View source for NL-03-173, Third Ten-Year Interval Inservice Inspection Program Pressure Retaining Piping Welds Relief Requests, RR 65 and RR 66 (for IP2), and RR 3-34 and RR 3-35 (for IP3)

{{Adams
| number = ML033070147
| issue date = 10/30/2003
| title = Third Ten-Year Interval Inservice Inspection Program Pressure Retaining Piping Welds Relief Requests, RR 65 and RR 66 (for IP2), and RR 3-34 and RR 3-35 (for IP3)
| author name = Kansler M
| author affiliation = Entergy Nuclear Northeast, Entergy Nuclear Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000247, 05000286
| license number = DPR-026, DPR-064
| contact person = 
| case reference number = NL-03-173
| document type = Letter type:NL
| page count = 53
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
440 Hamilton Avenue Entergy                                                                         White Plains, NY 10601 Tel 914 272 3200 Fax 914 272 3205 Michael R. Kansler President October 30, 2003 NL-03-1 73 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1-17 Washington, DC 20555-0001

==SUBJECT:==
Indian Point Nuclear Generating Unit No. 2 Docket No. 50-247 Indian Point Nuclear Generating Unit No. 3 Docket No. 50-286 Third Ten-Year Interval Inservice Inspection Program Pressure Retaining Piping Welds Relief Requests, RR 65 and RR 66 (for 1P2), and RR 3-34 and RR 3-35 (for P3)

==Reference:==
: 1. NRC Regulatory Issue Summary 2003-01, Examination of Dissimilar Metal Welds, Supplement 10 to Appendix Vil of Section Xl of the ASME Code, dated January 21, 2003.
: 2. USNRC letter from James W. Clifford to Mike Bellamy, dated May 7, 2003, regarding 'Pilgrim Relief Request (PRR)-30, Relief from ASME Code, Section Xl, Appendix Vill, Supplement 10, Performance Demonstration for Ultrasonic Examination Systems" (TAC No. MB7949)"
: 3. USNRC letter from L. Raghavan to William T. O'Connor, Jr. , dated June 3, 2003, regarding Fermi 2 - Evaluation of Relief Requests RR-A33 and RR-A34 Regarding Second 1-Year Inservice Inspection (TAC NOS.
MB7566 and MB7567)"
: 4. V. C. Summer Nuclear Station letter, regarding "Request to use alternatives to ASME Boiler and Pressure Vessel Code, Section Xl, RR                         15, RR-11-16, RR-11-17, RR-11-18, RR-11-19, RR-11-20, RR-11-21," dated July 11, 2003.

==Dear Sir or Madam:==

This letter requests NRC approval of Relief Requests (RRs) RR 65 and RR 66 for Indian Point Generating Unit No. 2 (P2); and RR 3-34 and RR 3-35 for Indian Point Generating Unit No. 3 (IP3). RR 65 (Enclosure 1) and RR 3-34 (Enclosure 3) are similar requests for relief from ASME Code, Section Xl, Appendix Vil qualification requirements for inspection of Class 1 pressure retaining piping welds. RR 66 (Enclosure 2) and RR 3-35 (Enclosure 4) are similar requests for relief from ASME Code requirements for ultrasonic examination from the inside surface of Class 1 pressure retaining piping welds. These RRs are consistent with the overall Performance 0       #

Demonstration Initiative (PDI) effort, and PDI will administer the alternative programs described in these RRs.
The ASME Code, Section XI, 1995 Edition, 1996 Addenda, Appendix Vil, Supplement 10 requires qualification of procedures, personnel, and equipment for examination of Section Xl, Appendix Vil, Category B-F, pressure retaining, dissimilar metal welds. In lieu of these ASME Code, Supplement 10 requirements, RR 65 and RR 3-34 request the use of PDI developed alternative qualification requirements for inspection of these pressure retaining welds. The Attachment to Enclosures 1 and 3 provides PDI developed proposed revisions to Supplement 10, and the proposed revisions are identified by bold print or by line out.
The ASME Code, Section Xl, 1995 Edition, 1996 Addenda, Appendix Vill, Supplement 3 requires qualification of procedures, personnel, and equipment for inside surface examination of Class 1 pressure retaining Category B-J piping welds. In lieu of certain of these ASME Code, Supplement 3 requirements, RR 66 (P2) and RR 3-35 (P3) request the use of PDI developed alternative qualification requirements for inside surface inspection of these pressure retaining piping welds. The PDI developed alternative requirements are provided in the proposed ASME Code, Section Xl, Appendix Vil, Supplement 14 (Enclosure 2, Attachment 1 and Enclosure 4,  respectively for P2 and P3). These Supplement 14 proposed alternative requirements will be coordinated with the proposed initiative for the Supplement 10 implementation program.
A similar request for relief regarding supplement 10 was approved for Pilgrim (Reference 2). A similar request for relief regarding supplement 3 was approved for Fermi (Reference 3). Similar Requests for Relief on supplement 3,10, and 14 were submitted by V.C. Summer in July 2003 (Reference 4) and are currently under NRC evaluation.
The NRC is requested to approve the 1P2 relief requests by June 2004 to support P2's Fall 2004 refueling outage. Although the next P3 outage is scheduled for Spring 2005, since these RRs are practically identical it is also requested that the P3 relief requests be approved at the same time.
There are no new commitments made in this letter. If you have any questions, please contact Ms. Charlene Faison at 914-272-3378.
Very truly yours, ichael R. Kansler President Entergy Nuclear Operations, Inc.

==Enclosures:==
Next Page 2

==Enclosures:==
: 1. Indian Point Nuclear Generating Unit No. 2, Third       Ten-Year Interval Inservice Inspection Program Relief Request RR 65.
: 2. Indian Point Nuclear Generating Unit No. 2, Third       Ten-Year Interval Inservice Inspection Program Relief Request RR 66.
: 3. Indian Point Nuclear Generating Unit No. 3, Third       Ten-Year Interval Inservice Inspection Program Relief Request RR 3-34.
: 4. Indian Point Nuclear Generating Unit No. 3, Third        Ten-Year Interval Inservice Inspection Program Relief Request RR 3-35.
cc:  Regional Administrator, Region I                 Mr. Paul Eddy U.S. Nuclear Regulatory Commission              NYS Dept of Public Service 475 Allendale Road                               3 Empire State Plaza, 10/F King of Prussia, PA 19406                        Albany, NY 12223 Mr. Patrick D. Milano, Sr. Project Manager       Mr. Peter R. Smith, Acting President Project Directorate I                            New York State Energy, Research, Division of Licensing Project Management              and Development Authority U.S. Nuclear Regulatory Commission               Corporate Plaza West Mail Stop 0-8-C2                                 286 Washington Avenue Extension Washington, DC 20555                             Albany, NY 12203-6399 Senior Resident Inspector's Office               Resident Inspector's Office Indian Point Unit 2                              Indian Point Unit 3 U.S. Nuclear Regulatory Commission               U.S. Nuclear Regulatory Commission P.O. Box 38                                      P.O. Box 337 Buchanan, NY 10511-0038                          Buchanan, NY 10511-0337 3

