Energy Corporation, approved the alternative for which WCNOC is seeking approval in the attached 10 CFR 50.55a Request 12R-32 listed above, for Catawba Unit 2.

The Second ISI Interval ends on September 2, 2005. WCNOC will complete the subject examinations addressed by the attached 10 CFR 50.55a Requests for the Second ISI Interval during RF14, which is scheduled for completion in May 2005.

WCNOC requests approval of these 10 CFR 50.55a Requests by August 12, 2005.

If you have any questions concerning this matter, please contact me at (620) 364-4000 or Mr. Kevin Moles at (620) 364-4126.

Sincerely, Richar Muench RAM/rig Attachment I: 10 CFR 50.55a Request 12R-29 Attachment II: 10 CFR 50.55a Request 12R-30 Attachment III: 10 CFR 50.55a Request 12R-31 Attachment IV: 10 CFR 50.55a Request 12R-32 Enclosure I: 10 CFR 50.55a Request 12R Proposed Revision to ASME Section Xi Appendix VIII, Supplement 10 cc: J. N. Donohew (NRC), w/a, wle D. N. Graves (NRC), w/a, w/e B. S. Mallett (NRC), w/a, w/e Senior Resident Inspector (NRC), w/a, w/e

Attachment I to WM 05-0013 Page 1 of 7 10 CFR 50.55a Request Number 12R-29 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

-Alternative Provides Acceptable Level of Qualityand Safety-

1. ASME Code Component(s) Affected Class I Pressure Retaining Piping Welds examined from the inside surface of Pressurized Water Reactors using procedures, personnel, and equipment qualified to ASME Section Xi, Appendix Vil, Supplement 10 criteria.

SAFE-END WELDS CODE CATEGORY B-F Code Description Weld No.

Item B5.10 Safe-end to Loop A RPV Inlet Nozzle RV-302-121-A (Note 1)

B5.10 Safe-end to Loop A RPV Outlet Nozzle RV-301-121-A (Note 1)

B5.10 Safe-end to Loop B RPV Inlet Nozzle RV-302-121-B (Note 2)

B5.10 Safe-end to Loop B RPV Outlet Nozzle RV-301-121-B (Note 2)

B5.10 Safe-end to Loop C RPV Inlet Nozzle RV-302-121-C (Note 2)

B5.10 Safe-end to Loop C RPV Outlet Nozzle RV-301-121-C (Note 2)

B5.10 Safe-end to Loop D RPV Inlet Nozzle RV-302-121-D (Note 1)

B5.10 Safe-end to Loop D RPV Outlet Nozzle RV-301-121-D (Note 2)

Note 1:These welds are selected for examination by the WCNOC Risk-informed ISI Program.

Note 2:Due to V. C. Summer hot leg nozzle cracking, it was decided that all inlet and outlet dissimilar metal nozzle-to-safe-end Cat. B-F welds are to be examined during Refuel 14 (Spring 2005).

2. Applicable Code Edition and Addenda

Wolf Creek Generating Station is in its second inservice inspection interval, which started on September 3, 1995 and ends on September 2, 2005. The applicable Code edition and addenda is ASME Section Xi, "Rules for Inservice Inspection of Nuclear Power Plant Components," 1989 Edition, with no Addenda. In addition, as required by 10 CFR 50.55a, ASME Section Xl, 1995 Edition through 1996 Addenda is used for Appendix Vil, Performance Demonstration for Ultrasonic Examination Systems.

3. Applicable Code Requirement

The following paragraphs or statements are from ASME Section Xi, Appendix VilI, Supplement 10 and identify the specific requirements that are addressed in this request for relief.

Attachment I to WM 05-0013 Page 2 of 7 10 CFR 50.55a Request Number 12R-29 Item 1 - Paragraph 1.1(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 1.1(d) states - All flaws in the specimen set shall be cracks.

Item 3 - Paragraph 1.1(dXl) 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.

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

4. Reason for Request

Relief is requested to use the following alternative requirements for implementation of the above Appendix Vil, Supplement 10 requirements. The alternative requirements will be implemented through the Performance Demonstration Initiative (PDI) Program.

It is important to note that the industry developed a proposed revision to Supplement 10, which included the alternatives identified below, along with additional clarifications and enhancements. A copy of that proposed revision is enclosed. The proposed alternatives are highlighted in the enclosure where they may be viewed in context.

ASME revised Supplement 10 in the 2004 Edition of Section Xl to incorporate the proposed industry revision.

Attachment I to WM 05-0013 Page 3 of 7 10 CFR 60.55a Request Number 12R-29

5. Proposed Alternative and Basis for Use The following alternatives are proposed, wherein a proposed alternative is specified for each Appendix Vil item listed in Section 3 above.

Item 1 - The proposed alternative to Paragraph 1.1(b) states:

"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 - The proposed alternative to Paragraph 1.1(d) states:

"At least 60% of the flaws shall be cracks, the remainder shall be alternative flaws. Specimens with IGSCC shall be used when available. Alternative flaws, shall meet the following requirements:

(1) 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)."

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.

Attachment I to WM 05-0013 Page 4 of 7 10 CFR 50.55a Request Number 12R-29 Item 3 - The proposed alternative to Paragraph 1.1(d)(1) states:

"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 little as 25% of the flaws may be contained in austenitic weld or buttering material. Recent experience has indicated that flaws are most likely to be contained within the weld. 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 - The proposed alternative to Paragraph 1.2(b) states:

"Personnel performance demonstration detection test sets shall be selected from Table VIII-SIO-1. The number of unflawed grading units shall be at least 1-1/2 times the number of flawed grading units."

Technical Basis - Proposed Table Vill-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, thus reducing 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 regard to competent personnel being successful and less skilled personnel being unsuccessful. The acceptance criteria for the statistical basis are in Table Vill-S10-1.

Item 5 - The proposed alternative to the flaw distribution requirements of Paragraph 1.2(c)(1) (detection) and 1.3(c) (length) is to use the Paragraph 1.4(b) (depth) distribution table (see below) for all qualifications.

Flaw Depth Minimum

(% 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.

Attachment I to WM 05-0013 Page 5 of 7 10 CFR 50.55a Request Number 12R-29 Item 6 - The proposed alternative to Paragraph 2.0 first sentence states:

"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 - The proposed alternatives to Paragraph 2.2(b) and 2.2(c) state:

"... 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 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 - The proposed alternative to Paragraph 2.3(a) and 2.3(b) state:

.... 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 Vill-S2-1 as follows:

Attachment I to WM 05-0013 Page 6 of 7 10 CFR 50.55a Request Number 12R-29 TABLE VIII-SX-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 1o 0 6 6 12 -

7 6 14 1 8 7 16 2 9 7 10 2 10 8 20- 15 3-2 11 9 2-17 3-3 12 9 24-18 3-3 13 10 26-20 4-3 14 10 28-21 3 15 11 3-23 3 16 12 38-24 6-4 17 12 34- 26 4 18 13 36-27 4 19 13 3-29 4 20 14 40 30 e- 5 Technical Basis - The proposed alternative is identified as new Table S10-1 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 Laboratories (PNNL) has reviewed the statistical significance of these revisions and offered the revised Table SI0-1.

