View source for NL-03-0596, Joseph M. Farley Nuclear Plant, Vogtle Electric Generating Plant, Response to RIS 2003-01 and Request for Technical Alternative to ASME Section Xl, Appendix Viii, Supplement 10

{{Adams
| number = ML031390028
| issue date = 05/14/2003
| title = Joseph M. Farley Nuclear Plant, Vogtle Electric Generating Plant, Response to RIS 2003-01 and Request for Technical Alternative to ASME Section Xl, Appendix Viii, Supplement 10
| author name = Gasser J
| 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 = DPR-057, NPF-002, NPF-005
| contact person = 
| case reference number = NL-03-0596, RIS-03-001
| document type = Letter type:NL
| page count = 24
| project = 
| stage = Supplement
}}

=Text=
{{#Wiki_filter:Jeffrey T.Gasser             Southern Nuclear Vice President               Operating Company, Inc.
40 Inverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.7721 Fax 205.992.0403 SOUTHERN May 14, 2003                                                                          COMPANY Energy to Serve Your World" Docket Nos.:        50-321      50-348       50-424                           NL-03-0596 50-366      50-364       50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Joseph M. Farley Nuclear Plant Vogtle Electric Generating Plant Response to RIS 2003-01 and Request for a Technical Altemative to ASME Section XI. Appendix VIII, Supplement 10 Ladies and Gentlemen:
On January 21, 2003, the NRC issued Regulatory Issue Summary (RIS) 2003-01, "Examination of Dissimilar Metal Welds, Supplement 10 to Appendix VIII of Section XI ofthe ASME Code." 10 CFR 50.55a(g)(6)(ii)(C) requires the implementation of Supplement 10 to Appendix VIII of the 1995 Edition with the 1996 Addenda to the ASME Section XI Code for the qualification requirements for dissimilar metal piping welds. The required implementation date for Supplement 10 is November 22, 2002. The NRC stipulates in RIS 2003-01 that:
* Facilities that do not have a program in place by November 22, 2002, to implement Supplement 10 to Appendix VIII of Section XI of the ASME Code are noncompliant with 10 CFR 50.55a(g)(6)(ii)(C), irrespective of when the actual examination of dissimilar metal welds must be conducted.
* A program that implements Supplement 10 is considered to be one that has in place qualified procedures, equipment, and personnel, not one that merely references or stipulates the use of qualified procedures, equipment, and personnel.
* The significance of this noncompliance is such that enforcement action is not warranted.
* Failure to implement Supplement 10 when such examinations must be performed, either in the course of normal inservice inspection program requirements or to fulfill unanticipated examination needs, is considered safety significant and is a performance deficiency under the Reactor Oversight Process.
* System operability may be affected until the regulatory noncompliance has been remedied and all regulatory requirements are met or appropriate regulatory relief is granted.
01`7

