View source for NL-19-0674, Proposed Alternative to Use ASME Code Case N-831-1, Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic or Austenitic Pipe Section XI, Division 1

{{Adams
| number = ML19273A926
| issue date = 09/30/2019
| title = Proposed Alternative to Use ASME Code Case N-831-1, Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic or Austenitic Pipe Section XI, Division 1
| author name = Gayheart C
| author affiliation = Southern Nuclear Operating Co, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000321, 05000348, 05000364, 05000366, 05000424, 05000425
| license number = 
| contact person = 
| case reference number = NL-19-0674
| document type = Letter type:NL, Report, Technical
| page count = 7
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:A Southern Nuclear                                  Cheryl A. Gayheart Regulatory Affairs Director 3535 Colonnade Parkway Birmingham, AL 35243 205 992 5316 tel cagayhea@southernco.com September 30,2019 Docket No.:     50-424   50-348     50-321                                             NL-19-0674 50-425   50-364     50-366 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Units 1&2 Joseph M. Farley Nuclear Plant Units 1&2 Vogtle Electric Generating Plant Units 1&2 Proposed Alternative to Use ASME Code Case N-831-1, Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic or Austenitic Pipe Section XI. Division 1 Ladies and Gentlemen:
Pursuant to 10 CFR 50.55a(z)(1), Southern Nuclear Operating Company (SNC) hereby requests Nuclear Regulatory Commission (NRC) approval of proposed Alternative GEN-ISI-ALT-2019-01. The ASME Section XI Code requires that certain ferritic and austenitic pipe welds be examined using radiographic examination techniques to satisfy nondestructive examination requirements.
SNC requests approval to use encoded Phased Array Ultrasonic Examination Techniques (PAUT) in accordance with ASME Section XI Code Case N-831-1, Ultrasonic Examination In Lieu of Radiography for Welds in Ferritic or Austenitic Pipe, as an alternative to radiographic examination. SNC considers the proposed alternative would provide an acceptable level of quality and safety. Enclosure 1 to this letter provides the basis for the proposed alternative.
NRC review and approval of the proposed alternative is respectfully requested by September 30, 2020. This timeline will support anticipated piping repair and replacement activities for the next upcoming refueling outages, currently scheduled to occur during fall 2020.
This letter contains no NRC commitments. If you have any questions, please contact Jamie Coleman at 205.992.6611.

U. S. Nuclear Regulatory Commission NL-19-0674 Page 2 Respectfully submitted, art Regulatory Affairs Director CAG/DSP/sm ENCLOSURE: Proposed Alternative GEN-ISI-ALT-2019-01 Cc:    Regional Administrator, Region II NRR Project Manager- Farley, Hatch, Vogtle 1 & 2 Senior Resident Inspector- Farley, Hatch, Vogtle 1 & 2 RTYPE: CGA02.001

Edwin I. Hatch Nuclear Plant - Units 1 and 2 Joseph M. Farley Nuclear Plant - Units 1 and 2 Vogtle Electric Generating Plant - Units 1 and 2 Proposed Alternative to Use ASME Code Case N-831-1, Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic or Austenitic Pipe Section XI, Division 1 Enclosure Proposed Alternative GEN-ISI-ALT-2019-01

Enclosure to NL-19-067 4 Proposed Alternative GEN-ISI-ALT-2019-01 10 CFR 50.55a Request No. GEN-ISI-ALT -2019-01 Implementation of Code Case N-831-1 Farley, Vogtle, and Hatch Nuclear Plants Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)
Acceptable Level in Quality and Safety
: 1. ASME Code Component(s) Affected American Society of Mechanical Engineers (ASME) Boiler & Pressure Vessel (B&PV) code, Section XI ferritic and austenitic piping welds requiring radiography during repair/replacement activities.
: 2. Requested Date for Approval Approval is requested by September 30, 2020.

===3. Applicable Code Edition and Addenda===
The following table identifies the ASME Section XI Code of Record for performing lnservice Inspection (lSI) activities at each applicable Southern Nuclear (SNC) site.
Interval lSI       ASME Section XI          Interval Plant            Interval      Edition/Addenda                      Scheduled Start End Farley Nuclear Plant,                  2007 Edition/2008 5                               12/01/2017     11/30/2027 Units 1 and 2                          Addenda Hatch Nuclear Plant,                   2007 Edition/2008 5                               01/01/2016     12/31/2025 Units 1 and 2                          Addenda Vogtle Nuclear Plant,                  2007 Edition/2008 4                               05/31/2017     05/30/2027 Units 1 and 2                          Addenda
: 4. Applicable ASME Code Requirements The 2007 Edition through the 2008 Addenda of ASME Section XI, paragraph IWA-4221 requires that items used for repair/replacement activities meet the applicable Owner's Requirements and Construction Code requirements when performing repair/replacement activities. IWA-4520 requires that welded joints made for fabrication or installation of items be examined in accordance with the Construction Code identified in the Repair/
Replacement Plan.