Alternative Examination In lieu of the requirements of ASME Section Xl, 1995 Edition through 1996 Addenda, Appendix Vil, Supplement 10, the proposed alternative shall be used. The proposed alternative is described in the enclosure. All other ASME Section Xl Code requirements for which relief is not specifically requested remain applicable, including third party review by the Authorized Nuclear Inservice Inspector. Pursuant to 10 CFR 50.55a(a)(3)(i), approval is requested to use the proposed alternatives described above in lieu of the ASME Section Xl, Appendix Vil, Supplement 10 requirements.

Compliance with the proposed alternatives will provide an adequate level of quality and safety for examination of the affected welds.

Attachment I to WM 05-0013 Page 7 of 7 10 CFR 50.55a Request Number 12R-29

6. Duration of Proposed Alternative The proposed alternative is requested for the duration of the second inservice inspection interval.

7. Precedents The NRC has granted similar relief to Callaway Plant [Reference AmerenUE Callaway Plant letter, dated August 14, 2003, Docket No. 50-483, "Requests for Relief Regarding Implementation of ASME Section Xi Appendix Vil Requirements", and the associated NRC Safety Evaluation, letter from Stephen Dembek to Garry Randolph (Union Electric Company) dated April 7, 2004;

Subject:

Callaway Plant Unit 1 - Relief Request ISI-27 through ISI-31 Pertaining to Implementation of ASME Section Xi Appendix VilI Requirements (TAC Nos. MC04478 through MC04482, respectively)].

Enclosure I to WM 05-0013 Page 1 of 12 10 CFR 50.55a Request 12R-29 Proposed Revision to ASME Section Xi Appendix Vill, Supplement 10 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning l 1.0 SCOPE _

Supplement 10 is applicable to dissimilar metal A scope statement provides added clarity regarding piping welds examined from either the inside or the applicable range of each individual Supplement.

outside surface. Supplement 10 is not applicable The exclusion of CRC provides consistency between to piping welds containing supplemental Supplement 10 and the recent revision to corrosion resistant clad (CRC) applied to mitigate Supplement 2 (Reference BC 00-755). Note, an IntergranularStress Corrosion Cracking additional change identifying CRC as "in course of (IGSCC). 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 specimens requirements listed herein, unless a set of specimens is designed to accommodate specific limitations is designed to accommodate specific limitations stated in the scope of the examination procedure stated in the scope of the examination procedure (e.g., pipe size, weld joint configuration, access (e.g., pipe size, weld joint configuration, access limitations). The same specimens may be used to limitations). The same specimens may be used to demonstrate both detection and sizing qualification. demonstrate both detection and sizing qualification.

1.1 General The specimen set shall conform to the 2.1 General. Renumbered.

following requirements. The specimen set shall conform to the following requirements.

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

(a) Specimens shall have sufficient volume to (b) Specimens shall have sufficient volume to Renumbered.

minimize spurious reflections that may interfere with minimize spurious reflections that may interfere with the interpretation process. the interpretation process.

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

nominal diameter shall be considered equivalent. diameter shall be considered equivalent Pipe

Enclosure I to WM 05-0013 Page 2 of 12 10 CFR 50.55a Request 12R-29 Proposed Revision to ASME Section Xl Appendix VilI, Supplement 10 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning Pipe diameters larger than 24 in. shall be considered diameters larger than 24 in. (610 mm) shall be to be flat. When a range of thicknesses is to be considered to be flat. When a range of thicknesses is examined, a thickness tolerance of +25% is to be examined, a thickness tolerance of +25% is acceptable. acceptable.

(c) The specimen set shall include examples of the (d) The specimen set shall include examples of the Renumbered, and changed "condition" to following fabrication condition: following fabrication conditions: "conditions."

(1) geometric conditions that normally require (1) geometric and material conditions that normally Clarified, since some of the items listed relate to discrimination from flaws (e.g., counterbore or weld require discrimination from flaws (e.g., counterbore material conditions rather than geometric conditions.

root conditions, cladding, weld buttering, remnants or weld root conditions, cladding, weld buttering, Weld repair areas were added as a result of recent of previous welds, adjacent welds in close remnants of previous welds, adjacent welds in close field experiences.

proximity); proximity, weld repair areas);

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

conditions for Inside surface examinations).

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

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

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

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

Enclosure I to WM 05-0013 Page 3 of 12 10 CFR 50.55a Request 12R-29 Proposed Revision to ASME Section Xi Appendix Vill, Supplement 10 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WNELDS CurrentRequirement Proposed Change Reasoning (2) At least 50% of the cracks in austenitic base 2.3 Flaw Type. Renumbered and re-titled. Alternative flaws are material shall be either IGSCC or thermal fatigue (a) At least 60% of the flaws shall be cracks, and required for placing axial flaws in the HAZ of the cracks. At least 50% of the cracks in ferritic material the remainder shall be alternative flaws. weld and other areas where implantation of a crack shall be mechanically or thermally induced fatigue Specimens with IGSCC shall be used when produces metallurgical conditions that result in an cracks. available. Alternative flaws shall meet the unrealistic ultrasonic response. This is consistent following requirements: with the recent revision to Supplement 2 (Reference (1) Alternative flaws, If used, shall provide crack- BC 00-755).

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

service-induced flaws. Metrified.

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

2.4 Flaw Depth. Created new paragraph 2.4 which consists of All flaw depths shall be greater than 10% of the requirements removed from old paragraph 1.3(c) and nominal pipe wall thickness. Flaw depths shall 1.4, and re-titled. Flaw depths table from 1.4 used exceed the nominal clad thickness when placed in for consistency between detection (old paragraph 1.3 cladding. Flaws in the sample set shall be (c)) and sizing specimen set (old paragraph 1.4 (b))

distributed as follows: requirements.

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.

Enclosure I to WM 05-0013 Page 4 of 12 10 CFR 50.55a Request 12R-29 Proposed Revision to ASME Section Xl Appendix Vill, Supplement 10 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning 1.2 Detection Specimens. The specimen set shall Renumbered, re-titled, and moved to paragraph include detection specimens that meet the following 3.1(a). No other changes.

requirements.

(a) Specimens shall be divided into grading units. Renumbered to paragraph 3.1(a)(1). No other Each grading unit shall include at least 3 in. of weld changes.

length. If a grading unit is designed to be unflawed, at least 1 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 Table VIII- Moved to new paragraph 3. 1(a)(2).