U. S. Nuclear Regulatory Commission NL-03-0596 Page 2 In retrospect, at the time Appendix VIII was added to the Code in the 1989 Addenda, the industry recognized that compliance with Appendix VIII would be complex and expensive. In response to this issue, the Performance Demonstration Initiative (PDI) was initiated with 100% membership of U.S. nuclear power plants and program management by the Electric Power Research Institute (EPRI). PDI's role was to develop cost-effective generic methods and techniques to satisfy the Code. PDI and EPRI have been successful in this effort to date. Representatives from EPRI and PDI, as well as the NRC, have worked with Section XI since 1991 to develop Code changes and Code Cases as needed to correct technical inadequacies in the Code and to facilitate Appendix VIII implementation. ASME Section XI Code Cases are currently being developed that will result in a better alignment between the PDI program and Supplement 10; however, until these Code Cases are approved, a technical alternative is needed. In the interim, PDI has developed a generic industry request for a technical alternative using PDI-developed proposed revisions to the requirements of Supplement 10 to Appendix VIII. The proposed revisions to Supplement 10 have been submitted to ASME Section XI for consideration and were approved by the ASME Section XI Subcommittee in February 2003. Final ASME Code approval is pending.
With respect to the Joseph M. Farley Nuclear Plant (FNP), Edwin I. Hatch Nuclear Plant (HNP), and Vogtle Electric Generating Plant (VEGP), there are no dissimilar metal welds scheduled for examination during their next scheduled refueling outages. In addition, there have not been any dissimilar metal welds examined since November 22, 2002, at these plants. However, when dissimilar metal weld examinations are performed, Southern Nuclear Operating Company (SNC) will use personnel, procedures, and equipment that meet the provisions of Supplement 10 as modified by PDI to the extent practical. If satisfying any provision of Supplement 10 as modified by PDI is not practical (e.g., depth sizing), the best available technical approach will be used on a case-by-case basis and the NRC will be notified accordingly.
Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), SNC hereby requests NRC approval for FNP, HNP, and VEGP to use the PDI-developed generic industry request for a technical alternative that incorporates PDI-developed proposed revisions to the requirements of Supplement 10 to Appendix VIII in lieu of the requirements of Supplement 10 to Appendix VIII of the 1995 Edition with the 1996 Addenda to the ASME Section XI Code. The details of the 0CFR50.55a request (SNC Generic Request number GR 01) are enclosed with proposed revisions identified by bold print or by line out.
Southern Nuclear Operating Company requests approval by August 31, 2003, in order to support possible unscheduled dissimilar metal weld examinations that may be required by scope expansions during the fall 2003 VEGP Unit 1 refueling outage.

U. S. Nuclear Regulatory Commission NL-03-0596 Page 3 If you have any questions or require additional information, please contact D. Rick Graham at (205) 992-5808.
Sincerely, Jeffrey T. Gasser JTG/DRG

==Enclosure:==
Generic Request for Alternative GR-03-01 cc:    Southern Nuclear Operating Company Mr. J. D. Woodard, Executive Vice President Mr. J. B. Beasley, Jr., Vice President, Plant Farley Mr. H. L. Sumner, Jr., Vice President, Plant Hatch Mr. D. E. Grissette, General Manager - Plant Farley Mr. G. R. Frederick, General Manager - Plant Hatch Mr. W. F. Kitchens, General Manager - Plant Vogtle Document Services RTYPE: CFA04.054; CHAO2.004; CVC7000; LC# 13759 U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. F. Rinaldi, NRR Project Manager - Farley Mr. L. N. Olshan, NRR Project Manager - Hatch Mr. F. Rinaldi, NRR Project Manager - Vogtle Mr. T. P. Johnson, Senior Resident Inspector - Farley Mr. N. P. Garrett, Acting Senior Resident Inspector - Hatch Mr. J. Zeiler, Senior Resident Inspector - Vogtle

Enclosure Joseph M. Farley Nuclear Plant Edwin I. Hatch Nuclear Plant Vogtle Electric Generating Plant Generic Request for Alternative GR-03-01

Joseph M. Farley Nuclear Plant Edwin I. Hatch Nuclear Plant Vogtle Electric Generating Plant 10 CFR 50.55a Request Number GR-03-01 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)
  -- Alternative Provides Acceptable Level of Quality and Safety--
SYSTEM/COMPONENT (S) FOR WHICH RELIEF IS REQUESTED Pressure Retaining Piping Welds subject to examination using procedures, personnel, and equipment qualified to ASME Section Xl, Appendix VIII, Supplement 10 criteria.
CODE REQUIREMENTS The following paragraphs or statements are from ASME Section Xl, Appendix VIII, Supplement 10 and identify the specific requirements that are included in this request for relief.
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(d)(1) 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.
Enclosure                               Page 1 of 20

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 Vil-S2-1 provides the false call criteria when the number of unflawed grading units is at least twice the number of flawed grading units.
RELIEF REQUESTED Relief is requested to use the following alternative requirements for implementation of Appendix VIII, Supplement 10 requirements. They will be implemented through the PDI Program.
A copy of the proposed revision to Supplement 10 is attached. It identifies the proposed alternatives and allows them to be viewed in context. It also identifies additional clarifications and enhancements for information. It has been submitted to the ASME Code for consideration and as of February 2003 had been approved by the ASME Section Xi Subcommittee.
BASIS FOR RELIEF 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 a range of 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 the nominal diameter minus 0.5 inch Enclosure                              Page 2 of 20

