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{{Adams
#REDIRECT [[NL-10-0266, Proposed Alternative FNP-ISI-ALT-08]]
| number = ML100550139
| issue date = 02/23/2010
| title = Proposed Alternative FNP-ISI-ALT-08
| author name = Ajluni M J
| author affiliation = Southern Nuclear Operating Co, Inc
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000364
| license number =
| contact person =
| case reference number = NL-10-0266
| document type = Letter
| page count = 10
}}
 
=Text=
{{#Wiki_filter:Southern Nuclear Operating Company, Inc. 40 r,,1 105 500D SOUTHERN'\'
February 23, 2010 COMPANY Docket Nos.: 50-364 NL-10-0266 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant -Unit 2 Proposed Alternative FNP-ISI-ALT-08 Ladies and Gentlemen:
By letter to the U.S. Nuclear Regulatory Commission (NRC) dated April 22, 2009, Southern Nuclear Operating Company, Inc. (SNC), submitted request for relief FNP-ISI-AL T-08, Version 1.0. This alternative requested relief from certain examination qualification requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section XI. SNC proposed the use of alternate root mean square error (RMSE) values of 0.189 inch for Supplement 10, 0.367 inch for Supplement 2, and 0.245 inch Supplements 10 and 2 combined.
On February 1, 2010, SNC received a request for additional information letter from the NRC. This letter stated that it is the NRC staff's understanding that the Supplement 2 is not a stand-alone qualification and requested SNC discuss why FNP-ISI-AL T-08 provides an RMSE for Supplement 2 examinations.
Based on a review of recent industry practices, SNC agrees with the NRC staffs understanding that supplement 2 is not a stand-alone qualification.
OS has been revised to remove the request for an alternate RMSE value for Supplement 2 only. FNP-ISI-AL T-OS, Version 2 is enclosed for your review and approval.
Approval is requested by March 20,2010.
U. S. Nuclear Regulatory Commission Log: NL-10-0266 Page 2 Ttlis letter contains no NRC commitments.
If you have any questions, please advise. Sincerely, M. J. Ajluni Manager -Nuclear Licensing MJAIT AHllac
 
