ML070680358

4.14.1: Inservice Inspection (ISI) Program, Evaluation of Aging Management Programs, 01/25/2006

ML070680358
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	01/25/2006
From:	Entergy Nuclear Vermont Yankee
To:	Office of Nuclear Reactor Regulation
References
LRPD-02, Rev 1
Download: ML070680358 (129)

Text

Vermont Yankee License Renewal Project Evaluation of Aging Management Programs 4J4.1: Inservice Inspection (Ism) Program

.1 LRPD-02 Revision 1 Page 158 of 275 VYNPS License Renewal Project Aging Management Program Evaluation Results lnservice Inspection (ISI) Program 4.1 4.1 lnservice Inspection (ISI) Program A. Proaram Descrbtion The VYNPS IS1 Program is a plant-specific program encompassing ASME Section XI Subsection IWA, IWB, IWC, IWD and IWF requirements.

The VYNPS IS1 Program is based on ASME Inspection Program B (IWA-2432), which has 1 0-year inspection intervals. Every 10 years the program is updated to the latest ASME Section XI code edition and addendum approved by the Nuclear Regulatory Commission in 1 OCFR50.55a.

On September 1, 2003 WNPS entered the fourth IS1 interval. The Code Edition and Addenda used for the fourth interval are the 1998 Edition with 2000 addenda. The current program ensures that the structural integrity of Class 1, 2, and 3 systems and associated supports is maintained at the level required by the Code of Federal Regulations, 1 OCFR50.55a. (Ref. Section 1.3, PP 7075) This program is credited in the following.

0 AMRC-01, Primary Containment AMRC-06, Bulk Commodities AMRM-31, Reactor Pressure Vessel AMRM-33, Reactor Coolant System Pressure Boundary B. Evaluation

1. Scope of Program The IS1 Program manages cracking, loss of material, and reduction of fracture toughness of reactor coolant system piping, components, and supports. The program implements applicable requirements of ASME Section XI, Subsections IWA, IWB, IWC, IWD and IWF, and other requirements specified in 1 OCFR50.55a with approved NRC alternatives and relief requests.

Every 10 years the IS1 Program is updated to the latest ASME Section XI code edition and addendum approved by the Nuclear Regulatory Commission in 1 OCFR50.55a. (Ref. Section 1, PP 7015) 1 . .I i 1 : 1 LR PD-02 Revision 1 Page 159 of 275 VYNPS License Renewal Project Aging Management Program Evaluation Results lnservice Inspection (61) Program ASME Section XI inspection requirements for Reactor Vessel Internals, (Subsection IWB, Categories B-N-1 and B-N-2) are not in the IS1 Program, but are included in the BWR Vessel lnternals Program. For more information on the BWR Vessel lnternals Program, see section 4.7 of this report.

2. Preventive Actions The Inservice Inspection Program is a condition monitoring program that does ',?. not include preventive actions.

3. Parameters MonitorecVlnspected The program uses nondestructive examination (NDE) techniques to detect and characterize flaws. Volumetric examinations such as radiographic, ultrasonic or eddy current examinations are used to locate surface and subsurface flaws.

Surface examinations, such as magnetic particle or dye penetrant testing, are used to locate surface flaws. Three levels of visual examinations are specified.

VT-1 visual examination is conducted to assess the condition of the surface of the part being examined, looking for cracks and symptoms of wear, corrosion, erosion or physical damage. It can be done with either direct visual observation or with remote examination using various optical and video devices.

VT-2 visual examination is conducted specifically to locate evidence of leakage from pressure retaining components (period pressure tests). While the system is under pressure for a leakage test, visual examinations are conducted to detect direct or indirect indication of leakage. VT-3 visual examination is conducted to determine general mechanical and structural condition of components and supports and to detect discontinuities and imperfections. (ff ef. ASME Section XI) 4. Detection of Aging Effects The IS1 Program manages cracking and loss of material, as applicable, for carbon steel, low alloy steel and stainless steelhickel based alloy subcomponents of the reactor pressure vessel using NDE techniques specified in ASME Section XI, Subsections IWB, IWC, and IWD examination categories (Ref. Attachment I, AMRM-31; Section 4, PP 7015; and Appendix C, Vermont Yankee IS1 Database) t 1 VYNPS License Renev Aging Management Program kvaiuanon lnservice Inspection (IS) Program The IS1 Program manages cracking, loss of material, and reduction of fracture toughness, as applicable, of reactor coolant system components using NDE techniques specified in ASME Section XI, Subsections IWB, IWC and IWD examination categories. (Ref. Attachment 1, AMRM-33; Section 4, PP 7015; and Appendix C, Vermont Yankee 1st Database)

No aging effects requiring management are identified for lubrite sliding supports.

However, the IS1 Program will confirm the absence of aging effects for the period of extended operation. (Ref. Attachment 1, AMRC-01) The IS1 Program manages loss of material for ASME Class 1, 2, and 3 steel piping supports and steel component supports, using NDE techniques specified in ASME Section XI, Subsection IWF examination categories. (Ref. Attachment 1, AMRC-01; Attachment 1, AMRC-06; Section 4, PP 7015; and Appendix C, Vermont Yankee 1st Database)

5. Monitoring and Trending Results are compared, as appropriate, to baseline data and other previous test results. If indications are accepted for continued use by analytical evaluation, the areas containing such flaws are monitored during successive inspection periods. (Ref. Section 4.5, PP 7015) IS1 results are recorded every operating cycle and provided to the NRC after each refueling outage via Owner's Activity Reports prepared by the IS1 Program Coordinator. These detailed reports include scope of inspection and significant inspection results. (Ref. Sections 3.1.8 and 6.3.3, PP 7015) IF. 6. Acceptance Criteria A preservice, or baseline, inspection of program components was performed prior to startup to assure freedom from defects greater than code-allowable.

This baseline data also provides a basis for evaluating subsequent inservice inspection results. Since plant startup, additional inspection criteria for Class 2 and 3 components have been imposed by 1 OCFR50.55a for which baseline and inservice data has also been obtained. Results of inservice inspections are compared, as appropriate, to baseline data, other previous test results, and acceptance criteria of the ASME Section XI, 1998 Edition, 2000 Addenda, for evaluation of any evidence of degradation. (Ref. Section 1.3, PP 7015) 7. Corrective Action If a flaw is discovered during an IS1 examination, an evaluation is conducted in accordance with articles IWA-3000, IWB-3000, IWC-3000, IWD-3000 or IWF-LRPD-02 Revision 1 Page 161 of 275 VYNPS License Renewal Project Aging Management Program Evaluation Results lnservice Inspection (IS) Program 3000 as appropriate.

If flaws exceed acceptance standards, such flaws are removed, repaired, or the component is replaced prior to its return to service. For Class 1, 2, and 3, repair and replacement is in conformance with IWA-4000.

Acceptance of flaws which exceed acceptance criteria may be accomplished through analytical evaluation without repair, removal or replacement of the flawed component if the evaluation meets the criteria specified in the applicable article of the code. (Ref. Section 4.5, PP 7015 and AP 0070) 8. Confirmation Process 0 B J 3 This attribute is discussed in Section 2.0, Background.

9. Administrative Controls This attribute is discussed in Section 2.0, Background.

10. Operating Experience C. D. Operating experience provides assurance that the program will be effective in managing effects of aging so that components crediting this program can perform their intended function consistent with the current licensing basis during the period of extended operation.

For more information on applicable operating experience, see VYNPS Report LRPD-05, "Operating Experience Review Results".