===5. Reason for Request===
Replacement of piping is periodically performed in support of the Flow Accelerated Corrosion (FAC) Program as well as other repair/replacement activities. The use of encoded Phased Array Ultrasonic Examination Techniques (PAUT) in lieu of radiography (RT) to perform the required examinations of fabrication, installation, or repair welds would eliminate the safety risk associated with performing RT, which includes both planned and unplanned radiation exposure to plant workers. PAUT also minimizes the impact on other outage activities normally involved with performing RT such as limited access to work locations. In addition, encoded PAUT is equivalent or superior to the code-required RT E-1

Enclosure to NL-19-0674 Proposed Alternative GEN-ISI-ALT-2019-01 examination for ASME ferritic and austenitic piping repair/replacement welds for detecting and sizing critical (planar) flaws such as cracks and lack of fusion. PAUT provides sizing capabilities for both depth and length dimensions of the flaw, which are required to apply the acceptance criteria of the applicable code case. RT does not provide depth sizing capabilities. This proposed alternative is requested to support both planned and unplanned piping repair and replacement activities.
: 6. Proposed Alternative The use of encoded PAUT is proposed in lieu of the code-required RT examination for ASME ferritic and austenitic piping repair/replacement welds. Similar techniques are being used throughout the nuclear industry for examination of dissimilar metal welds, overlaid welds, as well as other applications including 831.1 piping replacements. This proposed alternative request includes requirements that provide an acceptable level of quality and safety that satisfies the requirements of 10 CFR 50.55a(z)( 1). The capability of the alternative technique is comparable to the examination methods documented in the ASME Code Sections Ill, VIII, and IX, and associated code cases (References 9.1, 9.3, 9.4, 9.5, 9.7, 9.8, 9.9, 9.10, 9.11, 9.12, and 9.13) using ultrasonic examination techniques for weld acceptance. The examinations will be performed using procedures, equipment, and qualified personnel as defined in ASME Code Case N-831-1. The RMS Grading equation, as shown in the 2007 Edition through the 2008 Addenda of ASME Section XI, Article Vlll-3120(d), will be utilized in lieu of the incorrect equation in Section 7(d) of N-831-1.
II
                                                   ~ (111; - f;)~ll/2 RMS =
[      1
                                                   -'=- - - -
where m;  = measured flaw size f; = true flaw size n = number of flaws measured 6.1 Basis for Use The basis for this proposed alternative is that PAUT is equivalent or superior toRT for detecting and sizing critical (planar) flaws. In this regard, the basis for the proposed alternative was developed from numerous codes, code cases, associated industry experience, articles, and the results of RT and encoded PAUT examinations. The examination procedure and personnel performing examinations are qualified using representative piping conditions and flaws that demonstrate the ability to detect and size flaws that are both acceptable and unacceptable to the defined acceptance standards.
The demonstrated ability of the examination procedure and personnel to appropriately detect and size flaws provides an acceptable level of quality and safety alternative as allowed by 10 CFR 50.55a(z)(1 ).
It should also be noted that Code Case N-831 (Revision 0), which provides rules for performing ultrasonic examination of welds in ferritic piping in lieu of RT, is listed in Table 2, "Conditionally Accepted Section XI Code Cases," of Draft Regulatory Guide DG-1342. As stated in the Proposed Rule published in Vol. 83, No. 159 of the Federal Register, dated E-2