NL-03-173 ENCLOSURE 1 INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 THIRD TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST RR-65 SYSTEMICOMPONENT(S) FOR WHICH RELIEF IS REQUESTED ASME Section Xl, 1989 Edition, no Addenda, Class 1, Category B-F, Pressure Retaining Piping Welds, Item Numbers B5.10, B5.40, and B5.70 subject to ultrasonic examination using procedures, personnel, and equipment qualified to ASME Section XI, 1995 Edition, 1996 Addenda, Appendix ViII, Supplement 10 criteria.
CODE REQUIREMENTS The following paragraphs or statements are from ASME Section XI, Rules for Inservice Inspection of Nuclear Power plant Components, 1995 Edition, 1996 Addenda, Appendix ViII, Supplement 10, Qualification Requirements for Dissimilar Metal Piping Welds, 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.
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.
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NL-03-1 73 ENCLOSURE I 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 VIII-S2-1 provides the false call criteria when the number of unflawed grading units is at least twice the number of flawed grading units.
RELIEF REQUESTED Relief is requested to use the following alternative requirements for implementation of Appendix Vil, 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 Committee for consideration.
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 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 GSCC 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.
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NL-03-1 73 ENCLOSURE 1 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.
(t                in Base material I^~              4 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."
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 alternative 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 Vil-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 alternative reduces the ratio to 1.5 times to reduce the number of test samples to a more reasonable number from the human factors perspective. However, the statistical basis used for screening personnel and procedures is still maintained at the same level with competent personnel being successful 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.
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NL-03-1 73 ENCLOSURE 1 Flaw Depth               Minimum
(% Wall Thickness)       Number of Flaws 10-30%                   20%
31-60%                   20%
61-100%                  20%
In addition, the proposed alternative includes the following:   At least 75% of the flaws shall be in the range of 10 to 60% of wall thickness."
Technical Basis - The proposed alternative uses the depth sizing distribution for both detection and depth sizing because it provides for a better distribution of flaw sizes within the test set.
This distribution allows candidates to perform detection, length, and depth sizing demonstrations simultaneously utilizing the same test set. The requirement that at least 75% of the flaws shall be in the range of 10 to 60% of wall thickness provides an overall distribution tolerance yet the distribution uncertainty decreases the possibilities for testmanship that would be inherent to a uniform distribution. It must be noted that it is possible to achieve the same distribution utilizing the present requirements, but it is preferable to make the criteria consistent.
Item 6 - 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."
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NL-03-1 73 ENCLOSURE 1 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          '    ce criteria of Table VIII-S2-1 as follows:
1101 TABLE VIII-Si-l 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            Detectlon         Grading             of False Units             Criteria          Units                 Calls 5                  5              10                    0 6                 6              12 7                  6              1e                    1
* 7              lb                    2 9                  7              12 10                  8                    15                   2 il                  9              22 17                 3-3 12                  9              24 18                 3 13                 10              2r-20                 4-3 14                 10              26-21                 5    3 15                 11              30-- 23               5- 3 16                 12              3*-`24                6-.4 17                 12              3'+4- 26              6- 4 18                 13              36- 27                7-4 19                 13              3e 29                 7-4 20                 14              4     30              8- 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 Laboratory (PNNL) has reviewed the statistical significance of these revisions and offered the revised Table S10-1.
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NL-03-1 73 ENCLOSURE I ALTERNATIVE EXAMINATION In lieu of the requirements of ASME Section Xi, 1995 Edition, 1996 Addenda, Appendix Vil, Supplement 10, the proposed alternative shall be used. The proposed alternative is described in the attachment.
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, 1995 Edition, 1996 Addenda, Appendix ViII, Supplement 10 requirements. Compliance with the proposed alternatives will provide an adequate level of quality and safety for examination of the affected welds.
IMPLEMENTATION SCHEDULE The NRC is requested to approve this relief request for the remainder of the 3d Inservice Inspection Interval for Indian Point Unit 2.
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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 the        regarding the applicable range of each inside or outside surface. Supplement 10 is        individual Supplement. The exclusion of CRC not applicable to piping welds containing          provides consistency between Supplement 10 supplemental corrosion resistant clad (CRC)        and the recent revision to Supplement 2 applied to mitigate Intergranular Stress           (Reference BC 00-755). Note, an additional Corrosion Cracking (IGSCC).                        change identifying CRC as "incourse 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 specific limitations stated in the scope of the limitations stated in the scope of the examination examination procedure (e.g., pipe size, weld    procedure (e.g., pipe size, weld joint joint configuration, access limitations). The   configuration, access limitations). The same same specimens may be used to demonstrate       specimens may be used to demonstrate both both detection and sizing qualification.        detection and sizing qualification.
1.1 General. The specimen set shall conform     2.1 General. The specimen set shall conform to Renumbered to the following requirements.                  the following requirements.
(a)The minimum number of flaws in a test set New, changed minimum number of flaws to 10 shall be ten.                                      so 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          minimize spurious reflections that may interfere interfere with the interpretation process.      with the interpretation process.
Page 1 of 11 NL-03-1 73 Enclosure 1, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                                 Proposed Change                                      Reasoning (b)The specimen set shall include the            (c) The specimen set shall include the minimum    Renumbered, metricated, the change in pipe minimum and maximum pipe diameters and           and maximum pipe diameters and thicknesses        diameter tolerance provides consistency thicknesses for which the examination            for which the examination procedure is            between Supplement 10 and the recent procedure is applicable. Pipe diameters within   applicable. Pipe diameters within a range of 112  revision to Supplement 2 (Reference BC 00-a range of 0.9 to 1.5 times a nominal diameter   in. (13 mm) of the nominal diameter shall be      755).
shall be considered equivalent. Pipe             considered equivalent. Pipe diameters larger diameters larger than 24 in. shall be            than 24 in. (610 mm) shall be considered to be considered to be flat. When a range of           flat. When a range of thicknesses is to be thicknesses is to be examined, a thickness       examined, a thickness tolerance of +25% is tolerance of +25% is acceptable.                 acceptable.
(c)The specimen set shall include examples       (d) The specimen set shall include examples of    Renumbered, changed condition to of the following fabrication condition:          the following fabrication conditions:             "conditions".
(1) geometric conditions that normally require   (1)geometric and material conditions that         Clarification, some of the items listed relate to discrimination from flaws (e.g., counterbore or  normally require discrimination from flaws (e.g., material conditions rather than geometric weld root conditions, cladding, weld buttering,  counterbore or weld root conditions, cladding,    conditions. Weld repair areas were added as remnants of previous welds, adjacent welds in    weld buttering, remnants of previous welds,       a result of recent field experiences.
close proximity);                                adjacent welds in close proximity, and weld repair areas);
(2)typical limited scanning surface conditions   (2)typical limited scanning surface conditions    Differentiates between IDand OD scanning (e.g., diametrical shrink, single-side access    (e.g., weld crowns, diametrical shrink, single-   surface limitations. Requires that IDand OD due to nozzle and safe end external tapers). side access due to nozzle and safe end external   qualifications be conducted independently tapers for outside surface examinations; and      (Note, new paragraph 2.0 (identical to old internal tapers, exposed weld roots, and          paragraph 1.0) provides for alternatives when cladding conditions for inside surface            "aset of specimens is designed to examinations). Qualification requirements         accommodate specific limitations stated in the shall be satisfied separately for outside         scope of the examination procedure.").
surface and inside surface examinations.
(d)All flaws in the specimen set shall be                                                          Deleted this requirement, because new cracks.                                                                                            paragraph 2.3 below provides for the use of "alternative flaws" in lieu of cracks.
(1)At least 50% of the cracks shall be in        2.2 Flaw Location. At least 80% of the flaws      Renumbered and re-titled. Flaw location austenitic material. At least 50% of the cracks shall be contained wholly in weld or buttering     percentages redistributed because field in austenitic material shall be contained wholly material. At least one and a maximum of 10%       experience indicates that flaws contained in Page 2 of 11 NL-03-1 73 Enclosure 1, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS. FOR DISSIMILAR METAL PIPING WELDS Current Requirement.                              Proposed Change                                        Reasoning                       l in weld or buttering material. At least 10% of of the flaws shall be in ferritic base material. At weld or buttering material are probable and the cracks shall be in ferritic material. The  least one and a maximum of 10% of the flaws         represent the more stringent ultrasonic remainder of the cracks may be in either       shall be in austenitic base material.               detection scenario.
austenitic or ferritic material.
(2) At least 50% of the cracks in austenitic   2.3 Flaw Type.                                      Renumbered and re-titled. Alternative flaws base material shall be either IGSCC or         (a) At least 60% of the flaws shall be cracks,      are required for placing axial flaws in the HAZ thermal fatigue cracks. At least 50% of the    the remainder shall be alternative flaws.           of the weld and other areas where cracks in ferritic material shall be           Specimens with IGSCC shall be used when             implantation of a crack produces metallurgical mechanically or thermally induced fatigue      available. Alternative flaws, if used, shall        conditions that result in an unrealistic cracks.                                        provide crack-like reflective characteristics       ultrasonic response. This is consistent with and shall be limited to the case where              the recent revision to Supplement 2 implantation of cracks produces spurious            (Reference BC 00-755).
reflectors that are uncharacteristic of service induced flaws. Alternative flaw mechanisms          The 40% limit on alternative flaws is needed to shall have a tip width of less than or equal to     support the requirement for up to 70% axial 0.002 in. (.05 mm).                                 flaws. Metricated (3) At least 50% of the cracks shall be        (b) At least 50% of the flaws shall be coincident   Renumbered. Due to inclusion of altemative coincident with areas described in (c) above. with areas described in 2.1(d) above.               flaws", use of ucracks" is no longer appropriate.
2.4 Flaw Depth. All flaw depths shall be greater    Moved from old paragraph 1.3(c) and 1.4 and than 10% of the nominal pipe wall thickness.        re-titled. Consistency between detection and Flaw depths shall exceed the nominal clad           sizing specimen set requirements (e.g., 20%
thickness when placed in cladding.                  vs. 1/3 flaw depth increments, e.g., original Flaws in the sample set shall be distributed        paragraph 1.3(c)).
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 Page 3 of 11 NL-03-1 73 Enclosure 1, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                 l              Proposed Change                      Reasoning of 10 to 60% of wall thickness.
1.2 Detection Specimens. The specimen set                                         Renumbered and re-titled and moved to shall include detection specimens that meet                                       paragraph 3.1 (a). No other changes.
the following requirements.
(a) Specimens shall be divided into grading                                       Renumbered to paragraph 3.1(a)(1).
units. Each grading unit shall include at least                                   No other changes.
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.
(c) Flawed grading units shall meet the                                            Flaw depth requirements moved to new following criteria for flaw depth, orientation,                                    paragraph 2.4, flaw orientation requirements and type.                                                                          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%                                      Deleted, for consistency in sample sets the of the nominal pipe wall thickness. At least 1/3                                   depth distribution is the same for detection and of the flaws, rounded to the next higher whole                                     sizing.
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 Page 4 of 11 NL-03-1 73 Enclosure 1, Attachment