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, if used, shall provide crack-like reflective characteristics and shall be limited to the case where implantation of cracks produces spurious reflectors that are uncharacteristic of actual flaws. Alternative flaw mechanisms shall have a tip width of less than or equal to 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.
(E,,cavaAfi,,     Mechanical fatigue crack 1     5 iin            Base material 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 a maximum of 10% of the flaws shall be in ferritic base material. At least one and a maximum of 10% of the flaws shall be in austenitic base material."
Enclosure                               Page 3 of 20

Technical Basis - Under the current Code, as few as 25% of the flaws are contained in austenitic weld or buttering material. Recent experience has indicated that flaws contained within the weld are the likely scenarios. The metallurgical structure of austenitic weld material is ultrasonically more challenging than either ferritic or austenitic base material. The proposed altemative is therefore more challenging than the current Code.
Item 4 - The proposed alternative to Paragraph 1.2(b) states:
"Detection sets shall be selected from Table VIII-SIO-1. The number of unflawed grading units shall be at least one and a half times the number of flawed grading units."
Technical Basis - Table S10-1 provides a statistically based ratio between the number of unflawed grading units and the number of flawed grading units. The proposed altemative reduces the ratio to 1.5 times to reduce the number of test samples to a more reasonable number from the human factors perspective. However, the statistical basis used for screening personnel and procedures is still maintained at the same level with competent personnel being successful and less skilled personnel being unsuccessful. The acceptance criteria for the statistical basis are in Table VIl-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 altemative 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.
Enclosure                             Page 4 of 20

Item 6 - The proposed altemative 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 altemative 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 altematives 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 altemative 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 altemative modifies the acceptance criteria of Table VIII-S2-1 as follows:
Enclosure                             Page 5 of 20

TABLE VIII-S         ECS 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
                                   ,                10                   0 6                  6                11 7                  6                14                   1 8                  7                lb                   2 9                  :7               10                   2 10                   8                20- 15               3-2 211                  9                2- 17                3 12                  9                24-18                3 13                 10                2-20                 4-3 14                 10                2{ 21                5-3 15                 11                3-23                     3 16                 12                3-24                       4 17                 12                34-26                    4 18                 13                36 27                 '    4 19                 13                 I-429                   4 20                 14                48 30                      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, PNNL has reviewed the statistical significance of these revisions and offered the revised Table S10-1.
ALTERNATIVE EXAMINATION In lieu of the requirements of ASME Section XI, 1995 Edition, 1996 Addenda, Appendix VIII, Supplement 10, the proposed alternative shall be used. The proposed alternative is described in the enclosure.
JUSTIFICATION FOR GRANTING RELIEF 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 VIII, Supplement 10 requirements.                    Compliance with the Enclosure                                Page 6 of 20

proposed altematives will provide an adequate level of quality and safety for examination of the affected welds.
IMPLEMENTATION SCHEDULE This Technical Altemative will be used at the Joseph M. Farley Nuclear Plant, Edwin 1. Hatch Nuclear Plant, and the Vogtle Electric Generating Plant during each plant's present ten-year ISI interval.
Enclosure                           Page 7 of 20