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 following Flaw depth requirements moved to new paragraph criteria for flaw depth, orientation, and type. 2.4. Flaw orientation requirements moved to new paragraph 2.5. Flaw type requirements moved to new paragraph 2.3, "Flaw Type."

(1) All flaw depths shall be greater than 10% of the Deleted. For consistency in sample sets the depth nominal pipe wall thickness. At least 1/3 of the distribution is the same for detection and sizing.

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

oriented circumferentially. higher whole number, shall be oriented axially. The

Enclosure I to WM 05-0013 Page 5 of 12 10 CFR 50.55a Request 12R-29 Proposed Revision to ASME Section Xi Appendix Vill, Supplement 10 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning remainder of the flaws shall be oriented circumferentially.

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

following requirements.

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

circumferentially.

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

(c) All flaw depths shall be greater than 10% of the Moved, and included in new paragraph 2.4 above nominal pipe wall thickness. At least 1/3 of the flaws, after revision for consistency with detection rounded to the next higher whole number, shall have distribution.

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 set shall Moved, included in new paragraphs 2.1, 2.3, 2.4 include depth sizing specimens that meet the following requirements.

(a) The minimum number of flaws shall be ten. Moved, included in new paragraph 2.1 (b) Flaws in the sample set shall not be wholly Moved. Potential conflict with old paragraph contained within cladding and shall be distributed as 1.2(c)(1); "However, flaw depths shall exceed the follows: nominal clad thickness when placed in cladding.".

Revised for clarity and included in new paragraph 2.4.

Enclosure I to WM 05-0013 Page 6 of 12 10 CFR 50.55a Request 12R-29 Proposed Revision to ASME Section Xi Appendix Vill, Supplement 10 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning Flaw Depth Minimum Moved, and included in paragraph 2.4 for consistent

(% Wall Thickness) Number of Flaws applicability to detection and sizing samples.

10-30% 20%

31-60% 20%

61-100% 20%

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

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

requirements.

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

circumferentially.

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

2.0 CONDUCT OF PERFORMANCE 3.0 PERFORMANCE DEMONSTRATION Renumbered.

DEMONSTRATION The specimen inside surface and identification shall Personnel and procedure performance Differentiate between qualifications conducted from be concealed from the candidate. All examinations demonstration tests shall be conducted according the outside and inside surface.

shall be completed prior to grading the results and to the following requirements.

presenting the results to the candidate. Divulgence of (a) For qualifications from the outside surface, particular specimen results or candidate viewing of the specimen inside surface and Identification unmasked specimens after the performance shall be concealed from the candidate. When demonstration is prohibited. qualifications are performed from the inside surface, the flaw 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.

Enclosure I to WM 05-0013 Page 7 of 12 10 CFR 50.55a Request 12R-29 Proposed Revision to ASME Section Xl Appendix Vill, Supplement 10 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning 2.1 Detection Test. Flawed and unflawed grading 3.1 Detection Test. Renumbered, and moved text to paragraph 3.1(a)(3).

units shall be randomly mixed (a) The specimen set shall include detection Renumbered, and moved from old paragraph 1.2.

specimens that meet the following requirements.

(1) Specimens shall be divided into grading units. Renumbered, and moved from old paragraph 1.2(a).

(a) Each grading unit shall include at least 3 in. (76 Metrified. No other changes.

mm) of weld length.

(b)The end of each flaw shall be separated from an unflawed grading unit by at least 1 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 detection Moved from old paragraph 1.2(b). Table revised to test sets shall be selected from Table VIII-S10-1. reflect a change in the minimum sample set to 10 and The number of unflawed grading units shall be at the application of equivalent statistical false call least 1-1/2 times the number of flawed grading units. parameters to the reduction in unflawed grading units.

Human factors due to large sample size.

Enclosure I to WM 05-0013 Page 8 of 12 10 CFR 50.55a Request 12R-29 Proposed Revision to ASME Section XI Appendix Vill, Supplement 10 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning!

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

randomly mixed.

(b) Examination equipment and personnel are Moved from old paragraph 3.1. Modified to reflect qualified for detection when personnel the 100% detection acceptance criteria of procedures demonstrations satisfy the acceptance criteria of versus personnel and equipment contained in new Table VIH S10-1 for both detection and false calls. paragraph 4.0 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 the Provides consistency between Supplement 10 and separately or in conjunction with the detection test. detection test shall be length-sized. the recent revision to Supplement 2 (Reference BC 00-755).

Enclosure I to WM 05-0013 Page 9 of 12 10 CFR 50.55a Request 12R-29 Proposed Revision to ASME Section XI Appendix VilI, Supplement 10 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning (b) When the length sizing test is conducted in (b) When the length-sizing test is conducted in Change made to ensure security of samples, conjunction with the detection test, and less than ten conjunction with the detection test, and less than ten consistent with the recent revision to Supplement 2 circumferential flaws are detected, additional circumferential flaws are detected, additional (Reference BC 00-755).

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

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

determine the length of the flaw in each region. determine the length of the flaw in each region.

(d) Examination procedures, equipment, and Moved from old paragraph 3.2(a). Included "when" personnel are qualified for length-sizing when the as an editorial change. Metrified.

RMS error of the flaw length 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 flaws shall (a) The depth-sizing test may be conducted Change made to ensure security of samples, be sized at a specific location on the surface of the separately or in conjunction with the detection consistent with the recent revision to Supplement 2 specimen identified to the candidate. test. For a separate depth-sizing test, the regions (Reference BC 00-755).

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 each (b) When the depth-sizing test is conducted in Change made to be consistent with the recent specimen containing a flaw to be sized shall be conjunction with the detection test, and less than revision to Supplement 2 (Reference BC 00-755).

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

Enclosure I to WM 05-0013 Page 10 of 12 10 CFR 50.55a Request 12R-29 Proposed Revision to ASME Section XI Appendix Vill, Supplement 10 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning candidate. The candidate shall determine the maximum depth of the flaw in each region.

(c) Examination procedures, equipment, and Moved from old paragraph 3.2(b). Metrified.

personnel are qualified for depth sizing 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. Examination Moved to new paragraph 3.1(b), reference changed procedures, equipment, and personnel are qualified to Table SlO from S2 because of the change in the for detection when the results of the performance minimum number of flaws and the reduction in demonstration satisfy the acceptance criteria of Table unflawed grading units from 2X to I .5X.

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, and Moved to new paragraph 3.2(d), and included word personnel are qualified for length sizing the RMS "when" as an editorial change.

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, and Moved to new paragraph 3.3(c).

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.

