ML072220295

Relief Request No. RR-04

ML072220295
Person / Time
Site:	Indian Point
Issue date:	09/26/2007
From:	Kowal M G NRC/NRR/ADRO/DORL/LPLI-1
To:	Balduzzi M A Entergy Nuclear Operations
Boska J P, NRR, 301-415-2901
References
RR-04, TAC MD4699
Download: ML072220295 (17)

Text

September 26, 2007Mr. Michael A. BalduzziSr. Vice President & COO Regional Operations, NE Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 - RELIEF REQUEST NO. RR-04 (TAC NO. MD4699)

Dear Mr. Balduzzi:

By letter dated February 28, 2007, as supplemented by letter dated June 4, 2007, EntergyNuclear Operations Inc., (the licensee) submitted a relief request for the fourth 10-year Inservice Inspection (ISI) Interval and Containment ISI Program Plan for Indian Point Nuclear Generating Unit No. 2. The proposed alternative will use the dissimilar metal weld qualification criteria administered by the Electric Power Research Institute's Performance Demonstration Initiative program in lieu of selected American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, Appendix VIII, Supplement 10 requirements.Inservice inspection of ASME Code Class 1, 2, and 3 components is performed in accordancewith Section XI of the ASME Code and applicable addenda as required by Title 10 of the Codeof Federal Regulations (10 CFR) Section 50.55a(g), except where specific relief has beengranted by the Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 50.55a(g)(6)(i).

Also, 10 CFR 50.55a(a)(3) states that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if: (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.Based on the enclosed safety evaluation, the NRC staff concludes that, in accordance with10 CFR 50.55a(a)(3)(i), the proposed alternative program will provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the proposed alternative under relief request No. RR-04, for the duration of the fourth 10-year ISI interval.

M. Balduzzi- 2 -If you have any questions regarding this approval, please contact the Indian Point ProjectManager, John Boska, at (301) 415-2901.Sincerely,/RA/Mark G. Kowal, ChiefPlant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-247

Enclosure:

Safety Evaluationcc w/encl: See next page

ML072220295*See memo dated June 26, 2007OFFICELPL1-1/PMLPL1-1/LACPNB/BCOGCLPL1-1/BCNAMEJBoskaSLittleJTsao forTChan*STurkMKowalDATE8/29/078/30/076/26/079/15/079/26/07 Indian Point Nuclear Generating Unit No. 2 cc:

Mr. Michael R. KanslerPresident & CEO / CNO Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213Mr. John T. HerronSr. Vice President Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213Sr. Vice PresidentEngineering & Technical Services Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213Mr. Fred R. DacimoSite Vice President Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249Mr. Anthony Vitale - ActingGeneral Manager, Plant Operations Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway P.O. Box 249 Buchanan, NY 10511-0249Mr. Oscar LimpiasVice President Engineering Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213Mr. Joseph P. DeRoyVice President, Operations Support Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213Mr. John A. VentosaGM, Engineering Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. John F. McCannDirector, Nuclear Safety & Licensing Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Ms. Charlene D. FaisonManager, Licensing Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. Ernest J. HarknessDirector, Oversight Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213Mr. Patric W. ConroyDirector, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249Mr. T.R. Jones - ActingManager, Licensing Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P. O. Box 249 Buchanan, NY 10511-0249Mr. William C. DennisAssistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Indian Point Nuclear Generating Unit No. 2 cc:

Mr. Michael BalboniDeputy Secretary for Public Safety State Capitol, Room 229 Albany, NY 12224Mr. John P. SpathNew York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399Mr. Paul EddyNew York State Department of Public Service 3 Empire State Plaza Albany, NY 12223-1350Regional Administrator, Region IU.S. Nuclear Regulatory Commission

475 Allendale Road King of Prussia, PA 19406Senior Resident Inspector's OfficeIndian Point 2 U. S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511Mr. Charles Donaldson, EsquireAssistant Attorney General New York Department of Law 120 Broadway New York, NY 10271Mr. Raymond L. AlbaneseFour County Coordinator 200 Bradhurst Avenue Unit 4 Westchester County Hawthorne, NY 10532Mayor, Village of Buchanan236 Tate Avenue Buchanan, NY 10511Mr. William DiProfioPWR SRC Consultant 48 Bear Hill Road Newton, NH 03858Mr. Garry RandolphPWR SRC Consultant 1750 Ben Franklin Drive, 7E Sarasota, FL 34236Mr. William T. RussellPWR SRC Consultant 400 Plantation Lane Stevensville, MD 21666-3232Mr. Jim RiccioGreenpeace 702 H Street, NW Suite 300 Washington, DC 20001Mr. Phillip MusegaasRiverkeeper, Inc.