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                           Proposed Change                               Reasoning 1.0       SCOPE Supplement 10 is applicable to dissimilar   A scope statement provides added clarity metal piping welds examined from either     regarding the applicable range of each the inside or outside surface.              individual Supplement. The exclusion of Supplement 10 is not applicable to piping   CRC provides consistency between welds containing supplemental corrosion     Supplement 10 and the recent revision to resistant clad (CRC) applied to mitigate    Supplement 2 (Reference BC 00-755).
Intergranular Stress Corrosion Cracking     Note, an additional change identifying CRC (IGSCC).                                    as "in course of preparation" is being processed separately.
1.0     SPECIMEN REQUIREMENTS               2.0 SPECIMEN REQUIREMENTS                   Renumbered Qualification test specimens shall meet the Qualification test specimens shall meet the No Change requirements listed herein, unless a set of requirements listed herein, unless a set of specimens is designed to accommodate        specimens is designed to accommodate specific limitations stated in the scope of specific limitations stated in the scope of the examination procedure (e.g., pipe size, the examination procedure (e.g., pipe size, weld joint configuration, access            weld joint configuration, access limitations). The same specimens may be     limitations). The same specimens may be used to demonstrate both detection and      used to demonstrate both detection and sizing qualification.                       sizing qualification.
1.1 General. The specimen set shall         2.1 General. The specimen set shall         Renumbered conform to the following requirements.      conform to the following requirements.
(a) The minimum number of flaws in a        New, changed minimum number of flaws to test set shall be ten.                      10 so sample set size for detection is consistent with length and depth sizing.
(a) Specimens shall have sufficient volume  (b) Specimens shall have sufficient volume  Renumbered to minimize spurious reflections that may   to minimize spurious reflections that may interfere with the interpretation process. interfere with the interpretation process.
(b) The specimen set shall include the      (c) The specimen set shall include the      Renumbered, metricated, the change in pipe minimum and maximum pipe diameters and minimum and maximum pipe diameters and           diameter tolerance provides consistency Page 8 of 20 Enclosure

SUPPLEMENT 10- QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                             Proposed Chang e                                Reasoning thicknesses for which the examination         thicknesses for which the examination        between Supplement 10 and the recent procedure is applicable. Pipe diameters       procedure is applicable. Pipe diameters      revision to Supplement 2 (Reference BC within a range of 0.9 to 1.5 times a nominal  within a range of 1/2 in. (13 mm) of the     00-755) diameter shall be considered equivalent.      nominal diameter shall be considered Pipe diameters larger than 24 in. shall be    equivalent. Pipe diameters larger than 24 considered to be flat. When a range of        in. (610 mm) shall be considered to be flat.
thicknesses is to be examined, a thickness    When a range of thicknesses is to be tolerance of +25% is acceptable.              examined, a thickness tolerance of +25% is acceptable.
(c) The specimen set shall include examples   (d) The specimen set shall include           Renumbered, changed "condition" to of the following fabrication condition:       examples of the following fabrication        "conditions" conditions:
(1) geometric conditions that normally        (1) geometric and material conditions that   Clarification, some of the items listed relate require discrimination from flaws (e.g.,      normally require discrimination from flaws   to material conditions rather than geometric counterbore or weld root conditions,          (e.g., counterbore or weld root conditions,  conditions. Weld repair areas were added cladding, weld buttering, remnants of         cladding, weld buttering, remnants of        as a result of recent field experiences.
previous welds, adjacent welds in close       previous welds, adjacent welds in close proximity);                                   proximity, and weld repair areas);
(2) typical limited scanning surface          (2) typical limited scanning surface         Differentiates between ID and OD scanning conditions (e.g., diametrical shrink, single- conditions (e.g., weld crowns, diametrical   surface limitations. Requires that ID and side access due to nozzle and safe end        shrink, single-side access due to nozzle and OD qualifications be conducted external tapers).                             safe end external tapers for outside surface independently (Note, new paragraph 2.0 examinations; and internal tapers,           (identical to old paragraph 1.0) provides for exposed weld roots, and cladding             alternatives when "a set of specimens is conditions for inside surface                designed to accommodate specific examinations). Qualification                 limitations stated in the scope of the requirements shall be satisfied separately   examination procedure.").
for outside surface and inside surface examinations.
(d) All flaws in the specimen set shall be                                                 Deleted this requirement, because new Page 9 of 20 Enclosure