References AMRC-01, Aging Management Review of the Primary Containment AMRC-06, Aging Management Review of Bulk Commodities AMRM-31, Aging Management Review of the Reactor Pressure Vessel AMRM-33, Aging Management Review of the Reactor Coolant System Pressure Boundary AP 0070, Rev. 03, LPC 00, ASME Section XI Repair and Replacement Procedure PP 7015, Rev. 05, LPC 00, Vermont Yankee lnservice Inspection Program Vermont Yankee IS1 Database Summa& The Inservice Inspection Program provides reasonable assurance that effects of aging will be managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

Vermont Yankee Nuclear Power Station License Renewal Application Technical Information components (primary containment) and their integral attachments in accordance with the requirements of lOCFR50.55a(b)(2) and the 1998 Edition of ASME Section XI with 2000 Addenda, Inspection Program B. The primary inspection method for the primary containment and its integral attachments is visual examination. Visual examinations are performed either directly or remotely with sufficient illumination and resolution suitable for the local environment to assess general conditions that may affect either the containment structural integrity or leak tightness of the pressure retaining component.

The program includes augmented ultrasonic exams to measure wall thickness of the containment drywell shell. A.2.1 .17 Inservice Inspection-Inservice Inspection (ISI) Program The WNPS lnservice Inspection (ISI) Program is based on ASME Inspection Program B (IWA-2432), which has 10-year inspection intervals. Every 10 years the program is updated to the latest ASME Section XI code edition and addendum approved by the Nuclear Regulatory Commission in 1 OCFR50.55a.

On September 1, 2003 WNPS entered the fourth IS1 interval.

The Code Edition and Addenda used for the fourth interval is the 1998 Edition with 2000 addenda. The program consists of periodic volumetric, surface, and visual examination of components and their supports for assessment, signs of degradation, flaw evaluation and corrective actions. A.2.1.18 Instrument Air Quality Program The Instrument Air Quality Program ensures that instrument air supplied to components is maintained free of water and significant contaminants, thereby preserving an environment that is not conducive to loss of material. Dewpoint, particulate contamination, and hydrocarbon concentration are periodically checked to verify the instrument air quality is maintained.

A.2.1 .I9 Non-EQ Inaccessible Medium-Voltage Cable Program In the Non-EQ Inaccessible Medium-Voltage Cable Program, in-scope medium-voltage cables, not designed for, but exposed to significant moisture and voltage are tested at least once every ten years to provide an indication of the condition of the conductor insulation. The specific test performed is a proven test for detecting deterioration of the insulation system due to wetting, such as power factor, partial discharge, polarization index, or other testing that is state-of-the-art at the time the test is performed. Significant moisture is defined as periodic exposures that last more than a few days.

Significant voltage exposure is defined as being subjected to system voltage for more than 25% of the time. Appendix A Updated Final Safety Analysis Report Supplement Page A-I6 Vermont Yankee Power Station License Renewal Application Technical Information ultrasonic examination revealed no material loss. Also, visual inspection of drywell head exterior surface revealed areas of localized missing coating and primer with light corrosion, but no material loss. Resolution of these issues prior to loss of component intended function provides evidence that the program is effective at managing aging effects for primary containment and its integral attachments.

RFO 24 visual inspections of drywell interior surfaces, stabilizer assembly interior surfaces, torus penetrations, and drywell penetrations revealed areas of localized missing coating where the primer is intact, but no corrosion or material loss. Visual inspection of new drywell moisture barrier resulted in no recordable indications.

Absence of aging effects on these components provides evidence that the program is effective at managing aging effects for primary containment and its integral attachments.

QA surveillance during RFO 24 revealed a problem with program administrative controls. The issue was addressed and closed. The program was revised to require that engineering evaluations of indications that do not meet acceptance criteria be completed before the containment is declared operable. QA surveillance revealed an issue that could impact effectiveness of the program. Resolution of this issue provides evidence that the program remains effective at managing aging effects for primary containment and its integral attachments.

A recent engineering system health report revealed no issues or findings that could impact effectiveness of the program. Conclusioq The CII Program has been effective at managing aging effects.

The CI1 Program provides reasonable assurance that effects of aging will be managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

B.1.15.2 Inservice Inspection Proaram DescriDtioq The VYNPS Inservice Inspection (ISI) Program is a plant-specific program encompassing ASME Section XI Subsection IWA, IWB, IWC, IWD and IWF requirements.

The WNPS IS1 Program is based on ASME Inspection Program B (IWA-2432), which has 10- year inspection intervals. Every 10 years the program is updated to the latest ASME Section XI code edition and addendum approved by the Nuclear Regulatory Commission in 1 OCFR50.55a.

On September 1, 2003 WNPS entered the fourth IS1 interval.

The Code Edition and Addenda used for the fourth interval is the 1998 Edition with 2000 addenda. The current program ensures Appendix B Aging Management Programs and Activities Page B-55 E Vermont Yankee Nuclear Power Station License Renewal Application Technical Information that the structural integrity of Class 1, 2, and 3 systems and associated supports is maintained at the level required by the Code of Federal Regulations, 1 OCFR50.55a.

Evaluation

1. Scope of Program The lnservice Inspection Program manages cracking, loss of material, and reduction of fracture toughness of reactor coolant system piping, components, and supports. The program implements applicable requirements of ASME Section XI, Subsections IWA, IWB, IWC, IWD and IWF, and other requirements specified in 10CFR50.55a with approved NRC alternatives and relief requests.

Every 10 years the Inservice Inspection Program is updated to the latest ASME Section XI code edition and addendum approved by the Nuclear Regulatory Commission in 1 OCFR50.55a.

ASME Section XI inspection requirements for Reactor Vessel Internals, (Subsection IWB, Categories B-N-1 and B-N-2) are not in the IS1 Program, but are included in the BWR Vessel lnternals Program. For more information on the BWR Vessel lnternals Program, see Section B.1.7 of this report.

2. Preventive Actions The lnservice Inspection Program is a condition monitoring program that does not include preventive actions.

3. Parameters Monitored/lnspected The program uses nondestructive examination (NDE) techniques to detect and characterize flaws. Volumetric examinations such as radiographic, ultrasonic or eddy current examinations are used to locate surface and subsurface flaws. Surface examinations, such as magnetic particle or dye penetrant testing, are used to locate surface flaws. Three levels of visual examinations are specified.

VT-1 visual examination is conducted to assess the condition of the surface of the part being examined, looking for cracks and symptoms of wear, corrosion, erosion or physical damage. It can be done with either direct visual observation or with remote examination using various optical and video devices.

VT-2 visual examination is conducted specifically to locate evidence of leakage from pressure retaining components (period pressure tests).

While the system is under pressure for a leakage test, visual examinations are conducted to detect direct or indirect indication of leakage. VT-3 visual examination is conducted to determine general mechanical and structural condition of components and supports and to detect discontinuities and imperfections.

Appendix B Aging Management Programs and Activities Page B-56 m a Vermont Yankee Power Station License Renewal Application Technical Information ~ ~ 4. Detection of Aging Effects The lnservice Inspection Program manages cracking and loss of material, as applicable, for carbon steel, low alloy steel and stainless steelhickel based alloy subcomponents of the reactor pressure vessel using NDE techniques specified in ASME Section XI, Subsection IWB examination categories.

The lnservice Inspection Program manages cracking, loss of preload, loss of material, and reduction of fracture toughness, as applicable, of reactor coolant system components using NDE techniques specified in ASME Section XI, Subsections IWB, IWC and IWD examination categories.

No aging effects requiring management are identified for lubrite sliding supports.

However, the IS1 Program will confirm the absence of aging effects for the period of extended operation.

The lnservice Inspection Program manages loss of material for ASME Class 1, 2, and 3 steel piping supports and steel component supports within containment, using NDE techniques specified in ASME Section XI, Subsection IWF examination categories.

