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WDI-TJ-1044-NP, Revision 1, Ultrasonic Examination of Diablo Canyon, Unit 2 Reactor Pressure Vessel Nozzle to Safe End Welds from the Id Surface Through Welded Protective Layer, Enclosure 3 to DCL-10-103
	ML102350297
Person / Time
Site:	Diablo Canyon
Issue date:	06/01/2010
From:	Rishel R D; WesDyne International, Westinghouse
To:	; Office of Nuclear Reactor Regulation
References
	DCL-10-103, OL-DPR-82 WDI-TJ-1044-NP, Rev 1
	Download: ML102350297 (77)
	v • d • e

{{#Wiki_filter:Enclosure 3 PG&E Letter No. DCL-1 0-103 WDI-TJ-1044-NP, Rev. 1,"Demonstration Report/Technical Basis Document: Ultrasonic Examination of Diablo Canyon Unit 2 Reactor Pressure Vessel Nozzle to Safe End Welds from the ID Surface Through A Welded Protective Layer" 1 WOF-19.1-2, Rev. I NP Version Westinghouse Non-Proprietary Class 3 nwEsPvflE AWo StingIhouae Electriu. Coma "ny DOCUMENT NUMBER & REV: WDI-TJ-1044-NP, Rev. 1 COVER SHEET FOR: rJ CALIBRATION PROCEDURE DESIGN SPECIFICATION EQUIPMENT MANUFACTURE & TEST PROCEDURE FUNCTIONAL SPECIFICATION FUNCTIONAL TEST PROCEDURE QUALIFICATION PROCEDURE TECHNICAL JUSTIFICATION TRAINING PLAN USERS MANUAL OTHER TITLE: Demonstration Report/Technical Basis Document: Ultrasonic Examination of Diablo Canyon Unit 2 Reactor Pressure Vessei Nozzle to Safe End Welds from the ID Surface Through a Welded Protective Layer PLANT SITE/PLANT ALPHA: Diablo Canyon 2/ PEG KEY WORDS: RPV DM Weld Examination WESDYNE INTERNATIONAL LLC P.O. Box 409 Madison, Pennsylvania 15663 The procedure approval signature of the cognizant manager below confirms that prior concurrence of required review groups has been obtained.Originator R. D. Rishel Date L 7/I/2o01 Cognizant Manager D. C. Adamonis ,Date*Page 1 of 68*Effective/Revised Date 0 2010 Westinghouse Electric Company LLCAII rights reserved Printed copies are uncontrolled. FWEsDyfnE AWestinghouse Electric CompanylNUMBER & REV.WestinQhouse Non-Proorietarv Class 3 WDI-TJ-1044-NP, Rev. 1 Demonstration Report/Technical Basis Document: Ultrasonic Examination of Diablo Canyon Unit 2 Reactor Pressure Vessel Nozzle to Safe End Welds from the ID Surface Through a Welded Protective Layer Record of Revisions Revision Date of Pages Description No. Issuance 0 N/A --- N/A 1 June 2010 --- Initial issuance N Page 2 of 68 WDF-19.1-2, Rev. 0 tNE T , lE R NUMBER & REV.AWestingh'ouse Electr Company Westinghouse Non-Proprietary Class 3 WD -TJ-1044-NP, Rev. 1 Demonstration Report/Technical Basis Document: Ultrasonic Examination of Diablo Canyon Unit 2 Reactor Pressure Vessel Nozzle to Safe End Welds from the ID Surface Through a Welded Protective Layer Contents 1.0 PU R PO SE.................................................................................................... 4 2.0 EQ U IPM ENT .................................................................................................. 7 3.0 PROCEDURES .......... .................................... 10 4.0 M O C K -U PS .................................................................................................. 11 4.1 Justification -Materials of Construction .................................................. 22 4.2 Justification -Geom etry ......................................................................... 22 4.3 Justification -Physical Limitations ...................................................... 22 4.4 Justification -Geometric Conditions ....................................................... 23 4.5 Justification -Number of Flaws ............................... 24 4.6 Justification -Flaw Locations ............................................................... 24 5.0 PERSO NN EL ................................................................................................. 25 6.0 R ES U LTS ........... I ........................................................................... ........... 26 7.0 DISCUSSION OF RESULTS ....................................................................... 31 7.1 Adherence to Acceptance Criteria ........................................................ 31 7.2 Lim itations ................................................................................................ 32 7.3 Changes to Essential Variables ............................................................. 32 8.0 CO NC LUSIO NS ............................................................................................ 40 9.0 R EFERENC ES .............................................................................................. 41 ATTACHMENT 1: Site Specific Demonstration Checklist ................................. 43 ATTACHMENT 2: Images of Flaws (Indian Point Unit 2/3 Mock-up) ................. 48 ATTACHMENT 3: Images of Flaws (Weld Inlay Mock-up) ................................. 53 Page 3 of 68 WDF-19.1-2, Rev. 0 WEsDynE NUMBER&REV. ".N T E R N A T 1 0 N A L A N M E E .AWostinghouse Electic Company Westincihouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 Demonstration Report/Technical Basis Document: Ultrasonic Examination of Diablo Canyon Unit 2 Reactor Pressure Vessel Nozzle to Safe End Welds from the ID Surface Through a Welded Protective Layer 1.0 PURPOSE The Diablo Canyon Unit 2 Reactor Pressure Vessel Nozzle Piping weld design configuration is sketched in Figure 1.1 for the outlet nozzles and Figure 1.2 for the inlet nozzles. The materials of construction include a SA508,,Class 2 carbon steel forging (nozzle) welded to a SA-182 Type 316 stainless steel forging (nozzle extension piece) which is then welded to either to an A-376 Type 316 stainless steel forged pipe (outlet nozzle) or to an A-351 CF8M cast stainless steel elbow (inlet nozzle). The weld material is Alloy 182 for the nozzle to safe end weld, and is stainless steel for the safe end to piping weld. On the inner diameter and outer diameter surfaces of the nozzle extension piece and dissimilar metal weld, a nominal 0.090-inch thick layer of 312L stainless steel and Alloy 82 cladding exists [Refs. 9.1, 9.2, 9.20 and 9.21]. These layers were added during the fabrication of the reactor vessel. These are referred to as welded protective layers in this document since they were added to isolate a potentially sensitized material from the surrounding environment. The inlet and outlet nozzle to safe end welds, and inlet and outlet nozzle safe end to pipe welds were inspected during the Diablo Canyon Unit 2 10-Year RVISI in 2006 and will be re-examined in 2011. The examinations are conducted using a WesDyne International automated ultrasonic examination process qualified in accordance with the ASME Code Section XI, Appendix VIII Supplement 14 as modified by the Performance Demonstration Initiative (PDI). The WesDyne inspection procedure is PDI-ISI-254-SE [Ref. 9.3]. This procedure is qualified for detection and length sizing as defined in PDQS No. 634 [Ref. 9.4], and has a demonstrated through-wall sizing capability that is greater than 0.125" RMS but within 10% of the nominal wall thickness. The actual performance RMS for through-wall sizing is obtained from PDI by Licensee request.The 312L stainless steel and Alloy 82 cladding, added as a protective layer on the ID surface, is outside of the PDI qualification parameters as defined in the procedure. The PDI program allows for site specific demonstrations in accordance with the PDI Dissimilar Metal Weld Mock-Up Criteria [Ref. 9.5] and with the PDI Guideline for Ultrasonic Examination of Corrosion Resistant Cladding [Ref. 9.6]. The remainder of the weld and adjacent surfaces are compatible with the PDI qualification parameters (material, diameter, thickness) and no additional demonstration is necessary. Page 4 of 68 WDF-19.1-2, Rev. 0 FWESpynE AWestinghouse Electric Company NUMBER & REV.Westinahouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 The intent of a site specific demonstration is to expand on currently qualified essential variables (such as beam angles, probe element sizes, sound focal depths, probe contouring, scan patterns, etc.) and to allow the inspection personnel to gain specific knowledge of potential sources of UT responses associated with these welds. These sources may be from metallurgical, geometric, and defect conditions. It is noted that site specific demonstrations have been implemented that are relevant to justifying the examination approach for the Diablo Canyon -Unit 2 nozzle to safe end welds and nozzle safe-end to pipe welds. These include a site specific demonstration conducted in 2006 by WesDyne International for Indian Point Unit 2 and 3 [Ref. 9.7], and the weld inlay equivalency demonstration conducted in 2007 by EPRI under PWROG funding [Refs. 9.8 -9.10]. The Indian Point Unit 2/3 demonstration was witnessed by the site Level III and their ANII. The weld inlay equivalency test demonstration was witnessed by EPRI PDI personnel. Both demonstrations were performed under non-blind conditions using the same automated ultrasonic examination techniques defined in PDI-ISI-254-SE. As such, no new site specific demonstrations are necessary. This report serves as the demonstration report/technical basis document similar to that required by PDI [Refs. 9.5 and 9.6] in order to expand the applicability of the PDI-qualified procedure, PDI-ISI-254-SE, for use at Diablo Canyon Unit 2. It uses the information from the two previous demonstrations as justification. Completed Site Specific Demonstration Checklists are provided in Attachment 1.These checklists provide the specific paragraph reference in this document where demonstration report/technical basis requirements, as defined in References 9.5 and 9.6, can be found.I Page 5 of 68 WDF-19.1-2, Rev. 0 79WEsDvnFl IN ER C A ,T1ONAL AWe, inghouse E ectiic Company NUMBER & REV. I Westinqhouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 312L SS Welded Protective Layer EI~II///0.22 NOM 312L SS Welded, Protective Layer' Alloy 82 (Inco 82)Welded Protective Layer Figure 1.1: rCF8 Diablo Canyon Unit 2 Reactor Pressure Vessel Nozzle to Safe End and Safe End to Pipe Weld Design Configuration -Outlet Nozzle [Refs. 9.1, 9.2, 9.19, 9.20 and 9.21]312L SS Welded/Protective Layer* ' /ti---Alloy 82 (Inc0 82)I" i / /Protective Layer id I 31SK /1 2.53 /\ i I:. /\I / j/L -- --0. NOS 5 Cladding 712L S.eded Protective Layer Alloy 82 (Inco 82)Welded Protective Layer Diablo Canyon Unit 2 Reactor Pressure Vessel Nozzle to Safe End and Safe End to Elbow Weld Design Configuration -Inlet Nozzle [Refs. 9.1, 9.2, 9.19, 9.20 and 9.21]Figure 1.2: Page 6 of 68 WVDF-19.1-2, Rev. 0 A WeStinghotise E eetnc Company NUMBER & REV.Westinahouse Non-Prorietat Class 3 WDI-TJ-1h044-NP, Rev. 1 2.0 EQUIPMENT The essential equipment defined in Table 2.1 (Indian Point Unit 2/3 Demonstration) and Table 2.2 (Weld Inlay Equivalency Demonstration) was used for the