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| issue date = 06/29/2017
| issue date = 06/29/2017
| title = Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination Techniques in Lieu of Radiography
| title = Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination Techniques in Lieu of Radiography
| author name = Sartain M D
| author name = Sartain M
| author affiliation = Dominion Energy Nuclear Connecticut, Inc, Dominion Energy Services, Inc, Virginia Electric & Power Co (VEPCO)
| author affiliation = Dominion Energy Nuclear Connecticut, Inc, Dominion Energy Services, Inc, Virginia Electric & Power Co (VEPCO)
| addressee name =  
| addressee name =  
Line 16: Line 16:


=Text=
=Text=
{{#Wiki_filter:Dominion Energy Services, Inc. 5000 Dominion Boulevard, Glen Allen, VA 23060 Domin ion Energy.com June 29, 2017 P' Energy U. S. Nuclear Regulatory Commission Attention:
{{#Wiki_filter:Dominion Energy Services, Inc.
Document Control Desk Washington, DC 20555-0001 Serial No. NL OS/DEA Docket Nos.: DOMINION NUCLEAR CONNECTICUT, INC. License Nos.: VIRGINIA ELECTRIC AND POWER COMPANY MILLSTONE POWER STATION UNITS 2 & 3 NORTH ANNA POWER STATION UNITS 1 & 2 SURRY POWER STATION UNITS 1 & 2 PROPOSED ALTERNATIVE FOR THE USE OF ENCODED PHASED ARRAY ULTRASONIC EXAMINATION TECHNIQUES IN LIEU OF RADIOGRAPHY 17-234 R2' 50-305 50-336/423 50-338/339 50-280/281 DPR-43 DPR-65/49 NPF-4/7 DPR-32/37 Pursuant to 10 CFR 50.55a(z)(1), Dominion Nuclear Connecticut, Inc. (DNC), and Virginia Electric and Power Company (Dominion Energy Virginia) hereby request Nuclear Regulatory Commission (NRC) approval of the proposed inservice inspection (ISi) alternative for Millstone Power Station (MPS) Units 2 and 3, North Anna Power Station (NAPS) Units 1 and 2, and Surry Power Station (SPS) Units 1 and 2. For American Society of Mechanical Engineers (ASME) Section XI repair and replacement activities of ferritic circumferential pipe weld joints, radiographic examination techniques are performed to satisfy volumetric nondestructive examination requirements.
                                                                      ~Dominion 5000 Dominion Boulevard, Glen Allen, VA 23060 Domin ion Energy.com June 29, 2017       P'     Energy U. S. Nuclear Regulatory Commission                             Serial No. 17-234 Attention: Document Control Desk                                 NL OS/DEA    R2' Washington, DC 20555-0001                                       Docket Nos.: 50-305 50-336/423 50-338/339 50-280/281 DOMINION NUCLEAR CONNECTICUT, INC.                             License Nos.: DPR-43 VIRGINIA ELECTRIC AND POWER COMPANY                                           DPR-65/49 MILLSTONE POWER STATION UNITS 2 & 3                                           NPF-4/7 NORTH ANNA POWER STATION UNITS 1 & 2                                           DPR-32/37 SURRY POWER STATION UNITS 1 & 2 PROPOSED ALTERNATIVE FOR THE USE OF ENCODED PHASED ARRAY ULTRASONIC EXAMINATION TECHNIQUES IN LIEU OF RADIOGRAPHY Pursuant to 10 CFR 50.55a(z)(1), Dominion Nuclear Connecticut, Inc. (DNC), and Virginia Electric and Power Company (Dominion Energy Virginia) hereby request Nuclear Regulatory Commission (NRC) approval of the proposed inservice inspection (ISi) alternative for Millstone Power Station (MPS) Units 2 and 3, North Anna Power Station (NAPS) Units 1 and 2, and Surry Power Station (SPS) Units 1 and 2. For American Society of Mechanical Engineers (ASME) Section XI repair and replacement activities of ferritic circumferential pipe weld joints, radiographic examination techniques are performed to satisfy volumetric nondestructive examination requirements. Approval to use encoded Phased Array Ultrasonic Examination Techniques (PAUT) as an alternative to radiographic examination is requested.
Approval to use encoded Phased Array Ultrasonic Examination Techniques (PAUT) as an alternative to radiographic examination is requested.
The use of encoded PAUT in lieu of radiography (RT) to perform the required examinations of the replaced welds would eliminate the safety risk associated with performing RT,* which includes both planned and unplanned radiation exposure to plant workers. The proposed alternative is provided in Attachment 1. The duration of the proposed alternative is requested for the remainder of the ISi interval for MPS 2 and 3, NAPS 1 and 2, and SPS 1 and 2.
The use of encoded PAUT in lieu of radiography (RT) to perform the required examinations of the replaced welds would eliminate the safety risk associated with performing RT,* which includes both planned and unplanned radiation exposure to plant workers. The proposed alternative is provided in Attachment  
NRC review and approval of the proposed ISi alternative is respectfully requested to support anticipated piping repair and replacement activities for the next upcoming refueling outages, currently scheduled to occur during fall 2017. Timely approval of the proposed ISi alternative request supports an industry initiative to establish an acceptable standardized template for the PAUT in lieu of RT alternative request.
: 1. The duration of the proposed alternative is requested for the remainder of the ISi interval for MPS 2 and 3, NAPS 1 and 2, and SPS 1 and 2. NRC review and approval of the proposed ISi alternative is respectfully requested to support anticipated piping repair and replacement activities for the next upcoming refueling outages, currently scheduled to occur during fall 2017. Timely approval of the proposed ISi alternative request supports an industry initiative to establish an acceptable standardized template for the PAUT in lieu of RT alternative request.
 