828 South Broadway Tarrytown, NY 10591Mr. Mark JacobsIPSEC 46 Highland Drive Garrison, NY 10524 EnclosureSAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONREQUEST FOR RELIEF NO. RR-04ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NO. 2DOCKET NO. 50-24

71.0INTRODUCTION

By letter dated February 28, 2007, Agencywide Documents Access and Management System(ADAMS) Accession No. ML070640101, as supplemented by letter dated June 4, 2007, ADAMS Accession No. ML071620216, Entergy Nuclear Operations, Inc. (the licensee),

submitted the Indian Point Nuclear Generating Unit No. 2 (IP2) Fourth 10-year Interval Inservice Inspection (ISI) and Containment Inservice Inspection Program (CISI) plan. The application proposed relief request RR-04, alternatives to selected American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI requirements that relate to the ultrasonic examination of dissimilar metal welds at IP2. The request would authorize the use of the proposed alternative as administered by the Electric Power Research Institute's (EPRI's) Performance Demonstration Initiative (PDI) program in lieu of selected dissimilar metal weld qualification requirements of the ASME Code,Section XI, Appendix VIII, Supplement 10,for the fourth 10-year ISI interval, which began on March 1, 2007. IP2's current operating license will expire on September 28, 2013, approximately 3 years before the end of the fourth 10-year ISI interval, although a license renewal application is under review by the Nuclear Regulatory Commission (NRC).2.0REGULATORY REQUIREMENTSPursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(4), ASME CodeClass 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components,"

to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure test conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) twelve months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The ASME Code of record for IP2's fourth ISI interval is the 2001 Edition with the 2003 Addenda of Section XI of the ASME Code. In accordance with 10 CFR 50.55a(g)(6)(ii)(c), the implementation of Supplements 1 through 8,10 and 11 of Appendix VIII to Section XI, 1995 Edition with the 1996 Addenda of the ASME Code is required on a phased schedule ending on November 22, 2002. Supplement 10 was required to be implemented by November 22, 2002. Additionally, 10 CFR 50.55a(g)(6)(ii)(C)(2) requires licensees implementing the 1989 Edition and earlier editions of Section XI of the ASME Code to implement the 1995 Edition with the 1996 Addenda of Appendix VIII and supplementsto Appendix VIII of Section XI of the ASME Code.Alternatives to requirements may be authorized or relief granted by the NRC pursuant to 10 CFR 50.55a(a)(3)(i), 10 CFR 50.55a(a)(3)(ii), or 10 CFR 50.55a(g)(6)(i). In proposing alternatives or requesting relief, the licensee must demonstrate that: (1) the proposed alternatives provide an acceptable level of safety; (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety; or (3) conformance is impractical for the facility. Pursuant to 10 CFR 50.55a(g)(4)(iv), ISI items may meet the requirements set forth in subsequent editions and addenda of the ASME Code that are incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed therein, and subject to Commission approval. Portions of editions and addenda may be used provided that requirements of the respective editions and addenda are met.Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee submitted the request as a proposedalternative to selected ASME Code,Section XI, Appendix VIII, Supplement 10 requirements forthe fourth 10-year ISI interval at IP2 which began on March 1, 2007, and ends April 3, 2016. 3.0EVALUATION

3.1 Applicable

Code Requirements The licensee's applicable ISI code of record is the 2001 Edition, with the 2003 Addenda, of theASME Code,Section XI, Appendix VIII, Supplement 10, of which the implementation is requiredin accordance with 10 CFR 50.55a(g)(6)(ii)(c).The licensee proposed alternatives to the following Supplement 10 requirements: 1.1(b), 1.1(d), 1.1(d)(1), 1.2(b), 1.2(c)(1