previous site specific, demonstrations. There were no changes in equipment from that specified in PDI-ISI -254-SE.Page 7 of 68 WVDF-19.1-2, Rev. 0 AWestinghouse Electric Company NUMBER & REV.Westinahouse Non-ProDrietarv Class 3 WDI-TJ-1044-NP. Rev. 1 Table 2.1: List of Essential Equipment Used in the Site Specific Demonstration for Indian Point Unit 2 and 3 [Ref. 9.7] (1]Equipment Specific Equipment Definition Serial Number /Version etc.UT System PARAGON Acquisition Software 3.2.0 PARAGON Analysis Software 6.1.0 PARAGON Pulser-Receiver:[ ]a,c [2]Digital Cards: [ [2]]a8c Pulse Generator Cards: [ [2]]ac Cables 4-ft. long, RG-174 pigtail, Impulse 16 pin to male Suhner ---150-ft. long, RG-174, Impulse 16 pin to Lemo 60-in. long, RG-174, BNC to SMC Search Units Krautkramer, 700 TRL, [ [ ]ac[3]]a,c Krautkramer, 450 TRL, [ ]a,c [3]]a,c Calibration Stainless Steel Navships Test Block [2]Blocks Reference Blocks Stainless Steel Navships Test Block [2]Couplant De-mineralized Water Thermometer 229969 Note 1: PDI-ISI-254-SE, Revision 1 used.Note 2: Report did not identify specific serial numbers only the equipment type used. The equipment type is the same for all revisions of PDI-ISI-254-SE. Note 3: Whereas this serial number is recorded in Reference 9.7 it is not consistent with the model number used nor is it realistic for use on a flat block. The serial number corresponds to a transducer having a contour of R5.94" axial. The model number in the Specific Equipment Definition is consistent with the equipment essential variable and is consistent with that recorded in the text of Reference 9.7.Page 8 of 68 WDF-19.1-2, Rev. 0 n W~sDynEm A Wist .sghouse Electric Company NUMBER & REV.Westinqhouse Non-ProprietarvClass 3 WDI-TJ-1044-NP, Rev. 1 Table 2.2: List of Essential Equipment Used in the Site Specific Demonstration for Weld Inlay Equivalency Testing [Ref. 9.8] [1]Equipment Specific Equipment Definition Serial Number/UT System PARAGON Acquisition Software 3.5.0 Proto. 2 PARAGON Analysis Software 6.3.0 PARAGON Pulser-Receiver:[ ]a,c SAP1 04592 Digital Cards: [ SAP1 04591]ac (PARAGON)Pulse Generator Cards: [ SAP104591]a,c (PARAGON)Cables 4-ft. long, RG-174 pigtail, Impulse 16 pin to male Suhner ---150-ft. long, RG-174, Impulse 16 pin to Lemo 40-in. long, RG-174, BNC to SMC Search Units Krautkramer, 700 TRL, r]c/ ]a,c Krautkramer, 450 TRL, [ []a,c Krautkramer, 600 TRL, [ac]a,c Krautkramer, 370 TRL, ]a[c]ac Krautkramer, 450 TRL, ]3,C]a,c ]a,c Krautkramer, 00 PE, [ [ ]ac]a,c Calibration Stainless Steel Navships Test Block SAP103155 /Blocks SAP103933 Reference Blocks Stainless Steel Navships Test Block SAP103155 /B1 (Rompas) Block SAP 103939 Couplant ' .Ultragel (calibration) ---.Water (examination) Thermometer SAP105509 Note 1: PDI-ISI-254-SE, Revision 2 used.Page 9 of 68 WDF-19.1-2, Rev. 0 WoEs oynE AWestinghouse Electric Company' I NUMBER & REV.Westinahouse Non-Proorietarv Class 3 WDI-TJ-1044-NP. Rev. 1 3.0 PROCEDURES The inspection procedure, PDI-ISI-254-SE, which has been qualified in accordance with the PDI implementation of ASME Section XI, Appendix VIII was used in both of the previous site specific demonstrations. In the Indian Point Unit 2/3 demonstration, Revision 1 of this procedure was used. In the weld inlay equivalency testing demonstration, Revision 2 of this procedure was used. For the Diablo Canyon Unit 2 RVISI examinations in 2006, Revision 2 was the applicable revision [Ref. 9.19]. Revision 3 is the current revision.The procedure changes from Revision 1 to Revision 2 and from Revision 2 to Revision 3 were reviewed by EPRI and were determined to be associated with modifications that had no effect on essential variables [Refs. 9.11 and 9.12].There were no changes in essential variables as a result of these site specific demonstrations. As such Revisions 1, 2 and 3 to PDI-ISI-254-SE are all equivalent. Page 10 of 68 WDF-19.1-2, Rev. 0 ..TE ...jI'f l. A F " NUM BER & REV.AWetrnghouse ElectncCornpany Westinghouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 4.0 MOCK-UPS The Indian Point Unit 2/3 site specific demonstration was conducted on a modified Indian Point reference standard (IPP-RV-73). This standard is a 6" wide by 18.5" long flat weldment block containing a dissimilar weld (Inconel) between an A508 carbon steel forging (nozzle) and a 316 stainless steel forging (safe end), and a similar metal weld (stainless steel) between a 316 stainless steel forg'ing and an A351 Grade CF8M stainless steel casting (pipe/elbow). The block includes a welded stainless steel protective layer on the top surface (OD surface of the actual nozzle/piping configuration) and a welded stainless steel/Inconel protective layer on the bottom surface (ID surface of the actual nozzle/piping configuration). These protective layers are approximately 0.25-inch in thickness. The block contains two thermal fatigue cracks initiating at the protective layer/base metal interface. A drawing of this mock-up is included as Figure 4.1. Specifics on the two cracks are provided in Table 4.1.The mock-up was intended to be representative of the nozzle/piping configuration of Indian Point Unit 2 and 3. It is similarly representative of the Diablo Canyon Unit 2 configuration albeit with a thicker protective layer.The weld inlay equivalency test site specific demonstration was conducted on an existing PDI 601 series weld configuration. This block is a full-scale, 3600 mock-up, and is approximately 41-inches long and 27.5" ID. It contains a dissimilar metal weld (Inconel buttering and Inconel weld metal) between a SA-508 carbon steel forging (nozzle) and a 316 stainless steel forging (safe end), and a similar metal weld (stainless steel) between a 316 stainless steel forging and a 304 stainless steel forged pipe. An Alloy 52 (Inconel) weld inlay was added to three of the four quadrants across the dissimilar metal weld. The inlay thickness for each of the three quadrants was 0.2-inch, 0.07'-inch, and 1.0-inch for the 2 nd, 3 rd and 4 th quadrants, respectively. The 1 st quadrant was-not modified. Four alternative planar flaws were added to each of the three inlaid quadrants. These four flaws are essentially identical to flaws in the PDI 601 Series Practice Mock-up (Figure 4.3). In the 4 th quadrant of the weld inlay mock-up where there is an 1.0-inch thick inlay, an embedded planar flaw was also inserted.A drawing of the weld inlay equivalency test mock-up is included in Figure 4.2a and 4.2b. Specifics on the 13 flaws are provided in Table 4.2. The mock-up was intended to be representative of a nozzle to safe end dissimilar metal weld that has undergone an Alloy 600 PWSCC mitigation process. It is representative of the Diablo Canyon Unit 2 configuration with respect to a welded ID surface protective layer material on the ID surface.A comparison of characteristics of these mock-ups against the plant specific mock-up criteria in Reference 9.5, §4.2 -§4.6 is provided in Table 4.3. Differences with the criteria are discussed later in this section, as referenced in Table 4.3.Page 11 of 68 WDF-19.1-2, Rev. 0 ~WESDynlE k N T 5 oA N A e 1 0 N ACLmN AWestinghouse Electric Company NUMBER & REV.Westinahouse Non-Proorietarv Class 3 IWDI-TJ-1044-NP. Rev. 1'f ____ ____ ----I L. LLJ1 Figure 4.1: Drawing of Site Specific Demonstration" Mock-up -Indian Point Units 2 and 3 Demonstration [Ref. 9.14] )Page 12 of 68 WDF-19.1-2, Rev. 0 7qWEcsDvnfl AWistmnghouse Electnc Company NUMBER & REV.Westinahouse Non-Proorietarv Class 3 WDI-TJ-1044-NP. Rev. 1 a,c.Figure 4.2a: Drawing of Site Specific Demonstration Mock-up -Weld Inlay Equivalency Test Demonstration [Ref. 9.9]Page 13 of 68 WDF-19.1-2, Rev. 0 AWestinghouse Electric Company NUMBER & REV.Westinqhouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 a,c Figure 4.2b: Drawing of Site Specific Demonstration Mock-up -Weld Inlay Equivalency Test Demonstration [Ref. 9.9]Page 14 of 68 WDF-19.1-2, Rev. 0 nw sDyn f AWestinghouse E octna Company NUMBER & REV.Westinqhouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 a,c Figure 4.3: Drawing of PDI 601 Series Practice Mock-Up -Weld Inlay Equivalency Test Demonstration Original Configuration [Ref. 9.17]Page 15 of 68 WDF-19.1-2, Rev. 0 n W-=SyflE.AWest .nghouse Eloctoc Company NUMBER & REV.Westinahouse Non-Proorietarv Class 3 WDI-TJ-1044-NP, Rev. 1 Table 4.11: Description of Flaws in Mock-Up -. Indian Point Unit 2 and 3 Demonstration [Ref.9.14]Flaw Flaw Description Flaw Dimensions No. Location Type Length Through-Wall Width (in.) (in.) (in.)1 At boundary between Thermal fatigue 0.50 0.25 welded protective layer and crack safe' end base material, and at safe end to weld interface; not exposed to ID surface; parallel to weld; 00 tilt, 20' skew 2 At boundary between Thermal fatigue 0.50 0.25 welded protective layer and crack safe end base material, and in safe end base metal; not exposed to ID surface;parallel to weld; O0 tilt, 0'skew J Page 16 of 68 WDF-19.1-2, Rev. 0 mWEsDynfE I h oI s E e C p ' O .A ny A Westinghiouse Electri Company NUMBER & REV.Westinqhouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 Table 4.2: Description of Flaws in Mock-Up -Weld Inlay Equivalency Test Demonstration [[Ref. 9.9]Flaw Flaw Description Flaw Dimensions No. Location Type Length Through-Wall Width (in.) (in (in.)1-Q2 In weld inlay on Thermal fatigue crack 1.80 0.339 ---1-Q3 safe end side of 1-Q4 weld; exposed to ID surface; parallel to weld; 0' tilt, 80 skew 2-Q2 In weld inlay on Thermal fatigue crack 2.63 0.350 2-Q3 nozzle side of weld;2-Q4 exposed to ID surface; parallel to weld; 0' tilt, 00 skew 3-42 In weld inlay on Alternate planar flaw 0.50 0.374 3-43 safe end side of (EDM representative of 3-44 weld; exposed to ID crack topography) surface;perpendicular to weld; 00 tilt, 110 skew 12-42 In weld inlay in Thermal fatigue crack 3.05 0.815 12-43 center of weld;12-04 exposed to ID surface; parallel to weld; 00 tilt, 5°skew Embed At interface Alternate planar flaw 2.23 0.70 between weld inlay (EDM representative of and original weld; crack topography) in center of weld;embedded with ligament to ID surface of 1-inch;parallel to weld; 00 tilt, 0_ skew Note 1: Flaws 1, 2, 3 and 12 in the PDI 601/1 Series Practice Mock-up [Ref. 9.17] have similar flaw descriptions and flaw dimensions as reported in this table. The only exception is Flaw 3 where the flaw length in the practice mock-up is reported to be 0.6-inch long. [Ref. 9.18]Page 17 of 68 WDF-19.1-2, Rev. 0 AWestinghouse Electrc Company NUMBER & REV.Westinahouse Non-Proorietarv Class 3 IWDI-TJ-1044-NP, Rev. 1 Table 4.3: Comparison of Mockup Characteristics Against the Plant-Specific Mockup Requirements Requirement Requirement Actual Component Indian Point Units 2 & 3 EPRI Weld Inlay Reference Demonstration Mock-Up Equivalency Test Mock-Up Ref. 9.5, §4.2.1 Fabricated from