5. Monitoring and Trending Results are compared, as appropriate, to baseline data and, other previous test results. If indications are accepted for continued use by analytical evaluation, the areas containing such flaws are monitored during successive inspection periods. IS1 results are recorded every operating cycle and provided to the NRC after each refueling outage via Owner's Activity Reports prepared by the 1st Program Coordinator.

These detailed reports include scope of inspection and significant inspection results.

6. Acceptance Criteria A preservice, or baseline, inspection of program components was performed prior to startup to assure freedom from defects greater than code-allowable.

This baseline data also provides a basis for evaluating subsequent inspection results.

Since plant startup, additional inspection criteria for Class 2 and 3 components have been imposed by the Code of Federal Regulations, 1 OCFR50.55a for which baseline data has also been obtained. Results are compared, as appropriate, to baseline data, other previous test results, and acceptance criteria of the ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda, for evaluation of any evidence of degradation.

Appendix B Aging Management Programs and Activities Page 8-57 Vermont Yankee Nuclear Power Station License Renewal Application Technical Information

7. Corrective Actions If a flaw is discovered during an IS1 examination, an evaluation is conducted in accordance with articles IWA-3000, IWB-3000, IWC-3000, IWD-3000 or IWF-3000.

If flaws exceed acceptance standards, such flaws are removed, repaired or the component is replaced prior to its return to service. For Class I, 2, and 3, respectively, repair and replacement is in conformance with IWA-4000. Acceptance of flaws which exceed acceptance criteria may be accomplished through analytical evaluation without repair, removal or replacement of the flawed component if the evaluation meets the criteria specified in the applicable article of the code. 8. Confirmation Process This attribute is discussed in Section 9.0.3. 9. Administrative Controls 1 This attribute is discussed in Section 9.0.3. IO. Operating Experience I Pressure boundary components, including bolting, are evaluated using non- destructive examinations and visual inspections. Deviations from acceptance criteria are properly resolved. Inspections since 2001 revealed erosion of valve body internals, weld indications, recirculation pump bolting corrosion and RHR valve bolting corrosion.

The scope of welding inspections was expanded when rejectable indications were identified. Condition reports were used to document indications and ensured resolution of those conditions. Corrective actions included repair and replacement of components. These actions provide evidence that the program is effective at managing aging effects for applicable components.

QA audits, QA surveillances, engineering system health reports, and NRC inspections from 2001 to 2004 revealed no issues or findings that could impact effectiveness of the program. Conclusion The IS1 Program has been effective at managing aging effects. The IS1 Program provides reasonable assurance that effects of aging will be managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

Appendix B Aging Management Programs and Activities Page B-58 VYNPS License Renewal Project Operating Experience Review Results The results of OE reviews described in Section 2.0 are as follows. Item FAC Program Inspection

Records for 2002 Refueling Outage, VYM 2002- 010 Qua I i t y Assurance Surveillance Report 99- 01 6 self- Assessment VYM-SA- 2002-03 QA-8-2004-VY-1 ~ Issue Recent inspections (RFO 23) revealed that repairs or replacements were not necessary. Turbine cross- around piping inspections found that 1995 repairs mitigated the rate of erosion and that wall thickness is acceptable.

QA surveillance confirmed that the program was being implemented in accordance with industry guidelines and NRC expectations defined in Generic Letter 89-08. Program implementation was determined to be technically strong, with knowledgeable individuals involved in the program. A 2002 assessment of programmatic weaknesses identified at Davis- Besse resulted in two minor procedure changes and enhancement of one oversight activity.

QA audit confirmed that changes in tem peratu re, pressure, and velocity due to extended power uprate will have minimal impact on the FAC program and that no additional systems would need to be added to the scope of inspections.

LRPD-05 Revision 0 Paae 43 of I OE Evaluation Absence of loss of material due to flow- accelerated corrosion provides evidence that the program is effective for managing loss of material for carbon steel lines containing high-energy fluids. Also, past repairs, replacements, and modifications have been effective in mitigating FAC. QA surveillance revealed no issues or findings that could impact effectiveness of the program. Assessment of programmatic weaknesses identified at Davis-Besse revealed no significant issues or findings relative to effectiveness of the program. QA audit revealed no issues or findings that could impact effectiveness of the program. Section 4.4.14 presents conclusions regarding the effectiveness of this program for managing aging effects. 3.4.1 5. Inservice Inspection Program The VYNPS lnservice Inspection (ISI) Program encompasses ASME Section XI Subsection IWB, IWC, IWD and IWF requirements.

It is a condition monitoring program that ensures that the structural integrity of ASME Code Class 1, 2, and 3 components and their integral attachments and Class 1, 2, 3 and MC component supports is maintained at the level required WNPS License Renewal Project Operating Experience Review Results by the Code of Federal Regulations, 10CFR50.55a.

The attributes of this program are described in LRPD-02 (Ref. 5.17). LRPD-05 Revision 0 Page 44 of 122 The results of OE reviews described in Section 2.0 are as follows. Search CR-VTY- 2004-01 340 and TE 2004-045 Bolting Inspection Results RFO 22, May 2001 Bolting Inspection Results RFO 23, September 2002 Quality Assurance Audit 2001- 06B I I 1 (PT) examination results that failed to meet acceptance criteria. The scope of inspections was expanded and rejectable indications were repaired per the program criteria. Reactor recirculation pump cover to case bolting was found to have missing coating and corrosion.

Evaluation determined that the general surface corrosion resulted in minimal loss of material that did not impact the ability of the bolting to perform its intended function. Corrosion found OR residual heat removal system valve, V10-27A, bolting. Evaluation determined no loss of material had occurred.

QA audit concluded the program meets the requirements of IO CFR 50.55a and has been effectively implemented.

QA audit revealed no issues or findings that could impact effectiveness of the program.

Keyword Search CR-VTY- 2001 -00939 Item I Issue IS1 inspections during RFO 22 revealed erosion of valve body internals. Valve was repaired and scheduled for replacement during RFO 23. The subject valve in both safety trains was replaced during RFO 23. CRs document rejectable weld indications found during RFO 24 IS1 Program VT inspections.

The scope of VT inspections was expanded and all rejectable indications were Keyword Search CR-VTY- 2004-01 160 I repaired.

I CRs document IS1 penetrant testing Keyword I OE Evaluation I Repair and replacement of flawed valves provide evidence that the program is effective for managing aging effects for applicable corn ponen ts.

Scope expansion and repair of flawed welds provide evidence that the program is effective for managing aging effects for applicable components.

Scope expansion and repair of flawed welds provide evidence of program effectiveness in managing aging effects for applicable com pon e n ts . Evaluation of loss of material regarding bolting provides evidence that the program is effective at managing aging effects for applicable components.

Evaluation of loss of material on pressure boundary components provides evidence that the program is effective at managing aging effects for applicable components.

WNPS License Renewal Project Operating Experience Review Results Item QA Surveillances 41 C, and QS- Program Owner Interview Result: IS1 Program VYS R-2002- 2004-VY-079 LRPD-05 Revision 0 Page 45 of 122 Program Owner In tewiew Result: IS1 i Program Engineering Program Health Re port: Inservice Inspection Program Issue During RFO 23, QA surveillances confirmed personnel qualifications, test equipment, testing methods, and documentation are consistent with Droaram. QA performs audits and surveillances of the program almost every cycle - no significant findings have been identified.

QA audit and surveillances are positive. (e.g., Audit Report AR- NRC monitors IS1 Program each outage. NRC has not had findings in past 2 inspections, e.g., NW-04-075.

2003-22).