4.0 PROCEDURE QUALIFICATION New.

Procedure qualifications shall include the New. Based on experience gained in conducting following additional requirements. qualifications, the equivalent of 3 personnel sets (i.e.,

(a) The specimen set shall include the equivalent of a minimum of 30 flaws) is required to provide at least three personnel performance enough flaws to adequately test the capabilities of

Enclosure I to WM 05-0013 Page 11 of 12 10 CFR 50.55a Request 12R-29 Proposed Revision to ASME Section Xl Appendix Vill, Supplement 10 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change Reasoning demonstration test sets. Successful personnel the procedure. Combining successful performance demonstrations may be combined to demonstrations allows a variety of examiners to be satisfy these requirements. used to qualify the procedure. Detectability of each (b) Detectability of all flaws in the procedure flaw within the scope of the procedure is required to qualification test set that are within the scope of ensure acceptable personnel pass rate. The last the procedure shall be demonstrated. Length and sentence is equivalent to the previous requirements depth sizing shall meet the requirements of and is satisfactory for expanding the essential paragraph 3.1, 3.2, and 3.3. variables of a previously qualified procedure.

(c) At least one successful personnel demonstration shall be performed.

(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.

Enclosure I to WM 05-0013 Page 12 of 12 10 CFR 50.55a Request 12R-29 Proposed Revision to ASME Section XI Appendix Vill, Supplement 10 EC TABLE VIII-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 a 6 6 12 1 7 6 14 1 8 7 162 9 7 10 10 8 o- 15 2 11 9 22 17 3-3 12 9 24- 18 3-3 13 10 26-20 4 3 14 10 28-21 5-3 15 11 3o-23 5- 3 16 12 -3e-24 4 17 12 34- 26 6- 4 18 13 36-27 4 19 13 3e- 29 7- 4 20 14 4- 30 8-5

Attachment II to WM 05-0013 Page 1 of 8 10CFR50.55a Request Number 12R-30 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

-Alternative Provides Acceptable Level of Quality and Safety-1.ASME Code Comoonent(s) Affected Class 1 Pressure Retaining Piping Welds examined from the inside surface of Pressurized Water Reactors using procedures, personnel, and equipment qualified to ASME Section Xi, Appendix VIII, Supplement 2 or 10 criteria.

SAFE-END WELDS CODE CATEGORY B-F Code Item Description Weld No.

B5.10 Safe-end to Loop A RPV Inlet Nozzle RV-302-121-A (Note 1)

B5.10 Safe-end to Loop A RPV Outlet Nozzle RV-301-121-A (Note 1)

B5.10 Safe-end to Loop B RPV Inlet Nozzle RV-302-121-B (Note 2)

B5.10 Safe-end to Loop B RPV Outlet Nozzle RV-301-121-B (Note 2)

B5.10 Safe-end to Loop C RPV Inlet Nozzle RV-302-121-C (Note 2)

B5.10 Safe-end to Loop C RPV Outlet Nozzle RV-301-121-C (Note 2)

B5.10 Safe-end to Loop D RPV Inlet Nozzle V-302-121-D (Note 1)

B5.10 Safe-end to Loop D RPV Outlet Nozzle RV-301-121-D (Note 2)

SAFE-END WELDS CODE CATEGORY B-J Code Item Description Weld No. l B9.11 Elbow to Loop A RPV Inlet Safe-End Weld BB-01-F102 (Note 1)

B9.11 Pipe to Loop A RPV Outlet Safe-End Weld BB-01-F103 (Note 1)

B9.11 Elbow to Loop B RPV Inlet Safe-End Weld BB-01-F202 (Note 3)

B9.11 Pipe to Loop B RPV Outlet Safe-End Weld BB-01-F203 (Note 3)

B9.11 Elbow to Loop C RPV Inlet Safe-End Weld BB-01-F302 (Note 3)

B9.11 Pipe to Loop C RPV Outlet Safe-End Weld BB-01-F303 (Note 3)

B9.11 Elbow to Loop D RPV Inlet Safe-End Weld BB-01-F402 (Note 3)

B9.11 Pipe to Loop D RPV Outlet Safe-End Weld BB-01-F403 (Note 3)

Note 1:These welds are selected for examination by the WCNOC Risk-Informed ISI Program.

Note 2:Due to V. C. Summer hot leg nozzle cracking, it was decided that all inlet and outlet dissimilar metal nozzle-to-safe-end Cat. B-F welds are to be examined during Refuel 14 (Spring 2005).

Note 3:These stainless steel Cat. B-J welds are being examined due to the proximity to the dissimilar metal nozzle-to-safe-end Cat. B-F welds being examined for reasons identified in Notes 1 and 2.

Attachment II to WM 05-0013 Page 2 of 8 IOCFR50.55a Request Number 12R-30

2. Applicable Code Edition and Addenda

Wolf Creek Generating Station is in its second inservice inspection interval, which started on September 3, 1995 and ends on September 2, 2005. The applicable Code edition and addenda is ASME Section Xl, "Rules for Inservice Inspection of Nuclear Power Plant Components," 1989 Edition, with no Addenda. In addition, as required by 10 CFR 50.55a, ASME Section XI, 1995 Edition through 1996 Addenda is used for Appendix Vil, Performance Demonstration for Ultrasonic Examination Systems.

3. Applicable Code Requirement

Relief is requested from the qualification requirements contained in ASME Section Xl, 1995 Edition through 1996 Addenda, Appendix Vill Supplement 2 and Supplement 10 as specified in Table V11-3110-1, for applicable piping welds.

4. Reason for Request

Each Wolf Creek reactor pressure vessel (RPV) nozzle to main coolant piping configuration is fabricated using ferritic, austenitic, and cast stainless components and assembled using austenitic and dissimilar metal welds. These austenitic and dissimilar metal welds are in close proximity to each other, which means the same ultrasonic essential variables are used for each weld and the most challenging ultrasonic examination process is employed (e.g., the ultrasonic examination process associated with a dissimilar metal weld would be applied to a ferritic or austenitic weld).

With regard to qualification requirements for the inspection of such welds, separate qualifications to Supplements 2, 3, and 10 are redundant when done in accordance with the industry's Performance Demonstration Initiative (PDI) Program. For example, during a personnel qualification to the PDI Program, the candidate would be exposed to a minimum of 10 flawed grading units for each individual supplement. Personnel qualification to Supplements 2, 3, and 10 would therefore require a total of 30 flawed grading units. Test sets this large and tests of this duration are impractical.

Additionally, a full procedure qualification (i.e. 3 personnel qualifications) to the PDI Program requirements would require 90 flawed grading units. This is particularly burdensome for a procedure that will use the same essential variables or the same criteria for selecting essential variables for all 3 supplements.

To resolve these issues, the PDI Program recognizes the Supplement 10 qualification as the most stringent and technically challenging ultrasonic application. The same essential variables are used for the examinations subject to the requirements of Supplements 2, 3, and 10. A coordinated add-on implementation would be sufficiently stringent for qualification to the requirements of Supplements 2 and 3 if the requirements used for qualification to Supplement 10 are satisfied as a prerequisite.