Carbon Steel (CS)
CS Forging (SA508)
CS Forging (SA508)same material type Forging (SA508)
316 SS Safe End
316 SS Safe End and product form
316 Stainless Steel (SS)
Inconel weld metal
Alloy 82/182 weld Safe End
SS cladding on CS metal and buttering* Alloy 182 weld metal forging
SS cladding on CS* SS cladding on CS
SS and Inconel welded forging forging protective layer
Alloy 52 inlay* 312L SS and Alloy 82 [Ref. 9.7] [Ref. 9.10]welded protective layer Criteria met due to Criteria assumed to[Refs. 9.1 & 9.2] Citeria mee be met due to similarity, see similarity, see justification in §4.1 justification in §4.1 Ref. 9.5, §4.2.2 Welding method and Specifics not available
Welded similar to field
Welded similar to position simulate that components field components which was used to [Ref. 9.7] [Ref. 9;10]fabricate component (SMAW in 1G position is acceptable for weld, Criteria considered buttering is welded in Criteria considered met Creriatconsdr the same direction by replication of field met byrponeof that was used to component welding welding fabricate component; manual SMAW is acceptable for buttering)

Ref. 9.5, §4.2.3 Geometry such as Geometric discontinuity

Geometric discontinuity
No geometric tapers are on ID surface between on ID surface between discontinuity represented end of protective layer on end of protective layer
ID is approximately nozzle and nozzle on nozzle and nozzle 29-inches, thickness cladding cladding is approximately 2.9-Outlet nozzle -ID is
Mock-up is flat, inches approximately 29-inches, thickness is [Ref. 9.10]thickness is approximately 3-inches approximately 2.7-inches

[Ref. 9.7]Inlet nozzle -ID is Conditions not Conditions not approximately 27.5- replicated but replicated but inches, thickness is considered met, see considered met, see approximately 2.7-inches justification in §4.2 justification in §4.2[Ref. 9.1]1_ _ _ __ _ _ _ _Ref. 9.5, §4.2.4 Physical limitations

SS and Alloy 82 welded o SS and Inconel welded
Alloy 52 welded are represented protective layer (0.090- protective layer (0.25- protective layers inch thick)on ID surface of inch thick) on ID (0.070-inch, 0.2-inch safe end with extension surface of safe end and 1.0-inch thick across dissimilar metal with extension across inlaid on ID surface weld dissimilar metal weld of safe end with[Refs. 9.1 & 9.2] [Ref. 9.7] extension across dissimilar metal weld[Ref. 9.10]Criteria considered met, Criteria considered see justification in §4.3 met, see justification in §4.3 Page 18 of 68 WDF-19.1-2, Rev. 0 AWestinghouse Eledcn Company NUMBER & REV.Westinlhouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 Table 4.3: Comparison of Mockup Characteristics Against the Plant-Specific Mockup Requirements Requirement Requirement Actual Component Indian Point Units 2 & 3 EPRI Weld Inlay Reference Demonstration Mock-Up Equivalency Test Mock-Up Ref. 9.5, §4.2.5 Geometric
Design drawings show
Design drawings show
Design drawing condition(s) that dissimilar weld dissimilar weld indicates buttering require discrimination preparation interfaces of preparation interfaces interface at 15 0 off between geometry 70 (safe end side) and of 70 (safe end side) normal, and and flaw indications 22' (nozzle side) off and 22' (nozzle side) weld/buttering and is represented normal off normal weld/safe end No buttering
No buttering interfaces at 150 off[Ref. 9.1] [Ref. 9.13] normal* Buttering[Ref. 9.10]Criteriarconsidered Criteria met met, see justification in §4.4 Ref. 9.5, §4.2.6 Manufacture of N/A
Utility reference block
Fabricated under mockup in intended to duplicate EPRI QA program accordance with QA plant configuration

[Ref. 9.10]programs that have

Flaws inserted by following attributes:

FlawTech under their design control, QA program procurement, [Ref. 9.7]procedures and drawings, material control, welding, controls for special processes, control of measurement and Criteria assumed to be Criteria assumed to test equipment, met be inspection met be met procedures, non-conformance program and document control procedures Ref. 9.5, §4.2.7 Commercial grade N/A

Base metal, sample
Base metal, sample dedication of existing geometry and welding geometry and mock-ups are process met welding process met acceptable provided:

requirements requirements

Base material, o Dimensions of flaws
Dimensions of flaws sample verified under verified under EPRI geometry and FlawTech QA program QA program welding process o No unintended defects
No unintended used met detected that could defects detected that requirements of mask detection and could mask above characterization of the detection and* Dimensions of intended flaws characterization of flaws can be the intended flaws verified within applicable design tolerances using methods other Criteria assumed to be Criteria assumed to than UT met be met* Sample is free of unintended defects that could mask Page 19 of 68 WDF-19.1-2, Rev. 0 AWestinghouse Electric Company NUMBER & REV.Westinqhouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 Table 4.3: Comparison of Mockup Characteristics Against the Plant-Specific Mockup Requirements Requirement Requirement Actual Component Indian Point Units 2 & 3 EPRI Weld Inlay Reference Demonstration Mock-Up Equivalency Test Mock-Up detection and characterization of intended flaws Ref. 9.5, §4.3 Licensee shall N/A
2 circumferential flaws 0 10 circumferential determine the
embedded type flaws flaws and 3 axial quantity of flaws [Ref. 9.7] flaws taking into
ID and embedded consideration

§4.2.3, type flaws '§4.2.4, §4.2.5, §4.4 [Ref. 9.10]and §4.6 Criteria met, see Criteria met, see justification in §4.5 justification in §4.5 Ref. 9.5, §4.4 Flaw depths between N/A

Flaw depths are 10%
Circumferential ID 10% and 20% of of nominal wall flaws have flaw nominal wall thickness depths of 11.4%, thickness are [Ref. 9.7] 12%, and 27.4% of acceptable; flaw nominal wall heights > 20% are thickness acceptable with
Axial ID flaws have technical justification flaw depths of 12.6% of the nominal wall thickness* Circumferential embedded flaw has flaw depth of 24%of the nominal wall thickness[Ref. 9.10]Criteria met; Criteria met;appropriate flaw sizes appropriate flaw sizes represented represented Ref. 9.5, §4.5 Alternative flaws N/A
Flaws are thermal
Circumferential ID (e.g. HIP, CIP), fatigue flaws are thermal cracks, or a [Ref. 9.7] fatigue combination thereof
Axial ID flaws and are to be circumferential represented; embedded flaw are alternative flaws shall alternative flaws provide crack-like (EDM notches characteristics and a representing final width tip < topography of 0.002" crack)[Ref. 9.10]Criteria met Criteria met Ref. 9.5, §4.6 Flaws placed in N/A
Flaws located in safe ° Flaws located in locations susceptible end and at safe safe end and nozzle to cracking; axial and end/weld interface heat affected zones, circumferential flaw (heat-affected zone) and in weld orientations to be
Flaws are
Flaws are included circumferentially circumferential and oriented axial Page 20 of 68 WDF-19.1-2, Rev. 0 AWESDl nE AWest nghouse Electoc Company NUMBER & REV.Westincihouse Non-Proprietary Class 3 IWDI-TJ-1044-NP, Rev. 1 Table 4.3: Comparison of Mockup Characteristics Against the Plant-Specific Mockup Requirements Indian Point Units 2 & 3 Demonstration Mock-Up EPRI Weld Inlay Equivalency Test Mock-Up Criteria conditionally met, see justification in§4.6 Criteria met Page 21 of 68 WVDF-19.1-2, Rev. 0 IWEsyTE 0 NUMBER & REV.AWest nghouse Electrc Company Westinghouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 4.1 Justification

-Materials of Construction The underlying safe end, butt weld material and the nozzle forging materials of the demonstration mock-ups are the same, i.e. stainless steel, Ni-alloy and low alloy carbon steel, respectively. The Indian Point Unit 2/3 mock-up has the same welded protective layer materials (stainless steel and Ni-alloy). The weld inlay equivalency mock-up contains only a Ni-alloy weld protective layer.Stainless steel and Ni-alloy weld materials are considered similar in terms of acoustic properties. Both materials will have the dendritic, coarse-grained weld structure common to welds. This anisotropic structure causes the more significant attenuation of the ultrasonic energy. EPRI has performed some investigations comparing stainless steel and Ni-based material used in structural weld overlays, and they have found no significant acoustic differences [Ref. 9.15]. The similarity in the signal-to-noise ratios for the two identical flaws in the Indian Point Unit 2/3 mock-up substantiates-this minimal impact (see Table 6.1).4.2 Justification -Geometry The Indian Point Unit 2/3 mock-up is flat but does contain a more severe geometric discontinuity (taper) on the ID surface than the Diablo Canyon Unit 2 nozzle to safe end design configuration given the 0.16-inch difference in welded protective layer thickness. This geometric discontinuity affects the smoothness of the scan and can result in geometric responses in the ultrasonic test data. The flat geometry is not anticipated to impact defect detection and characterization since the smallest Diablo Canyon component diameter is greater than 27-inches. It is recognized in ASME Section Xl, Appendix I, Supplement 3 that flat calibration blocks may be used in lieu of contoured calibration blocks if the diameter is greater than 20-inches. [Ref. 9.16]The weld inlay equivalency mock-up represents a similar ID surface contour (27" ID)to the Diablo Canyon Unit 2 nozzle to safe end configuration but contains no geometric discontinuity. Both mock-ups collectively represent the geometrical aspects of the Diablo Canyon Unit 2 nozzle to safe end configurations.