Program status in 1 st quarter of 2004 was "Green" indicating site compliance with program objectives.

OE Evaluation QA surveillances revealed no issues or findings that could impact effectiveness of the program. QA audits and surveillances revealed no issues or findings that could impact effectiveness of the program. NRC inspections revealed no issues or findings that could impact effectiveness of the program. Engineering program health report revealed no issues or findings that could impact effectiveness of the program. Section 4.4.1 5 presents conclusions regarding the effectiveness of this program for managing aging effects. 3.4.16. Containment Inservice Inspection Program The VYNPS Containment lnsewice Inspection Program is a plant specific condition monitoring program encompassing the requirements of ASME Section XI Subsection IWE. The program implements the requirements of Code of Federal Regulations I OCFR50.55a pertaining to inspection and testing of the primary containment.

The attributes of this program are described in LRPD-02 (Ref. 5.17). 1 3 I I The results of OE reviews described in Section 2.0 are as follows.

WNPS License Renewal Project Operating Experience Review Results 4.4.14. Flow-Accelerated Corrosion Program L RP 0-0 5 Revision 0 Page 72 of 122 Recent inspection results (RFO 23) revealed that repairs or replacements were not necessary. Turbine cross-around piping inspections found that 1995 repairs mitigated the rate of erosion and that wall thickness is acceptable.

Absence of loss of material due to flow-accelerated corrosion provides evidence that the program is effective for managing loss of material for carbon steel lines containing high-energy fluids.

Also, past repairs, replacements, and modifications have been effective in mitigating FAC. QA surveillances and self-assessments from 1999 to 2004 revealed no issues or findings that could impact effectiveness of the program. The Flow Accelerated Corrosion Program has been effective at managing aging effects. The Flow Accelerated Corrosion Program provides reasonable assurance that the effects of aging will be managed such that the applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

4.4.15. Inservice Inspection Program Pressure boundary components, including bolting, are evaluated using non-destructive examinations and visual inspections, Deviations from acceptance criteria are properly resolved.

Inspections since 2001 revealed erosion of valve body internals, weld indications, recirculation pump bolting corrosion and RHR valve bolting corrosion. The scope of welding inspections was expanded when rejectable indications were identified. Condition reports were used to document indications and ensured resolution of those conditions. Corrective actions included repair and replacement of components.

These actions provide evidence that the program is effective at managing aging effects for applicable components.

QA audits, QA surveillances, engineering system health reports, and NRC inspections from 2001 to 2004 revealed no issues or findings that could impact effectiveness of the program. The lnservice Inspection Program has been effective at managing aging effects. The Inservice Inspection Program provides reasonable assurance that the effects of aging will be managed such that the applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

4.4.16. Containment lnservice Inspection Program RFO 21 inspections found only two areas of potential age-related degradation; the drywell floor to metal containment moisture barrier had missing paint, cracked paint, and areas of corrosion on the base metal in the seal area; and corrosion was found in the area of the X-5G penetration.

Engineering evaluation was performed and no significant wall loss was identified.

Base metal was prepared, primed and painted to protect it from further corrosion, and the moisture barrier was replaced.

RFO 22 inspections found two more areas of potential age-related degradation; surface pitting of primary containment vent headers and vent pipe bowls; and corrosion on torus penetrations X-207A-H. Evaluation determined that the components have significant margin to code minimum wall thickness and that the rate of corrosion is low due to the inerted containment environment during operation.

Augmented inspections were not necessary since 1 .1 : ,1 LPC Effective No. Date . r{ VERMONT YANKEE NUCEAR POWER STATION Affected Pages REVISION 3 ASME SECTION XI REPAIR AND REPLACEMENT PROCEDURE USE CLASSIFICATION:

INFORMGTXON 1 1 Implementation Statement:

N/A I Issue Date: 09/01/2003 AP 0070 Rev. 3 Page 1 of 10 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0 TABLE OF CONTENTS PURPOSE, SCOPE, ANI) DISCUSSXON

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3 DEFINITIONS

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4 PRIMARY RESPONSIBILITIES

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5 PROCEDURE

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6 4.1. Work Package P=pmtion ...................................................................................................

6 4.2. 4.3. 4.4. RRPC Work Package Review ..............................................................................................

7 RepakRep1acement Work Package Implementation

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7 RRPC Oversight Responsibilities

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7 4.5. Reporti.ng

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8 REFERENCES AND COMMiTMJWTS

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8 mAL CoFWTIom ..........................................

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9 . 9 - ...........................................*...............*.*.................................*.......................

QA WEQLXRE- XNTS CROSS REF'EmNCE

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10 I I! 1 I I C, I f AP 0070 Rev. 3 Page 2 of 10 1.0 PURPOSE, SCOPE, ANT) DISCUSSION

1.1. Purpose

The purpose of this procedure is to implement the ASME Boiler & Pressure Vessel Code,Section XI Repair and Replacement requirements at Vermont Yankee. 1.2. Scope This procedure provides the process for Vermont Yankee (VY) to satisfy the Section XI mles and requirements for repWreplacements to pressure retaining components and their supports, including appurtenances and subassemblies or parts of component and core support structures.

Definition of the process for the development, implementation and documentation of repair and replacement activities is also provided. The procedure delineates the interfaces for departments involved in the process. . I. >, 1.3. Discussion ASME Section XI Code requirements specify that a documented repair and replacement program shall be provided and replacemenk of ASME Class 1,2 and 3 pressure boundaries of pressure retaining ts including their supports, subassemblies and parts. This procedure provides for ASME Class 1,2 and 3 Repair and Replacement criteria that satisfy the requirements of AS repairs/replacemen NRC and the Authorized Nuclear Inspector (ANI). All process procedures with the potential to involve ASME Section XI work shall include a reference to this procedure which will ensure that those responsible individuals involved in the preparation, review and approval of work packages include the required elements and obtain Repair Replacement Program Coordinator (RRPC) review and approval.

ection XI, IWA 41 1001) 1998 Edition through the 2000 Addenda, and ified by lOCFR'50.55a.-

This procedure is subject to review by the Components that are exempt from the requirements of ASME Section XT are identified in Appendix A. Appendix C shall be used to assist with the applicabiIity of Section XI Repair/Replacement Activities.

Appendix D shall be used to assist with the applicability of components that are outside the ASME Class 1,2 and 3 pressure boundaries but are considered safety cIass by AI? 6006. In accordance with AP 6002, Preparing 50.59 Evaluations, an Applicability Determination (AD) has determined that an AD is not reqW for future changes provided that the intent and type of activities associated with this procedure remain unchanged.

The basis *or this conclusion is that this document is a managerial and an administrative monitoring process, subject to 10CFR50.55a and 10CFRSO Appendix B, that does not alter the design, performance requirements, operation, or control of Systems, Structures, or Components (SSCs). AP 0070 Rev. 3 Page 3 of 10 2.0 I I *.l- I 2-2. 2.3. 2.4. 2.5. -c. I?,' ! 2.8. I 2 2.10. 2.11. 2.12. 2.13. I DEFINITIONS Additional definitions contained in IWA 9000 of Section XI. Authorized Nuclear hswtor (ANI) : An employee of an authorized inspection agency who has been qualified in accordance with NCA-5000 of Section III Construction Code: Nationally recognized codes, standards, and specifications (e.g. ASME, ASTM, ANSI) including designated cases, providing construction requirements for an item. Construction Specification:

The specifications written for the fabricatiodconstruction of a plant component andor plant systems. Maintenance:

Act,. that are routine in nature and are intended to either ensure, prolong or maintain the t mice life or operability of components or systems. i -- 0 c ally ut;"7PA struction.

d Constructio-

'- e: The codes and standards that plant systems and components were - . The document that originates the work activity such as an Engineering 3DCR), VY Design Change (VYDC), Temporary Modification 0, I t I 1 ~qut - -1IC &L d'.i- *-Gi - ,'*. :L' or Work Order (WO) etc. AS of evaluating and justifying use of alternate construction code :equirements.