The basis for this conclusion is the fact that the majority of the flaws addressed in Supplement 10 are located wholly in austenitic weld material. This configuration is known to be challenging for ultrasonic techniques due to the variable dendritic structure

Attachment II to WM 05-0013 Page 4 of 8 10CFR50.55a Request Number 12R-30

7. Precedents The NRC has granted similar relief to Callaway Plant [Reference AmerenUE Callaway Plant letter, dated August 14, 2003, Docket No. 50-483, "Requests for Relief Regarding Implementation of ASME Section Xi Appendix Vil Requirements", and the associated NRC Safety Evaluation, letter from Stephen Dembek to Garry Randolph (Union Electric Company) dated April 7, 2004;

Subject:

Callaway Plant Unit 1 - Relief Request ISI-27 through ISI-31 Pertaining to Implementation of ASME Section Xi Appendix VilI Requirements (TAC Nos. MC04478 through MC04482, respectively)].

Attachment II to WM 05-0013 Page 5 of 8 10 CFR 50.55a Request Number 12R-30 SUPPLEMENT 14 - QUALIFICATION REQUIREMENTS FOR COORDINATED IMPLEMENTATION OF SUPPLEMENT 10, 2 AND 3 FOR PIPING EXAMINATIONS PERFORMED FROM THE INSIDE SURFACE Proposed Requirements Technical Basis 1.0 SCOPE This Supplement is applicable to wrought There iscurrently no available Code action austenitic, ferritic and dissimilar metal piping allowing for a coordinated implementation of welds examined from the inside surface. This the fundamental qualifications required for the Supplement provides for expansion of typical examinations performed from the IDof Supplement 10 qualifications to permit PWR nozzles. Without this Code coordinated qualification for Supplements 2 and Case/Change, qualifications would require an

3. excessive amount of flawed and unflawed grading units. This proposed supplement uses the more technically stringent Supplement 10 qualification as a base and then incorporates a limited number of Supplement 2 and Supplement 3 samples. This proposal Is consistent with the philosophy of Supplement 12, the proposed changes to Supplement 10, and the approved changes to Supplement 2 and 11.

2.0 SPECIMEN REQUIREMENTS Qualification test specimens shall meet the requirements listed herein, unless a set of specimens is designed to accommodate specific limitations stated in the scope of the examination procedure (e.g., pipe size, access limitations). The same specimens may be used to demonstrate both detection and sizing qualification.

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

(a)Specimens shall have sufficient volume to minimize spurious reflections that may interfere with the interpretation process.

(b)The specimen set shall include the Tolerances are from the applicable minimum and maximum pipe diameters and Supplements because Supplement 2 and 3 thicknesses for which the examination procedure dimensions and tolerances are typically based isapplicable. Applicable tolerances are provided on wrought nominal pipe size that is not inSupplements 2, 3,and 10. appropriate for DM welds that are typically associated with forged and machined safe ends.

(c) The specimen set shall include examples of the following fabrication conditions:

(1) geometric and material conditions that normally require discrimination from flaws (e.g.,

counterbore or weld root conditions, cladding, weld buttering, remnants of previous welds, adjacent welds in dose proximity, and weld repair areas);

Attachment II to WM 05-0013 Page 6 of 8 10 CFR 50.55a Request Number 12R-30 SUPPLEMENT 14 - QUALIFICATION REQUIREMENTS FOR COORDINATED IMPLEMENTATION OF SUPPLEMENT 10, 2 AND 3 FOR PIPING EXAMINATIONS PERFORMED FROM THE INSIDE SURFACE Proposed Requirements Technical Basis (2) typical limited scanning surface conditions (e.g., internal tapers, exposed weld roots, and cladding conditions).

2.2 Supplement 2 Flaws (a) At least 70% of the flaws shall be cracks, the remainder shall be alternative flaws.

(b) Specimens with IGSCC shall be used when available.

(c) Alternative flaws, if used, shall provide crack-like reflective characteristics and shall comply with the following:

(1) Alternative flaws shall be used only when implantation of cracks produces spurious reflectors that are uncharacteristic of service-induced flaws.

(2) Alternative flaws shall have a tip width of less than or equal to 0.002 in. (0.05 mm).

2.3 Supplement 3 Flaws Supplement 3 flaws shall be mechanical or thermal fatigue cracks.

2.4 Distribution Since the number of flaws will be limited words The specimen set shall contain a representative such as "uniform distribution' could lead to distribution of flaws. Flawed and unflawed testmanship and are considered inappropriate.

grading units shall be randomly mixed.

3.0 PERFORMANCE DEMONSTRATION Personnel and procedure performance demonstration tests shall be conducted according to the following requirements.

(a) The same essential variable values, or, when appropriate, the same critieria for selecting values as demonstrated in Supplement 10 shall be used.

(b) The flaw location and specimen identification shall be obscured to maintain a 'blind test".

(c) 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.

3.1 Detection Test (a) The specimen set for Supplement 2 qualification shall include at least five flawed grading units and ten unflawed grading units in austenitic piping. A maximum of one flaw shall be oriented axially.

(b) The specimen set for Supplement 3

Attachment II to WM 05-0013 Page 7 of 8 10 CFR 50.55a Request Number 12R-30 SUPPLEMENT 14 - QUALIFICATION REQUIREMENTS FOR COORDINATED IMPLEMENTATION OF SUPPLEMENT 10, 2 AND 3 FOR PIPING EXAMINATIONS PERFORMED FROM THE INSIDE SURFACE Proposed Requirements Technical Basis qualification shall include at least three flawed grading units and six unflawed grading units in ferritic piping. A maximum of one flaw shall be oriented axially.

(c) Specimens shall be divided into grading units.

(1) Each grading unit shall include at least 3 in.

(76 mm) of weld length.

(2) The end of each flaw shall be separated from an unflawed grading unit by at least 1 in. (25 mm) of unflawed material. A flaw may be less than 3 in. (76 mm) in length.

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

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

(d) All grading units shall be correctly identified as being either flawed or unflawed.

3.2 Length-sizing Test (a) The coordinated implementation shall include the following requirements for personnel length sizing qualification.

(b) The specimen set for Supplement 2 Axial flaws are not length sized in Supplement qualification shall include at least four flaws in 2.

austenitic material.

(c) The specimen set for Supplement 3 qualification shall include at least three flaws in ferritic material.

(d) Each reported circumferential flaw in the detection test shall be length sized. When only length-sizing is being tested, the regions of each specimen containing a flaw to be sized may be identified to the candidate. The candidate shall determine the length of the flaw in each region.

(e) Supplement 2 or Supplement 3 examination procedures, equipment, and personnel are qualified for length-sizing when the flaw lengths estimated by ultrasonics, as compared with the true lengths, do not exceed 0.75 in. (19 mm)

RMS, when they are combined with a successful Supplement 10 qualification.