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                l              Proposed Change               I                 Reasoning cracks.                                                                                       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       2.2 Flaw Location. At least 80% of the       Renumbered and re-titled. Flaw location austenitic material. At least 50% of the         flaws shall be contained wholly in weld or   percentages redistributed because field cracks in austenitic material shall be           buttering material. At least one and a       experience indicates that flaws contained in contained wholly in weld or buttering            maximum of 10% of the flaws shall be in      weld or buttering material are probable and material. At least 10% of the cracks shall       ferritic base material. At least one and a   represent the more stringent ultrasonic be in ferritic material. The remainder of the    maximum of 10% of the flaws shall be in      detection scenario.
cracks may be in either austenitic or ferritic   austenitic base material.
material.
(2) At least 50% of the cracks in austenitic     2.3 Flaw Type.                               Renumbered and re-titled. Alternative base material shall be either IGSCC or           (a) At least 60% of the flaws shall be       flaws are required for placing axial flaws in thermal fatigue cracks. At least 50% of the      cracks, the remainder shall be alternative   the HAZ of the weld and other areas where cracks in ferritic material shall be             flaws. Specimens with IGSCC shall be         implantation of a crack produces mechanically or thermally induced fatigue        used when available. Alternative flaws, if   metallurgical conditions that result in an cracks.                                          used, shall provide crack-like reflective    unrealistic ultrasonic response. This is characteristics and shall be lmited to the   consistent with the recent revision to case where implantation of cracks            Supplement 2 (Reference BC 00-755).
produces spurious reflectors that are uncharacteristic of actual flaws.            The 40% limit on alternative flaws is Alternative flaw mechanisms shall have a     needed to support the requirement for up to tip width of less than or equal to 0.002 in. 70% axial flaws. Metricated
(.05 mm).
(3) At least 50% of the cracks shall be          (b) At least 50% of the flaws shall be       Renumbered. Due to inclusion of coincident with areas described in (c)           coincident with areas described in 2.1(d)    "alternative flaws", use of "cracks" is no above.                                           above.                                       longer appropriate.
2.4 Flaw Depth. All flaw depths shall be     Moved from old paragraph 1.3(c) and 1.4 greater than 10% of the nominal pipe wall    and re-titled. Consistency between thickness. Flaw depths shall exceed the      detection and sizing specimen set nominal clad thickness when placed in        requirements (e.g.,20% vs. 1/3 flaw depth Page 10 of 20 Enclosure

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                          Proposed Change                                Reasoning cladding. Flaws in the sample set shall be increments, e.g., original paragraph 1.3(c))
distributed as follows:
Flaw Depth             Minimum
(% Wall Thickness) Number of Flaws 10-30%               20%
31-60%               20%
61-100%              20%
At least 75% of the flaws shall be in the range of 10 to 60% of wall thickness.
1.2 Detection Specimens. The specimen                                                    Renumbered and re-titled and moved to set shall include detection specimens that                                               paragraph 3.1 (a). No other changes meet the following requirements.
(a) Specimens shall be divided into grading                                              Renumbered to paragraph 3.1(a)(1). No units. Each grading unit shall include at                                                other changes.
least 3 in. of weld length. If a grading unit is designed to be unflawed, at least 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                                                Moved to new paragraph 3.1(a)(2).
Table VIII-S2-1. The number of unflawed grading units shall be at least twice the number of flawed grading units.
Page 11 of 20 Enclosure