., 7 -:- Remx: The process of restoring a nonconforming item by welding, brazing, or metal removal such that existing design requirements are met. - Rc- ,$Replacement Plan: The document(s) that define the essential elements for the completion of a .epu +eplacement effort. L L I f ReuairmeDlacement Activity:

An activity that includes welding, brazing, defect removal, and .- removing, adding, and modifving items or system. RemidReplacement Prom Coordinator (RRPC]: A person assigned to maintain and implement the ASME Section XI RepaidReplacement program at VY. , ReuaidReulacement Ormnkation: The organization that perfoms repair/replacement activities under the provisions of the owner's quality assurance program. The owner may be the repaidreplacement organization.

Replacement:

Installation of spare and renewal components, appurtenances, and subassemblies or parts of a component or system. Replacement may also include the addition of components, such as valves, and system changes, such as rerouting of piping. AP 0070 Rev. 3 Page 4 of 10 2.14. 3.0 3.1. I I Work Package:

The complete set of documentation required to implement a work activity.

The package may include the Originating Document, Installation and Test Procedures, Equivalency Evaluations, etc. PlRTMARY RESPONSIBILITIES The RRPC: Meet the expectations of the R&R Program Owner, as described in AP 0098, Appendix A. Reviews all work packages (electronic andor original) associated with ASME Section XI RepaidReplacement activities to verify that the required elements have been incorporated.

Maintains cognizance of ongoing and upcoming work activities to ensure that work packages have been adequately reviewed.

This may include periodic oversight of work planning efforts and review of the various modification indices. Maintains a log of all ASME Section XI work and a fib of ASME Section XI Repair and Replacement Traveler Sheets. Evaluates the suitability of the applicable Welding Procedure(s) to be used to make the repair or replacement.

Evaluates the applicability of the VY ISI, IST and Pressure Test Programs to the Repair/Replacement Activity.

Prepares NTS 2 form and reports. Reconciles RepairReplacement Log on a quarterly basis. Communicate with the IS1 Coordinator when IS1 Program components are affected by .- repair/repIacement activities.

.- Ap 0070 Rev. 3 Page 5 of 10 3.2. 3.3. 4.0 4.1. The Wginator (Planner or other technical individual):

e Determines if ASME Section M Repair and Replacement requirements are applicable.

e Prepares the work package including examination and tests. e Verifies use of original or alternate construction codes.

If alternate construction code is used, verify that the RepairReplacement approach and materials have been reconciled to applicable requirements by Engineering.

e Forwards the completed work packages to the RRPC for review/approval.

Engineering (Point of Contact Fluid Engineering Supervisor) 0 Identify alternate construction codes as required.

e Perform reconciliation evaluations as required by the defined work scope and ASME Section XI. PROclEDURE Work Package Preparation 4.1.1. The Planner or other technical individual (originator) involved in the potential repaidreplacement Work Package preparation activity shall: 4.1.1.1. Using Appendix A, C and D, determine if the work scope is applicable to ASME Section XI and if RepaXXeplacement requirements are applicable.

4.1.1.2. If the work scope is a Section XI RepairReplacement activity, perform the following steps. 4.1.1.2.1.

Notify the RRPC of the potential development of a RepairReplacement Work Package. Notification may be made electronically and should include a VY work document number (as applicable).

4.1.1.2.2.

Complete Section A of the RepairReplacement Traveler Sheet (VYAPF 0070.01).

4.1.1.2.3.

Subrnit the completed RepaidRepIacement Traveler Sheet and the Work Package to the RRPC for review and approval.

4.1.1.3. If the Work Package is revised after review by the RRPC, the package must be rerouted for review prior to start of work. Review shall be per step 4.2. 4.1.1.4. The Originator shall notify the ANI of the pending ASME RepairReplacement Work (notification may be electronically).

I ! .- AP 0070 Rev. 3 Page 6 of 10

i. i '1 4.2. RRPC Work Package Review 4.2.1. The RRPC shall: 4.2.1.1. Review the RepairlReplacement Work Package and confirm that all the required elements in the Repairfieplacement Traveler Sheet, VYAPF 0070.01, are appropriately addressed in accordance with ASME Section XI. Identify necessary changes or additions, and provide comments as warranted.

Assess applicability of the Work Package to the VY ISI, IST and Pressure Test programs.

If applicable, notify the ISI andor IST Coordinators of the Work Package being issued. 4.2.1.2. 4.2,1.3. If changes, additions or comments to the RepairAZepiacement Work Package are required, complete section B of the RepairlReplacement Traveler Sheet (VYAPF 0070.01) and return the Work Package to the originator for disposition.

4.2.1.4. If the Work Package is acceptable, complete Section B of the Repair/Replacement Traveler Sheet. Sign and return the Work Package with the RepaidEteplacernent Traveler Sheet to the originator for implementation.

4.2.1.5. Update the Repair and Replacement Log (VYAPF 0070.02).

4.2.1.6. Not~fy the AM of the approval of a pending Section XI RepairlReplacement Work Package. 4.3. RepaidReplacement Work Package Implementation 4.3.1. Work Packages shall not be issued for implementation until both the originator and the RRPC (or designee) have signed the RepaidReplacement Traveler Sheet verifying that aI1 of the applicable requirements have beeri satisfied.

4.3.1.1. If the Work Package is revised after issue for implementation (ie. new sub Work Order, flaws identified), the Work Package shall be reviewed and approved again by the RRPC for applicability to Section XI RepairReplacement activities.

Review shall be per step 4.2. 4.3.2. The implementing department shall notify the RRPC upon completion of work. 4.4. RRPC Oversight Responsibilities 4.4.1. When requested, assist the Work Package originator during development to obtain required information, provide technical input and provide assistance in resolving comments 4.4.2. Maintain cognizance and awareness of ongoing and upcoming work activities to ensure that ASME Section XI applicability is established and the requirements of this procedue are met. AP 0070 Rev. 3 Page 7 of 10 4.5. 5.0 5.1. 5.2. 5.3. 5.4. 4.4.3. Perform periodic reviews of work order and modification indices as warranted, to ensure that the requirements of this procedure are met and work completed.

4.4.4. Perform

a quarterly reconciliation of the RepairReplacernent Program Lag. Reporting 4.5.1. The Code Programs Supervisor shall ensure that the Repair/Replacement Activity is documented in the NIS-2 report for submission to the NRC. REFlERENCES AND COMMITMlENTS Technical Specifications and Site Documents 5.1.1. T.S.4.6.E.l

5.1.2. Vermont

Yankee Nuclear Power Station Design Basis Documents Administrative Limits 5.2.1. None Codes, Standards, and Regulations 5.3.1. ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition through the 2000 Addenda 5.3.2. lOCFR50.55a, Codes and Standards