3.3 Depth-sizing Test _

The coordinated implementation shall include the following requirements for personnel depth-sizing qualification.

(a) The specimen set for Supplement 2 Axial flaws are not depth sized in Supplement qualification shall include at least four 2.

Attachment II to WM 05-0013 Page 8 of 8 10 CFR 50.55a Request Number 12R-30 SUPPLEMENT 14 - QUALIFICATION REQUIREMENTS FOR COORDINATED IMPLEMENTATION OF SUPPLEMENT 10, 2 AND 3 FOR PIPING EXAMINATIONS PERFORMED FROM THE INSIDE SURFACE Proposed Requirements Technical Basis circumferentially oriented flaws in austenitic material.

(b) The specimen set for Supplement 3 qualification shall include at least three flaws in ferritic material.

(c) For a separate depth-sizing test, the regions of each specimen containing a flaw to be sized may be identified to the candidate. The candidate shall determine the depth of the flaw in each region.

(d) Supplement 2 or Supplement 3 examination procedures, equipment, and personnel are qualified for depth-sizing when the flaw depths estimated by ultrasonics, as compared with the true depths, do not exceed 0.125 in. (3 mm)

RMS, when they are combined with a successful Supplement 10 qualification.

4.0 PROCEDURE QUALIFICATION Procedure qualifications shall include the following additional requirements.

(a) The specimen set shall include the equivalent of at least three personnel performance demonstration test sets. Successful personnel performance demonstrations may be combined to satisfy these requirements.

(b) Detectability of all flaws in the procedure qualification test set that are within the scope of the procedure shall be demonstrated. Length and depth sizing shall meet the requirements of 3.1, 3.2, and 3.3.

(c) At least one successful personnel demonstration shall be performed.

(d) To qualify new values of essential variables, at least one personnel performance demonstration is required. The acceptance criteria of 4.0(b) shall be met.

Attachment III to WM 05-0013 Page 1 of 4 10 CFR 50.55a Request Number 12R-31 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

-Alternative Provides Acceptable Level of Quality and Safety-

1. ASME Code Component(s) Affected ASME Category B-A Pressure Retaining Welds In Reactor Pressure Vessel (RPV), Item No. B1.30 upper shell to flange weld from flange Inside Diameter (ID).

Weld No.: RV-101-121

2. Applicable Code Edition and Addenda

Wolf Creek Generating Station is in its second inservice inspection interval, which started on September 3, 1995 and ends on September 2, 2005. The applicable Code edition and addenda is ASME Section Xl, "Rules for Inservice Inspection of Nuclear Power Plant Components," 1989 Edition, with no Addenda. In addition, as required by 10 CFR 50.55a, ASME Section XI, 1995 Edition through 1996 Addenda is used for Appendix Vil, Performance Demonstration for Ultrasonic Examination Systems.

3. Applicable Code Requirement

ASME Section Xl, "Rules for Inservice Inspection of Nuclear Power Plant Components,"

1989 Edition, No Addenda, Subsection IWA-2232 and Appendix I, Subparagraph I-2110, requires UT examination of the RPV shell-to-flange weld to be in accordance with ASME Code,Section V, Article 4. In addition, WCNOC has committed to follow Regulatory Guide 1.150, Revision 1, "Ultrasonic Testing of Reactor Vessel Welds during Preservice and Inservice Examinations," which augments the ultrasonic testing (UT) examination of RPV welds.

4. Reason for Reauest WCNOC is required to perform inservice examination of the RPV shell-to-flange weld in accordance with the requirements of ASME Section V Article 4 and the augmented requirements of Regulatory Guide 1.150 Rev 1.

10 CFR 50.55a Codes and Standards requires that ASME Section Xl, Appendix Vil, Supplement 4, "Qualification Requirements For The Clad/Base Metal Interface of Reactor Vessel," and Supplement 6, "Qualification Requirements For Reactor Vessel Welds Other Than Clad/Base Metal Interface," be implemented for most of the RPV welds by Nov 22, 2000. The RPV shell-to-flange and closure head-to-flange welds are not required to be conducted in accordance with Appendix Vil.

This relief is requested to allow the use of a Performance Demonstration Initiative (PDI) qualified procedure to complete the UT examination of the RPV shell-to-flange weld from the vessel ID surface of the weld in accordance with ASME Section Xl, Div. 1, 1995 Edition through 1996 Addenda, Appendix Vil Supplement 4 and 6 as amended by the 10 CFR 50.55a in lieu of ASME Section V, Article 4.

Attachment IlIl to WM 05-0013 Page 2 of 4 10 CFR 50.55a Request Number 12R-31

5. Proposed Alternative and Basis for Use During the upcoming ten (10) year RPV weld examinations, WCNOC will be employing personnel, procedures and equipment that are demonstrated and qualified by PDI and in accordance with ASME Section Xl, Div.1, 1995 Edition through 1996 Addenda, Appendix Vil, Supplements 4 and 6 as amended by 10 CFR 50.55a for applicable RPV welds.

The remote examinations will be performed using the Westinghouse SUPREEM Robot and the Paragon UT data acquisition system in accordance with a PDI qualified procedure. The Westinghouse procedure PDI-ISI-254, "Remote Inservice Examination of Reactor Vessel Shell Welds," in accordance with ASME Section Xl, Appendix VilI, Supplements 4 and 6, was demonstrated at the PDI qualification session in 2001 (Performance Demonstration Qualification Sheet (PDQS) No. 407). The procedure complies with ASME Section Xl, Appendix Vill, 1995 Edition through 1996 Addenda as modified by 10 CFR 50.55a.

Appendix Vil was developed to ensure the effectiveness of UT examinations within the nuclear industry by means of a rigorous, item-specific performance demonstration. The performance demonstration was conducted on a RPV mockup containing flaws of various sizes and locations. The demonstration established the capability of equipment, procedures, and personnel to find flaws that could be detrimental to the integrity of the RPV.

Although Appendix Vill is not a requirement for this weld, the qualification process to Appendix Vil criteria demonstrates that the examination and evaluation techniques are equal to or surpass the requirements of paragraph IWA-2232 and Appendix I subparagraph 1-2110 of Section Xl of the ASME Code and the guidance in RG 1.150.

A comparison between the ASME Code,Section V, Article 4 based UT methods and the procedures developed to satisfy the PDI/Appendix Vil can be best described as a comparison between a compliance-based procedure (ASME Code,Section V, Article 4) and a results-based procedure (PDI Appendix Vill). ASME Code,Section V procedures use an amplitude-based technique and a known reflector. The proposed alternate UT method was established independently from the acceptance standards for flaw size found in ASME Code, Section Xl.

The PDI qualified sizing method is considered more accurate than the method used in ASME Code,Section V, Article 4. The proposed alternate UT examination technique provides an acceptable level of quality and examination repeatability as compared to the Article 4 requirements.