), 1.3(c), 1.4(b), 2.0, 2.2(b), 2.2(c), 2.3(a), 2.3(b), and Table VIII-S2-1. 3.1.1 Applicable Systems/Components The requested relief from the Supplement 10 requirements is applicable to pressure-retainingdissimilar metal welds in vessel nozzles subject to ultrasonic examination using procedures, personnel, and equipment qualified to the ASME Code,Section XI, Appendix VIII, Supplement10 criteria.3.2 Licensee's Proposed Alternative and Bases Pursuant to the alternative provisions in 10 CFR 50.55a(a)(3)(i), the licensee proposed thefollowing for the duration of the fourth 10-year ISI interval at IP2. The proposed alternative will be implemented through the PDI program. Paragraph 1.1(b) proposed alternative:"The specimen set shall include the minimum and maximum pipe diameters and thicknesses forwhich 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 thediameter 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.Paragraph 1.1(d) proposed alternative:

"At least 60% of the flaws shall be cracks, the remainder shall be alternative flaws. Specimenswith intergranular stress corrosion cracking (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 produce spurious reflectors that are uncharacteristic of actual flaws. Alternative flaw mechanisms shall have a tip width of less than or equal to 0.002 in.

(.05 mm). Note, to avoid confusion, the proposed alternative modifies instances of the term"cracks" or "cracking" to the term "flaws" because of the use of alternative flaw mechanisms."Technical Basis - As illustrated by the licensee's submittal, implanting a crack requiresexcavation 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.Paragraph 1.1(d)(1) proposed alternative:

"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 ASME Code, as few as 25% of the flaws are contained inaustenitic weld or buttering material. Recent experience has indicated that flaws contained within the weld are the likely scenario. 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 ASME Code. Paragraph 1.2(b) proposed alternative:"Detection sets shall be selected from Table VIII-S10-1. The number of unflawed grading unitsshall be at least one and a half times the number of flawed grading units."Technical Basis - New Table VIII-S10-1 provides a statistically based ratio between the numberof unflawed grading units and the number of flawed grading units. The proposed alternative reduces the ratio to 1.5 times. This reduces 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 Vlll-S10-1.Paragraph 1.2(c)(1) and 1.3(c) proposed alternative:

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 (% Wall Thickness)Minimum Numberof Flaws10-30%20%31-60%20%61-100%20%Technical Basis - The proposed alternative uses the depth sizing distribution for both detectionand 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. 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.Paragraph 2.0 first sentence proposed alternative:

"For qualifications from the outside surface, the specimen inside surface and identification shallbe 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"."The current Code requires that the inside surface be concealed from the candidate. This makesqualifications conducted from the inside of the pipe (e.g., pressurized-water reactor nozzle to safe end welds) impractical. The proposed alternative differentiates between inner diameter (ID) and outer diameter (OD) scanning surfaces, requires that they be conducted separately, and requires that flaws be concealed from the candidate. Paragraph 2.2(b) and 2.2(c) proposed alternative:"The regions containing a flaw to be sized may be identified to the candidate."

Technical Basis - The current ASME Code requires that the regions of each specimencontaining a flaw to be length sized shall be identified to the candidate. The candidate shalldetermine 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 recentrevision to Supplement 2.Paragraph 2.3(a) and 2.3(b) proposed alternative:

"... regions of each specimen containing a flaw to be sized may be identified to the candidate."Technical Basis - The current ASME Code requires that a large number of flaws be sized at aspecific 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. Table VIII-S2-1 acceptance criteria proposed alternative:Table VIII-S2 10-1PERFORMANCE DEMONSTRATION DETECTION TESTACCEPTANCE CRITERIADetection TestAcceptance CriteriaFalse Call TestAcceptance CriteriaNo. ofFlawedGrading UnitsMinimumDetectionCriteriaNo. ofUnflawedGradingMaximumNumberof False Calls 5 5 10 0 6 6 12 1 7 6 14 1 8 7 16 2 9 7 18 210820 153 211922 173 312924 183 3131026 204 3141028 215 3151130 235 3161232 246 4171234 266 4181336 277 4191338 297 4201440 308 5Technical Basis - The proposed alternative is identified as new Table VIII-S10-1. It wasmodified to reflect the reduced number of unflawed grading units and allowable false calls. As a part of ongoing ASME Code activities, Pacific Northwest National Laboratory (PNNL) has reviewed the statistical significance of these revisions and offered the revised Table VIII-S10-1.3.3 Staff Evaluation The licensee proposed the use of the examination program developed by PDI. The NRC staff'sevaluation of the PDI program is discussed below. Paragraph 1.1(b):The ASME Code requirement that 0.9 to 1.5 times the nominal diameter are equivalent wasestablished for a single nominal diameter. When applying the ASME Code-required tolerance to a range of diameters, the tolerance rapidly expands on the high side. Based on the current requirements, a 5-inch outer diameter pipe would be equivalent to a range of 4.5-inch to 7.5-inch diameter pipe. Under the proposed PDI guidelines, the equivalent range would be reducedto 4.5-inch to 5.5-inch diameter pipe. Additionally, with the current ASME Code requirements, a 16-inch nominal diameter pipe would be equivalent to a range of 14.4-inch to 24-inch diameterpipe. The proposed PDI guidelines would significantly reduce the equivalent range to between 15.5-inch and 16.5-inch diameter pipe. The difference between the ASME Code and the proposed PDI program for diameters less than 5 inches is not significant because of a shorter metal path and beam spread associated with smaller diameter piping.The NRC staff reviewed the licensee's technical basis for the proposed alternative and agreeswith the licensee's assessment that the alternative provides tolerances more in-line with industry practice. Based on the discussion as presented above, the staff finds the proposed alternative will provide more conservative tolerance results for a range of piping diameters in comparison to the current ASME Code requirements. The staff also finds that the differences in tolerance results for smaller diameter piping are not significant. Therefore, the NRC staff finds the proposed alternative acceptable.Paragraph 1.1(d):

The ASME Code requires all flaws to be cracks. Manufacturing test specimens containingcracks free of spurious reflections and telltale indicators is extremely difficult in austenitic material. To overcome these difficulties, the EPRI developed a process for fabricating flaws that produce ultrasonic acoustic responses similar to the responses associated with actual cracks. EPRI presented its process at public meetings held June 12 through 14, 2001, and January 31 through February 2, 2002, at EPRI's Non-Destructive Examination Center located in Charlotte, North Carolina.The NRC staff attended the meetings and determined that the process parameters used formanufacturing fabricated flaws demonstrated the ability to produce acoustic responses similar to those associated with actual cracks. In addition, the staff reviewed the licensee's technical basis and agrees with the licensee's assessment. Therefore, the NRC staff concludes that the proposed alternative adequately demonstrates that ASME Code requirements are met. Paragraph 1.1(d)(1):

The ASME Code requires that at least 50% of the flaws be contained in austenitic material andat least 50% of the flaws in the austenitic material shall be contained fully in weld or buttering material. This means that at least 25% of the total flaws must be located in the weld or buttering material. Industry experience shows that flaws identified during ISI of dissimilar metal welds are more likely to be located in the weld or buttering material. The grain structure of austenitic weld and buttering material represents a much more stringent ultrasonic scenario than that of a ferritic or austenitic base material. Flaws in austenitic base material that are free of spurious reflectors and telltale indicators are difficult to create. The NRC staff finds the proposed alternative that at least 80% of the flaws be contained in theweld metal or buttering material provides a testing scenario reflective of industry experience and minimizes difficulties associated with telltale reflectors common to placing flaws in austenitic base material. Therefore, the NRC staff finds the proposed alternative provides a more rigorous inspection than that required by the ASME Code and, therefore, is acceptable.Paragraph 1.2(b):

The ASME Code requires that detection sets meet the requirements of Table VIII-S2-1, whichspecify the minimum number of flaws in a test set to be five with 100% detection. The ASME Code also requires the number of unflawed grading units to be two times the number of flawed grading units. The proposed alternative would follow the detection criteria of the table beginning with a minimum number of flaws in a test set being 10, reducing the number of false calls to one and a half times the number of flawed grading units.The NRC staff reviewed the licensee's technical basis and finds that the proposed alternativesatisfies the pass/fail objective established in ASME Code,Section XI, Appendix VIII forperformance demonstration acceptance criteria.Paragraph 1.2(c)(1), Paragraph 1.3(c):