Serial No. 17-234 Proposed Alternative for Use of PAUT in Lieu of RT Page 2 of 4 Should you have any questions in regard to this submittal, please contact Ms. Diane E. Aitken at (804) 273-2694.
Serial No. 17-234 Proposed Alternative for Use of PAUT in Lieu of RT Page 2 of 4 Should you have any questions in regard to this submittal, please contact Ms. Diane E.
Sincerely, Mark D. Sartain Vice President  
Aitken at (804) 273-2694.
-Nuclear Engineering and Fleet Support Virginia Electric and Power Company Dominion Energy Nuclear Connecticut, Inc.  
Sincerely, Mark D. Sartain Vice President - Nuclear Engineering and Fleet Support Virginia Electric and Power Company Dominion Energy Nuclear Connecticut, Inc.


==Attachment:==
==Attachment:==
: 1. Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination Techniques In Lieu of Radiography In Accordance with 10 CFR 50.55a(z)(1)
: 1. Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination Techniques In Lieu of Radiography In Accordance with 10 CFR 50.55a(z)(1)
Commitments made in this letter: None.
Commitments made in this letter: None.
Serial No. 17-234 Proposed Alternative for Use of PAUT in Lieu of RT Page 3of4 cc: U.S. Nuclear Regulatory Commission Region I 2100 Renaissance Boulevard, Suite 100 King of Prussia, PA 19406-2713 U.S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 Mr. Richard Guzman NRC Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 08 C-2 Rockville, MD 20852-2738 Ms. K. R. Cotton-Gross NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 08 G-9A Rockville, MD 20852-2738 Mr. James R. Hall NRC Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 08 G-9A Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station NRC Senior Resident Inspector North Anna Power Station NRC Senior Resident Inspector Surry Power Station Mr. J. E. Reasor, Jr. Serial No. 17-234 Proposed Alternative for Use of PAUT in Lieu of RT Page 4 of 4 Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Blvd. Suite 300 Glen Allen, VA 23060 ATTACHMENT 1 Serial No. 17-234 Page 1 of 6 PROPOSED ALTERNATIVE FOR THE USE OF ENCODED PHASED ARRAY ULTRASONIC EXAMINATION TECHNIQUES IN LIEU OF RADIOGRAPHY IN ACCORDANCE WITH 10 CFR 50.55a(z)(1)
Millstone Power Station, Units 2 and 3 North Anna Power Station, Units 1 and 2 Surry Power Station, Units 1 and 2 Serial No. 17-234 Proposed Alternative for Use of PAUT in Lieu of RT Attachment 1 Page 2of6 Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination Techniques In Lieu of Radiography In Accordance with 10 CFR 50.55a(z)(1)
--Proposed Alternative Provides an Acceptable Level of Quality and Safety --1. ASME Code Components Affected All American Society of Mechanical Engineers (ASME), Boiler & Pressure Vessel (B&PV) Code, Section XI, ferritic piping welds requiring radiography during repair/replacement activities.
: 2. Applicable Code Edition and Addenda Plant Interval Edition Start End North Anna Power Station, Fourth 2004 May 1, 2009 April 30, 2019 Unit 1 North Anna Power Station, Fourth 2004 December 14, December 13, Unit 2 2010 2020 Surry Power Station, Unit 1 Fifth 2004 December 14, October 13, 2023 2013 Surry Power Station, Unit 2 Fifth 2004 May 10, 2014 May 9, 2024 Millstone Power Station, Fourth 2004 April 1, 2010 March 31, 2020 Unit2 Millstone Power Station, Third 2004 April 23, 2009 April 22, 2019 Unit 3 3. Applicable Code Requirement The 2004 Edition of ASME Section XI, paragraph IWA-4221 requires that items used for repair/replacement activities meet the applicable Owner's Requirements and Construction Code requirements when performing repair/replacement activities.
IWA-4520 requires that welded joints made for installation of items be examined in accordance with the Construction Code identified in the Repair/Replacement Plan. 4. Reason for Request Replacement of piping is periodically performed in support of the Flow Accelerated Corrosion (FAC) program as well as other repair and replacement activities.
The use of encoded Phased Array Ultrasonic Examination Techniques (PAUT) in lieu of radiography (RT) to perform the required examinations of the replaced welds reduces both safety and radiological risk to plant workers. PAUT also minimizes the impact on other outage activities normally involved with performing RT such as Serial No. 17-234 Proposed Alternative for Use of PAUT in Lieu of RT Attachment 1 Page 3of6 limited access to work locations.
In addition, encoded PAUT is equivalent or superior to the code-required RT examination for ASME ferritic piping repair/replacement welds for detecting and sizing critical (planar) flaws, such as cracks and lack of fusion (Reference 15). PAUT provides sizing capabilities for both depth and length dimensions of the flaw which are required to apply the acceptance criteria of the applicable code case. RT does not provide depth sizing capabilities.
This proposed alternative is requested to support anticipated piping repair and replacement activities starting in the fall 2017 outage season. The duration of the proposed alternative request is for the remainder of the inservice inspection interval for the plants defined in Section 2 of this request. 5. Proposed Alternative and Basis for Use The use of encoded PAUT examination technique is proposed in lieu of the required RT examination for ASME ferritic piping repair/replacement welds. Similar techniques are being used throughout the nuclear industry for examination of dissimilar metal welds, overlaid welds, as well as other applications including 831.1 piping replacements.
This proposed alternative request includes requirements that provide an acceptable level of quality and safety that satisfies the requirements of 10 CFR 50.55a(z)(1
). The capability of the alternative technique is comparable to the examination methods documented in the ASME Code Sections Ill, VIII, and IX, and associated code cases (References 1, 3, 5, 6, 8, 9, 10, 11, 12, 13 and 14) using ultrasonic examination techniques for weld acceptance.
The examinations will be performed using personnel and procedures qualified by performance demonstration in accordance with Section 5.1 below. 5.1 Proposed Alternative Perform encoded PAUT examination techniques using demonstrated procedures,, equipment and personnel in accordance with the process defined in ASME approved Code Case N-831, Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic Pipe, dated October 26, 2016. 5.2 Basis for Use The overall basis for this proposed alternative is that encoded PAUT is equivalent or superior to RT for detecting and sizing critical (planar) flaws. In this regard, the basis for the proposed alternative was developed from numerous codes, code cases, associated industry experience, articles, and the results of RT and encoded PAUT examinations.
The examination procedure and personnel performing examinations are qualified using representative piping conditions and flaws that demonstrate the ability to detect and size flaws that are both acceptable and unacceptable to the 
--------------------------------------------------
Serial No. 17-234 Proposed Alternative for Use of PAUT in Lieu of RT Attachment 1 Page 4of6 defined acceptance standards.
The demonstrated ability of the examination procedure and personnel to appropriately detect and size flaws provides an acceptable level of quality and safety alternative as allowed by 10 CFR 50.55a(z)(1
). 6. Duration of Proposed Alternative This alternative request will be applied for the remainder of the inservice inspection intervals for the plants defined in Section 2 of this request. 7. Precedents