The PDI Program's PDQS No. 407 attests that Westinghouse procedure PDI-ISI-254 is in compliance with the detection and sizing tolerance requirements of Appendix Vil.

The PDI qualification method is based on a group of samples, which validate the acceptable flaw sizes in ASME Section Xl. The sensitivity to detect these flaws is considered to be equal to or greater than the sensitivity obtained through ASME Section V Article 4 because the Westinghouse procedure PDI-ISI-254 relies on a smaller scan index and a higher scan sensitivity for the detection of the UT signals.

Attachment III to WM 05-0013 Page 3 of 4 10 CFR 50.55a Request Number 12R-31 The examination and sizing procedure uses echo-dynamic motion and tip diffraction characteristics of the flaw instead of the amplitude characteristics required by ASME Code,Section V, Article 4. The search units interrogate the same examination volume as depicted by ASME Code, Section Xl, Figure IWB-2500-4, 'Shell-to-Flange Weld Joint."

The use of procedures for satisfying the requirements of ASME Code,Section V, Article 4 for the UT examination of the RPV shell-to-flange weld from the vessel shell ID has not received the same qualifications as a PDI qualified procedure.

The PDI qualification specimens are curved vessel shell plate sections and do not have taper transition geometry. However, the procedure is used to examine reactor vessel shell welds, which have taper transitions at weld joints of dissimilar thickness. The PDI qualification for Supplements 4 and 6 allows for examination of material thickness up to 12.3 inches or a metal path distance of 17.5 inches in the case of the 45 degree transducer. This qualified test range bounds a significant percentage of the flange-to-shell weld examination volume even in the thicker portion above the weld centerline.

Wolf Creek's RPV flange-to-shell weld was examined during pre-service by remote automated inspection in accordance with Section Xl. The pre-service examination was performed from the vessel ID surface, using Section Xl techniques at 0 degree longitudinal and 45 and 60 degree shear beam angles. Examination from the flange surface was performed using 0, 8, and 19 degree longitudinal. For inservice examinations, during the first interval the weld examination from flange surface was performed in accordance with Section Xl using 0, 8, and 19 degree longitudinal. The weld IDsurface examination was performed using 45 and 60 degree shear wave, and 0, 45, and 70 degree longitudinal beam angles by remote automated inspection in accordance with Section Xl and Regulatory Guide 1.150 Revision 1. No matters of concern were identified during the aforementioned examinations.

The use of Appendix VIII Supplements 4 and 6 for the completion of the RPV shell-to-flange weld from the shell ID side (which PDI has qualified) is expected to reduce examination time, which translates to reduced personnel radiation exposure.

Additionally, this relief would allow a smooth transition to the welds adjacent to the RPV circumferential and longitudinal welds (welds B 1.11 and B 1.12), which do require an examination in accordance with Appendix VIII, Supplements 4 and 6. This would eliminate the need to switch to the different calibrations, procedure, and technique required by ASME Code,Section V, Article 4 and Regulatory Guide 1.150, Rev 1. This would result in a reduction in transition time to the different calibration, procedure, and technique required, which translates to reduced personnel radiation exposure and is more cost effective.

For ultrasonic examination of the reactor vessel shell-to-flange weld conducted from the face of the flange, the examination procedure shall continue to meet the requirements of the 1989 Edition of ASME Section Xl, Category B-A and ASME Section V, Article 4 as

Attachment IlIl to WM 05-0013 Page 4 of 4 10 CFR 50.55a Request Number 12R-31 augmented by Regulatory Guide 1.150 Rev. 1. This examination has already been completed and is not part of the reactor vessel examinations to be performed in conjunction with the 10-year vessel examinations in Refuel 14.

Alternate Examinations The automated shell-to-flange weld examinations from the shell inside diameter shall be performed using a qualified procedure in accordance with ASME Code, Section Xl, Div.

1, 1995 Edition through 1996 Addenda, Appendix Vill, Supplements 4 and 6 as amended by 10 CFR 50.55a. All other ASME Section Xl Code requirements for which relief is not specifically requested remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.

The Appendix Vill criteria were developed to ensure the effectiveness of UT examinations within the nuclear industry by means of a rigorous, item-specific performance demonstration. The performance demonstration was conducted on RPV mockups containing flaws of various sizes and locations. The demonstration established the capability of equipment, procedures, and personnel to find flaws that could be detrimental to the integrity of the RPV. The performance demonstration showed that the proposed UT technique is equal to or surpasses the requirements of the Code and the recommendations of Regulatory Guide 1.150. Therefore, there is reasonable assurance that the proposed alternative provides an acceptable level of quality and safety.

6. Duration of Proposed Alternative The proposed alternative is requested for the duration of the second inservice inspection interval.

7. Precedents The NRC has granted similar relief to Callaway Plant [Reference AmerenUE Callaway Plant letter, dated August 14, 2003, Docket No. 50-483, "Requests for Relief Regarding Implementation of ASME Section Xl Appendix Vil Requirements", and the associated NRC Safety Evaluation, letter from Stephen Dembek to Garry Randolph (Union Electric Company) dated April 7, 2004;

Subject:

Callaway Plant Unit 1 - Relief Request ISI-27 through ISI-31 Pertaining to Implementation of ASME Section Xi Appendix VilI Requirements (TAC Nos. MC04478 through MC04482, respectively)].

Attachment IV to WM 05-0013 Page 1 of 8 10 CFR 50.55a Request Number 12R-32 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)

--Alternative Provides Acceptable Level of Quality and Safety-

1. ASME Code Component(s) Affected Class I Reactor Pressure Vessel Pressure-Retaining Nozzle-to-Vessel welds.

NOZZLE WELDS CODE CATEGORY B-D Code Item Description Weld No.

B3.90 Loop A Outlet Nozzle to Vessel Weld RV-107-121-A B3.90 Loop A Inlet Nozzle to Vessel Weld RV-105-121-A B3.90 Loop B Inlet Nozzle to Vessel Weld RV-105-121-B B3.90 Loop B Outlet Nozzle Vessel Weld RV-107-121-B B3.90 Loop C Outlet Nozzle to Vessel Weld RV-1 07-121-C B3.90 Loop C Inlet Nozzle to Vessel Weld RV-1 05-121-C B3.90 Loop D Inlet Nozzle to Vessel Weld RV-105-121-D B3.90 Loop D Outlet to Vessel Weld RV-107-121-D

2. Applicable Code Edition and Addenda

Wolf Creek Generating Station is in its second inservice inspection interval, which started on September 3, 1995 and ends on September 2, 2005. The applicable Code edition and addenda is ASME Section Xl, "Rules for Inservice Inspection of Nuclear Power Plant Components," 1989 Edition, with no Addenda. In addition, as required by 10 CFR 50.55a, ASME Section Xl, 1995 Edition through 1996 Addenda is used for Appendix VIII, Performance Demonstration for Ultrasonic Examination Systems.