4.3 Justification

-Physical Limitations The Indian Point Unit 2/3 mock-up includes a 0.25-inch thick layer of dendritic, coarse-grained weld structure compared to the nominal 0.09-inch thick layer of the actual Page 22 of 68 WDF-19.1-2, Rev. 0 ,. -N AT IO N AL N NUM BER & REV.AWestinghouse Electic Company Westinghouse Non-Proprietary Class 3 WDI-TJ-1 044-NP, Rev. 1 Diablo Canyon Unit 2 components. This weld structure causes attenuation of the incident ultrasonic energy and beam angle shifts. The thicker weld structure is considered to be conservative in that this should result in greater attenuation and larger beam angle shifts.The weld inlay equivalency mock-up includes three different thicknesses of dendritic, coarse-grained weld structure (0.07-inch, 0.2-inch and 1-inch) compared to the 0.09-inch thick layer of the actual Diablo Canyon Unit 2 components. Since these welded protective layer thicknesses span the actual component, the anticipated extent of ultrasound attenuation and beam angle shifts are considered. Both mock-ups represent conservatively the physical aspects of the Diablo Canyon Unit 2 nozzle to safe end configurations particularly the impact of the welded protective layer on the incident ultrasonic energy. Similarly the safe end side of the safe end to piping weld is represented.

4.4 Justification

-Geometric Conditions The Indian Point Unit 2/3 mock-up weld configuration matches Diablo Canyon Unit 2 nozzle to safe end weld configuration. The weld bevel angles are the same and no buttering is present. Thus metallurgical reflectors from the weld bevel surfaces are expected to be similar.The weld inlay equivalency mock-up contains an additional welded interface with the presence of the buttering. This welded interface will likely result in more metallurgical reflectors that will conservatively complicate the data analysis process.The 15-degree bevel angle on the weld preparation in the weld inlay equivalency mock-up is different than the 7-degree and 22-degree bevel angles in the Diablo Canyon Unit 2 weld configuration. The 22-degree bevel angle provides a more normal beam impingement for the 70-degree detection transducer than a 15-degree bevel angle, which could result in more spurious metallurgical responses from the interface in the actual Diablo Canyon Unit 2 dissimilar metal weld examinations. The angles of impingement are 92-degrees and 85-degrees, respectively. This difference is considered minimal given the procedural instructions in PDI-ISI-254-SE for determining the validity of indications. The 7-degree bevel angle provides a less normal beam impingement for the 70-degree detection transducer (77-degree) and as such is not relevant.Page 23 of 68 WDF-19.1-2, Rev. 0 AWestinghouse Electrc Company NUMBER & REV.Westinjqhouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev.. 1 4.5 Justification -Number of Flaws The Indian Point Unit 2/3 mock-up contains two thermal fatigue cracks (one in the safe end and one that lies along the safe end to weld interface). One crack is underneath the stainless steel welded protective layer and the other is underneath the Ni-alloy welded protective layer. This positioning provides information on the relative difference in ultrasound attenuation between the two weld materials. The weld inlay mock-up contains 10 circumferential flaws and 3 axial flaws that initiate at the ID surface and 1 embedded circumferential flaw. As such both flaw orientations are represented. Both mock-ups collectively contain flaws in the Ni-alloy portion of the weld and offer the capability to determine the significance of stainless steel versus Ni-alloy welded protective layers.4.6 Justification -Flaw Locations The one flaw in the Indian Point Unit 2/3 mock-up is well within the safe end at a location that is not known to be susceptible to cracking. Its reason for inclusion in the flaw matrix was to obtain information on the relative difference in ultrasound attenuation between the two welded protective layer materials (stainless steel and Ni-alloy) and to be representative of the safe end side of the safe end to piping weld.The remaining flaws in the two mock-ups are at locations that are known to be susceptible to cracking including the weld and the weld interfaces. Both mock-ups collectively contain the flaw locations that are known to be susceptible to cracking.Page 24 of 68 WDF-19.1-2, Rev. 0 nWESDn Vn... .. ..I .ANUMBER & REV.AWestinghouse Electoc Company Westinghouse Non-Proprietary Class 3 IWDI-TJ-1044-NP, Rev. 1 5.0 PERSONNEL The following personnel participated in the Indian Point Unit 2/3 demonstration:

Dal Nelson -WesDyne International Level I UT qualified using procedure PDI-ISI-254-SE Rev. 0, and WDI-STD-1 19-C Rev. 01 (PDQS No. 466), data acquisition and data analysis" David Kurek -WesDyne International Level III UT, data analysis support The following personnel participated in the weld inlay equivalency test demonstration: " Dal Nelson -WesDyne International Level II UT qualified using procedure PDI-ISI-254-SE Rev. 0, and WDI-STD-119-C Rev. 0 (PDQS No. 466), data acquisition
Andre Moreau -WesDyne International Level II UT qualified using procedure PDI-ISI-254-SE Rev. 0, PDI-UT-2 Rev. C2, and PDI-UT-3 Rev. B 3 (PDQS No.1), data analysis It is noted on the procedure PDQS [Ref. 9.4] that personnel qualified with PDI-ISI-254-SE, Revision 0 are also qualified with the Revision 2 issue with no re-qualification.

Since there are no essential variable changes between Revision 3 and Revision 2 (see Section 3.0), personnel qualified to Revision 0 are also qualified to Revision 3 without no re-qualification. This is also stated in Reference 9.12.1 Includes single-sided detection and length sizing with IGSCC per Supplement 2 Includes single-sided detection and length sizing with IGSCC per Supplement 2 Includes through-wall depth sizing with IGSCC per Supplement 2 Page 25 of 68 WDF-19.1-2, Rev. 0 ~WESDynlE t N t g ANhA T I O tN A L n AWestinghouse Electric Company NUMBER & REV.Westinqhouse Non-Proprietary Class 3 IWDI-TJ-1044-NP, Rev. 1 6.0 RESULTS The results from the scans on the Indian Point Unit 2/3 mock-up are summarized in Table 6.1. Both thermal fatigue cracks were detected and sized. Images of these flaws are shown in Attachment 2.The results from the scans on the weld inlay mock-up and the PDI 601 Practice Block are summarized in Figure 6.1. All of the cracks were detected and sized. The PDI 601 Practice Block does not contain an embedded flaw. Images of these flaws are shown in Attachment

3. It is noted that there was an increased level of noise that decreased the signal-to-noise ratio of both the axial and circumferential flaws (see Attachment 3, Figure 15). This increased noise was more pronounced for the circumferential scans [Ref. 9.10].Coverage maps for the site-specific mock-ups are shown in Figures 6.2 and 6.3.Page 26 of 68 WDF-19.1-2, Rev. 0 I A r Aghus E n C o m p an AWestinghouse Electric Company NUMBER & REV.Westinchouse Non-Proorietarv Class 3 1WDI-TJ-1044-NP, Rev. 1 Table 6.11: Results Summary from Indian Point Unit 2/3 Demonstration

[Ref. 9.7]Flaw Detected Scan Scan Amp SIN Measured Measured Transducer No. (Yes/No) Surface Direction (%) Ratio Length Depth[4] V] (in.) (in.)1 Yes ID Toward 65 6.0 N/A N/A 700 TRL[ ID Carbon 6100 5] --- 0.625 0.22 450 TRL Steel Yes ID Away from 98 6.8 N/A N/A 700 TRL] ID Carbon 317T-- ___ [3] 0.22 450 TRL Steel 2 Yes ID Toward 76 6.3 N/A N/A 700 TRL[2] ID Carbon 4 0.25 450 TRL Steel Yes I D Away from 100 6.6 N/A N/A 700 TRL I ID Carbon 47-7F- --- 0.625 0.29 450 TRL Steel Note 1: Signal-to-noise (SN) ratio levels determined using the PARAGON histogram feature from recent review of electronic data by T. Bushmire (PDQS 964, PDI-ISI-254-SE Rev. 1 detection and length sizing)Note 2: 450 transducer not used for detection per PDI-ISI-254-SE; only used for sizing Note 3: Not used; the longest length size is used.Note 4: ID is bottom surface of block consistent with the ID surface of the actual component. Note 5: Amplitude of strongest crack tip response Page 27 of 68 WDF-19.1-2, Rev. 0 AWESDynl E AWest nghouse Electno Company NUMBER & REV.Westinahouse Non-Proorietarv Class 3 WDI-TJ-1044-NP, Rev. 1 PADT P01 supplcmaunit2o~Demmrwition PROCEMIRE PI63 4SI-254-SM Rv 2*COMPONE. Ac" Fl o t. *o LI.T ts*a

W1 b.oc* , a.wIii~th1*

0*tfwW %An~uvý ýi,"T*Ws, KIICdND., L 5 h CCm ~C MIETAws.1 1.9Wy 0.33S9'. 1.875" 0.37" 1-02 1.75 0.37' * *: * .- _ .__2 267 * ,0.351y' 2.754 0,39V s 2-02 2,75" 0.34, * / '_ ... " .3 --,0.W' a 0,374". 040" 04.44. 3-02 0.64", .0.40' -- ..* -. , S12 .0,81 " 325 0,'- .12-02 3,00" .0.-1' -'.: ef-ted 2.23. 0;70' _______ ________ _____ _____________.