===7.1 Oconee===
Serial No. 17-234 Proposed Alternative for Use of PAUT in Lieu of RT Page 3of4 cc: U.S. Nuclear Regulatory Commission Region I 2100 Renaissance Boulevard, Suite 100 King of Prussia, PA 19406-2713 U.S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 Mr. Richard Guzman NRC Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 08 C-2 Rockville, MD 20852-2738 Ms. K. R. Cotton-Gross NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 08 G-9A Rockville, MD 20852-2738 Mr. James R. Hall NRC Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 08 G-9A Rockville, MD 20852-2738
Request for Relief No. 2006-0N-001, dated June 20, 2006; requested relief on butt welds between the Pressurizer Level and Sample Tap nozzles and their respective Safe Ends. The reason for the request was based on the difficulty to perform the code required radiography.
 
The alternative was to perform ultrasonic examination per similar requirements to Code Case N-659-0. (ML061210495) 7 .2 Wolf Creek 10 CFR 50.55a Request ET 06-0029, dated September 1, 2006; requested relief on main steam and feedwater piping welds being replaced.
Serial No. 17-234 Proposed Alternative for Use of PAUT in Lieu of RT Page 4 of 4 NRC Senior Resident Inspector Millstone Power Station NRC Senior Resident Inspector North Anna Power Station NRC Senior Resident Inspector Surry Power Station Mr. J. E. Reasor, Jr.
The reason for the request was based on the acceptability of the proposed ultrasonic examination alternative process, radiation exposure reduction, outage costs and duration, and radiography exposure risk. (ML062500093) 7.3 Palo Verde Nuclear Generating Station Relief Request 48, dated August 1, 2012(ML12229A046).
Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Blvd.
NRC approval dated April 12, 2013(ML13091A177).
Suite 300 Glen Allen, VA 23060
 
Serial No. 17-234 Page 1 of 6 ATTACHMENT 1 PROPOSED ALTERNATIVE FOR THE USE OF ENCODED PHASED ARRAY ULTRASONIC EXAMINATION TECHNIQUES IN LIEU OF RADIOGRAPHY IN ACCORDANCE WITH 10 CFR 50.55a(z)(1)
Millstone Power Station, Units 2 and 3 North Anna Power Station, Units 1 and 2 Surry Power Station, Units 1 and 2
 
Serial No. 17-234 Proposed Alternative for Use of PAUT in Lieu of RT Attachment 1 Page 2of6 Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination Techniques In Lieu of Radiography In Accordance with 10 CFR 50.55a(z)(1)
    -- Proposed Alternative Provides an Acceptable Level of Quality and Safety --
: 1. ASME Code Components Affected All American Society of Mechanical Engineers (ASME), Boiler & Pressure Vessel (B&PV) Code, Section XI, ferritic piping welds requiring radiography during repair/replacement activities.
 