5.3.3. Generic

Letter 90-05, Guidance for Performing Temporary Non-Code Repair of ASME Code Class 1,2, and 3 Piping 5.3.4. Reg Guide 1.147 Rev. 13 5.3.5. Code Case, N-504-2, Alternative Rules for Repair of Class I, 2 and 3 Austenitic Stainless Steel Piping 5.3.6. Code Case, N-555, Use of Section II, V and IX Code Cases Commitments 5.4.1. LER 98-018, Rev. 1, ASME Section XI Code VT-3 Examination not Completed Following Repair of Main Steam Isolation Valve due to the Omission of Relevant Information fiom a Plant Work Order AP 0070 Rev. 3 Page 8 of 10 5.5. 1 I I I 6.0 6.1. 7.0 I 7.1. 7.2. 7.3. 7.4. 7.5. 7.6. Supplemental References 5.5.1. ENN-DC-138, Technical Evaluations of Components and Replacement Items 5.5.2. AP 0020, Control of Temporary and Minor Modifications 5.5.3. AI? 0021, Work Orders 5.5.4. AP 0048, Work Planning 5.5.5. AP 0098, Procedure Writers Guide 5.5.6. AP 0203, Control of Special Processes 5.5.7. OP 4026, Pressure Boundary Repair Procedure 5.5.8. AP 6001, Installation and Test and Special Test Procedures 5.5.9. AP 6002, Preparing 50.59 Evaluations 5.5.10. AP 6006, Safety Classification of Structures, Systems, Components and Parts 5.5.1 1. AP 6008, Vermont Yankee Design Change 5.5.12. AP 6807, Collection, Temporary Storage and Retrieval of QA Records 5.5.13. PP 7015, Vermont Yankee Inservice Inspection Program 5.5.14. PP 7024, Containment Inservice Inspection Program (TWE) 5.5.15. PP 7034, Inservice Inspection Pressure Test Program 5.5.16. PP 7205, Welding Program FINAL CONDITIONS The ASA4E Section XI Repair/Repl&ement Log shall be maintained as a working file dufing the course of the year. Once the NIS-2 has been completed and approved, the log may be kept for information or destroyed.

ATTACHMENTS Appendix A Appendix B Deleted Appendix C Appendix D VYAPF 0070.01 RepairlReplacement Traveler Sheet VYAPF 0070.02 ASME Section XI Repair & Replacement Work Package Preparation Guidelines ASME Section XI Applicability Flow Chart Applicability for Components Outside the ASME Class Boundaries ASME Section XI Repair and Replacement Log -- e Ap 0070 Rev. 3 Page 9 of 10

- -_ 8.0 8.1. 8.2. 8.3. 8.4. 8.5. 8.6. 8.7. 8.8. QA REQUIREMENTS CROSS REFERENCE Section OM-1998 through OMb-200 A.1.d A.2.e.8 A.3.f B.1.c B. 14.a B.14.c B.14.e - Procedure Section 1.3 1.3 3.1 3.1 1.3,4.0 4.0 4.1.1,4.2.1.3 4.2.1.4,4.3 AP 0070 Rev. 3 Page 10 of 10

,I 1. 2. AF'PENDIXA ASME SECTION XI REPAIR & REPLACEMENT WOK PACKAGE PREPARATION GulDELINEs Exclusions:

The following items are excluded from ASME Section XI RepairReplacement requirements.

1.1 1.2 1.3 1.4 1.5 1.6 Nom For all items classified as excluded, Section 2 of this appendix must be applied for final exclusion from repair and replacement activities Valve operators, controllers, position indicators, pump impellers, pump drivers, or other accessories and devices unless they have been classified as Code Class 1,2, or 3 pressure retaining items. Instruments or permanently-sealed, fluid-filled tubing systems furnished with instruments, the code does apply to instrument, control, and sampling piping when classified as Code Class 1,2, or 3. Rupture disk materid (the requkments of ASME Section XI do apply to the portion of a rupture disk holder that forms the pressure boundary). Orifice plates not exceeding 1/2 in. nominal thickness that are used only in flow-measuring service.

Other than component supports or core supports, material that is not associated with the pressure retaining function of component, such as shafts, stems, trim, spray nozzles, bearings, bushings, springs, wear plates, seals, packing, gaskets, valve seats, and ceramic insulating material and special alloys used as seal material in electrical penetration assemblies.

Component support items such as gaskets, seals, bushing, springs, compression spring end plates, bearings, retaining rings, washers, wear shoes, shims, slide plates, and hydraulic fluids. Additional requirements for excluded items: 2.1 When repair/replacement activities are performed on items identified in Section 1 of this appendix, the originator shall determine if installation of these items affects any preservice inspection or test requirements.

2.2 If items in Section 1.6 of this appendix are replaced in snubbers, the snubbers shall be examined and tested in accordance with OP 5203, Inspection and Testing of Shock suppressors. . -- Appendix A AP 0070 Rev 3 - Page 1 of 2 APPENDIX A (Continued) 2.3 If items identified in Section 1 of this appendix require welding to the pressure retaining portion of a component or to a component support such installation shall compIy with the requirements of AP 0070, ASME Section XI Repair and Replacement Procedure.

2.4 Applicable

Construction Code requirements, such as design requirements for Class 1 valve stems, originator responsibilities for assuring adequacy of intervening elements in the component support load path, and nondestructive examination of springs for CIass 1 component supports, shall be met for items identified in Section 1 of this appendix.

I 3. This pTncedure does not apply to warehouse items, which are returned to the supplier for Pee xir and replacement activities.

c Appendix A AP 0070 Rev. 3 Page 2 of 2 I APPrnIXC ASME SECTION XI APPLJCAE3Iz;TTY FLOW CHART ala nolwIIhln Iha acopa 01 8aalIon XI auam IhmIph Ul. Ilam on whloh La aollulq &a pollofmad 11 WIlhln La 8aollon XI boundq. oaleooq ala lneludad In fapaliliapIaOama mI Tar AT0070 Appendix C AP 0070 Rev. 3 Page 1 of 1 APPENDED AJ?PLICABILLTy FOR COMPONENTS OUTSIDE THE ASME CLASS BOUNDARES

1. W Safety Class Boundaries

= ASME Class Boundaries.

2. WAP 0070 does not apply to NNS piping outside VY Safety Class boundary.

3. Supports inside the Seismic Structurai Boundary to the VY Safety Class Boundary require IS1 baseline inspections if modified andor worked on. Safety Class Boundary Valve Repair/Replacement Required, F AP 0070 applies to plping and associated compo ne nts (including supports)

NNS Piping AP 0070 does not apply VY Safety Class Boundary (P&ID) and ASME Class Boundary

• Support, W Seismic Structural Boundary (5920 series seismic isometriics)

This support considered safety class per WAP 6006. Any active sue~ort (including the Boundary Support) from this Boundary to the Safety Class/ASME Class Boundary is subject to VYA? 0070 and will require IS1 baseline if worked on as part of a repair or replacement work package. i F i 1 .- f-.. I' Appendix D AP 0070 Rev. 3 Page 1 of 1 REPALRJREPLACEMENT~VEIERSHEET Basis Document Number Section A - originator

1. The ASME RepaidReplacement Work Package shall be prepared incorporating ail the following elements.

Check box to indicate the required elements have been included in the work package. Include text in Work Package to document that ASME Section Xi 1998 Edition through 2000 Addenda is repaidreplacement code of record. 111 Describe the condition requiring repair or replacement including the nondestructive method that revealed the flaw.

0 Describe the cause of failure and/or reason for replacement.

0 Identify the original Code of Construction or Construction Specification or alternate Construction Code with justification and reconciliation analysis. (Alternate Construction Code justifications and reconciliations performed by Engineering.)

Notify the ANI prior to the start of work. Include a step in the step text of work package to notify the RRPC upon work completion.

2. The ASME RepairlReplacement Work Package shall also include the following elements as applicable to the work being performed. Check the box of the elements that appIy to this repaidreplacement work package and which will be included in the work package. Identifies applicable weld procedures, post weid heat treatment and weld inspection NDE methods specified to satisfy original construction code andor construction or Section XI code for the systedcomponent.

Describes the methods for removal of condition, indication or components being replaced.