==Enclosures:==
 
Proposed Alternative FNP-ISI-AL T-08 Version 2.0, in Accordance with 10 CFR 50.55a(a)(3)(i) Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. J. R. Johnson, Vice President
-Farley Ms. P. M. Marino, Vice President
-Engineering RTYPE: CFA04.054 U. S. Nuclear Regulatory Mr. L. A. Reyes, Regional Mr. R. E. Martin, NRR Project Manager -Mr. E. L. Crowe, Senior Resident Inspector
-
Joseph M. Farley Nuclear Plant -Unit Proposed Alternative FNP-ISI-AL T
Proposed Alternative FNP-ISI-AL T -08 Version 2.0, in with 10 CFR Enclosure Plant Site-Unit:
Interval Dates: Requested Date for Approval:
ASME Code Components Affected:
Applicable Code Edition and Addenda: Applicable Code Requirements:
Proposed Alternative FNP-ISI-AL T -08 Version in Accordance with 10 CFR Joseph M. Farley Nuclear Plant (FNP) -Unit 2. 4th lSI Interval-December 1,2007 through November 30,2017. It should be noted that alternative FNP-ISI-AL T -01, Version 1.0 changed the Farley-2 lSI interval dates to coincide with the Farley-1 interval dates. This alternative was approved by NRC safety evaluation dated October 17, 2008. Approval is requested by March 20, 2010 to support scheduled examinations performed during FNP 2R20 (April 2010). The affected components are the Class 1, Category 8-F, Item 85.10, Reactor Pressure Vessel (RPV) nozzle to safe-end dissimilar metal (DSM) butt welds and the adjacent Category 8-J, Item 89.11, austenitic safe-end welds. Lists of welds are provided in Figures 1 and 2. The applicable Code edition and addenda is ASME Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," 2001 Edition through the 2003 addenda. In addition, as required by 10 CFR 50.55a, ASME Section XI, 2001 Edition is used for Appendix VIII, "Performance Demonstration for Ultrasonic Examination Systems." Examination Category 8-F, Item 85.10, "RPV nozzle to safe-end DSM butt welds" and Examination Category 8-J, Item 89.11, "austenitic safe-end welds" specify volumetric examination.
IWA-2232 requires that ultrasonic (UT) examinations be performed per Appendix I. Appendix I, 1-2220 requires that ultrasonic examination procedures, equipment, and personnel be qualified by performance demonstration in accordance with Appendix VIII. Instead of the Appendix VIII qualification requirements, Southern Nuclear Operating Company (SNC) is using NRC approved Code Case N-695, "Qualification Requirements for Dissimilar Metal Piping Welds" and NRC approved Code Case N-696, "Qualification Requirements for Appendix VIII Piping Examinations Conducted From the Inside Surface." Code Case N-695 provides an alternative to the Appendix VIII, Supplement 10 requirements for the qualification requirements of DSM welds. Paragraph 3.3(c) indicates examination procedures, equipment, and personnel are qualified for depth-sizing when the Root Mean Square (RMS) error of the flaw depth measurements, as compared with the true depths, does not exceed 0.125 inches. Code Case N-696 provides an alternative to the Appendix VIII, Supplement 2 and 10 qualification requirements for piping welds that are conducted from the inside surface. Paragraph 3.3(d) indicates examination procedures, E1 -1 Reason for Request: Proposed Alternative Enclosure Proposed Alternative FNP-ISI-AL T -08 Version in Accordance with 10 CFR equipment, and personnel are qualified for depth-sizing when the RMS error of the flaw depth measurements, as compared to the true depths, does not exceed 0.125 inches. This alternative is needed because: 1. To date, the examination vendor for Farley has not met the required root mean square error (RMSE) of 0.125 inches for depth sizing. 2. The examination vendor for the FNP reactor vessel nozzle examinations has qualified for detection of axial flaws in accordance with Appendix VIII. Supplements 10 and 2, as demonstrated through the Electric Power Research Institute (EPRI) Performance Demonstration Initiative (POI) Program. for DSM nozzle-to-safe-end and austenitic safe-end welds examined from the inside diameter (10) surface provided the surface is machined or ground smooth with no exposed root reinforcement or counter-bore.
However, surface roughness may be present that could call into question the UT qualifications demonstrated for detection of axial flaws. Note: The examination vendor has qualified for detection of circumferential flaws in accordance with Appendix VIII, Supplements 10 and 2, as demonstrated through the EPRI POI Program, for DSM nozzle-to-safe end and austenitic safe-end welds examined from the 10 surface. (1) Variation to 0.125 RMSE SNC proposes to use a RMSE of 0.189 inches instead of the 0.125 inches required for Supplement 10 and a RMSE of 0.245 inches instead of the 0.125 inches for Supplements 10 and 2 combined.
In the event an indication is detected that requires depth sizing, the difference between the required RMSE and the demonstrated RMSE will be added to the measured through-wall extent for comparison with applicable ASME Section XI acceptance criteria.
If the examination vendor demonstrates an improved depth sizing RMSE prior to the examination, the excess of that improved RMSE over the 0.125 inch RMSE requirement, if any, will be added to the measured value for comparison with applicable acceptance criteria.
(2) Inside Diameter UT Examinations Supplemented by Eddy-Current SNC proposes using surface geometry profiling software (profilometry) in conjunction with a focused immersion ultrasonic transducer positioned to permit accurate profile data across the examination volume, to help the examiner confirm locations where the raw data indicates lack of transducer contact due to problematic surface geometry.
Subsequently, eddy current examination will be used to supplement ultrasonic examination where there is sufficient surface roughness to call into question the applicability of the E1 -2 Basis for Use: Enclosure Proposed Alternative FNP-ISI-AL T -08 Version in Accordance with 10 CFR ultrasonic examination qualification to detect axial flaws. The ultrasonic examinations, supplemented by eddy current examinations and profilometry, will be conducted to the maximum extent practical and are subject to third party review by the Authorized Nuclear Inservice Inspector.