===2. Applicable Code Edition and Addenda===
Plant            Interval Edition        Start                End North Anna Power Station, Fourth    2004      May 1, 2009        April 30, 2019 Unit 1 North Anna Power Station,                        December 14,        December 13, Fourth    2004 Unit 2                                      2010                  2020 December 14, Surry Power Station, Unit 1    Fifth    2004                        October 13, 2023 2013 Surry Power Station, Unit 2 Fifth        2004      May 10, 2014          May 9, 2024 Millstone Power Station, Fourth    2004      April 1, 2010      March 31, 2020 Unit2 Millstone Power Station, Third    2004    April 23, 2009      April 22, 2019 Unit 3


===7.4 Millstone===
===3. Applicable Code Requirement===
The 2004 Edition of ASME Section XI, paragraph IWA-4221 requires that items used for repair/replacement activities meet the applicable Owner's Requirements and Construction Code requirements when performing repair/replacement activities.
IWA-4520 requires that welded joints made for installation of items be examined in accordance with the Construction Code identified in the Repair/Replacement Plan.


Power Station Unit 2 Alternative Request RR-04-16, dated August 1, 2013 (ML 13220A019).
===4. Reason for Request===
NRC approval dated April 4, 2014(ML14091A973).  
Replacement of piping is periodically performed in support of the Flow Accelerated Corrosion (FAC) program as well as other repair and replacement activities. The use of encoded Phased Array Ultrasonic Examination Techniques (PAUT) in lieu of radiography (RT) to perform the required examinations of the replaced welds reduces both safety and radiological risk to plant workers. PAUT also minimizes the impact on other outage activities normally involved with performing RT such as


===7.5 Millstone===
Serial No. 17-234 Proposed Alternative for Use of PAUT in Lieu of RT Attachment 1 Page 3of6 limited access to work locations. In addition, encoded PAUT is equivalent or superior to the code-required RT examination for ASME ferritic piping repair/replacement welds for detecting and sizing critical (planar) flaws, such as cracks and lack of fusion (Reference 15). PAUT provides sizing capabilities for both depth and length dimensions of the flaw which are required to apply the acceptance criteria of the applicable code case. RT does not provide depth sizing capabilities.
This proposed alternative is requested to support anticipated piping repair and replacement activities starting in the fall 2017 outage season. The duration of the proposed alternative request is for the remainder of the inservice inspection interval for the plants defined in Section 2 of this request.
: 5. Proposed Alternative and Basis for Use The use of encoded PAUT examination technique is proposed in lieu of the code-required RT examination for ASME ferritic piping repair/replacement welds. Similar techniques are being used throughout the nuclear industry for examination of dissimilar metal welds, overlaid welds, as well as other applications including 831.1 piping replacements. This proposed alternative request includes requirements that provide an acceptable level of quality and safety that satisfies the requirements of 10 CFR 50.55a(z)(1 ). The capability of the alternative technique is comparable to the examination methods documented in the ASME Code Sections Ill, VIII, and IX, and associated code cases (References 1, 3, 5, 6, 8, 9, 10, 11, 12, 13 and 14) using ultrasonic examination techniques for weld acceptance. The examinations will be performed using personnel and procedures qualified by performance demonstration in accordance with Section 5.1 below.
5.1    Proposed Alternative Perform encoded PAUT examination techniques using demonstrated procedures,,
equipment and personnel in accordance with the process defined in ASME approved Code Case N-831, Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic Pipe, dated October 26, 2016.
5.2 Basis for Use The overall basis for this proposed alternative is that encoded PAUT is equivalent or superior to RT for detecting and sizing critical (planar) flaws. In this regard, the basis for the proposed alternative was developed from numerous codes, code cases, associated industry experience, articles, and the results of RT and encoded PAUT examinations. The examination procedure and personnel performing examinations are qualified using representative piping conditions and flaws that demonstrate the ability to detect and size flaws that are both acceptable and unacceptable to the


Power Station Unit 2 Alternative Request RR-04-21, dated October 6, 2014 (ML14283A128).
Serial No. 17-234 Proposed Alternative for Use of PAUT in Lieu of RT Attachment 1 Page 4of6 defined acceptance standards. The demonstrated ability of the examination procedure and personnel to appropriately detect and size flaws provides an acceptable level of quality and safety alternative as allowed by 10 CFR 50.55a(z)(1 ).
NRC approval dated September 21, 2015 (ML 15257 A005). 7.6 Millstone Power Station Unit 3 Alternative Request IR-3-25, dated October 6, 2014 (ML 14283A 128). NRC approval dated September 21, 2015 (ML 15257 A005). 7.7 Millstone Power Station Unit 2 Alternative Request RR-04-023, dated April 11, 2016 (ML16106A105).
: 6. Duration of Proposed Alternative This alternative request will be applied for the remainder of the inservice inspection intervals for the plants defined in Section 2 of this request.
NRC approval dated January 23, 2017 (ML 16363A089).  
: 7. Precedents 7.1    Oconee Request for Relief No. 2006-0N-001, dated June 20, 2006; requested relief on butt welds between the Pressurizer Level and Sample Tap nozzles and their respective Safe Ends. The reason for the request was based on the difficulty to perform the code required radiography. The alternative was to perform ultrasonic examination per similar requirements to Code Case N-659-0. (ML061210495) 7 .2  Wolf Creek 10 CFR 50.55a Request ET 06-0029, dated September 1, 2006; requested relief on main steam and feedwater piping welds being replaced.
The reason for the request was based on the acceptability of the proposed ultrasonic examination alternative process, radiation exposure reduction, outage costs and duration, and radiography exposure risk. (ML062500093) 7.3    Palo Verde Nuclear Generating Station Relief Request 48, dated August 1, 2012(ML12229A046). NRC approval dated April 12, 2013(ML13091A177).
7.4    Millstone Power Station Unit 2 Alternative Request RR-04-16, dated August 1, 2013 (ML13220A019). NRC approval dated April 4, 2014(ML14091A973).
7.5    Millstone Power Station Unit 2 Alternative Request RR-04-21, dated October 6, 2014 (ML14283A128). NRC approval dated September 21, 2015 (ML15257A005).
7.6   Millstone Power Station Unit 3 Alternative Request IR-3-25, dated October 6, 2014 (ML14283A128).         NRC approval dated September 21, 2015 (ML15257A005).
7.7   Millstone Power Station Unit 2 Alternative Request RR-04-023, dated April 11, 2016 (ML16106A105).          NRC approval dated January 23, 2017 (ML16363A089).
7.8    Millstone Power Station Unit 3 Alternative Request IR-3-28, dated April 11, 2016 (ML16106A105).          NRC approval dated January 23, 2017 (ML16363A089).