SUPPLEMENT .10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                                Proposed Change                                       Reasoning thickness.
(2) At least 30% and no more than 70% of the    2.5 Flaw Orientation.                             Note, this distribution is applicable for flaws, rounded to the next higher whole          (a) For other than sizing specimens, at least 30% detection and depth sizing. Paragraph number, shall be oriented axially. The           and no more than 70% of the flaws, rounded to     2.5(b)(1) requires that all length- sizing flaws remainder of the flaws shall be oriented         the next higher whole number, shall be oriented   be oriented circumferentially.
circumferentially.                               axially. The remainder of the flaws shall be oriented circumferentially.
1.3 Length Sizing Specimens. The                                                                   Renumbered and re-titled and moved to new specimen set shall include length sizing                                                           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 above.
ten.
(c) All flaw depths shall be greater than 10%                                                      Moved, included in new paragraph 2.4 above of the nominal pipe wall thickness. At least 1/3                                                   after revision for consistency with detection of the flaws, rounded to the next higher whole                                                     distribution.
number, shall have depths between 10% and 30% of the nominal pipe wall thickness.
However, flaw depth shall exceed the nominal clad thickness when placed in cladding. At least 1/3 of the flaws, rounded to the next whole number, shall have depths greater than 30% of the nominal pipe wall thickness.
1.4 Depth Sizing Specimens. The specimen                                                           Moved, included in new paragraphs 2.1, 2.3, set shall include depth sizing specimens that                                                      2.4.
meet the following requirements.
(a) The minimum number of flaws shall be                                                           Moved, included in new paragraph 2.1.
ten.
(b) Flaws in the sample set shall not be wholly                                                    Moved, potential conflict with old paragraph contained within cladding and shall be                                                             1.2(c)(1); "However, flaw depths shall exceed distributed as follows:                                                                            the nominal clad thickness when placed in Page 5 of 11 NL-03-1 73 Enclosure 1, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                               Proposed Change                                      Reasoning cladding.". Revised for clarity and included in new paragraph 2.4.
Flaw Depth             Minimum                                                                 Moved, included in paragraph 2.4 for
(% Wall Thickness)     Number of Flaws                                                         consistent applicability to detection and sizing 10-30%                20%                                                              samples.
31-60%                20%
61-100%               20%
The remaining flaws shall be in any of the above categories.
(b) Sizing Specimen sets shall meet the         Added for clarity.
following requirements.
(1)All 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     CONDUCT OF PERFORMANCE                  Renumbered DEMONSTRATION                                  DEMONSTRATION The specimen inside surface and identification For qualifications from the outside surface,    Differentiate between qualifications conducted shall be concealed from the candidate. All     the specimen inside surface and                 from the outside and inside surface.
examinations shall be completed prior to       identification shall be concealed from the grading the results and presenting the results candidate. When qualifications are performed to the candidate. Divulgence of particular     from the inside surface, the flaw location and specimen results or candidate viewing of       specimen identification shall be obscured to unmasked specimens after the performance       maintain a "blind test". All examinations shall demonstration is prohibited.                   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.
Page 6 of 11 NL-03-1 73 Enclosure 1, Attachment

SUPPLEMENT 10- QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                                 Proposed Change                                                 Reasoning 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 1.2.
specimens that meet the following requirements.
(1) Specimens shall be divided into grading                        Renumbered, moved from old paragraph units.             I                                        1.2(a). Metricated. No other changes.
(a) Each grading unit shall include at least 3 in.
(76 mm) of weld length.
(b) The end of each flaw shall be separated from an unflawed grading unit by at least 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) Detection sets shall be selected from Table                    Moved from old paragraph 1.2(b). Table VIII-Sl 0-1. The number of unflawed grading                        revised to reflect a change in the minimum units shall be at least one and a half times the                   sample set to 10 and the application of number of flawed grading units.                                    equivalent statistical false call parameters to the reduction in unflawed grading units.
Human factors due to large sample size.
(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 qualified for detection when personnel                             reflect the 100% detection acceptance criteria demonstrations satisfy the acceptance criteria                     of procedures versus personnel and
__________ ___ t _ @ V__   _t_-__ _ _ -_ -_ _ _ _ _ ._ _ t tI_ -_   _- . . _-   - _ _ _ !. . _ _._. ._ ___ _  1 Page 7 of 11 NL-03-1 73 Enclosure 1, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                                 Proposed Change                    I                   Reasoning of Table Vil SIO-1 for both detection and false     equipment contained in new paragraph 4.0 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 Vil-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 separately or in conjunction with the detection detection test shall be length sized.                and the recent revision to Supplement 2 test.                                                                                                (Reference BC 00-755).
(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   conjunction with the detection test, and less than   consistent with the recent revision to than ten circumferential flaws are detected,    ten circumferential flaws are detected, additional   Supplement 2 (Reference BC 00-755).
additional specimens shall be provided to the   specimens shall be provided to the candidate candidate such that at least ten flaws are      such that at least ten flaws are sized. The          Note, length and depth sizing use the term sized. The regions containing a flaw to be      regions containing a flaw to be sized may be         aregions" while detection uses the term sized shall be identified to the candidate. The identified to the candidate. The candidate shall     ugrading units". The two terms define different candidate shall determine the length of the     determine the length of the flaw in each region. concepts and are not intended to be equal or flaw in each region.                                                                                 interchangeable.
(c) For a separate length sizing test, the      (c) For a separate length sizing test, the regions   Change made to ensure security of samples, regions of each specimen containing a flaw to   of each specimen containing a flaw to be sized       consistent with the recent revision to be sized shall be identified to the candidate. may be identified to the candidate. The              Supplement 2 (Reference BC 00-755).
The candidate shall determine the length of     candidate shall determine the length of the flaw the flaw in each region.                        in each region.
(d) Examination procedures, equipment, and           Moved from old paragraph 3.2(a) includes personnel are qualified for length sizing when       inclusion of uwhen" as an editorial change.
the RMS error of the flaw length measurements,       Metricated.
as compared to the true flaw lengths, is less than or equal to 0.75 in. (19 mm).
Page 8 of 11 NL-03-1 73 Enclosure 1, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                               Proposed Change                                       Reasoning 2.3 Depth Sizing Test                           3.3 Depth Sizing Test                             Renumbered (a) For the depth sizing test, 80% of the flaws (a) The depth sizing test may be conducted        Change made to ensure security of samples, shall be sized at a specific location on the    separately or in conjunction with the             consistent with the recent revision to surface of the specimen identified to the       detection test. For a separate depth sizing       Supplement 2 (Reference BC 00-755).
candidate.                                      test, the regions of each specimen containing a flaw to be sized may be identified to the candidate. The candidate shall determine the maximum depth of the flaw in each region.
(b) For the remaining flaws, the regions of     (b)When the depth sizing test is conducted in     Change made to be consistent with the recent each specimen containing a flaw to be sized     conjunction with the detection test, and less     revision to Supplement 2 (Reference BC 00-shall be identified to the candidate. The       than ten flaws are detected, additional           755).
candidate shall determine the maximum depth     specimens shall be provided to the candidate of the flaw in each region.                     such that at least ten flaws are sized. The       Changes made to ensure security of samples, regions of each specimen containing a flaw to be  consistent with the recent revision to sized may be identified to the candidate. The     Supplement 2 (Reference BC 00-755).
candidate shall determine the maximum depth of the flaw in each region.
(c) Examination procedures, equipment, and        Moved from old paragraph 3.2(b). Metricated.
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. (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 the personnel are qualified for detection when the                                                    change in the minimum number of flaws and results of the performance demonstration                                                          the reduction in unflawed grading units from satisfy the acceptance criteria of Table VIII-                                                    2X to 1.5X.
S2-1 for both detection and false calls.
3.2 Sizing Acceptance Criteria                                                                    Deleted as a separate category. Moved to Page 9 of 11 NL-03-1 73 Enclosure 1, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FORDISSIMILAR METAL PIPING WELDS Current Requirement                              Proposed Change                                    Reasoning new paragraph on length 3.2 and depth 3.3 (a) Examination procedures, equipment, and                                                    Moved to new paragraph 3.2(d), included word personnel are qualified for length sizing the                                                 Twhen" as an editorial change.
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, 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 following additional requirements.              conducting qualifications, the equivalent of 3 (a) The specimen set shall include the          personnel sets (i.e., a minimum of 30 flaws) is equivalent of at least three personnel sets. required to provide enough flaws to Successful personnel demonstrations may be      adequately test the capabilities of the combined to satisfy these requirements.         procedure. Combining successful (b) Detectability of all flaws within the scope demonstrations allows a variety of examiners of the procedure shall be demonstrated.         to be used to qualify the procedure.
Length and depth sizing shall meet the          Detectability of each flaw within the scope of requirements of paragraph 3.1, 3.2 and 3.3. the procedure is required to ensure an (c) At least one successful personnel           acceptable personnel pass rate. The last demonstration shall be performed.               sentence is equivalent to the previous (d) To qualify new values of essential          requirements and is satisfactory for expanding variables, at least one personnel qualification the essential variables of a previously qualified set is required. The acceptance criteria of     procedure 4.0(b) shall be met.
Page 10 of 11 NL-03-1 73 Enclosure 1, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement         I            Proposed Change                               Reasoning 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                    0 6                                                     16 7                  6             14                   1 8                  7            16                    2 9                  7            10                    2 10                   8            2- 15                 3-2 11                   9            22-17                 3-3 12                   9            24-18                 3-3 13                  10            2f-20                 4-3 14                  10            2{-21                 5- 3 15                  11            30-23                 53 16                  12            3Z 24                 6 @4 17                  12            34- 26                6-    4 18                  13            3627                      4 19                  13            3e-29                 7-4 20                  14            4     30              8     5 Page 11 of 11 NL-03-1 73 Enclosure 1, Attachment