Describes the methods for measurement and dimensioning of critical areas before, during and after the work. 0 Verifies that materials conform to the original construction code or construction specification or alternate construction code. Specifies required NDE, Hydrostatic pressure test or Leakage test per applicable code requirements. Originator (PrintlSign)

Date VYAPF 0070.01 AP 0070 Rev. 3 Page 1 of 2 RFPAWFtEPLACEMENT TRAVELER SHEET (Continued)

Section B - RepairlReplacernent Program Coordinator The ASME Repair/Replacement Work Package has been reviewed to ensure incorporation of all necessary ASME Section XI Repair/RepIacement requirements.

Additional requirements or comments are identified below: Comments:

RepairReplacement Program Coordinator (Print/Sign)

Date I Traveler Sheet Approved:

I RepMeplacement Program Coordinator (Print/Sign)

Date . _- I. ! VYAPF 0070.01 AP 0070 Rev. 3 Page 2 of 2

VERMONT YANKEE NUCLEAR POWER STATION E-Plan Security Probable Risk Analysis (PRA) PROGRAM PROCEDURE lOCFR50.54(q)

No lOCFR50.54(p)

NO No PP 7015 REVISION 5 VERMONT YANKEE IN-SERVICE INSPECTION PROGRAM LPC No. USE CLASSIFICATION:

INFORMATION Affected Pages Effective Date RESPONSIBLE PROCEDURE OWNER: Manager, System Engineering I REQUIRED REWIEWS I Yes/No I I Reactivitv Management I I No I I 1 . J This procedure is excluded from further ENN-LI-100 review. I Implementation Statement

N/A I Effective Date:

09/08/05 PP 7015 Rev. 5 Page 1 of 24 1 .o 2.0 3.0 4.0 5.0 6.0 7.0 8.0 TABLE OF CONTENTS PURPOSE, SCOPE, AND DISCUSSION

................................,. , .................................................

3 DEFINITIONS

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................................................................................... . ....... 9 PRIMARY RESPONSIBILITIES

................................................................................................

9 PROCEDURE

.........

........................................................................ , ...........................................

13 4.1 Class 1 Scope, Examination Requirements, and Exemptions

............................................

13 4.2 Class 2 Scope, Examination Requirements, and Exemptions

... . ..... ... . ..... . , . ...... .. . , . . . ... .. . . , .. 15 4.3 Class 3 Scope, Examination Requirements, and Exemptions

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16 4.4 Component Supports Scope, Examination Requirements, and Exemptions . .. ....... . , . . . .... .. 17 4.5 Successive Inspections (Fiollow-up Examinations)

..........

....... ..........

..................

.. ..... .. .., .. 19 4.6 Additional Examinations (Expansions)

..... . . . . . . . . . . . , . . , . . . . . . . . . .. . . . . .. . . .. . .. ... . . . . . . . . . . . . . , . . . . . . . . . , . . . ..20 4.7 Implementing Procedures and Documents

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2 0 REFERENCES AND COMMITMENTS

.... . ...................................................................

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21 FINAL CONDITIONS

..................

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22 ATTACHMENTS

.............................................................................................................

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23 QA REQUIREmNTS CROSS REFERENCE

.............................. . .........................................

24 1 1 f 1 .. PP 7015 Rev. 5 Page 2 of 24 1.0 1.1. 1.2. I .i 3 :I t 1.3. PURPOSE, SCOPE, AND DISCUSSION Purpose The purpose of the Vermont Yankee In-service Inspection (VYISI) Program Procedure is to identify safety class systems, sub-systems, and components required to be examined, outline the examination requirements, and increase or expand examination scope as required such that the requirements of 10CFR50.55a are satisfied.

scope The scope of this procedure is to identify, plan, and schedule components for examination as required by the Code of Federal Regulations, 10CFR50.55a and the ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda. This program procedure scope does not include the examination requirements for metal containment (SFbsection WE), which are found in PP 7024, reactor internds (Subsection IWB, Categories B-N-1 and B-N-2), which are found in PP 7027 and pressure testing (Subsections IWB, Category B-P, IWC, Category C-H, Subsection lWD, Category D-B, and Articles IWX-5000), which are found in PP 7034. In-service Testing requirements are controlled by the IST Program Procedure. The scope of this program procedure is focused on the requirements of ASME Section XI, Subsections IWA, TWB, IWC, IWD, and NirF. Appendix A contains relief requests that address alternative examination requirements.

Discussion

Background:

Vermont Yankee is a General Electric designed boiling water reactor (BWR) power plant buiIt in accordance with the ANSI B3 1.1 Construction Code, 1967 Edition. The safety class boundaries used by this program are based on the assignment of safety classifications as designated in the VY Safety Classification Manual.

The primary reference document for the Safety Classification Manual is ANS-22, Draft 4, Revision 1. The VYISI Program is designed to ensure that the structural integrity of all Class 1,2, and 3 systems and associated supports are maintained at the level required by the Code of Federal Regulations, 10CFR50.55a, and augmented by the ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, ZOO0 Addenda. A preservice, or baseline, inspection of program components was performed to assure freedom fiom defects greater than code-allowable.

This baseline data also provides a basis for evaluating subsequent inspection results. Since plant startup, additional inspection criteria for Class 2 and 3 components have been imposed by the Code of Federal Regulations, 10CFR50.55a for which baseline data has also been obtained.

Current results are compared, as appropriate, to baseline data, other previous test results, and acceptance criteria of the ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda, for evaluation of any evidence of degradation.

Vermont Yankee utilizes Inspection Program B for schedule determination of all components requiring inspection per Subsections IWB, IWC, IWD and IWF. PP 7015 Rev. 5 Page 3 of 24 All inspection results, associated procedures and documentation, and calibration standards are maintained on-site for the life of the plant.

Governing Codes The fourth interval in-service inspection (ISI) requirements are outlined in this program procedure.

The requirements of Title 10 Code of Federal Regulations, Part 50, Section 50.55a, Codes and Standards (10CFR50.55a), and, by reference, the American Society for Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, "Rules for In-service Inspection of Nuclear Power Plant Components," are satisfied in this program procedure.

The Code Edition and Addenda used for the Fourth Interval is the 1998 Edition with 2000 Addenda. Code Cases This progi ;Im incorporates alternative inspection and examination requirements for components governed by certain Code Cases as outlined in Regulatory Guide 1.147 Revision 13. In ticular, t' irogram utilizes the alternative requirements of the following Code Cases:

w . .iative Examination Coverage for Class 1 and 2 Welds h-,,6, ALS iative Requirements for Successive Inspections of Class 1 and 2 Vessels 1T-c?2- 1, Alternative Requirements to Repair and Replacement Documentation Requirements 7pni;ce Summary Report Preparation and Submission as Required by IWA-4000 and Ab%"rrl N-537, Location of Ultrasonic Depth-Sizing Flaws N-545, Alternative Requirements for Conduct of Performance Demonstration Detection Test of Reactor Vessel N-552, Alternative Methods - Qualifications for Nozzle Inside Radius Section from the Outside Surface N-629, Use of Fracture Toughness Test Data to Establish Reference Temperature for Pressure Retaining Materials N-639, Alternative Calibration Block Material This program also incorporates alternative inspection and examination requirements for components governed by the following Code Cases for which relief has been sought from the USNRC: N-560, Alternative Examination Requirements for Class 1, Category B-J Piping Welds I i I PP 7015 Rev. 5 Page 4 of 24 I 11 N-613, Ultrasonic Examination of Full Penetration Nozzles in Vessels, Examination Category B-D, Item Nos. B3.10 and B3.90, Reactor Vessel-to-Nozzle Welds, Fig. IWB-2500-7(a), (b), and (c) N-652, Alternative Requirements to Categories B-G- 1, B-G-2, and C-D Bolting Examination Methods and Selection Criteria N-663, Alternative Requirements for Class 1 and 2 Surface Examinations Specific requirements relative to these Code Cases have been incorporated into applicable implementing procedures and the requirements provided in Table 8, the IS1 Database.