The ASME Code requires, for detection and length sizing, that at least 1/3 of the flaws belocated between 10-30% through the wall thickness and 1/3 located greater than 30% through the wall thickness. The remaining 40% would be located randomly throughout the pipe wall thickness. The proposed alternative sets the distribution criteria for detection and length sizing to be the same as the depth sizing distribution, which stipulates that at least 20% of the flaws be located in each of the increments of 10-30%, 31-60%, and 61-100%. The remaining 40%

would be located randomly throughout the wall thickness. With the exception of the 10-30%

increment, the proposed alternative is a subset of the ASME Code requirements. The 10-30%

increment would be in the subset if it contained at least 30% of the flaws.The NRC staff reviewed the licensee's technical basis for the proposed alternative. The stafffinds the change simplifies the assembly of test sets for detection and sizing qualifications and, based on industry experience, is more indicative of actual conditions in the field. In addition,the staff finds the proposed alternative does not significantly deviate from, or reduce the level of, detection and length sizing from that required in the ASME Code. Therefore, the NRC staff finds the alternative is acceptable.Paragraph 2.0:

The current ASME Code requires that the inside surface be concealed from the candidate. Thismakes qualifications conducted from the inside of the pipe 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. The NRC staff concludes that the intent behind the concealment of the ID is to assure that tests conducted from the outside are blind examinations that do not provide location information to the examiner. The NRC staff concludes that the licensee's alternative to conceal the OD surface from the candidate for examinations performed from the ID meets the same intent to perform a "blind" examination and is, therefore, acceptable. Paragraph 2.2(b) and 2.2(c):The ASME Code requires that the region of flaws added to the test set for length sizing beidentified to the candidate. The proposed alternative would make identifying the location of additional flaws an option.The NRC staff finds that the proposed alternative will provide an additional element of difficultyto the testing process, since the candidate would be expected to demonstrate the skill of detecting and sizing flaws over a larger area in comparison to a specific region. The NRC staff finds the alternative, if utilized, would require the demonstration of a higher level of skill than that currently required by the ASME Code and is, therefore, acceptable.Paragraph 2.3(a):

The ASME Code requires that 80% of the flaws be sized in a specific location that is identifiedto the candidate. The proposed alternative permits detection and depth sizing to be conducted separately or concurrently. In order to maintain a blind test, the location of flaws cannot be shared with the candidate. For depth sizing that is conducted separately, allowing the test administrator the option of not identifying flaw locations makes the testing process more difficult.The NRC staff finds that the proposed alternative will provide an additional element of difficultyto the testing process, since the candidate would be expected to demonstrate the skill of detecting and sizing flaws in an unknown location. The NRC staff finds the alternative, if utilized, would require the demonstration of a higher level of skill than that currently required by the ASME Code and is, therefore, acceptable.Paragraph 2.3(b):

The ASME Code requires that the region of flaws added to the test set for depth sizing shall beidentified to the candidate. The proposed alternative would make identifying the region of flaws an option.The NRC staff finds that the proposed alternative will provide an additional element of difficultyto the testing process since the candidate would be expected to demonstrate the skill of finding and sizing flaws in an area larger than a specific location. The NRC staff finds the alternative, if utilized, would require the demonstration of a higher level of skill than that currently required by the ASME Code and is, therefore, acceptable.Table VIII-S2-1 acceptance criteria:

The ASME Code requirements, discussed in Paragraph 1.2(b) above, are based on statisticalparameters for screening personnel. The proposed alternative increases the minimum number of flawed grading units and reduces the number of unflawed grading units while maintaining the same statistical parameters as the ASME Code. The NRC staff finds that the proposed alternative provides the same pass/fail screening criteria used to develop the test size tables in Appendix VIII are also used to create the PDI alternative Supplement 10, Table VIII-S10-1. Therefore, the NRC staff determined that the alternative does not significantly impact the false call criteria established in the table and, therefore, is acceptable.

4.0CONCLUSION

SThe NRC staff has reviewed the licensee's submittal and determined that, in accordance with 10 CFR 50.55a(a)(3)(i), the proposed alternative program will provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the proposed alternative under relief request No. RR-04 for the duration of the fourth 10-year ISI interval, which began on March 1, 2007.

All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in this request remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.Principal Contributor: Isaac A. Anchondo Date: September 26, 2007