SUPPLEMENT 10- QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                            Proposed Change                                 Reasoning (c) Flawed grading units shall meet the                                                   Flaw depth requirements moved to new following     criteria for      flaw depth,                                               paragraph 2.4, flaw orientation orientation, and type.                                                                    requirements moved to new paragraph 2.5, flaw type requirements moved to new paragraph 2.3, "Flaw Type".
(1) All flaw depths shall be greater than                                                 Deleted, for consistency in sample sets the 10% of the nominal pipe wall thickness. At                                                depth distribution is the same for detection least 1/3 of the flaws, rounded to the next                                               and sizing.
higher whole number, shall have depths between 10% and 30% of the nominal pipe wall thickness. However, flaw depths shall exceed the nominal clad thickness when placed in cladding. At least 1/3 of the flaws, rounded to the next whole number, shall have depths greater than 30% of the nominal pipe wall thickness.
(2) At least 30% and no more than 70% of      2.5 Flaw Orientation.                       Note, this distribution is applicable for the flaws, rounded to the next higher whole   (a) At least 30% and no more than 70% of    detection and depth sizing. Paragraph number, shall be oriented axially. The        the flaws, rounded to the next higher whole 2.5(b)(1) requires that all length- sizing remainder of the flaws shall be oriented      number, shall be oriented axially. The      flaws be oriented circumferentially.
circumferentially.                            remainder of the flaws shall be oriented circumferentially.
1.3 Length Sizing Specimens. The                                                          Renumbered and re-titled and moved to specimen set shall include length sizing                                                  new paragraph 3.2 specimens that meet the following requirements.
(a) All length sizing flaws shall be oriented                                             Moved, included in new paragraph 3.2(a) circumferentially.
(b) The minimum number of flaws shall be                                                  Moved, included in new paragraph 2.1 ten.                                                                                      above Page 12 of 20 Enclosure

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS CurrentRequirement               l Proposed Change                 Reasoning (c) All flaw depths shall be greater than                     Moved, included in new paragraph 2.4 10% of the nominal pipe wall thickness. At                   above after revision for consistency with least 1/3 of the flaws, rounded to the next                   detection distribution higher whole number, shall have depths between 10% and 30% of the nominal pipe wall thickness. However, flaw depth shall exceed the nominal clad thickness when placed in cladding. At least 1/3 of the flaws, rounded to the next whole number, shall have depths greater than 30% of the nominal pipe wall thickness.
1.4 Depth Sizing Specimens. The                               Moved, included in new paragraphs 2. 1, specimen set shall include depth sizing                       2.3, 2.4 specimens that meet the following requirements.
(a) The minimum number of flaws shall be                      Moved, included in new paragraph 2.1 ten.
(b) Flaws in the sample set shall not be                      Moved, potential conflict with old wholly contained within cladding and shall                    paragraph 1.2(c)(1); "However, flaw depths be distributed as follows:                                    shall exceed the nominal clad thickness when placed in cladding.". Revised for clarity and included in new paragraph 2.4 Page 13 of 20 Enclosure

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                            Proposed Changc                                   Reasoning Moved, included in paragraph 2.4 for Flaw Depth              Minimum                                                               consistent applicability to detection and
(% Wall Thickness)      Number of Flaws                                                       sizing samples.
10-30%                 20%
3 1-60%                20%
61-100%                20%
The remaining flaws shall be in any of the above categories.
(b) Sizing Specimen sets shall meet the         Added for clarity following requirements.
(I) All length-sizing flaws shall be oriented Moved from old paragraph 1.3(a) circumferentially.
(2) Depth sizing flaws shall be oriented as Included for clarity. Previously addressed in 2.5(a).                                      by omission (i.e., length, but not depth had a specific exclusionary statement) 2.0      CONDUCT OF                           3.0     CONDUCT OF                              Renumbered PERFORMANCE DEMONSTRATION                     PERFORMANCE DEMONSTRATION The specimen inside surface and               For qualifications from the outside             Differentiate between qualifications identification shall be concealed from the    surface, the specimen inside surface and        conducted from the outside and inside candidate. All examinations shall be          identification shall be concealed from the surface.
completed prior to grading the results and    candidate. When qualifications are presenting the results to the candidate.      performed from the inside surface, the Divulgence of particular specimen results or flaw location and specimen identification candidate viewing of unmasked specimens       shall be obscured to maintain a "blind after the performance demonstration is        test". All examinations shall be completed prohibited.                                   prior to grading the results and presenting the results to the candidate. Divulgence of particular specimen results or candidate I viewing of unmasked specimens after the       I Page 14 of 20 Enclosure