'1-03. 4.75".. 0.42' .A ._.-: ____: ': __2-03 2-375" 0.33' .....__-:- _-_-_ ..S ' ",'."_. '1 !. .' '. .. .1 ..3-0 3 :0 ,64 ' 0,37'- '.". .' __ "."______ _____ t2-03 2.B75' '0.81- _______-...0..... ..j.. .0.3". : : .'. .: : .: -... .... ......... " 2-04 2,625' A 037' -__ _ '_ _' " .... .. 3-04 0.72' j 927" " " ' ..... _ ., ..... ._,' ._ _ ..... : " : t12-04 3.125' 9. 77' .. _ .'__. __ _ _.,_- _ _._... : _ _"_-

_ _.. _. _ ...I " -* nbLd 225" 0,71' ___ : __ ....__ __!1 Tlab flcks Figure 6.11: Results Table from Weld Inlay Equivalency Demonstration

[Refs. 9.8 8, 9.10]Page 28 of 68 WDF-19.1-2, Rev. 0 9WESDylnE AWestinghouse Electric Company NUMBER & REV.Westinahouse Non-ProDrietarv Class 3 WDI-TJ-1044-NP, Rev. 1 Examination Volume (EV) Cross-Section = 2.3 in 2 700 Out Transducer Only- EV Limitation Cross-Section = 1.1 in 2 700 In Transducer Only -EV Limitation Cross-Section = 0 in 2 Both 700 Transducers -EV Limitation Cross-Section = 0.023 In 2 EV Coverage. 70- Beams Directed Out -(2.3 -1.1 -0.023)/2.3 "100 = 51.1%EV Coverage, 700 Beams Directed In -(2.3 -0.023)/2.3100 = 99%Averaged Coverage for Axial Beams -(51.1 + 99)2 = 75%Examinalton Volume (EV) Cross-Section = 2.3 in 2 700 CWICCW Transducers -EV Limitation Cross-Section = 0.49 in 2 EV Coverage 700 Beams CW Direction -(2.3 -0.49)Y2 3"100 = 78.7%EV Coverage 700 Beams CCW Direction -(2.3 -0.49)2.3100 = 78.7%Averaged EV Coverage for Circumferential Beams -78&7%Figure 6.2: Coverage Map for the Indian Point Unit 2/3 Mock-up Page 29 of 68 WDF-19.1-2, Rev. 0 nWESDyRfE.44 1 15 .t ..In. 0 o A LN AWestinghouse Electric Company NUMBER & REV.Westinahouse Non-Proorietarv Class 3 WDI-TJ-1044-NP. Rev. 1 6.an,wnaion Vo9.,n, (653 Or.-Section 3.14 W;0- 0,4 Trwamdti, Orily -EV Limitation Crow-0.ctboo = 0.06 70' In Tanedre 4Oanlyn- V L C616790077-08089n -0 061 ir2 6.7, 70'Trsn9,n, -EV Linitaton r~~-Oedon -0 0349,W EV Co..rage. 7T Bens Directed Out .-(3,14 -0.046-a0 034)13 14 '100 97 5%EV Coverage, 701 San,. Directed M -(3 t4 -0,061. 0034Y3 14*100 = 97%A-.07.4 C-9... fo k- e 8 -. ea, -(97 5 -97('2 -97.3%E.4,nan4or, Vo4-n (EV) Croo-Section =3 14 rY'7(3-CWfCCWTrann7449¶- EV Lirr6009 Cn7-Socfi- =0629" EV Co..,g.70' 6...C W 09-mon -(3.14-0 62(13 14106

2%EV 0.909.79B.,O CCW D60o909-(3,14-O.6Z(0.14'100

=80.2%Av,.g.d EV Oo..r.. W. 0-ro i-tealla Bne-. -802%Figure 6.3: Coverage Map for the Weld Inlay Equivalency Mock-up Page 30 of 68 WDF-19.1-2, Rev. 0 A Wisigi~eESectfl , opnNUMBER & REV. Westinghouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 7.0 DISCUSSION OF RESULTS 7.1 Adherence to Acceptance Criteria As stated in Section 1.0 the primary objective of the site specific demonstration is to support obtaining coverage credit for the ASME Code Section XI examinations through an ID surface welded protective layer. Both the Indian Point Unit 2/3 and weld inlay equivalency demonstrations are relevant in achieving this objective for the Diablo Canyon Unit 2 nozzle to safe end and safe end to piping weld configurations. All of the flaws in the two welded protective layer mock-ups were detected Using the data interpretation criteria in PDI-ISI-254-SE. The correlation between actual flaw length and measured flaw length is shown in Table 7.1 and Figure 7.1 for the flaws in the two mock-ups (15 flaws). The calculated length RMS error is 0.135-inch, and the maximum length sizing error is 0.255-inch. Both of these values are within the ASME Section XI, Appendix-VIII, Supplements 2 and 10 length sizing criteria (i.e. RMS error _ 0.75-inch). The correlation between actual through-wall depth and measured through-wall depth is shown in Table 7.1 and Figure 7.2 for the flaws in the two mock-ups (15 flaws). The calculated through-wall depth RMS error is 0.041-inch, and the maximum through-wall sizing error is 0.104-inch. Both of these values are within the ASME Section XI, Appendix VIII, Supplements 2 and 10 through-wall sizing criteria (i.e. RMS error _0.125-inch). Table 7.2 provides the actual flaw dimensions and the measured flaw measurements for the same flaws in the PDI 601 Practice Mock-up as are in the welded inlay equivalency test mock-up. The calculated RMS errors are 0.043-inch through-wall depth and 0.158-inch length. The maximum errors are 0.066-inch through-wall depth and 0.2-inch length. Such errors are equivalent with and without a welded protective layer.Therefore these two demonstrations(confirmed that flaws in the examination volume of a component with a welded protective layer can be detected, characterized, length sized and through-wall depth sized using the existing PDI-ISI-254-SE procedure. Whereas for the welded inlay equivalency demonstration there was a decrease in signal-to-noise ratio as a result of the welded protective layer, this decrease did not affect the capabilities of the procedure for flaw detection and sizing.Page 31 of 68 WDF-19.1-2, Rev. 0 I,. r. ..,1 .0NUMBER & REV.AWe,,rngho,,o Ec ncCompay Westinqhouse Non-Proprietary Class 3 IWDI-TJ-1044-NP, Rev. 1 7.2 Limitations The measured surface profiles for the Diablo Canyon Unit 2 Reactor Vessel Nozzle to Safe End Welds are shown' in Figures 7.3 and 7.4. These profiles were obtained by WesDyne during the Diablo Canyon Unit 2 10-Year RVISI 2006 examinations. Whereas Figures 1.1 and 1.2 indicate design configurations that have a definitive ID surface geometric discontinuity at the start of the welded protective layer on the nozzle side of the nozzle to safe end weld, the actual configurations exhibit a gradual taper that does not cause localized areas of transducer non-contact. As such 100%examination volume coverage for each of the nozzle to safe end welds was reported in the 2006 examinations [Ref. 9.19].Figures 1.1 and 1.2 indicate that the end of the welded protective layer on the safe end side of the safe end to piping weld creates a counterbore that could cause a localized area of transducer non-contact. This is consistent with the profiles in Figures 7.3 and 7.4 however weld 'suck-up' is also a contributor to examination volume limitations. However these surface conditions still allowed foressentially 100%(>90%) examination volume coverage for each of the safe end to piping welds as reported in the 2006 examinations [Ref. 9.19]; the least examination volume coverage reported was 90.33% (Outlet Nozzle @1580), and the best examination volume coverage reported was 92.84% (Inlet Nozzle @2470).It is noted that automated eddy current inspection is also conducted on the ID surface of the nozzle to safe end and safe end to piping welds. The ECT probes have a small footprint-and are able to detect ID surface-initiating flaws in the regions not covered by the 70' TRL transducers. Whereas the ECT process is not formally qualified in the US, it does provide relevant information regarding the presence of ID surface-connected flaws.7.3 Changes to Essential Variables The site-specific demonstrations resulted in no changes to the essential variables as defined in inspection procedure, PDI-ISI-254-SE. Page 32 of 68 WDF-19.1-2, Rev. 0 IN rTge R No A eT10 NCAmLNy A westinghouse Electric Company NUMBER & REV.Westinqhouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 Table 7.1: Comparison of Sizing Results Mock-Up Flaw Actual Measured Through- Actual Measured Length No. Through- Through- Wall Depth Length Length Error Wall Depth Wall Depth Error (in.) (in.) [meas. -(in.) (in.) [meas. -actual]actual] (in.)(in.)Indian Point 1 0.25 0.22 -0.03 0.5 0.625 0.125 Units 2/3 Indian Point 2 0.25 0.29 0.04 0.5 0.625 0.125 Units 2/3 Weld Inlay 1-Q2 0.339 0.37 0.031 1.8 1.75 -0.05 Weld Inlay 1-Q3 0.339 0.42 0.081 1.8 1.75 -0.05 Weld Inlay 1-Q4 0.339 0.36, 0.021 1.8 1.625 -0.175 Weld Inlay 2-42 0.35 0.34 -0.01 2.63 2.75 0.12 Weld Inlay 2-Q3 0.35 0.33 -0.02 2.63 2.375 -0.255 Weld Inlay 2-Q4 0.35 0.37 0.02 2.63 2.625 -0.005 Weld Inlay 3-Q2 0.374 0.4 0.026 0.5 0.64 0.14 Weld Inlay 3-Q3 0.374 0.37 -0.004 0.5 0.64 0.14 Weld Inlay 3-Q4 0.374 0.27 -0.104 0.5 0.72 0.22 Weld Inlay 12-42 0.815 0.81 -0.005 3.05 3.0 -0.05 Weld Inlay 12-Q3 0.815 0.81 -0.005 3.05 2.875 -0.175 Weld Inlay 12-04 0.815 0.77 -0.045 3.05 3.125 0.075 Weld Inlay Embed 0.7 0.71 0.01 2.23 2.25 0.02 Max. Error -0.104 Max. Error -0.255_RMS Error_ o 1 0.041 RMS Error7 1] 0.135 Note 1: RMS is as defined in ASME Section Xl, Appendix VIII, Article VIII-3120. Page 33 of 68 WDF-19.1-2, Rev. 0 AWestinghouse Electric Company r NUMBER & REV.Westinghouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 Table 7.2: Sizing Results for Flaws in Non-Weld Inlaid 601 Practice Mock-Up Mock-Up Flaw Actual Measured Through- Actual Measured Length No. Through- Through- Wall Depth Length Length Error Wall Depth Wall Depth Error (in.) (in.) [meas. -(in.) (in.) [meas. -actual]actual] (in.)(in.)601 Practice 1 0.339 0.37 0.031 1.8 1.875 0.075 Mock-Up 601 Practice 2 0.35 0.39 0.04 2.63 2.75 0.12 Mock-Up 601 Practice 3 0.374 0.44 0.066 0.6 0.4 -0.2 Mock-Up 601 Practice 12 0.815 0.79 -0.025 3.05 3.25 0.2 Mock-Up Max. Error 0.066 Max. Error 0.2 RMS Error"1' 0.043 RMS Error" 1 0.158 Note 1: RMS is as defined in ASME Section X1, Appendix VIii, Article V111-3120. Page 34 of 68 WDF-19.1-2, Rev. 0 n WESDvnfl AW,.stighous. Etactric Company r NUMBER & REV.Westinahouse Non-ProDrietarv Class 3 WDI-TJ-1 044-NP, Rev. 1 I.I-JU I 3.5 3 2,5 2 1.5 1 0.5 0 0 0.5 1 15 2 2.5 3 35 Actual Crac Length (n.)Figure 7.1: Correlation of Actual Flaw Length and Measured Flaw Length for the 15 Flaws in the Two Demonstration Mock-Ups 0.9S 08 3 I 07 ___ __H S0.6 --___ __ _________0.5 0.4 M 0,3 -"-0,2 0.1 -0 01 0.2 03 04 05 06 07 08 09 Actual Crack Through-Wall Depth (in.)Figure 7.2: Correlation of Actual Flaw Through-Wall Depth and Measured Flaw Through-Wall Depth for the 15 Flaws in the Two Demonstration Mock-Ups Page 35 of 68 WDF-19.1-2, Rev. 0 AWestinghouse Electric Company NUMBER & REV.Westinqhouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 Profile WN22-SEPRPDETO0004.pfd Sweep 1, Xb -0.0--0.5 0.1_ _/ _ \IA.1.0///2.° \ / __113.0 114.0 115.0 116.0 117.0 118.0 119.0 120.0 121.0 122.0 123.0 Diablo Canyon Unit 2 Outlet Nozzle 220 Profile WNIS8-SEPRPDETON_04.pfd Sweep 1, Xb -0.0--0.5/ I \ N 0.5//1.0///1.5/113.0 114.0 115.0 116.0 117.0 118.0 119.0 120.0 121.0 122.0 123.0 Diablo Canyon Unit 2 Outlet Nozzle @ 1580 Figure 7.3a: Measured Surface Profiles for the Diablo Canyon Unit 2 Reactor Vessel Nozzle to Safe End and Safe End to Pipe Welds -Outlet Nozzles (data from 2006 examinations) Page 36 of 68 WDF-19.1-2, Rev. 0 n W-oSyflE IN TA 6 o ON A AWesfinghouso Eloctni Company NUMBER & REV.Westinahouse Non-Pronrietarv Class 3 WDI-TJ-1044-NP. Rev. 1 Profile WN202SEPRPDEZT0N.utr_04.pfd Sweep 1, Xb -0.0--0.5 0.0 1.01 1.° / /2.0/ i V 11i.0 114.0 1XS.0 116.0 117.0 118.0 119.0 120.0 121.0 122.0 123.0 Diablo Canyon Unit 2 Outlet Nozzle @ 2020 Profile WN338-SEPRPDETONO4.pfd Sweep 2, Xb -1.0-Diablo Canyon Unit 2 Outlet Nozzle 0. 3380 Figure 7.3a: Measured Surface Profiles for the Diablo Canyon Unit 2 Reactor Vessel Nozzle to Safe End and Safe End to Pipe Welds -Outlet Nozzles (data from 2006 examinations) Page 37 of 68 WDF-19.1-2, Rev. 0 `72WESDvnflE AWestinghouse Electric Company NUMBER & REV.Westinachouse Non-Proprietary Class 3 WDI-TJ-1 044-NP, Rev. 1 Profile 1N67-SEPRPDETINO04.pfd Sweep 4, Xb -3.1--0.5 0.0 o.s/ /1.0/!1.,___'_____t___/__ _\_____2.0 121.0 122.0 123.0 124.0 125.0 126.0 127.0 128.0 129.0 130.0 131.0 Diablo Canyon Unit 2 Inlet Nozzle @ 670 Profile WN113-SEPRPDETIN_04.pfd Sweep 9, Xb -8.3--0.5 17___ /_ I \0.5 / /', 1.0 N. / ,/1.5 i -I I/ \ _2.0/-1----- -/ I \ t__121.0 122.0 123.0 124.0 125.0 126.0 127.0 128.0 129.0 130.0 131.0 Diablo Canyon Unit 2 Inlet Nozzle @ 113*Figure 7.4a: Measured Surface Profiles for the Diablo Canyon Unit 2 Reactor Vessel Nozzle to Safe End and Safe End to Pipe Welds -Inlet Nozzles (data from 2006 examinations) Page 38 of 68 WDF-19.1-2, Rev. 0 7qWESpyn1E AW4.trnghouse Etoct,, Company NUMBER & REV.Westinqhouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 Profile WN247-SERPPDETIN_04.pfd Sweep 1, Xb -0.0-0.5/ i7 1.0 //7__/ /_/1.5 2.0 /_i I _ /121.0 122.0 123.0 124.0 125.0 126.0 127.0 128.0 129.0 130.0 131.0 Diablo Canyon Unit 2 Inlet Nozzle @ 2470 Profile KN293-SEPRPDETIN_04.pfd Sweep 5, Xb -4.2'-0.5 20.i/ /1.0 / /1.5s/ / \\!2.0 /121.0 122.0 123.0 124.0 125.0 126.0 127.0 128.0 129.0 130.0 131.0 Diablo Canyon Unit 2 Inlet Nozzle @ 2930 Figure 7.4b: Measured Surface Profiles for the Diablo Canyon Unit 2 Reactor Vessel Nozzle to Safe End and Safe End to Pipe Welds -Inlet Nozzles (data from 2006 examinations) Page 39 of 68 WDF-19.1-2, Rev. 0 IWESDynNE NUMBER & REV.AWestirogho'use EectrCompany Westinghouse Non-Proprietary Class 3 IWDI-TJ-1044-NP, Rev. 1