===7.8 Millstone===
Serial No. 17-234 Proposed Alternative for Use of PAUT in Lieu of RT Attachment 1 Page 5of6 7.8   Millstone Power Station Unit 3 Alternative Request IR-3-28, dated April 11, 2016 (ML16106A105).        NRC approval dated January 23, 2017 (ML16363A089).
: 8. References 8.1. ASME Section Ill Code Case N-659-2, "Use of Ultrasonic Examination in Lieu of Radiography for Weld Examination Section Ill, Divisions 1 and 3," dated June 9, 2008.
8.2. Pacific Northwest National Laboratory Report PNNL-19086, "Replacement of Radiography with Ultrasonics for the Nondestructive Inspection of Welds -
Evaluation of Technical Gaps - An Interim Report," dated April 2010.
8.3. ASME B31.1, Case 168, "Use of Ultrasonic Examination in Lieu of Radiography for B31. 1 Application," dated June 1997.
8.4. ASME Sections Ill and XI, 2004 Edition, No Addenda.
8.5. ASME Section Ill, Code Case N-818, "Use of Analytical Evaluation approach for Acceptance of Full Penetration Butt Welds in Lieu of Weld Repair," dated December 6, 2011.
8.6. ASME Code Case 2235-9, 2005; "Use of Ultrasonic Examination in Lieu of Radiography Section I, Section VIII, Divisions 1 and 2, and Section XII," dated October 11, 2005.
8.7. Journal of Pressure Vessel Technology, "Technical Basis for ASME Section VIII Code Case 2235 on Ultrasonic Examination of Welds in Lieu of Radiography;" Rana, Hedden, Cowfer and Boyce, Volume 123, dated August 2001.
8.8. ASME Code Case 2326, "Ultrasonic Examination in Lieu of Radiographic Examination for Welder Qualification Test Coupons Section IX," dated January 20, 2000.
8.9. ASME Code Case 2541, "Use of Manual Phased Array Ultrasonic Examination Section V," dated January 19, 2006.
8.10. ASME Code Case 2558, "Use of Manual Phased Array E-Scan Ultrasonic Examination Per Article 4 Section V", dated December 30, 2006.
8.11. ASME Code Case 2599, "Use of Linear Phased Array E-Scan Ultrasonic Examination Per Article 4 Section V," dated January 29, 2008.
8.12. ASME Code Case 2600, "Use of Linear Phased Array S-Scan Ultrasonic Examination Per Article 4 Section V," dated January 29, 2008.


Power Station Unit 3 Alternative Request IR-3-28, dated April 11, 2016 (ML 16106A105).
Serial No. 17-234 Proposed Alternative for Use of PAUT in Lieu of RT Attachment 1 Page 6of6 8.13. ASME Section XI, Code Case N-713, "Ultrasonic Examination in Lieu of Radiography," dated November 10, 2008.
NRC approval dated January 23, 2017 (ML 16363A089).
8.14. ASME Section XI, Code Case N-831, "Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic Pipe," dated October 26, 2016.
Serial No. 17-234 Proposed Alternative for Use of PAUT in Lieu of RT Attachment 1 Page 5of6 7.8 Millstone Power Station Unit 3 Alternative Request IR-3-28, dated April 11, 2016 (ML 16106A105).
8.15. US NRC, NUREG/CR-7204, "Applying Ultrasonic Testing in Lieu of Radiography for Volumetric Examination of Carbon Steel Piping" (ML15253A674).}}
NRC approval dated January 23, 2017 (ML 16363A089).
: 8. References 8.1. ASME Section Ill Code Case N-659-2, "Use of Ultrasonic Examination in Lieu of Radiography for Weld Examination Section Ill, Divisions 1 and 3," dated June 9, 2008. 8.2. Pacific Northwest National Laboratory Report PNNL-19086, "Replacement of Radiography with Ultrasonics for the Nondestructive Inspection of Welds -Evaluation of Technical Gaps -An Interim Report," dated April 2010. 8.3. ASME B31.1, Case 168, "Use of Ultrasonic Examination in Lieu of Radiography for B31. 1 Application," dated June 1997. 8.4. ASME Sections Ill and XI, 2004 Edition, No Addenda. 8.5. ASME Section Ill, Code Case N-818, "Use of Analytical Evaluation approach for Acceptance of Full Penetration Butt Welds in Lieu of Weld Repair," dated December 6, 2011. 8.6. ASME Code Case 2235-9, 2005; "Use of Ultrasonic Examination in Lieu of Radiography Section I, Section VIII, Divisions 1 and 2, and Section XII," dated October 11, 2005. 8.7. Journal of Pressure Vessel Technology, "Technical Basis for ASME Section VIII Code Case 2235 on Ultrasonic Examination of Welds in Lieu of Radiography;" Rana, Hedden, Cowfer and Boyce, Volume 123, dated August 2001. 8.8. ASME Code Case 2326, "Ultrasonic Examination in Lieu of Radiographic Examination for Welder Qualification Test Coupons Section IX," dated January 20, 2000. 8.9. ASME Code Case 2541, "Use of Manual Phased Array Ultrasonic Examination Section V," dated January 19, 2006. 8.10. ASME Code Case 2558, "Use of Manual Phased Array E-Scan Ultrasonic Examination Per Article 4 Section V", dated December 30, 2006. 8.11. ASME Code Case 2599, "Use of Linear Phased Array E-Scan Ultrasonic Examination Per Article 4 Section V," dated January 29, 2008. 8.12. ASME Code Case 2600, "Use of Linear Phased Array S-Scan Ultrasonic Examination Per Article 4 Section V," dated January 29, 2008.
Serial No. 17-234 Proposed Alternative for Use of PAUT in Lieu of RT Attachment 1 Page 6of6 8.13. ASME Section XI, Code Case N-713, "Ultrasonic Examination in Lieu of Radiography," dated November 10, 2008. 8.14. ASME Section XI, Code Case N-831, "Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic Pipe," dated October 26, 2016. 8.15. US NRC, NUREG/CR-7204, "Applying Ultrasonic Testing in Lieu of Radiography for Volumetric Examination of Carbon Steel Piping" (ML 15253A674).}}