It is anticipated that all six DSM nozzle-to-safe-end welds and all six safe-end welds could be examined using this process. The following eddy current techniques will be utilized:
-Up to two plus point probes applied circumferentially on the inside surface in scan increments of 0.08 inches circumferentially (for axial flaws) and 0.25 inches axially. -Automated systems for data collection and analysis.
The target flaw size for the eddy current procedure is 0.28 inches long, well within the ASME Code linear flaw acceptance standards of 0.45 inches for austenitic material, and 0.625 inches for ferritic material (defined for the outside surface in the Code Tables). The examinations are scheduled to be performed during FNP 2R20 outage (April 2010). (1) Variation to 0.125 RMSE The proposed alternative assures that the DSM nozzle-to-safe-end welds and the subject austenitic safe-end welds will be fully examined by procedures, personnel and equipment qualified by demonstration in all aspects except depth sizing. In the event that an indication is detected that requires depth sizing, a process will be used where the difference between the required RMSE and vendor demonstrated RMSE will be added to the measured through-wall depth for comparison with the Section IWB-3500 acceptance criteria.
This process will assure that there is reasonable assurance of structural integrity and thus, will provide an acceptable level of quality and safety. Permission is requested to use this process in accordance with 10 CFR 50.55a(a)(3)(i).
(2) Inside Diameter UT Examinations Supplemented by Eddy-Current The eddy current technique was first used in the V. C. Summer reactor vessel primary nozzle examinations of 2000. The procedure was refined by applying it to the V. C. Summer hot leg dissimilar metal weld section removed from service. The removed section had a number of primary water stress corrosion cracking flaws along with non-relevant indications resulting from metallurgical interface and surface geometry.
Using these actual flaws and geometric conditions in the removed section to refine the technique, the vendor developed reliable flaw-screening criteria which allowed for the successful use of the procedure in the V. C. Summer 2002 and 2003 examinations.
E1 -3 Duration of Proposed Alternative:
Precedents:
Enclosure Proposed Alternative FN P-ISI-AL T -08 Version in Accordance with 10 CFR Subsequently, the technique was successfully blind tested for the Swedish authority SQC Kvalificeringscentrum AS (SQC NOT Qualification Center) under the program, "Qualification of Equipment, Procedure and Personnel for Detection, Characterization and Sizing of Defects in Areas in Nozzle to Safe End Welds at Ringhals Unit 3 and 4," Hakan Soderstrand 7-10-03. The important qualification parameters for eddy current in the SQC blind tests (Ref. SQC Qualification Report No. 019AN03) were as follows:
* Defect types: fatigue and stress corrosion cracks, surface initiated
* Tilt: +/-10 degrees; Skew: +/-10 degrees
* Detection target size: IDSCC 6mm (0.25 inches) long
* Flaw Location:
within 10mm (13/32 inch)
* Length of the planar flaw within a 70% confidence interval:
+/-(3/8 inch)
* False call rate: less than or equal to 20% for the personnel qualification tests As noted in the Precedents section below, Comanche Peak submitted and received approval for this technique.
The use of ultrasonic profilometry and eddy current examination, with procedures and personnel qualified through the SQC blind tests to supplement Appendix VIII qualified ultrasonic procedures and personnel, provides additional assurance that surface-breaking flaws (that may be present) will be detected in the presence of potential surface roughness.
This process will assure that there is reasonable assurance of structural integrity and thus, will provide an acceptable level of quality and safety. Permission is requested to use this process in accordance with 10 CFR 50.55a(a)(3)(i).
The proposed alternative is applicable for the 4th Inservice Inspection Interval for FNP Unit 2. Use of the combined qualification requirements for Supplements 2 and 10 prior to availability of Code Case N-696, and the concept of adding the difference between the required RMS error value and the demonstrated RMS error value to the measured indication depth, were separately approved for V.C. Summer Station by NRC letter dated February 3,2004. The proposed alternative was approved for profilometry and eddy current for the V. C. Summer Station by NRC letter dated November 21, 2006. This alternative is similar to and closely follows the content and statements made in the Comanche Peak Nuclear Power Plant request submitted initially in a letter to the NRC dated July 10, 2008 and approved by the staff in a letter dated September 18,2008. In addition, SNC updated the proposed alternative based on the NRC Safety Evaluations for the Donald C. Cook Plant E1 -
Enclosure Proposed Alternative FNP-ISI-AL T -08 Version 2.0 in Accordance with 10 CFR 50.55a(a)(3)(i) and the Seabrook Station.
 
==References:==
 
The referenced ADAMS numbers for the V. C. Summer Station are ML040340450 (2004 SER) and ML063070540 (2006 SER). The referenced ADAMS number for the Comanche Peak Nuclear Plant is ML082490050.
The referenced ADAMS numbers for the Donald C. Cook Plant and the Seabrook Station are ML083540071 and ML090850504, respectively.
Status: Awaiting NRC approval.
E1 -
FIGURE FARLEY-2INLET NOZZLE ....NOZZLE**f -2.8" "Potential" root \ ... ULTRASONIC EXAMINATION VOLUME and counterbore interferences APRI-4100-13, 4200-13, and 4300-13 \ APR 1-4100-14DM, 4200-14DM, and 4300-14DM E1 -
.. -4.4" \ \ FLOW .... t FIGURE FARLEY-2 OUTLET NOZZLE "Potential" root and counterbore interferences EXAMINATION APRI-4100-1 OM, 4200-1 OM, and 4300-1 OM APRI-41 00-2,4200-2, and 4300-2 E1 -}}

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