8.0 CONCLUSION

S The following conclusions can be made from this work: 1. All of the flaws in both the Indian Point Units 2/3 and welded inlay equivalency mock-ups were detected with no change in procedure essential variables.

2. All of the flaws in both the Indian Point Units 2/3 and welded inlay equivalency mock-ups were length sized and through-wall sized consistent with the RMS error criteria in ASME Code Section XI, Appendix VIII, Supplements 2 and 10, and with no change in procedure essential variables.

3. Similar flaws in the PDI 601 Practice Sample (no welded protective layer) and the welded inlay equivalency mock-up (welded protective layer) were detected, length sized and through-wall depth sized and shown to be equivalent.

While an increase noise (and thus a decreased signal-to-nose ratio) was observed in the test data for ihe flaws in the welded inlay equivalency mock-up, there was no impact to flaw detection, flaw length sizing and flaw through-wall depth sizing.4. The flaws in the mock-ups were located in the dissimilar metal weld or in the safe end representative of the nozzle to safe end weld (Supplement 10 weld)condition and the safe end side of the safe end to piping weld (Supplement 2 weld) condition in Diablo Canyon Unit 2. Since the demonstrated flaw indication detection, length sizing and through-wall sizing capabilities using the PDI-qualified Supplement 14 procedure, PDI-ISI-254-SE, were maintained on these flaws, this procedure can be extended for use on the welded protective layer surfaces as present on the Diablo Canyon Unit 2 nozzle to safe end weld and the safe end.5. The transition from the nozzle onto the welded protective layer in the Diablo Canyon Unit 2 nozzles was not observed in the measured surface profiles. As such 100% examination volume coverage was obtained.6. The transition from the safe end onto the adjacent stainless steel safe end to piping weld in the Diablo Canyon Unit 2 nozzles was observed in the measured surface profiles. However such surfaces still allowed for essentially 100%(>90%) examination volume coverage.7. The inspection procedure, PDI-ISI-254-SE, requires no changes in essential variables for the qualification extension. Page 40 of 68 WDF-19.1-2, Rev. 0 I E f E R N T ,o 0 N NUMBER & REV.~ Westinghouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1