Latest revision as of 16:45, 4 February 2020

Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination Techniques in Lieu of Radiography
ML17188A379
Person / Time
Site: Millstone, Surry, North Anna  Dominion icon.png
Issue date: 06/29/2017
From: Mark D. Sartain
Dominion Energy Nuclear Connecticut, Dominion Energy Services, Virginia Electric & Power Co (VEPCO)
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
17-234
Download: ML17188A379 (10)
v • d • e


Text

Dominion Energy Services, Inc.

~Dominion 5000 Dominion Boulevard, Glen Allen, VA 23060 Domin ion Energy.com June 29, 2017 P' Energy U. S. Nuclear Regulatory Commission Serial No.17-234 Attention: Document Control Desk NL OS/DEA R2' Washington, DC 20555-0001 Docket Nos.: 50-305 50-336/423 50-338/339 50-280/281 DOMINION NUCLEAR CONNECTICUT, INC. License Nos.: DPR-43 VIRGINIA ELECTRIC AND POWER COMPANY DPR-65/49 MILLSTONE POWER STATION UNITS 2 & 3 NPF-4/7 NORTH ANNA POWER STATION UNITS 1 & 2 DPR-32/37 SURRY POWER STATION UNITS 1 & 2 PROPOSED ALTERNATIVE FOR THE USE OF ENCODED PHASED ARRAY ULTRASONIC EXAMINATION TECHNIQUES IN LIEU OF RADIOGRAPHY Pursuant to 10 CFR 50.55a(z)(1), Dominion Nuclear Connecticut, Inc. (DNC), and Virginia Electric and Power Company (Dominion Energy Virginia) hereby request Nuclear Regulatory Commission (NRC) approval of the proposed inservice inspection (ISi) alternative for Millstone Power Station (MPS) Units 2 and 3, North Anna Power Station (NAPS) Units 1 and 2, and Surry Power Station (SPS) Units 1 and 2. For American Society of Mechanical Engineers (ASME)Section XI repair and replacement activities of ferritic circumferential pipe weld joints, radiographic examination techniques are performed to satisfy volumetric nondestructive examination requirements. Approval to use encoded Phased Array Ultrasonic Examination Techniques (PAUT) as an alternative to radiographic examination is requested.

The use of encoded PAUT in lieu of radiography (RT) to perform the required examinations of the replaced welds would eliminate the safety risk associated with performing RT,* which includes both planned and unplanned radiation exposure to plant workers. The proposed alternative is provided in Attachment 1. The duration of the proposed alternative is requested for the remainder of the ISi interval for MPS 2 and 3, NAPS 1 and 2, and SPS 1 and 2.

NRC review and approval of the proposed ISi alternative is respectfully requested to support anticipated piping repair and replacement activities for the next upcoming refueling outages, currently scheduled to occur during fall 2017. Timely approval of the proposed ISi alternative request supports an industry initiative to establish an acceptable standardized template for the PAUT in lieu of RT alternative request.

Serial No.17-234 Proposed Alternative for Use of PAUT in Lieu of RT Page 2 of 4 Should you have any questions in regard to this submittal, please contact Ms. Diane E.

Aitken at (804) 273-2694.

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering and Fleet Support Virginia Electric and Power Company Dominion Energy Nuclear Connecticut, Inc.

Attachment:

1. Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination Techniques In Lieu of Radiography In Accordance with 10 CFR 50.55a(z)(1)

Commitments made in this letter: None.