Enclosure to NL-19-0674 Proposed Alternative GEN-ISI-ALT-2019-01 Thursday, August 16, 2018, ''The NRC finds the Code Case acceptable with the condition that it is prohibited for use in new reactor construction."
: 7. Duration of Proposed Alternative Use of the proposed alternative is requested for the duration of the lSI intervals identified in Section 3.
: 8. Precedents 8.1    Palo Verde Nuclear Generating Station Relief Request 48, dated August 1, 2012 (ML12229A046). NRC approval dated April12, 2013 (ML13091A177).
8.2    Millstone Power Station Unit 2 Alternative Request RR-04-16, dated August 1, 2013 (ML13220A019). NRC approval dated April4, 2014 (ML14091A973).
8.3    Millstone Power Station Unit 2 Alternative Request RR-04-21, dated October 6, 2014 (ML14283A128). NRC approval dated September 21, 201S (ML 1S2S7ADOS).
8.4    Millstone Power Station Unit 3 Alternative Request IR-3-2S, dated October 6, 2014 (ML14283A128). NRC approval dated September 21, 201S (ML 1S2S7ADOS).
8.5    Millstone Power Station Unit 2 Alternative Request RR-04-023, dated April 11, 2016 (ML 161 06A 1OS). NRC approval dated January 23, 2017 (ML16363A089).
8.6    Millstone Power Station Unit 3 Alternative Request IR-3-28, dated April 11, 2016 (ML 16106A10S). NRC approval dated January 23, 2017 (ML16363A089).
8.7    Millstone Power Station, Units 2 and 3; North Anna Power Station, Units 1 and 2; and Surry Power Station, Units 1 and 2; Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination, dated June 29, 2017 (ML17188A379). NRC approval dated January 24, 2018 (ML 18019A 19S).
8.8    Millstone Power Station, Units 2 and 3; Proposed Alternative Requests RR-04-27 and IR-3-38, Use of Encoded Phased Array Ultrasonic Examination Techniques in Lieu of Radiography, dated February 28, 2018 (ML 18066AS22). NRC approval dated September 17,2018 (ML182S2A003).
8.9    Surry Power Station, Units 1 and 2; Proposed Alternative Requests S1-1S-ISI-04 and S2-1S-ISI-04, Use of Encoded Phased Array Ultrasonic Examination Techniques in Lieu of Radiography, dated April 11, 2018 (ML 181 DBA 123). NRC approval dated September 26, 2018 (ML18236A236).
8.10   South Texas Project, Units 1 and 2; Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination Techniques in Lieu of Radiography; Relief Request RR-ENG-3-22, dated December 12, 2017 (ML173468279). NRC approval dated July 24, 2018 (ML18187A149).
8.11   Exelon Generation Company, LLC, "Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination Techniques In Lieu of Radiography," dated November 2, 2016 and amended by letter dated March 13, 2017 (ML 16307A2S3 and ML 17072A38S respectively). NRC approval dated June S, 2017 (ML 171SOA091 ).
E-3

Enclosure to NL-19-0674 Proposed Alternative GEN-ISI-ALT-2019-01
: 9. References 9.1   ASME Section Ill Code Case N-659-2, "Use of Ultrasonic Examination in Lieu of Radiography for Weld Examination Section Ill, Divisions 1 and 3," dated June 9, 2008.
9.2   Pacific Northwest National Laboratory Report PNNL-19086, "Replacement of Radiography with Ultrasonics for the Nondestructive Inspection of Welds- Evaluation of Technical Gaps- An Interim Report," dated April 2010.
9.3   ASME B31.1, Case 168, "Use of Ultrasonic Examination in Lieu of Radiography for B31.
1 Application," dated June 1997.
9.4   ASME Section Ill, Code Case N-818, "Use of Analytical Evaluation approach for Acceptance of Full Penetration Butt Welds in Lieu of Weld Repair," dated December 6, 2011.
9.5   ASME Code Case 2235-9; "Use of Ultrasonic Examination in Lieu of Radiography Section I, Section VIII, Divisions 1 and 2, and Section XII," dated October 11, 2005.
9.6   Journal of Pressure Vessel Technology, ''Technical Basis for ASME Section VIII Code Case 2235 on Ultrasonic Examination of Welds in Lieu of Radiography;" Rana, Hedden, Cowfer and Boyce, Volume 123, dated August 2001.
9.7   ASME Code Case 2326, "Ultrasonic Examination in Lieu of Radiographic Examination for Welder Qualification Test Coupons Section IX," dated January 20, 2000.
9.8   ASME Code Case 2541 , "Use of Manual Phased Array Ultrasonic Examination Section V," dated January 19, 2006.
9.9   ASME Code Case 2558, "Use of Manual Phased Array E-Scan Ultrasonic Examination Per Article 4 Section V'', dated December 30, 2006.
9.10  ASME Code Case 2599, "Use of Linear Phased Array E-Scan Ultrasonic Examination Per Article 4 Section V," dated January 29, 2008.
9.11  ASME Code Case 2600, "Use of Linear Phased Array S-Scan Ultrasonic Examination Per Article 4 Section V," dated January 29, 2008.
9.12  ASME Section XI, Code Case N-713, "Ultrasonic Examination in Lieu of Radiography,"
dated November 10, 2008.
9.13  ASME Section XI, Code Case N-831, "Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic Pipe," dated October 20, 2016.
9.14  ASME Section XI, Code Case N-831-1, "Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic or Austenitic Pipe," dated July 25, 2018.
9.15  US NRC, NUREG/CR-7204, "Applying Ultrasonic Testing in Lieu of Radiography for Volumetric Examination of Carbon Steel Piping" (ML15253A674).
9.16  Technical Basis for Substituting Ultrasonic Testing for Radiographic Testing for New, Repaired, and Replacement Welds for ASME Section XI, Division 1, Stainless Steel Piping. EPRI, Palo Alto, CA: 2017. 3002010297 E-4}}