NL-03-1 73 Enclosure 1, Addenda Indian Point Unit 2 Relief Request RR 65, Addenda

==Subject:==

In addition to the base relief requested, Entergy requests that this qualification specific relief be allowed for examination of dissimilar metal welds referenced in the ASME Code, Section Xl, Appendix VIII, Supplement 10.
Entergy has been informed by its inspection vendor that procedures were not capable of being completely qualified to the Appendix VIII, Supplement 10 through-wall RMS sizing value of less than or equal to 0.125" RMS, (Ref. Par 3.2). Additionally, applicable to the IP2 reactor nozzle to primary piping dissimilar metal weld, the procedure is fully qualified only for the detection and length sizing of circumferential flaws.
Components:
ASME Code Class 1 - Reactor Vessel to Primary Piping Dissimilar Metal Field Welds.
Code Requirement:
Procedures must be qualified to the Appendix Vil, Supplement 10 (Paragraph3.2), sizing value of less than or equal to 0.125" RMS.
Alternative Approach/Basis for Relief:
The utility's vendor is presently developing improvements to their depth sizing performance. If the vendor's current performance does not meet the ASME Code 0.125" RMS acceptance criteria, the utility will consider the achieved performance of the procedure during evaluations of detected flaws. Entergy proposes to evaluate the depth sizing performance of their selected vendor and determine the appropriate sizing error to consider during such flaw evaluations. The difference between the achieved sizing error and the code required value of 0.125" RMS would be added to the size of flaws measured during the examination for the purpose of flaw evaluation.
It is the utility's position that compensating for the flaw through-wall sizing error band in fracture mechanics evaluation will provide an acceptable margin of safety in the in-service examination of P2 nozzle to primary loop dissimilar metal welds.
Implementation Schedule:
The NRC is requested to approve this relief request for the remainder of the 3rd Inservice Inspection Interval for Indian Point Unit 2.
Page 1 of 1

NL-03-1 73 ENCLOSURE 2 INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 THIRD TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST RR-66 SYSTEMICOMPONENT(S) FOR WHICH RELIEF IS REQUESTED ASME Code, Section Xl, 1989 Edition, no Addenda, Class 1, Category B-J, Item Numbers 89.11 and 9.12, Pressure Retaining Piping Welds ultrasonically examined from the inside surface of Pressurized Water Reactors using procedures, personnel, and equipment qualified to ASME Section XI, 1995 Edition, 1996 Addenda, Appendix Vil, Supplements 2 and 3 criteria.
CODE REQUIREMENTS Relief is requested from the qualification requirements for piping welds contained in Table Vil-3110-1 of Appendix Vil to ASME Section Xl, 1995 Edition, 1996 Addenda, Supplements 2 and 3 criteria.
RELIEF REQUESTED Relief is requested to use the enclosed proposed alternative for implementation of Appendix Vil, Supplements 2 and 3, as coordinated with the proposed alternative for the Supplement 10 implementation program (Attachment to Enclosure I (RR 65)).                     The Performance Demonstration Initiative (PDI) will administer the alternative program.
BASIS FOR RELIEF Depending upon the particular design, the nozzle to main coolant piping may be fabricated using ferritic, austenitic, or cast stainless components and assembled using ferritic, austenitic, or dissimilar metal welds. Additionally, differing combinations of these assemblies may be in close proximity, which typically 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.)
Separate qualifications to Supplements 2, 3, and 10 are redundant when done in accordance with the 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 essential variables used for the examination of Supplements 2, 3, and 10 are equivalent and a coordinated Page 1 of 2

NL-03-173 ENCLOSURE 2 implementation would be sufficiently stringent to qualify all 3 Supplements if the requirements used to qualify Supplement 10 are satisfied as a prerequisite. The basis for this conclusion is the fact that the majority of the flaws in Supplement 10 are located wholly in austenitic weld material, which is known to be challenging for ultrasonic techniques due to the variable dendritic structure of the weld material. Flaws in Supplements 2 and 3 are located in fine-grained base materials, which are known to be less challenging.
Additionally, the proposed alternative is more stringent than current Code requirements for a detection and length sizing qualification. For example, the current Code would allow a detection procedure, personnel, and equipment to be qualified to Supplement 10 with 5 flaws, Supplement 2 with 5 flaws, and Supplement 3 with 5 flaws, a total of only 15 flaws. The proposed alternative of qualifying Supplement 10 using 10 flaws and adding on Supplement 2 with 5 flaws and Supplement 3 with 3 flaws results in a total of 18 flaws which will be multiplied by a factor of 3 for the procedure qualification.
Based on the above, the use of a limited number of Supplement 2 or 3 flaws is sufficient to access the capabilities of procedures and personnel who have already satisfied Supplement 10 requirements. 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 proposed alternative is consistent with other coordinated qualifications currently contained in Appendix Vil.
The proposed alternate program is provided as Attachment 1 and is identified as Supplement
: 14. It has been submitted to the ASME Code Committee for consideration as new Supplement 14 to Appendix Vil.
ALTERNATIVE EXAMINATION In lieu of the requirements of ASME Section Xi, 1995 Edition, 1996 Addenda, Appendix ViII, Table VilI-3110-1, the Performance Demonstration Initiative (PDI) Program for implementation of Appendix Vil, Supplements 2 & 3, as coordinated with the alternative PDI Supplement 10 implementation program shall be used (see the Attachment to Enclosure 1 (RR-65). The PDI Program alternative is described in Attachment 1.
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 XI, Appendix Vil, Supplements 2 & 3 requirements. Compliance with the proposed alternatives will provide an adequate level of quality and safety for examination of the affected welds.
IMPLEMENTATION SCHEDULE The NRC is requested to approve this relief request for the remainder of the third Inservice Inspection Interval.
Page 2of2

SUPPLEMENT 14- QUALIFICATION REQUIREMENTS FOR COORDINATED SUPPLEMENT 2 AND 3 QUALIFICATION PERFORMED FROM THE INSIDE SURFACE Proposed Requirements                                 Technical Basis 1.0 SCOPE                                                               Reasoning This Supplement provides requirements for           There is currently no available Code action expansion of Supplement 10 procedure,               allowing for a coordinated implementation of equipment, and personnel inside surface             the fundamental qualifications required for the qualifications with add-ons of Supplements 2        typical examinations performed from the ID of and 3 qualifications. The same ultrasonic           PWR nozzles. Without this Code essential variables values, or, when                Case/Change, qualifications would require an appropriate, the same criteria for selecting        excessive amount of flawed and unflawed values as demonstrated in Supplement 10 shall grading units. This proposed supplement uses be used. This Supplement is applicable to           the more technically stringent Supplement 10 examinations conducted from the inside              qualification as a base and then incorporates a surface.                                            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 2.1 General 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. The specimen sets 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               This criteria is consistent with Supplement 10.
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.
(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, NL-03-1 73 ENCLOSURE 2, ATTACHMMENT I Page 1 of 5