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Reguirement                        Proposed Change                                    Reasoning performance demonstration is prohibited.
2.1 Detection Test. Flawed and unflawed 3.1 Detection Qualification.                    Renumbered, moved text to paragraph grading units shall be randomly mixed                                                   3.1(a)(3)
(a) The specimen set shall include detection    Renumbered, moved from old paragraph specimens that meet the following                1.2.
requirements.
(1) Specimens shall be divided into grading     Renumbered, moved from old paragraph units. Each grading unit shall include at        1.2(a). Metricated. No other changes.
least 3 in. (76 mm) of weld length. If a grading unit is designed to be unflawed, at least I in. (25 mm) 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.
(2) Detection sets shall be selected from       Moved from old paragraph 1.2(b). Table Table VIII-S10-1. The number of unflawed        revised to reflect a change in the minimum grading units shall be at least one and a       sample set to 10 and the application of half times the number of flawed grading         equivalent statistical false call parameters to units.                                          the reduction in unflawed grading units.
Human factors due to large sample size.
(3) flawed and unflawed grading units shall     Moved from old paragraph 2.1 be randomly mixed.
Page 15 of 20 Enclosure

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS CurrentRequirement                            Proposed Change                               Reasoning (b) Examination equipment and personnel    Moved from old paragraph 3.1. Modified are qualified for detection when personnel to reflect the 100% detection acceptance demonstrations satisfy the acceptance      criteria of procedures versus personnel and criteria of Table VIII S10-1 for both      equipment contained in new paragraph 4.0 detection and false calls.                 and the use of 1.5X rather than 2X unflawed grading units contained in new paragraph 3.1 (a)(2). Note, the modified table maintains the screening criteria of the original Table VIII-S2-1.
2.2 Length Sizing Test                      3.2 Length Sizing Test                     Renumbered (a) The length sizing test may be conducted (a) Each reported circumferential flaw in  Provides consistency between Supplement separately or in conjunction with the       the detection test shall be length sized. 10 and the recent revision to Supplement 2 detection test.                                                                        (Reference BC 00-755).
Page 16 of 20 Enclosure

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                 l              Proposed Change                                  Reasoning (b) When the length sizing test is conducted   Change made to ensure security of samples, (b) When the length sizing test is conducted     in conjunction with the detection test, and    consistent with the recent revision to in conjunction with the detection test, and      less than ten circumferential flaws are        Supplement 2 (Reference BC 00-755).
less than ten circumferential flaws are          detected, additional specimens shall be detected, additional specimens shall be          provided to the candidate such that at least   Note, length and depth sizing use the term provided to the candidate such that at least     ten flaws are sized. The regions containing    "regions" while detection uses the term ten flaws are sized. The regions containing      a flaw to be sized may be identified to the    "grading units". The two terms define a flaw to be sized shall be identified to the    candidate. The candidate shall determine       different concepts and are not intended to candidate. The candidate shall determine         the length of the flaw in each region.         be equal or interchangeable.
the length of the flaw in each region.
(c) For a separate length sizing test, the     Change made to ensure security of samples, (c) For a separate length sizing test, the       regions of each specimen containing a flaw     consistent with the recent revision to regions of each specimen containing a flaw       to be sized may be identified to the           Supplement 2 (Reference BC 00-755).
to be sized shall be identified to the           candidate. The candidate shall determine candidate. The candidate shall determine         the length of the flaw in each region.
the length of the flaw in each region.
(d) Examination procedures, equipment,         Moved from old paragraph 3.2(a) includes and personnel are qualified for length sizing  inclusion of "when" as an editorial change.
when the RMS error of the flaw length          Metricated.
measurements, as compared to the true flaw lengths, is less than or equal to 0.75 in. (19 mm).
3.3 Depth Sizing Test                          Renumbered 2.3 Depth Sizing Test (a) For the depth sizing test, 80% of the        (a) The depth sizing test may be               Change made to ensure security of samples, flaws shall be sized at a specific location on   conducted separately or in conjunction         consistent with the recent revision to the surface of the specimen identified to the    with the detection test. For a separate        Supplement 2 (Reference BC 00-755).
candidate.                                       depth sizing test, the regions of each specimen containing a flaw to be sized may be identified to the candidate. The Page 17 of 20 Enclosure