3. Applicable Code Requirement

ASME Section Xl 1989 Edition with no addenda, Table IWB-2500-1, Examination Category B-D, Item B3.90, Figure IWB-2500-7(a) requires volumetric examination of a minimum volume of base material on each side of the weld equal to a distance of t'/2 (one half of the RPV shell thickness adjacent to the weld).

4. Reason for Request

The required examination volume for the RPV nozzle-to-shell welds extends far beyond the weld into the base material and is unnecessarily large. The Section Xl examination volume for the pressure retaining nozzle-to-vessel welds extends from the edge of the weld on the nozzle side and includes a substantial portion of the nozzle forging (radially inward) and the RPV upper shell course (radially outward). This large volume causes a major increase in examination time with no resultant increase in quality or safety. The proposed alternative would define the examination volume as the weld and one-half inch of base material on each side of the widest portion of the weld. The Code required examination volume defined by Figure IWB-2500-7(a) was ultrasonically examined during preservice and subsequent inservice examinations to the maximum extent

Attachment IV to WM 05-0013 Page 2 of 8 10 CFR 50.55a Request Number 12R-32 possible. The preservice examination and the first interval inservice examinations identified no recordable indications in the Code required volume that were outside of the volume defined in Code Case N-613-1, Figure 1. Relief is requested to use the examination volume shown in Code Case N-613-1 Figure 1 in lieu of the examination volume requirements of ASME Section Xl, Figure IWB-2500-7(a), 1989 Edition with no addenda.

5. Proposed Alternative and Basis for Use In lieu of the requirements of ASME Section Xl, Figure IWB-2500-7(a), WCNOC proposes to reduce the examination volume to that shown in Figure 1 of Code Case N-613-1. All other ASME Section Xl Code requirements for which relief is not specifically requested remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.

The proposed examination volume for the inlet and outlet nozzles is shown on the attached vendor scan plans. The scan plans are derived from the vessel manufacturer design drawings, which are the most dependable source for weld location, size and thickness. As added conservatism, the vendor scan plans have included an additional 0.5 inch of radial scan path on each side of the weld to ensure that the boundaries of the weld are covered by the ultrasonic beams.

Stresses caused by welding are concentrated at the weld and heat affected zone. Post weld heat treatment reduces these stresses and any residual stresses decrease as a function of the distance from the weld.

Operational stresses originate from internal pressure in the vessel and temperature changes occurring during transients. These stresses are limited by design to ensure that ASME Code stress limits are not exceeded. Additionally, a fatigue analysis is required by ASME Section III to ensure that flaws are unlikely to initiate during operation.

Compared to the Code limit of 1.0, the maximum fatigue usage in the nozzle-to-shell weld regions are 0.1104 for the inlet nozzles and 0.324 for the outlet nozzles.

Therefore, because stresses are reduced by post weld heat treatment and design requirements, the occurrence of flaws during service is unlikely in the volume excluded by the use of Case N-613-1. Cracks, should they initiate, occur in the higher stressed area of the weld. The higher stressed areas are within the volume included in the reduced examination volume of Case N-613-1.

During preceding preservice and first interval ultrasonic examinations, no recordable indications were found in the RPV nozzle to vessel weld examination volume excluded by Code Case N-613-1. These examinations were conducted from the inside surface of the RPV and the inside diameter of the nozzle in accordance with ASME Section V, Article 4 and Regulatory Guide 1.150, Rev. 1. The previous ultrasonic examinations used an automated system to acquire, analyze and store data. The ultrasonic examinations scheduled for the current interval will use personnel, automated equipment and procedures qualified in accordance with ASME Section Xl, Appendix Vil, Supplements 4, 6 and 7, 1995 Edition through the 1996 Addenda, as amended by 10 CFR 50.55a. These Section Xl Appendix Vil examinations will interrogate the weld

Attachment IV to WM 05-0013 Page 3 of 8 10 CFR 50.55a Request Number 12R-32 and base metal volume specified in Code Case N-613-1 from the nozzle bore and from the vessel inside diameter surface using techniques and procedures specifically qualified to inspect nozzle-to-vessel welds. These procedures were qualified in accordance with ASME Section Xl, Appendix Vill, Supplement 7 for examinations from the nozzle bore and Supplements 4 and 6 for examinations from the vessel inside diameter surface, as amended by 10 CFR 50.55a. WCNOC is confident that satisfactory comparisons can be made between past and present examinations, if necessary.

The following table provides additional information on the RPV nozzles:

Component Description Azimuth Code Case Full Exam Previous Repair in ID N-613-1 Coverage Weld Code Case Figure Completed' Repair Boundary RV-107- Outlet Nozzle 220 1 PSI and 1" No N/A 121-A to Shell Weld l Interval ISI RV-105- Inlet Nozzle 670 1 PSI and I" No N/A 121-A to Shell Weld Interval ISI RV-105- Inlet Nozzle 1130 1 PSI and 1" No N/A 121-B to Shell Weld Interval ISI RV-107- Outlet Nozzle 1580 1 PSI and 1" No N/A 121-B to Shell Weld Interval ISI RV-107- Outlet Nozzle 2020 1 PSI and 1" No N/A 121-C to Shell Weld Interval ISI RV-105- Inlet Nozzle 2470 1 PSI and 1" No N/A 121-C to Shell Weld Interval ISI RV-105- Inlet Nozzle 2930 1 PSI and I" No N/A 121-D to Shell Weld Interval ISI RV-107- Outlet Nozzle 3380 1 PSI and I" No N/A 121-D to Shell Weld Interval ISI Note 1: Coverage of the examination volume as shown in ASME Section Xl, Figure IWB-2500-7(a) was performed to the maximum extent possible using a combination of angles to achieve maximum coverage but was limited due to the scanning requirements contained in ASME Section V, Article 4 which was used to examine these welds in the first interval. The Preservice examinations were also performed to the maximum extent possible but were also limited.

Note 2: Station personnel investigated the weld repair issue and it is confidently concluded that no weld repairs were performed since original construction.

The on-site documentation of the vessel fabrication was reviewed. No evidence was found of weld repairs being made to the nozzle-to-shell welds.

For the reasons discussed above, the proposed alternative will provide an acceptable level of quality and safety.

Attachment IV to WM 05-0013 Page 4 of 8 10 CFR 50.55a Request Number 12R-32

6. Duration of Proposed Alternative The proposed alternative is requested for the duration of the second inservice inspection interval.

7. Precedents The NRC has granted similar relief to Duke Power for Catawba Unit 2 [Reference Duke letters dated August 6, 2004, Docket No. 50-414, "Relief Request for Altemative to ASME Section Xl Appendix ", and dated September 15, 2004, Docket No. 50-414, "Response to Request for Additional Information", and the associated NRC Safety Evaluation dated October 7, 2004.]

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