SUPPLEMENT 14- QUALIFICATION REQUIREMENTS FOR COORDINATED SUPPLEMENT 2 AND 3 QUALIFICATION PERFORMED FROM THE INSIDE SURFACE Proposed Requirements               I              Technical Basis adjacent welds in close proximity, and weld repair areas);
(2)typical limited scanning surface conditions (e.g., internal tapers, exposed weld roots, and cladding conditions).                             I 2.2 At least 70% of the Supplement 2 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. (0.05 mm).                              +
2.3 Supplement 3 flaws shall be mechanical or thermal fatigue cracks.
2.4 The specimen set shall contain a                Since the number of flaws will be limited words representative distribution of flaws. Flawed and such as uniform distribution" could lead to unflawed grading units shall be randomly            testmanship and are considered inappropriate.
mixed.
3.0 CONDUCT OF PERFORMANCE DEMONSTRATION 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.
NL-03-1 73 ENCLOSURE 2, ATTACHMMENT 1 Page 2 of 5

SUPPLEMENT 14 - QUALIFICATION REQUIREMENTS FOR COORDINATED SUPPLEMENT 2 AND 3 QUALIFICATION PERFORMED FROM THE INSIDE SURFACE Proposed Requirements                 l                 Technical Basis 4.0 DETECTION QUALIFICATION The coordinated implementation shall include the following requirements for personnel detection qualification.
4.1 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.
4.2 The specimen set for Supplement 3 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.
4.3 Specimens shall be divided into grading units. Each grading unit shall include at least 3 in. (76 mm) of weld length. If a grading unit is designed to be unflawed, at least 1 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.
4.4 All grading units shall be correctly identified as beina either flawed or unflawed.                 4-5.0 LENGTH SIZING QUALIFICATION                     *1-The coordinated implementation shall include the following requirements for personnel length sizinq qualification.
5.1 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.
5.2 The specimen set for Supplement 3 qualification shall include at least three flaws in ferritic material.
NL-03-1 73 ENCLOSURE 2, ATTACHMMENT I Page 3 of 5

SUPPLEMENT 14 - QUALIFICATION REQUIREMENTS FOR COORDINATED SUPPLEMENT 2 AND 3 QUALIFICATION PERFORMED FROM THE INSIDE SURFACE Proposed Requirements                                Technical Basis 5.3 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.
5.4 Supplement 2 examination procedures, equipment, and personnel are qualified for length sizing when the flaw lengths estimated by ultrasonics, as compared with the true lengths, does not exceed 0.75 in. (19 mm)
RMS when they are combined with a successful Supplement 10 qualification.
5.5 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, does not exceed 0.75 in. (19 mm)
RMS when they are combined with a successful Supplement 10 qualification.
6.0 DEPTH SIZING QUALIFICATION The coordinated implementation shall include the following requirements for personnel depth sizing qualification.
6.1 The specimen set for Supplement 2               Axial flaws are not depth sized in Supplement qualification shall include at least four           2.
circumferentially oriented flaws in austenitic material.
6.2 The specimen set for Supplement 3 qualification shall include at least three flaws in ferritic material.
6.3 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.
NL-03-1 73 ENCLOSURE 2, ATTACHMMENT I Page 4 of 5

SUPPLEMENT 14 - QUALIFICATION REQUIREMENTS FOR COORDINATED SUPPLEMENT 2 AND 3 QUALIFICATION PERFORMED FROM THE INSIDE SURFACE Proposed Requirements                      Technical Basis 6.4 Supplement 2 examination procedures, equipment, and personnel are qualified for depth sizing when the flaw depths estimated by ultrasonics, as compared with the true depths, does not exceed 0.125 in. (3 mm)
RMS when they are combined with a successful Supplement 10 qualification.
6.5 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, does not exceed 0.125 in. (3 mm)
RMS when they are combined with a successful Supplement 10 qualification.
7.0 PROCEDURE QUALIFICATION Procedure qualifications shall include the following additional requirements.
(a)The specimen set shall include the equivalent of at least three personnel sets.
Successful personnel demonstrations may be combined to satisfy these requirements.
(b) Detectability of all flaws within the scope of the procedure shall be demonstrated. Length and depth sizing shall meet the requirements of paragraph 5.0 and 6.0.
(c)At least one successful personnel demonstration has been performed.
(d)To qualify new values of essential variables, at least one personnel qualification set is required.
NL-03-173 ENCLOSURE 2, ATTACHMMENT I Page 5 of 5

NL-03-1 73 ENCLOSURE 3 INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 THIRD TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST RR 3-34 SYSTEM/COMPONENT(S) FOR WHICH RELIEF IS REQUESTED ASME Section XI, 1989 Edition, no Addenda, Class 1, Category B-F, Pressure Retaining Piping Welds, Item Numbers B5.10, B5.40, B5.70, subject to ultrasonic examination using procedures, personnel, and equipment qualified to ASME Section XI, 1995 Edition, 1996 Addenda, Appendix VIII, Supplement 10 criteria.
CODE REQUIREMENTS The following paragraphs or statements are from ASME Section XI, Rules for Inservice Inspection of Nuclear Power plant Components, 1995 Edition, 1996 Addenda, Appendix VIII, Supplement 10, Qualification Requirements for Dissimilar Metal Piping Welds, 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.
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.
1 of 6

NL-03-1 73 ENCLOSURE 3 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.
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 Committee for consideration.
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 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 2 of 6

NL-03-1 73 ENCLOSURE 3 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.
xaeaI          Mechanical fatigue crac[k l =a      4       in 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."
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 alternative 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 alternative reduces the ratio to 1.5 times to reduce the number of test samples to a more reasonable number from the human factors perspective. However, the statistical basis used for screening personnel and procedures is still maintained at the same level with competent personnel being successful and less skilled personnel being unsuccessful. The acceptance criteria for the statistical basis are in Table Vil-S10-1.
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NL-03-173 ENCLOSURE 3 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%
In addition, the proposed alternative includes the following: At least 75% of the flaws shall be in the range of 10 to 60% of wall thickness.'
Technical Basis - The proposed alternative uses the depth sizing distribution for both detection and depth sizing because it provides for a better distribution of flaw sizes within the test set.
This distribution allows candidates to perform detection, length, and depth sizing demonstrations simultaneously utilizing the same test set. The requirement that at least 75% of the flaws shall be in the range of 10 to 60% of wall thickness provides an overall distribution tolerance yet the distribution uncertainty decreases the possibilities for testmanship that would be inherent to a uniform distribution. It must be noted that it is possible to achieve the same distribution utilizing the present requirements, but it is preferable to make the criteria consistent.
Item 6 - 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.
4 of 6

NL-03-173 ENCLOSURE 3 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             ce criteria of Table Vil-S2-1 as follows:
1 101 TABLE VIII-S/-l 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                                12 7                  6             14                   1 8                  7             16                   2 9                  7             10 10                   8                   15             3-I   2 11                   9             2- 17                3-    3 12                   9             24-18                33 13                  10             26-20                4-3 14                  10             26 21                5     3 15                  11             30- 23                5-   3 16                 12             3z-24                6     4 17         -        12             3 26                 6-    4 18                  13                  27               74 4 19                  13              J&deg; 29               7-4 20                  14             4 30                 8     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 5 of 6

NL-03-173 ENCLOSURE 3 part of ongoing Code activities, Pacific Northwest National Laboratory (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 VII, Supplement 10, the proposed alternative shall be used. The proposed alternative is described in the attachment.
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 XI, 1995 Edition, 1996 Addenda, Appendix VII, Supplement 10 requirements. Compliance with the proposed alternatives will provide an adequate level of quality and safety for examination of the affected welds.
IMPLEMENTATION SCHEDULE The NRC is requested to approve this relief request for the remainder of the 3d Inservice Inspection Interval for Indian Point Unit 3.
6 of 6

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                                Proposed Change                                      Reasoning 1.0      SCOPE Supplement 10 isapplicable to dissimilar           A scope statement provides added clarity metal piping welds examined from either the        regarding the applicable range of each inside or outside surface. Supplement 10 Is        individual Supplement. The exclusion of CRC not applicable to piping welds containing          provides consistency between Supplement 10 supplemental corrosion resistant clad (CRC)        and the recent revision to Supplement 2 applied to mitigate ntergranular Stress            (Reference BC 00-755). Note, an additional Corrosion Cracking (IGSCC).                        change identifying CRC as "incourse 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 specific limitations stated in the scope of the limitations stated in the scope of the examination examination procedure (e.g., pipe size, weld    procedure (e.g., pipe size, weld joint joint configuration, access limitations). The   configuration, access limitations). The same same specimens may be used to demonstrate       specimens may be used to demonstrate both both detection and sizing qualification.        detection and sizing qualification.
1.1 General. The specimen set shall conform     2.1 General. The specimen set shall conform to Renumbered to the following requirements.                  the following requirements.
(a)The minimum number of flaws in a test set New, changed minimum number of flaws to 10 shall be ten.                                      so 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          minimize spurious reflections   that may interfere interfere with the interpretation process.      with the interpretation process.
Page 1 of 11 NL-03-1 73 Enclosure 3, Attachment