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                  l                Proposed Change                  I                  Reasoning r                                                 7 candidate shall determine the maximum deDth of the flaw in each region.
(b) For the remaining flaws, the regions of         (b) When the depth sizing test is                 Change made to be consistent with the each specimen containing a flaw to be sized         conducted in conjunction with the                 recent revision to Supplement 2 (Reference shall be identified to the candidate. The           detection test, and less than ten flaws are       BC 00-755).
candidate shall determine the maximum               detected, additional specimens shall be depth of the flaw in each region.                   provided to the candidate such that at            Changes made to ensure security of least ten flaws are sized. The regions of         samples, consistent with the recent revision each specimen containing a flaw to be sized       to Supplement 2 (Reference BC 00-755).
may be identified to the candidate. The candidate shall determine the maximum depth of the flaw in each region.
(c) Examination procedures, equipment,            Moved from old paragraph 3.2(b).
and personnel are qualified for depth sizing      Metricated.
when the RMS error of the flaw depth measurements, as compared to the true flaw depths, is less than or equal to 0.125 in. (3 mm).
3.0     ACCEPTANCE CRITERIA                                                                           Delete as a separate category. Moved to new paragraph detection (3.1) and sizing 3.2 and 3.3 3.1     Detection    Acceptance       Criteria.                                                       Moved to new paragraph 3.1(b), reference Examination procedures, equipment, and                                                                changed to Table S10 from S2 because of personnel are qualified for detection when                                                            the change in the minimum number of flaws the     results    of      the   performance                                                          and the reduction in unflawed grading units demonstration satisfy the acceptance                                                                  from 2X to 1.5X.
criteria of Table VIII-S2-1 for both detection and false calls.
3.2 Sizing Acceptance Criteria                                                                        Deleted as a separate category. Moved to new paragraph on length 3.2 and depth 3.3 Page 18 of 20 Enclosure

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Reguirement                            Proposed Change                                 Reasoning (a) Examination procedures, equipment,                                                     Moved to new paragraph 3.2(d), included and personnel are qualified for length sizing                                              word "when" as an editorial change.
the RMS error of the flaw length measurements, as compared to the true flaw lengths, is less than or equal to 0.75 inch.
(b) Examination procedures, equipment,                                                     Moved to new paragraph 3.3(c) and personnel are qualified for depth sizing when the RMS error of the flaw depth measurements, as compared to the true flaw depths, is less than or equal to 0.125 in.
4.0 PROCEDURE QUALIFICATION                  New Procedure qualifications shall include the   New. Based on experience gained in following additional requirements.           conducting qualifications, the equivalent of (a) The specimen set shall include the       3 personnel sets (i.e., a minimum of 30 equivalent of at least three personnel sets. flaws) is required to provide enough flaws Successful personnel demonstrations may      to adequately test the capabilities of the be combined to satisfy these                 procedure. Combining successful requirements.                                demonstrations allows a variety of (b) Detectability of all flaws within the    examiners to be used to qualify the scope of the procedure shall be              procedure. Detectability of each flaw demonstrated. Length and depth sizing        within the scope of the procedure is shall meet the requirements of paragraph     required to ensure an acceptable personnel 3.2 and 3.3.                                 pass rate. The last sentence is equivalent to (c) At least one successful personnel        the previous requirements and is demonstration has been performed.            satisfactory for expanding the essential (d) To qualify new values of essential       variables of a previously qualified variables, at least one personnel            procedure qualification set is required.
Page 19 of 20 Enclosure

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                        Proposed Change                        l           Reasoning TABLE VIII-S-1             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                     103 6                  61                                         1 7                  6                     14                   1 B                  7                     16                   2 9                  7                     10                   2 10                  8                       - 15               3-2 11                  9                     2-    17             3- 3 12                  9                     24-18                3 3 13                 10                     26-20                    3 14                 10                     26- 21               5- 3 15                 11                     30- 23               v     3 16                 12                     32-24                      4 17                 12                     34-26                6- 4 18                 13                     36- 27               7- 4 19                 13                     3-29                 7-4 20                 14                     4     30             8- 5 Page 20 of 20 Enclosure}}