Serial No.17-234 Proposed Alternative for Use of PAUT in Lieu of RT Page 3of4 cc: U.S. Nuclear Regulatory Commission Region I 2100 Renaissance Boulevard, Suite 100 King of Prussia, PA 19406-2713 U.S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 Mr. Richard Guzman NRC Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 08 C-2 Rockville, MD 20852-2738 Ms. K. R. Cotton-Gross NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 08 G-9A Rockville, MD 20852-2738 Mr. James R. Hall NRC Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 08 G-9A Rockville, MD 20852-2738

Serial No.17-234 Proposed Alternative for Use of PAUT in Lieu of RT Page 4 of 4 NRC Senior Resident Inspector Millstone Power Station NRC Senior Resident Inspector North Anna Power Station NRC Senior Resident Inspector Surry Power Station Mr. J. E. Reasor, Jr.

Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Blvd.

Suite 300 Glen Allen, VA 23060

Serial No.17-234 Page 1 of 6 ATTACHMENT 1 PROPOSED ALTERNATIVE FOR THE USE OF ENCODED PHASED ARRAY ULTRASONIC EXAMINATION TECHNIQUES IN LIEU OF RADIOGRAPHY IN ACCORDANCE WITH 10 CFR 50.55a(z)(1)

Millstone Power Station, Units 2 and 3 North Anna Power Station, Units 1 and 2 Surry Power Station, Units 1 and 2

Serial No.17-234 Proposed Alternative for Use of PAUT in Lieu of RT Attachment 1 Page 2of6 Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination Techniques In Lieu of Radiography In Accordance with 10 CFR 50.55a(z)(1)

-- Proposed Alternative Provides an Acceptable Level of Quality and Safety --

1. ASME Code Components Affected All American Society of Mechanical Engineers (ASME), Boiler & Pressure Vessel (B&PV) Code,Section XI, ferritic piping welds requiring radiography during repair/replacement activities.

2. Applicable Code Edition and Addenda

Plant Interval Edition Start End North Anna Power Station, Fourth 2004 May 1, 2009 April 30, 2019 Unit 1 North Anna Power Station, December 14, December 13, Fourth 2004 Unit 2 2010 2020 December 14, Surry Power Station, Unit 1 Fifth 2004 October 13, 2023 2013 Surry Power Station, Unit 2 Fifth 2004 May 10, 2014 May 9, 2024 Millstone Power Station, Fourth 2004 April 1, 2010 March 31, 2020 Unit2 Millstone Power Station, Third 2004 April 23, 2009 April 22, 2019 Unit 3

3. Applicable Code Requirement

The 2004 Edition of ASME Section XI, paragraph IWA-4221 requires that items used for repair/replacement activities meet the applicable Owner's Requirements and Construction Code requirements when performing repair/replacement activities.

IWA-4520 requires that welded joints made for installation of items be examined in accordance with the Construction Code identified in the Repair/Replacement Plan.

4. Reason for Request

Replacement of piping is periodically performed in support of the Flow Accelerated Corrosion (FAC) program as well as other repair and replacement activities. The use of encoded Phased Array Ultrasonic Examination Techniques (PAUT) in lieu of radiography (RT) to perform the required examinations of the replaced welds reduces both safety and radiological risk to plant workers. PAUT also minimizes the impact on other outage activities normally involved with performing RT such as

Serial No.17-234 Proposed Alternative for Use of PAUT in Lieu of RT Attachment 1 Page 3of6 limited access to work locations. In addition, encoded PAUT is equivalent or superior to the code-required RT examination for ASME ferritic piping repair/replacement welds for detecting and sizing critical (planar) flaws, such as cracks and lack of fusion (Reference 15). PAUT provides sizing capabilities for both depth and length dimensions of the flaw which are required to apply the acceptance criteria of the applicable code case. RT does not provide depth sizing capabilities.

This proposed alternative is requested to support anticipated piping repair and replacement activities starting in the fall 2017 outage season. The duration of the proposed alternative request is for the remainder of the inservice inspection interval for the plants defined in Section 2 of this request.

5. Proposed Alternative and Basis for Use The use of encoded PAUT examination technique is proposed in lieu of the code-required RT examination for ASME ferritic piping repair/replacement welds. Similar techniques are being used throughout the nuclear industry for examination of dissimilar metal welds, overlaid welds, as well as other applications including 831.1 piping replacements. This proposed alternative request includes requirements that provide an acceptable level of quality and safety that satisfies the requirements of 10 CFR 50.55a(z)(1 ). The capability of the alternative technique is comparable to the examination methods documented in the ASME Code Sections Ill, VIII, and IX, and associated code cases (References 1, 3, 5, 6, 8, 9, 10, 11, 12, 13 and 14) using ultrasonic examination techniques for weld acceptance. The examinations will be performed using personnel and procedures qualified by performance demonstration in accordance with Section 5.1 below.

5.1 Proposed Alternative Perform encoded PAUT examination techniques using demonstrated procedures,,

equipment and personnel in accordance with the process defined in ASME approved Code Case N-831, Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic Pipe, dated October 26, 2016.