SUPPLEMENT 10- QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                                   Proposed Change                                      Reasoning (b)The specimen set shall include the              (c) The specimen set shall include the minimum    Renumbered, metricated, the change in pipe minimum and maximum pipe diameters and             and maximum pipe diameters and thicknesses        diameter tolerance provides consistency thicknesses for which the examination              for which the examination procedure is            between Supplement 10 and the recent procedure is applicable. Pipe diameters within     applicable. Pipe diameters within a range of 1/2  revision to Supplement 2 (Reference BC 00-a range of 0.9 to 1.5 times a nominal diameter     in. (13 mm) of the nominal diameter shall be      755).
shall be considered equivalent. Pipe               considered equivalent. Pipe diameters larger diameters larger than 24 in.shall be               than 24 in. (610 mm) shall be considered to be considered to be flat. When a range of             flat. When a range of thicknesses is to be thicknesses is to be examined, a thickness         examined, a thickness tolerance of +25% is tolerance of +25% is acceptable.                   acceptable.
(c)The specimen set shall include examples         (d) The specimen set shall include examples of    Renumbered, changed "condition" to of the following fabrication condition:            the following fabrication conditions:             "conditions".
(1)geometric conditions that normally require      (1) geometric and material conditions that        Clarification, some of the items listed relate to discrimination from flaws (e.g., counterbore or    normally require discrimination from flaws (e.g., material conditions rather than geometric weld root conditions, cladding, weld buttering,    counterbore or weld root conditions, cladding,    conditions. Weld repair areas were added as remnants of previous welds, adjacent welds in      weld buttering, remnants of previous welds,       a result of recent field experiences.
close proximity);                                  adjacent welds in close proximity, and weld
                          ._______________________ repair areas);
(2)typical limited scanning surface conditions     (2)typical limited scanning surface conditions    Differentiates between IDand OD scanning (e.g., diametrical shrink, single-side access      (e.g., weld crowns, diametrical shrink, single-   surface limitations. Requires that IDand OD due to nozzle and safe end external tapers).       side access due to nozzle and safe end external   qualifications be conducted independently tapers for outside surface examinations; and      (Note, new paragraph 2.0 (identical to old internal tapers, exposed weld roots, and          paragraph 1.0) provides for alternatives when cladding conditions for inside surface            "a set of specimens is designed to examinations). Qualification requirements         accommodate specific limitations stated in the shall be satisfied separately for outside         scope of the examination procedure.").
surface and inside surface examinations.
(d)All flaws in the specimen set shall be                                                            Deleted this requirement, because new cracks.                                                                                              paragraph 2.3 below provides for the use of "alternative flaws" in lieu of cracks.
(1)At least 50% of the cracks shall be in          2.2 Flaw Location. At least 80% of the flaws      Renumbered and re-titled. Flaw location austenitic material. At least 50% of the cracks shall be contained wholly in weld or buttering       percentages redistributed because field in austenitic material shall be contained wholly material. At least one and a maximum of 10%         experience indicates that flaws contained in Page 2 of 11 NL-03-1 73 Enclosure 3, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                               Proposed Change                      l                   Reasoning in weld or buttering material. At least 10% of of the flaws shall be in ferritic base material. At   weld or buttering material are probable and the cracks shall be in ferritic material. The  least one and a maximum of 10% of the flaws           represent the more stringent ultrasonic remainder of the cracks may be in either       shall be in austenitic base material.                 detection scenario.
austenitic or ferritic material.
(2)At least 50% of the cracks in austenitic    2.3 Flaw Type.                                        Renumbered and re-titled. Alternative flaws base material shall be either IGSCC or         (a)At least 60% of the flaws shall be cracks,         are required for placing axial flaws in the HAZ thermal fatigue cracks. At least 50% of the    the remainder shall be alternative flaws.             of the weld and other areas where cracks in ferritic material shall be           Specimens with IGSCC shall be used when               implantation of a crack produces metallurgical mechanically or thermally induced fatigue      available. Alternative flaws, if used, shall          conditions that result in an unrealistic cracks.                                        provide crack-like reflective characteristics         ultrasonic response. This is consistent with and shall be limited to the case where                the recent revision to Supplement 2 implantation of cracks produces spurious              (Reference BC 00-755).
reflectors that are uncharacteristic of service induced flaws. Alternative flaw mechanisms            The 40% limit on alternative flaws is needed to shall have a tip width of less than or equal to       support the requirement for up to 70% axial 0.002 in. (.05 mm).                                   flaws. Metricated (3)At least 50% of the cracks shall be         (b)At least 50% of the flaws shall be coincident      Renumbered. Due to inclusion of "alternative coincident 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. All flaw depths shall be greater      Moved from old paragraph 1.3(c) and 1.4 and than 10% of the nominal pipe wall thickness.          re-titled. Consistency between detection and Flaw depths shall exceed the nominal clad             sizing specimen set requirements (e.g., 20%
thickness when placed in cladding.                    vs. 1/3 flaw depth increments, e.g., original Flaws in the sample set shall be distributed          paragraph 1.3(c)).
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 Page 3 of 11 NL-03-173 Enclosure 3, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                                 Proposed Change                      Reasoning l of 10 to 60% of wall thickness.
1.2 Detection Specimens. The specimen set                                          Renumbered and re-titled and moved to shall include detection specimens that meet                                        paragraph 3.1(a). No other changes.
the following requirements.
(a) Specimens shall be divided into grading                                        Renumbered to paragraph 3.1(a)(1).
units. Each grading unit shall include at least                                    No other changes.
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 V111-S2-1. The number of unflawed grading units shall be at least twice the number of flawed grading units.
(c) Flawed grading units shall meet the                                            Flaw depth requirements moved to new following criteria for flaw depth, orientation,                                    paragraph 2.4, flaw orientation requirements and type.                                                                          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%                                       Deleted, for consistency in sample sets the of the nominal pipe wall thickness. At least 1/3                                   depth distribution is the same for detection and of the flaws, rounded to the next higher whole                                     sizing.
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 Page 4 of 11 NL-03-1 73 Enclosure 3, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                                 Proposed Change                                        Reasoning thickness.
(2)At least 30% and no more than 70% of the      2.5 Flaw Orientation.                              Note, this distribution is applicable for flaws, rounded to the next higher whole          (a) For other than sizing specimens,  at least 30% detection  and depth sizing. Paragraph number, shall be oriented axially. The           and no more than 70% of the flaws, rounded to      2.5(b)(1) requires that all length- sizing flaws remainder of the flaws shall be oriented         the next higher whole number, shall be oriented be oriented circumferentially.
circumferentially.                               axially. The remainder of the flaws shall be oriented circumferentially.
1.3 Length Sizing Specimens. The                                                                    Renumbered and re-titled and moved to new specimen set shall include length sizing                                                            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 above.
ten.
(c)All flaw depths shall be greater than 10%                                                        Moved, included in new paragraph 2.4 above of the nominal pipe wall thickness. At least 1/3                                                    after revision for consistency with detection of the flaws, rounded to the next higher whole                                                      distribution.
number, shall have depths between 10% and 30% of the nominal pipe wall thickness.
However, flaw depth shall exceed the nominal clad thickness when placed in cladding. At least 1/3 of the flaws, rounded to the next whole number, shall have depths greater than 30% of the nominal pipe wall thickness.
1.4 Depth Sizing Specimens. The specimen                                                            Moved, included in new paragraphs 2.1, 2.3, set shall include depth sizing specimens that                                                       2.4.
meet the following requirements.
(a)The minimum number of flaws shall be                                                             Moved, included in new paragraph 2.1.
ten.
(b) Flaws in the sample set shall not be wholly                                                     Moved, potential conflict with old paragraph contained within cladding and shall be                                                              1.2(c)(1); However, flaw depths shall exceed distributed as follows:                                                                             the nominal clad thickness when placed in Page 5 of 11 NL-03-1 73 Enclosure 3, Attachment