9.0 REFERENCES

9.1 Combustion

Engineering Inc. Drawing, E234-155: Nozzle Details, 173" ID PWR, Revision 3.9.2 Combustion Engineering Detail Welding Procedures: 9.2.1 GTAA-801-0 for welding of P8 to P8 materials, clad overlay, September 9, 1971.9.2.2 GTAA-901 -0 for welding of P8 to P43 materials, clad overlay, September 9, 1971.'9.2.3 GTAA-1 002-0 for welding of P43 to P43 materials, clad overlay, September 9, 1971.9.3 WesDyne International Field Service Inspection Procedure, PDI-ISI-254-SE: Remote In-service Examination of Reactor Vessel Nozzle to Safe End, Nozzle to Pipe, and Safe End to Pipe Welds, Revision 3.9.4 Performance Demonstration Initiative Program Specific Detail of Qualifications, PDQS No. 634, Procedure: PDI-ISI-254-SE, Revision 2, Addenda 0 -Remote In-service Examination of Reactor Vessel Nozzle to Safe End, Nozzle to Pipe, and Safe End to Pipe Welds.9.5 Performance Demonstration Initiative (PDI), Dissimilar Metal Weld Mock-Up Criteria, Revision A.9.6 Performance Demonstration Initiative (PDI), PDI-GL-002: Guideline for Ultrasonic Examination of Corrosion Resistant Cladding (CRC), Revision B, January 29, 2003.9.7 WesDyne International Report, Demonstration of Procedure Capabilities for Examination of Reactor Vessel Primary Loop Dissimilar and Similar Metal Piping Welds from the I.D. Surface -Indian Point Units 2 and 3, Revision 1, March 2006.9.8 WesDyne International Report, WDI-DFD-2009-QDP-001: Demonstration of Technique -Report Summary for Supplements 2 and 10 Flaw Comparisons Between EPRI Block 601 and the Inlay Test Block, Revision 0, December 2007.Page 41 of 68 WDF-19.1-2, Rev. 0 AWESDynE ENUMBER & REV.AWest.oghousolect~o Compay Westinghouse Non-Proprietary Class 3 IWDI-TJ-1044-NP, Rev. 1 9.9 EPRI Report, 1016543: Nondestructive Evaluation -Ultrasonic Equivalency Testing of Weld Inlaid and Weld Onlaid.Components, December 2008 [used with permission from PG&E].9.10 EPRI Report, 1016655: Nondestructive Evaluation -Ultrasonic Equivalency Testing of Weld Inlaid Components, April 2008 [used with permission from PG&E].9.11 EPRI Letter dated January 17, 2005, C. Latiolais (EPRI) to J. Munson (WesDyne International). 9.12 EPRI Letter dated July 30, 2009, Ronnie Swain (EPRI) to Steve Sabo (WesDyne International). 9.13 Combustion Engineering Inc. Drawing, E234-045-1: Nozzle Details for Westinghouse Electric Corp. 173" ID Reactor Vessel, Revision 1.9.14 FlawTech Drawing, RV73resoricl: Flawed Calibration Block, Nozzle to Safe-End to Elbow, IPP-RV-73, Revision 1.9.15 Personal communication between Carl Latiolais (EPRI) and Rick Rishel (WesDyne International). 9.16 American Society of Mechanical Engineers (ASME), Section Xl: Rules for In-Service Inspection of Nuclear Power Plant Components, 1989 Edition with No Addenda.9.17 Sonaspection Drawing, EPRI 2098601-1 AB: PDI DSMW Test Sample, 601/1 PWR Outlet Nozzle/Pipe As-Built, Revision 1.9.18 EPRI Excel 4 Spreadsheet, 601_1 noz to SE rev 2 08.08.02.9.19 WesDyne International Field Service Report, WDI-PJF-1303340-FSR-001: Diablo Canyon Nuclear Power Plant Unit 2 10 Year Reactor Vessel In-Service Examination, Outage 2R13, Period 3, Interval 2, 2006.9.20 Combustion Engineering Weld Procedure Assignment, A-245-725-8: Sheet for E-234-155 Nozzle Details, 173" ID PWR, Rev. 8.9.21 Westinghouse Electric, WCAP-14576: Aging Management Evaluation for Class 1 Piping and Associated Pressure Boundary Components, August 1996.4 Excel is a registered trademark of Microsoft Corporation. Page 42 of 68 WDF-19.1-2, Rev. 0 AWestinghouse Electric Company NUMBER & REV.Westinahouse Non-Proorietarv Class 3 WDI-TJ-1044-NP, Rev. 1 ATTACHMENT 1: Site Specific Demonstration Checklist Page 43 of 68 WDF-19.1-2, Rev. 0 AWEst yn Cn t N r ...A I .N A L AMestinghouse Electric Company FNUMBER & REV Westinghouse Non-Proprietary Class 3 IWDI-TJ-1044-NP, Rev. 1 Site Specific Demonstration Checklist for WDI-TJ-1 044, Rev. 1 DM Weld Requirement Paragraph Checker Initials /Mockup Reference in Date Criteria Demonstration [Ref. 9.5] Report/Technical Requirement Basis Document Reference§3.1 Personnel have current Supplement 10 §5.0 RDR PDI qualification for intended application 3/9/2010§3.2 Personnel performing Generic Letter 88- N/A 01 examinations have current Supplement 2 PDI qualification with IGSCC endorsement for intended application §4.1 Plant-specific mockups shall be required §1.0 Note 1 if the configuration being examined is not RDR included in the PDItest set or any of the 3/9/2010 conditions in §4.1.1 -§4.1.4 apply§4.2 Plant specific mockups meet the stated §4.0, Table 4.3 Note 2 requirements in §4.2.1 -§4.2.7 and §4.3 RDR-§4.6 3/9/2010§5.1 Technical basis document is prepared for .,: each site-specific mockup to document its applicability to qualified essential variables including: -" Drawing of site-specific mockup and §4.0, Figures 4.1 -RDR configuration of joint to be examined 4.2 and §1.0, 3/9/2010 Figures 1.1 -1.2" Documentation detailing actual §4.0, Tables 4.1 RDR attributes of flaw size distribution, and 4.2 and §4.0, 3/9/2010 placement and orientation of mockup Figures 4.1 and 4.2 flaws" Demonstrated coverage map §6.0, Figures 6.2 RDR and 6.3 3/9/2010" Full documentation of probes not N/A Note 3 previously demonstrated for use with RDR qualified procedure 3/9/2010§5.2 Exceptions to the qualified procedure are §7.3 Note 4 noted (probe angle, metal path focal RDR point, contouring, scan pattern) 3/9/2010§6.1 Licensee has ensured that examination personnel are familiar with data collection and analysis processes used in demonstration Qualification Sign-Off Sheet requirement Note 5 RDR 3/9/2010 Page 44 of 68 WDF-19.1-2, Rev. 0 AWestinghouse Electrc Company NUMBER & REV.Westinahouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 Site Specific Demonstration Checklist for WDI-TJ-1044, Rev. I DM Weld Requirement Paragraph Checker Initials /Mockup Reference in Date Criteria Demonstration [Ref. 9.5] Report/Technical Requirement Basis Document Reference§6.2 Plant specific demonstrations are §1.0 RDR conducted either blind or non-blind 3/9/2010§6.3 ANII witnessed the demonstration Not included Note 6 RDR 3/9/2010§6.4 Licensee Level III or its Level III Not included Note 6 representative witnessed demonstration RDR 3/9/2010§6.5 Changes to essential variables defined in §7.3 Note 7 qualified procedure are documented RDR 3/9/2010§7.1 Flaws are discernible in accordance with §7.1 RDR examination procedure 3/9/2010§7.2 ANII noted his review and acceptance of Qualification Sign- RDR modified procedure and the Technical Off Sheet 3/9/2010 Basis Document§8.0 -Limitations in coverage of examination §7.2 RDR volume are documented 3/9/2010§9.1 Demonstration report is prepared this document RDR detailing the procedure defined details including 3/9/2010 and for automated techniques, images of Attachments 2 and flaws are included 3§9.2 Demonstration report includes a drawing §4.0, Figures 4.1 -RDR and technical basis for the number and 4.3; 3/9/2010 location of flaws in the site-specific §4.0, Table 4.3;mockup(s) §4.5; §4.6§9.3 Licensee included specific examination Qualification Sign- RDR requirements in their site examination Off Sheet 3/9/2010 procedure requirement §9.4 Licensee maintains demonstration report Qualification Sign- RDR basis document for future reference Off Sheet 3/9/2010 requirement Note 1: Reference 9.5 §4.1.4 and Reference 9.6 §3.2 state that ASME Section Xl, Appendix III is applicable for examining welds with corrosion resistant cladding; Appendix III has no specific performance demonstration requirements. The ID surface welded protective layer associated with the Diablo Canyon Unit 2 nozzle-to-safe end welds and the safe end side of the safe end to piping welds can be classified as a corrosion Page 45 of 68 WDF-19.1-2, Rev. 0 C A Westinghouse Eleactn Company NUMBER & REV.Westinahouse Non-ProDrietarv Class 3 WDI-TJ-1044-NP. Rev. 1 Site Specific Demonstration Checklist for WDI-TJ-1044, Rev. I DM Weld Requirement Paragraph Checker Initials /Mockup Reference in Date Criteria Demonstration [Ref. 9.5] Report/Technical Requirement Basis Document Reference Note 2: Note 3: Note 4: Note 5: Note 6: Note 7: resistant cladding since it was intended to isolate a potentially sensitive material from the primary water environment. These welded protective layers were applied during the reactor vessel fabrication stage and are not considered structural weld inlays.Variations associated with materials of construction, geometry, physical limitations, geometric conditions, number of flaws, and flaw locations were noted. Justification is provided in §4.1 -§4.6 of this report.All search units have been previously demonstrated for use with the qualified procedure, PDI-ISI-254-SE. As such documentation is not included.There are no exceptions to the qualified procedure, PDI-ISI-254-SE. Requirement noted on Qualification Sign-off Sheet.The Diablo Canyon Unit 2 ANII and site Level III personnel were not present for these demonstrations. The Indian Point Units 2/3 demonstration was witnessed by the Indian Point Units 2/3 Level III and their ANII.The weld inlay equivalency demonstration was witnessed by EPRI PDI personnel. There are no changes to the essential variables in the qualified procedure, PDI-ISI-254-SE. Page 46 of 68 WDF-19.1-2, Rev. 0 AWestinghouse Electric Comparny NUMBER & REV.Westinahouse Non-Proorietarv Class 3 WDI-TJ-1044-NP. Rev. 1 Site Specific Demonstration Checklist for WDI-TJ-1 044, Rev. I Corrosion Requirement Paragraph Checker Initials /Resistant Reference in Date Cladding (CRC) Demonstration Qualification Report/Technical Criteria Basis Document[Ref. 9.6]Requirement Reference§4.1.1.1 Personnel have current PDI Supplement §5.0 RDR 2 IGSCC qualification for the task at 3/9/2010 hand; refracted longitudinal waves shall be utilized for examination of the CRC and personnel shall have demonstrated capability in their use.§4.1.2.1 Personnel have current PDI Supplement §5.0 RDR 10 qualification for the task at hand 3/9/2010 ,§4.2.1 The combination of personnel, procedure, §6.0 RDR and equipment shall demonstrate the 3/9/2010 capability to locate planar reflectors in the, CRC on a site-specific mock-up.§4.3 This guideline proposes no changes to §7.3 RDR any other factors in the examination 3/9/2010 process, such as the examination frequency, scanning directions, examination volume, acceptance criteria, etc.§5.1 Adequate records shall be maintained to This report RDR provide evidence of personnel, 3/9/2010 equipment, and procedure qualification. Demonstrated variations in the qualified procedure, caused by site-specific conditions, shall be documented. Page 47 of 68 WDF-19.1-2, Rev. 0 79w-aspyflE AWestmghourse Electric Company NUMBER & REV.Westinahouse Non-Prorxietarv Class 3 WDI-TJ-1044-NP, Rev. 1 ATTACHMENT 2: Images of Flaws (Indian Point Unit 2/3 Mock-up)Page 48 of 68 WDF-19.1-2, Rev. 0 AWestinghous. Electoc Company NUMBER & REV.Westincahouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 700 IN 70 0 OUT Attachment 2, Figure 1: Flaw 1 -Detection with 700 TRL Transducers Page 49 of 68 WDF-19.1-2, Rev. 0 AWestinghouse Electric Company NUMBER & REV.Westinclhouse Non-Provrietarv Class 3 WDI-TJ-1 044-NP. Rev. 1____ ____ _ __ ___ __ _ ____ _47.: 70°IN 700 OUT Attachment 2, Figure 2: Flaw 2 -Detection with 700 TRL Transducers Page 50 of 68 WDF-19.1-2, Rev. 0 FWESDyfnE AWostinghous. Elecic Company NUMBER & REV.Westinghouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 4.~ M.0% a I4 Tt 7.*.Jt 4.-b 7-'450 OUT 450 IN U F iq iw.,u. A"q-61V *4.L42 i,&S1 A..S2 9ý3 ft- l4.fO-14g%1"~% .1 ZVI 'I 7.WAI 0.81 Attachment 2, Figure 3: Flaw 1 -Sizing with 450 TRL Transducers Page 51 of 68 WDF-19.1-2, Rev. 0 9WESDynE A Westmnghous. Electric Company NUMBER & REV.Westinqhouse Non-Proprietary Class 3 WDI-TJ-1 044-NP, Rev. 1 42,93% MA 450IN.Paell 52of6 61M OWNa *O.J Ae913 S-01.9 M&2 &U3 Attachment 2, Figure 4: Flaw 2 -Sizing with 450 TRIL Transducers Page 52 of 68 VVDF-19.1-2, Rev. 0 Ai~estinghwose Electric Comnpany NUMBER & REV.Westinclhouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 ATTACHMENT 3: Images of Flaws (Weld Inlay Equivalency Mock-up)Page 53 of 68 WDF-19.1-2, Rev. 0 IWE.SDvn lE......... o ...AWestingbouso Electric Company NUMBER & REV.Westinqhouse Non-Proprietary Class 3 WDI-TJ-1 044-NP, Rev. 1 Attachment 3, Figure 1: All Flaws -Detection with 700 TRL Axial Beam Transducers Page 54 of 68 WDF-19.1-2, Rev. 0 79DpyflE AW.stmnghouse Electric Company NUMBER & REV.Westinahouse Non-Proorietary Class 3 WDI-TJ-1044-NP, Rev. 1 Attachment 3, Figure 2: Flaw I (-Q2, -Q3, -Q4, PDI 60111) -Detection with 700 TRL Axial Beam Transducers Page 55 of 68 WDF-19.1-2, Rev. 0 NqWESDyfl AWestinghous. Elecbor CornpanyV NUMBER & REV.Westinqhouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 t&343-OPlb 16.40 2b -0.12 AM 19.2 3WWp 351 AS 29 kft 23I Attachment 3, Figure 3: Flaw 2 (-Q2, -Q3, -Q4, PDI 601/1) -Detection with 700 TRL Axial Beam Transducers Page 56 of 68 WDF-19.1-2, Rev. 0 n WESDyflE........ ON..AC AWestmghoust Ekeotri Company NUMBER & REV.Westinahouse Non-Prolnrietarv Class 3 WDI-TJ-1 044-NP. Rev. 1 Westinnhouse Non-Propri arv Clas 3 IWDI-TJ-1 044-NP Rev. 1 Attachment 3, Figure 4: Flaw 3 (-Q2, -Q3, -Q4, PDI 601/1) -Detection with 700 TRL Circumferential Beam Transducers Page 57 of 68 WDF-19.1-2, Rev. 0 F-1WESD~fl AWestinghouse Elecnir Company NUMBER & REV.Westinahouse Non-Proorietarv Class 3 WDI-TJ-1044-NP, Rev. 1~~b ~ I8.W --- 158 -b. A~2.i 5w.2 Aci -2 Attachment 3, Figure 5: Flaw 12 (-Q2, -Q3, -Q4, PDI 601/1) -Detection with 70 TRL Axial Beam Transducers Page 58 of 68 WDF-19.1-2, Rev. 0 F971WES~nflE AWestirngbouse Electric Company NUMBER & REV.Westinchouse Non-Proprietary Class 3 IWDI-TJ-1044-NP, Rev. 1 Aa -QM A ,1 -"pl JAW __ __25M0 26.0 27. 211. 29.0 30.0 Prelte Correcked Yb Zb EFPJ INL&Y BLOCK INOD 1-03 Cu-rent 27.11 0.41 LENGTH- 1.75" Atcmn 3, Figure6: Flaw (-2 -3) -Sz27in gQ.4Z wi2 9.545 W L AIt 9T Attachment 3, Figure 6: Flaw I (-Q2, -Q3) -Sizing with 450 TRIL Axial Beam Transducer Page 59 of 68 WDF-19.1-2, Rev. 0 AWESDl nE AWestmnahous. Electico Company NUMBER & REV.Westinqhouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 28.0 29.5 30.0 EPRI INLAY BLOCK IND# 1-04 LENGTH- 1.625" I 5.0+7 I I'T 1.0 1 0.5 _ l -_2.0 18.6 iOim '*mZSý 9 fl n Aedw, 1 Wit k 1/\ I 4I L. 4 4--- -.....-4-.....16.0 kI/17.0 1.0\118.0 Yb Fh In"I 15.31 19.5 20.0 2 hoIS tit OrK lNo I I LI§NG111 1,875i'Attachment 3, Figure 7: Flaw I (-Q4, PDI 601/1) -Sizing with 450 TRL Axial Beam Transducer Page 60 of 68 WDF-19.1-2, Rev. 0 AWestinghouse Electric Company NUMBER & REV.Westinahouse Non-Pronrietarv Class 3 WDI-TJ-1044-NP. Rev. 1 JAMP 83.9 82 , MR 46.0 so Attachment 3, Figure 8: Flaw 2 (-Q2, -Q3) -Sizing with 450 TRL Axial Beam Transducer Page 61 of 68 WDF-19.1-2, Rev. 0 AWostinghous. Etectric Company NUMBER & REV.Westinlhouse Non-Proprietarv Class 3 WDI-TJ-1 044-NP, Rev. 1 0_7_ .I.E 1//I I-- -#---! --I 4 -IS./ /-- I -I--#-------4--4 44-R.0.0 26.I 14 I I2\.21.1 28.0/I 25 29.0 "1.8 Profile Cofetad~ Yb Zb Curmat 26.43 0.3?EPAI INLAY BLtOCK INDI M-4 LENGTH" 2.626" IcSZW*291 26&V3 Aa$41. $MOMp ~AsunI W40.Attachment 3, Figure 9: Flaw 2 (-Q4, PDI 601/1) -Sizing with 450 TRL Axial Beam Transducer Page 62 of 68 WDF-19.1-2, Rev. 0 AWostinghousa Electnc Company NUMBER & REV.Westinahouse Non-ProDrietarv Class 3 IWDI-TJ-1 044-NP, Rev. 1 I.AMP ARL 23.6 so b i7.24 Vb1O3W*A,0 p4foS O A"p~ Iaca33 2 MKItS Attachment 3, Figure 10: Flaw 3 (-Q2, -Q3) -Sizing with 600 TRL Circumferential Beam Transducer Page 63 of 68 WDF-19.1-2, Rev. 0 IWESDyrlE t N T s tn m p ' '