5.2 Basis for Use The overall basis for this proposed alternative is that encoded PAUT is equivalent or superior to RT for detecting and sizing critical (planar) flaws. In this regard, the basis for the proposed alternative was developed from numerous codes, code cases, associated industry experience, articles, and the results of RT and encoded PAUT examinations. The examination procedure and personnel performing examinations are qualified using representative piping conditions and flaws that demonstrate the ability to detect and size flaws that are both acceptable and unacceptable to the

Serial No.17-234 Proposed Alternative for Use of PAUT in Lieu of RT Attachment 1 Page 4of6 defined acceptance standards. The demonstrated ability of the examination procedure and personnel to appropriately detect and size flaws provides an acceptable level of quality and safety alternative as allowed by 10 CFR 50.55a(z)(1 ).

6. Duration of Proposed Alternative This alternative request will be applied for the remainder of the inservice inspection intervals for the plants defined in Section 2 of this request.
7. Precedents 7.1 Oconee Request for Relief No. 2006-0N-001, dated June 20, 2006; requested relief on butt welds between the Pressurizer Level and Sample Tap nozzles and their respective Safe Ends. The reason for the request was based on the difficulty to perform the code required radiography. The alternative was to perform ultrasonic examination per similar requirements to Code Case N-659-0. (ML061210495) 7 .2 Wolf Creek 10 CFR 50.55a Request ET 06-0029, dated September 1, 2006; requested relief on main steam and feedwater piping welds being replaced.

The reason for the request was based on the acceptability of the proposed ultrasonic examination alternative process, radiation exposure reduction, outage costs and duration, and radiography exposure risk. (ML062500093) 7.3 Palo Verde Nuclear Generating Station Relief Request 48, dated August 1, 2012(ML12229A046). NRC approval dated April 12, 2013(ML13091A177).

7.4 Millstone Power Station Unit 2 Alternative Request RR-04-16, dated August 1, 2013 (ML13220A019). NRC approval dated April 4, 2014(ML14091A973).

7.5 Millstone Power Station Unit 2 Alternative Request RR-04-21, dated October 6, 2014 (ML14283A128). NRC approval dated September 21, 2015 (ML15257A005).

7.6 Millstone Power Station Unit 3 Alternative Request IR-3-25, dated October 6, 2014 (ML14283A128). NRC approval dated September 21, 2015 (ML15257A005).

7.7 Millstone Power Station Unit 2 Alternative Request RR-04-023, dated April 11, 2016 (ML16106A105). NRC approval dated January 23, 2017 (ML16363A089).

7.8 Millstone Power Station Unit 3 Alternative Request IR-3-28, dated April 11, 2016 (ML16106A105). NRC approval dated January 23, 2017 (ML16363A089).

Serial No.17-234 Proposed Alternative for Use of PAUT in Lieu of RT Attachment 1 Page 5of6 7.8 Millstone Power Station Unit 3 Alternative Request IR-3-28, dated April 11, 2016 (ML16106A105). NRC approval dated January 23, 2017 (ML16363A089).

8. References 8.1. ASME Section Ill Code Case N-659-2, "Use of Ultrasonic Examination in Lieu of Radiography for Weld Examination Section Ill, Divisions 1 and 3," dated June 9, 2008.

8.2. Pacific Northwest National Laboratory Report PNNL-19086, "Replacement of Radiography with Ultrasonics for the Nondestructive Inspection of Welds -

Evaluation of Technical Gaps - An Interim Report," dated April 2010.

8.3. ASME B31.1, Case 168, "Use of Ultrasonic Examination in Lieu of Radiography for B31. 1 Application," dated June 1997.

8.4. ASME Sections Ill and XI, 2004 Edition, No Addenda.

8.5. ASME Section Ill, Code Case N-818, "Use of Analytical Evaluation approach for Acceptance of Full Penetration Butt Welds in Lieu of Weld Repair," dated December 6, 2011.

8.6. ASME Code Case 2235-9, 2005; "Use of Ultrasonic Examination in Lieu of Radiography Section I,Section VIII, Divisions 1 and 2, and Section XII," dated October 11, 2005.

8.7. Journal of Pressure Vessel Technology, "Technical Basis for ASME Section VIII Code Case 2235 on Ultrasonic Examination of Welds in Lieu of Radiography;" Rana, Hedden, Cowfer and Boyce, Volume 123, dated August 2001.

8.8. ASME Code Case 2326, "Ultrasonic Examination in Lieu of Radiographic Examination for Welder Qualification Test CouponsSection IX," dated January 20, 2000.

8.9. ASME Code Case 2541, "Use of Manual Phased Array Ultrasonic Examination Section V," dated January 19, 2006.

8.10. ASME Code Case 2558, "Use of Manual Phased Array E-Scan Ultrasonic Examination Per Article 4 Section V", dated December 30, 2006.

8.11. ASME Code Case 2599, "Use of Linear Phased Array E-Scan Ultrasonic Examination Per Article 4 Section V," dated January 29, 2008.

8.12. ASME Code Case 2600, "Use of Linear Phased Array S-Scan Ultrasonic Examination Per Article 4 Section V," dated January 29, 2008.

Serial No.17-234 Proposed Alternative for Use of PAUT in Lieu of RT Attachment 1 Page 6of6 8.13. ASME Section XI, Code Case N-713, "Ultrasonic Examination in Lieu of Radiography," dated November 10, 2008.

8.14. ASME Section XI, Code Case N-831, "Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic Pipe," dated October 26, 2016.

8.15. US NRC, NUREG/CR-7204, "Applying Ultrasonic Testing in Lieu of Radiography for Volumetric Examination of Carbon Steel Piping" (ML15253A674).

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