SUPPLEMENT 10- QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                               Proposed Change                                     Reasoning cladding.". Revised for clarity and included in new paragraph 2.4.
Flaw Depth             Minimum                                                                 Moved, included in paragraph 2.4 for
(% Wall Thickness)     Number of Flaws                                                         consistent applicability to detection and sizing 10-30%                20%                                                              samples.
31-60%                20%
61-100%               20%
The remaining flaws shall be in any of the above categories.
(b) Sizing Specimen sets shall meet the         Added for clarity.
following requirements.
(1)All 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     CONDUCT OF PERFORMANCE                  Renumbered DEMONSTRATION                                  DEMONSTRATION The specimen inside surface and identification For qualifications from the outside surface,    Differentiate between qualifications conducted shall be concealed from the candidate. All     the specimen inside surface and                 from the outside and inside surface.
examinations shall be completed prior to       identification shall be concealed from the grading the results and presenting the results candidate. When qualifications are performed to the candidate. Divulgence of particular     from the inside surface, the flaw location and specimen results or candidate viewing of       specimen identification shall be obscured to unmasked specimens after the performance       maintain a "blind test". All examinations shall demonstration is prohibited.                   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.
Page 6 of 11 NL-03-1 73 Enclosure 3, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement.                         Proposed Change                                       Reasoning 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 1.2.
specimens that meet the following requirements.
(1) Specimens shall be divided into grading        Renumbered, moved from old paragraph units.                                         1.2(a). Metricated. No other changes.
(a) Each grading unit shall include at least 3 in.
(76 mm) of weld length.
(b) The end of each flaw shall be separated from an unflawed grading unit by at least I in.
(25 mm) of unflawed material. A flaw my 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) Detection sets shall be selected from Table    Moved from old paragraph 1.2(b). Table Vil-SI0-1. The number of unflawed grading          revised to reflect a change in the minimum units shall be at least one and a half times the   sample set to 10 and the application of number of flawed grading units.                    equivalent statistical false call parameters to the reduction in unflawed grading units.
Human factors due to large sample size.
(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 qualified for detection when personnel             reflect the 100% detection acceptance criteria demonstrations satisfy the acceptance criteria     of procedures versus personnel and of Table Vil SIO-1 for both detection and false    equipment contained in new paragraph 4.0 Page 7 of 11 NL-03-1 73 Enclosure 3, Attachment

SUPPLEMENT 10- QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement.                                Proposed Change                                      Reasoning 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 VII-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 separately or in conjunction with the detection detection test shall be length sized.              and the recent revision to Supplement 2 test.                                                                                              (Reference BC 00-755).
(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   conjunction with the detection test, and less than consistent with the recent revision to than ten circumferential flaws are detected,    ten circumferential flaws are detected, additional Supplement 2 (Reference BC 00-755).
additional specimens shall be provided to the   specimens shall be provided to the candidate candidate such that at least ten flaws are      such that at least ten flaws are sized. The        Note, length and depth sizing use the term sized. The regions containing a flaw to be      regions containing a flaw to be sized may be       "regions" while detection uses the term sized shall be identified to the candidate. The identified to the candidate. The candidate shall   Ugrading units". The two terms define different candidate shall determine the length of the     determine the length of the flaw in each region. concepts and are not intended to be equal or flaw in each region.                                                                               interchangeable.
(c) For a separate length sizing test, the      (c) For a separate length sizing test, the regions Change made to ensure security of samples, regions of each specimen containing a flaw to   of each specimen containing a flaw to be sized     consistent with the recent revision to be sized shall be identified to the candidate. may be identified to the candidate. The            Supplement 2 (Reference BC 00-755).
The candidate shall determine the length of     candidate shall determine the length of the flaw the flaw in each region.                        in each region.
(d) Examination procedures, equipment, and         Moved from old paragraph 3.2(a) includes personnel are qualified for length sizing when     inclusion of "when" as an editorial change.
the RMS error of the flaw length measurements,     Metricated.
as compared to the true flaw lengths, is less than or equal to 0.75 in. (19 mm).
Page 8 of 11 NL-03-1 73 Enclosure 3, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                                Proposed Change                                      Reasoning 2.3 Depth Sizing Test                           3.3 Depth Sizing Test                             Renumbered (a) For the depth sizing test, 80% of the flaws (a) The depth sizing test may be conducted        Change made to ensure security of samples, shall be sized at a specific location on the    separately or in conjunction with the             consistent with the recent revision to surface of the specimen identified to the       detection test. For a separate depth sizing       Supplement 2 (Reference BC 00-755).
candidate.                                      test, the regions of each specimen containing a flaw to be sized may be identified to the candidate. The candidate shall determine the maximum depth of the flaw in each region.
(b) For the remaining flaws, the regions of     (b)When the depth sizing test is conducted in     Change made to be consistent with the recent each specimen containing a flaw to be sized     conjunction with the detection test, and less     revision to Supplement 2 (Reference BC 00-shall be identified to the candidate. The       than ten flaws are detected, additional           755).
candidate shall determine the maximum depth     specimens shall be provided to the candidate of the flaw in each region.                     such that at least ten flaws are sized. The       Changes made to ensure security of samples, regions of each specimen containing a flaw to be  consistent with the recent revision to sized may be identified to the candidate. The     Supplement 2 (Reference BC 00-755).
candidate shall determine the maximum depth of the flaw in each region.
(c) Examination procedures, equipment, and        Moved from old paragraph 3.2(b). Metricated.
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. (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 the personnel are qualified for detection when the                                                    change in the minimum number of flaws and results of the performance demonstration                                                          the reduction in unflawed grading units from satisfy the acceptance criteria of Table VilI-                                                    2X to 1.5X.
S2-1 for both detection and false calls.
3.2 Sizing Acceptance Criteria                                                                    Deleted as a separate category. Moved to Page 9 of 11 NL-03-1 73 Enclosure   3,  Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                              Proposed Change                                    Reasoning new paragraph on length 3.2 and depth 3.3 (a) Examination procedures, equipment, and                                                    Moved to new paragraph 3.2(d), included word personnel are qualified for length sizing the                                                 "when" as an editorial change.
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, 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 following additional requirements.              conducting qualifications, the equivalent of 3 (a) The specimen set shall include the          personnel sets (i.e., a minimum of 30 flaws) is equivalent of at least three personnel sets. required to provide enough flaws to Successful personnel demonstrations may be adequately test the capabilities of the combined to satisfy these requirements.         procedure. Combining successful (b) Detectability of all flaws within the scope demonstrations allows a variety of examiners of the procedure shall be demonstrated.         to be used to qualify the procedure.
Length and depth sizing shall meet the          Detectability of each flaw within the scope of requirements of paragraph 3.1, 3.2 and 3.3. the procedure is required to ensure an (c) At least one successful personnel           acceptable personnel pass rate. The last demonstration shall be performed.               sentence is equivalent to the previous (d) To qualify new values of essential          requirements and is satisfactory for expanding variables, at least one personnel qualification the essential variables of a previously qualified set is required. The acceptance criteria of     procedure 4.0(b) shall be met.
Page 10 of 11 NL-03-1 73 Enclosure 3, Attachment

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement                      Proposed Change                 I          Reasoning I
TABLE VII-S"-1E 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                               10                   0 6            14                   1 7                  6            14                   1 8                  7            16                   2 9                  7            10                   2 10                  8            So- 15               }- 2 11                  9            2- 17                3-- 3 12                  9            24-18                3- 3 13                 10            26-20                4- 3 14                 10            26-21                5--3 15                 11            3- 23                5- 3 16                 12            32-24                6--4 17                 12            34- 26               6 4 18                 13            36- 27               7-- 4 19                 13            38-29                7 4 20                  14            40- 30               8- 5 Page 11 of 11 NL-03-173 Enclosure 3, Attachment

NL-03-1 73 Enclosure 3, Addenda Indian Point Unit 3 Relief Request RR 3-34, Addenda

==Subject:==

In addition to the base relief requested, Entergy requests that this qualification specific relief be allowed for examination of dissimilar metal welds referenced in the ASME Code, Section Xl, Appendix Vil, Supplement 10.
Entergy has been informed by its inspection vendor that procedures were not capable of being completely qualified to the Appendix VIII, Supplement 10 through-wall RMS sizing value of less than or equal to 0.125" RMS, (Ref. Par 3.2). Additionally, applicable to the P3 reactor nozzle to primary piping dissimilar metal weld, the procedure is fully qualified only for the detection and length sizing of circumferential flaws.
Components:
ASME Code Class 1 - Reactor Vessel to Primary Piping Dissimilar Metal Field Welds.
Code Requirement:
Procedures must be qualified to the Appendix VIII, Supplement 10 (Paragraph3.2), sizing value of less than or equal to 0.125" RMS.
Alternative Approach/Basis for Relief:
The utility's vendor is presently developing improvements to their depth sizing performance. If the vendor's current performance does not meet the ASME Code 0.125" RMS acceptance criteria, the utility will consider the achieved performance of the procedure during evaluations of detected flaws.
Entergy proposes to evaluate the depth sizing performance of their selected vendor and determine the appropriate sizing error to consider during such flaw evaluations. The difference between the achieved sizing error and the code required value of 0.125" RMS would be added to the size of flaws measured during the examination for the purpose of flaw evaluation.
It is the utility's position that compensating for the flaw through-wall sizing error band in fracture mechanics evaluation will provide an acceptable margin of safety in the in-service examination of IP3 nozzle to primary loop dissimilar metal welds.
Implementation Schedule:
The NRC is requested to approve this relief request for the remainder of the 3d Inservice Inspection Interval for Indian Point Unit 3.
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NL-03-1 73 ENCLOSURE 4 INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 THIRD TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST RR 3-35 SYSTEMICOMPONENT(S) FOR WHICH RELIEF IS REQUESTED ASME Code, Section XI, 1989 Edition, no Addenda, Class 1, Category B-J, Item Numbers B9.11 and 9.12, Pressure Retaining Piping Welds ultrasonically examined from the inside surface of Pressurized Water Reactors using procedures, personnel, and equipment qualified to ASME Section XI, 1995 Edition, 1996 Addenda, Appendix Vil, Supplements 2 and 3 criteria.
CODE REQUIREMENTS Relief is requested from the qualification requirements for piping welds contained in Table Vil-3110-1 of Appendix Vil to ASME Section XI, 1995 Edition, 1996 Addenda, Supplements 2 and 3 criteria.
RELIEF REQUESTED Relief is requested to use the enclosed proposed alternative for implementation of Appendix Vill, Supplements 2 and 3, as coordinated with the proposed alternative for the Supplement 10 implementation program (Attachment to Enclosure 3 (RR 3-34)).                    The Performance Demonstration Initiative (PDI) will administer the alternative program.
BASIS FOR RELIEF Depending upon the particular design, the nozzle to main coolant piping may be fabricated using ferritic, austenitic, or cast stainless components and assembled using ferritic, austenitic, or dissimilar metal welds. Additionally, differing combinations of these assemblies may be in close proximity, which typically 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.)
Separate qualifications to Supplements 2, 3, and 10 are redundant when done in accordance with the 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 essential variables used for the examination of Supplements 2, 3, and 10 are equivalent and a coordinated Page of 2