A ny Al~estinghouse Electric Companry NUMBER & REV.Westinghouse Non-Proprietary Class 3 WDI-TJ-1044-NP, Rev. 1 ,ds Z7.G ~4~Z94.WtO.33 91r922.4 SwO5p~. dcm945 WI.93 kiup UPI IS.I A Attachment 3, Figure 11: Flaw 3 (-Q4, PDI 601/1) -Sizing with 600 TRL Circumferential Beam Transducer Page 64 of 68 WDF-19.1-2, Rev. 0 Fq1,wPpyfl A Wosttnghouso Electrn Company f NUMBER & REV.Westinahouse Non-ProDrietarv Class 3 WDI-TJ-1 044-NP. Rev. 1 I Attachment 3, Figure 12: Flaw 12 (-Q2, -Q3) -Sizing with 450 TRL Axial Beam Transducer Page 65 of 68 WDF-19.1-2, Rev. 0

~WESDynlE , ON T .N A ,IO N *AWestighous. Electuic Company NUMBER & REV.Westinahouse Non-Proorietarv Class 3 WDI-TJ-1044-NP. Rev. 1 Attachment 3, Figure 13: Flaw 12 (-Q4, PDI 60111) -Sizing with 450 TRL Axial Beam Transducer Page 66 of 68 WDF-19.1-2, Rev. 0 A Westimghouse Eloctic Company NUMBER & REV.Westinlhouse Non-Proprietary Class 3 IWDI-TJ-1044-NP, Rev. 1 Attachment 3, Figure 14: Embedded Flaw (-Q4) -Sizing with 370 TRL Axial Beam Transducer Page 67 of 68 WDF-19.1-2, Rev. 0 AWESDynrE AWestinghouse Electrc Company NUMBER & REV.Westincghouse Non-Proprietary Class 3 WDI-TJ-1 044-NP. Rev. 1 I Attachment 3, Figure 15: Noise Comparison Between Weld Inlay Equivalency Test Mock-Up and Non-Overlaid 601/1 Practice Block -60° TRL Circumferential Beam Transducer Page 68 of 68 WDF-19.1-2, Rev. 0 Enclosure 4 PG&E Letter No. DCL-1 0-103 Westinghouse authorization letter, CAW-10-2851, Accompanying Affidavit, Proprietary Information Notice, and Copyright Notice 1

Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Westinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA Direct tel: (412) 374-4643 Direct fax: (412) 374-3846 e-mail: greshaja@westinghouse.com Proj letter PGE-10-33 CAW-10-2851 June 14, 2010 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

WDI-TJ-1044-P, Revision 1, "Demonstration Report/Technical Basis Document: Ultrasonic Examination of Diablo Canyon Unit 2 Reactor Pressure Vessel Nozzle to Safe End Welds from the ID Surface Through a Welded Protective Layer" (Proprietary) The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-10-2851 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations. Accordingly, this letter authorizes the utilization of the accompanying affidavit by Pacific Gas & Electric.Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-10-2851 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355. Very truly urs, J. A. Gresham, Manager Regulatory Compliance and Plant Licensing Enclosures CAW-10-2851 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA: ss COUNTY OF ALLEGHENY: Before me, the undersigned authority, personally appeared J. A. Gresham, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief: A. Gresham, Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed before me this 14th day of June 2010 Notary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Renee Giampole, Notary Public Penn Township, Westmoreland County My Commission Expires September 25, 2013 2 CAW- 10-2851 (1) 1 am Manager, Regulatory Compliance and Plant Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse. (2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit. (3) 1 have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information. (4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows: (a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of 3 CAW-10-2851 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.(f) It contains patentable ideas, for which patent protection may be desirable. There are sound policy reasons behind the Westinghouse system which include the following: (a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense. 4 CAW-10-2851 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390; it is to be received in confidence by the Commission.(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WDI-TJ- 1044-P, Revision 1, "Demonstration Report/Technical Basis Document: Ultrasonic Examination of Diablo Canyon Unit 2 Reactor Pressure Vessel Nozzle to Safe End Welds from the ID Surface Through a Welded Protective Layer" (Proprietary) dated June 1, 2010, for submittal to the Commission, being transmitted by Pacific Gas & Electric letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with justifying an in-service inspection approach on a unique weld configuration and may be used only for that purpose. 5 CAW-10-2851 This information is part of that which will enable Westinghouse to provide a uniquely qualified in-service inspection technology to our customers in order to address required examinations of reactor pressure vessel nozzle to safe end welds.Further this information has substantial commercial value as follows: (a) Westinghouse plans to sell the use of similar information to its customers for purpose ofjustifying a similar in-service inspection approach consistent with the unique weld configuration.(b) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse. Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar inspection technology and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information. The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.Further the deponent sayeth not. PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f)located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1). COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.}}

v t e Letter Sequence Request
TAC:ME4577, (Open)
Initiation Request, Request Acceptance Administration Withholding Request Acceptance Questions Answers Results Approval... Other:
MONTHYEAR2010-06-01 [Table View]

ML102350297: Difference between revisions