NL-03-1 73 ENCLOSURE 4 implementation would be sufficiently stringent to qualify all 3 Supplements if the requirements used to qualify Supplement 10 are satisfied as a prerequisite. The basis for this conclusion is the fact that the majority of the flaws in Supplement 10 are located wholly in austenitic weld material, which is known to be challenging for ultrasonic techniques due to the variable dendritic structure of the weld material. Flaws in Supplements 2 and 3 are located in fine-grained base materials, which are known to be less challenging.
Additionally, the proposed alternative is more stringent than current Code requirements for a detection and length sizing qualification. For example, the current Code would allow a detection procedure, personnel, and equipment to be qualified to Supplement 10 with 5 flaws, Supplement 2 with 5 flaws, and Supplement 3 with 5 flaws, a total of only 15 flaws. The proposed alternative of qualifying Supplement 10 using 10 flaws and adding on Supplement 2 with 5 flaws and Supplement 3 with 3 flaws results in a total of 18 flaws which will be multiplied by a factor of 3 for the procedure qualification.
Based on the above, the use of a limited number of Supplement 2 or 3 flaws is sufficient to access the capabilities of procedures and personnel who have already satisfied Supplement 10 requirements. 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 proposed alternative is consistent with other coordinated qualifications currently contained in Appendix Vil.
The proposed alternate program is provided as Attachment 1 and is identified as Supplement
: 14. It has been submitted to the ASME Code Committee for consideration as new Supplement 14 to Appendix VIII.
ALTERNATIVE EXAMINATION In lieu of the requirements of ASME Section Xl, 1995 Edition, 1996 Addenda, Appendix Vil, Table VIII-3110-1, the Performance Demonstration Initiative (PDI) Program for implementation of Appendix Vil, Supplements 2 and 3, as coordinated with the alternative PDI Supplement 10 implementation program shall be used (see the Attachment to Enclosure 3 (RR 3-34). The PDI Program alternative is described in Attachment 1.
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 XI, Appendix Vil, Supplements 2 and 3, requirements. Compliance with the proposed alternatives will provide an adequate level of quality and safety for examination of the affected welds.
IMPLEMENTATION SCHEDULE The NRC is requested to approve this relief request for the remainder of the third Inservice Inspection Interval.
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SUPPLEMENT 14- QUALIFICATION REQUIREMENTS FOR COORDINATED SUPPLEMENT 2 AND 3 QUALIFICATION PERFORMED FROM THE INSIDE SURFACE Proposed Requirements                X                Technical Basis 1.0 SCOPE                                                              Reasoning This Supplement provides requirements for          There is currently no available Code action expansion of Supplement 10 procedure,              allowing for a coordinated implementation of equipment, and personnel inside surface            the fundamental qualifications required for the qualifications with add-ons of Supplements 2       typical examinations performed from the IDof and 3 qualifications. The same ultrasonic          PWR nozzles. Without this Code essential variables values, or, when               Case/Change, qualifications would require an appropriate, the same criteria for selecting       excessive amount of flawed and unflawed values as demonstrated in Supplement 10 shall      grading units. This proposed supplement uses be used. This Supplement is applicable to          the more technically stringent Supplement 10 examinations conducted from the inside             qualification as a base and then incorporates a surface.                                           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 2.1General 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. The specimen sets 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             This criteria is consistent with Supplement 10.
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.
(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.
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SUPPLEMENT 14 - QUALIFICATION REQUIREMENTS FOR COORDINATED SUPPLEMENT 2 AND 3 QUALIFICATION PERFORMED FROM THE INSIDE SURFACE Proposed Requirements                            Technical Basis adjacent welds in close proximity, and weld repair areas);
(2) typical limited scanning surface conditions (e.g., internal tapers, exposed weld roots, and cladding conditions).
2.2 At least 70% of the Supplement 2 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. (0.05 mm).
2.3 Supplement 3 flaws shall be mechanical or thermal fatigue cracks.
2.4 The specimen set shall contain a              Since the number of flaws will be limited words representative distribution of flaws. Flawed and such as uniform distribution" could lead to unflawed grading units shall be randomly          testmanship and are considered inappropriate.
mixed.
3.0 CONDUCT OF PERFORMANCE DEMONSTRATION 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.
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SUPPLEMENT 14 - QUALIFICATION REQUIREMENTS FOR COORDINATED SUPPLEMENT 2 AND 3 QUALIFICATION PERFORMED FROM THE INSIDE SURFACE Proposed Requirements                               Technical Basis 4.0 DETECTION QUALIFICATION The coordinated implementation shall include the following requirements for personnel detection qualification.
4.1 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.
4.2 The specimen set for Supplement 3 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.
4.3 Specimens shall be divided into grading units. Each grading unit shall include at 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.
4.4 All grading units shall be correctly identified as being either flawed or unflawed.
5.0 LENGTH SIZING QUALIFICATION The coordinated implementation shall include the following requirements for personnel length sizing qualification.
5.1 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.
5.2 The specimen set for Supplement 3 qualification shall include at least three flaws in ferritic material.
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SUPPLEMENT 14 - QUALIFICATION REQUIREMENTS FOR COORDINATED SUPPLEMENT 2 AND 3 QUALIFICATION PERFORMED FROM THE INSIDE SURFACE Proposed Requirements                                 Technical Basis 5.3 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.
5.4 Supplement 2 examination procedures, equipment, and personnel are qualified for length sizing when the flaw lengths estimated by ultrasonics, as compared with the true lengths, does not exceed 0.75 in. (19 mm)
RMS when they are combined with a successful Supplement 10 qualification.
5.5 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, does not exceed 0.75 in. (19 mm)
RMS when they are combined with a successful Supplement 10 qualification.
6.0 DEPTH SIZING QUALIFICATION The coordinated implementation shall include the following requirements for personnel depth sizing qualification.
6.1 The specimen set for Supplement 2               Axial flaws are not depth sized in Supplement qualification shall include at least four           2.
circumferentially oriented flaws in austenitic material.
6.2 The specimen set for Supplement 3 qualification shall include at least three flaws in ferritic material.
6.3 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.
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SUPPLEMENT 14- QUALIFICATION REQUIREMENTS FOR COORDINATED SUPPLEMENT 2 AND 3 QUALIFICATION PERFORMED FROM THE INSIDE SURFACE Proposed Requirements                     Technical Basis 6.4 Supplement 2 examination procedures, equipment, and personnel are qualified for depth sizing when the flaw depths estimated by ultrasonics, as compared with the true depths, does not exceed 0.125 in. (3 mm)
RMS when they are combined with a successful Supplement 10 qualification.
6.5 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, does not exceed 0.125 in. (3 mm)
RMS when they are combined with a successful Supplement 10 qualification.
7.0 PROCEDURE QUALIFICATION_
Procedure qualifications shall include the following additional requirements.
(a) The specimen set shall include the equivalent of at least three personnel sets.
Successful personnel demonstrations may be combined to satisfy these requirements.
(b) Detectability of all flaws within the scope of the procedure shall be demonstrated. Length and depth sizing shall meet the requirements of paragraph 5.0 and 6.0.
(c) At least one successful personnel demonstration has been performed.
(d) To qualify new values of essential variables, at least one personnel qualification set is required.
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