Requests for Relief The below listed Requests for Relief from existing regulatory requirements are part of this pr0grZUn:

ISI-0 1) ISI-02) ISI-03) ISI-04) ISI-05) ISI-06) ISI-07) ISI-08) ISI-09) ISI-010) Not utilized Use of Code Case N-560 as an alternative to ASME Section XI, Category B-J for Examination of Piping Welds Use of Code Case N-652 as an alternative to ASME Section XI, Categories B-G-1, B-G-2, and C-D for Examination of Bolting Use of N-663 as an alternative to ASME Section XI, Class 1, Categories B-F, C-F- 1, and C-F-2 for Surface Examinations Alternative Requirements to ASME Section XI, Appendix VIII, Supplement 10 for Examination of Dissimilar Metal Welds On hold Use of BWRVIP-75 as an alternative to GL 88-01 for Frequency of Overlay Examinations Use of RMS for Grading Purposes as an alternative to ASME Section XI, Appendix VIII, supplement 4, Paragraph 3.2.c for Examination of RPV Shell Welds Use of Code Case N-613 as an dtemative to ASME Section XI, Appendix VIII, Supplement 7 for Examination of RPV Nozzle-to-Shell Welds Alternative Requirements to ASME Section XI, Appendix VIU, Supplement 11 for Examination of Overlaid Piping PP 7015 Rev. 5 Page 5 of 24

..-- ISI-0 1 1) Use of Appendix VIII of ASME Section XI, as modified by lOCFR50.55a(b)(2), for Examination of RPV Flange-to-Shell Weld NRC Commitments The following items constitute commitments to NRC that are not addressed by customary regulatory documents:

1. BVY 2001-002-03, "Perform Ultrasonic Inspections of Feedwater Nozzles In Accordance With GE-NE-523-A71-0594, Revision 1" Interval Schedule:

The fourth inspection interval for VY began on September 1,2003 and extends to August 31,2013. Schedule 1, below outlines the inspection interval dates as well as the starting and ending dates of each period within the intervals.

VY's IS1 Program is based on ASME Inspection Program B (IWA-2432), which has four 10 year inspection intervals.

Schedule 1: Notes: The 1" Interval was five years long, due to the delay in the development and implementation of ASME Section XI. 1 The end date of the lst Interval was extended by five months, in accordance with IWA-2430(c), to permit inspections concurrent with a plant refueling outage. Consequently, all subsequent intervals were adjusted back (later) five months. 2 In the 2"d Interval, the end date of Period 1 was extended by four months to reflect the 1985-86 pipe replacementhefueling outage (nine months duration), in accordance with IWA-2430(e).

Consequently, all subsequent intervals were adjusted back (later) four months. 3 Vermont Yankee's operating license expires March 21,2012. 4 PP 7015 Rev. 5 Page 6 of 24 IB B - ~ Code Category Scheduled Components and Percentages by Period Period 3 Percentage Min. = 100% Percentage Percentage Min.= 16% 2 Min.=50% Max. = 50% Max. = 75% Total Scheduled B-A 28 9 32% 11 71% 8 100% B -D 58 18 31% 24 72% 16 100% B-F 22 7 32% 7 63 % 8 100% B-G-1 208 44 21% 88 63% 76 100% B-G-2 135 Performed when disassembled 100% B-J 65 22 34% 24 71% 19 100% B-K 3 1 33% 1 67% 1 100% B -L-2 2 Performed when disassembled 100% B-M-2 43 Performed when disassembled 100% B-O 6 2 33% 2 67% 2 100% C-A 4 1 25% 2 50% 1 100% C-B 2 1 50% 0 50% 1 100% C-C 5 1 17% 3 67% 1 100% C-F-2 63 22 35% 23 71% 18 100% D-A 10 2 20% 4 60% 4 100% F-A 129 43 33% 53 74% 33 100%

• Aug. -Welds 8 3 38% 2 63 8 3 100% *Aug.Supports 7 3 43% 2 71% 2 100% Components scheduled by percentage to complete for each period in the 4" Interval are given below:

• Welds and supports in the Main Steam System selected for examination in accordance with NRC commitment in BVY94-124.

IS1 Program Revisions Revisions to the IS1 Program shall be implemented to reflect changes in code requirements (additions or reductions in scope), augmented exams, or regulatory requirements.

Changes will be initiated by the In-service Inspection Program Coordinator (ISIPC) or designee.

When additions or deletions to the Program are identified, they shall be promptly revised to reflect the current requirements.

Revisions shall be processed in accordance with the requirements of AP 0095, Plant Procedures.

PP 7015 Rev. 5 Page 7 of 24 Drawing Revisions:

The IS1 drawings are coordinated to the Vermont Yankee seismic isometric drawings and controlled by AP 6802. Both drawings are very similar in content, however, different information is contained on each. The IS1 drawings contain information specific to the IS1 program, such as component numbers, support identification numbers, weld locations, etc.

When the seismic isometric drawings are revised for design changes, corrective update, or for any other reason, the companion IS1 drawings are flagged for revision, and revised as necessary. This ensures that the IS1 drawings remain accurate and updated. Summary of Organizational Responsibilities:

The IS1 Program is organized under the System Engineering Department, Code Programs Group.

The In-service Inspection Program Coordinator (ISIPC) is the designated owner and central information point regarding the IS1 Program. The ISPC reports to the System Engineering Code Programs Supervisor (SECPS). The ISIPC shall report any examination results that could have an adverse affect on plant equipment or operation.

The SECPS will keep Plant Management informed of examination progress, discrepancies, or any other aspects related to ISI. Design Engineering will support the IS1 Program, as necessary, to evaluate and make recommendations on examir. ition discrepancies.

QAD is responsible for periodically auditing the IS1 Program for code compliance and adherence.

This procedure defines organizational responsibilities as they are currently being implemented.

As pa- f the . T!c- Eluh-DC-120, ASME Section XI Code Programs.

When the transition officially occurs, this xocedure will be revised to specifically address IS1 Program implementation. ition plan to ENN programs and procedures, the IS1 Program ownership 1 be transitioned to the White Plains Office (WPO) with implementation A remaining at the site. These respective responsibilities are defined in P 0. componmts to WL ,:I ASAJE Section XI, IS1 applies and is utilized to determine if the requirements of this program apply. ' -30 : e. AP 0048, AP 0021, AP 0070, OP 4101, can affect and implement portions flected in each procedure.

The EMPAC data base identifies equipment and I I. t i i PP 7015 Rev. 5 Page 8 of 24 2.0 2.1. 2.2. 2.3. 2.4. 2.5. 2.6. 2.7. 3.0 3.1. DEFINITIONS Authorized Nuclear In-service Inspector - a person who is employed and has been qualified by an Authorized Inspection Agency to verify that examinations, test, and repairs are performed in accordance with the rules and requirements of Section XI. ComDonent - an item in a nucIear power plant such as a vessel, pump, valve, piping system, or component support. Evaluation - the process of determining the significance of examination or test results, including the comparison of examination or test results with applicable acceptance criteria or previous results. Examination Category - a grouping of items to be examined or tested. In-service Inspection - methods and actions for assuring the structural and pressure-retaining integrity of safety-related nucIear power plant components in accordance with Section XI. Insuection Promam - the plan and schedule for performing examinations or tests. Nondestructive Examination - an examination by the visual, surface, or volumetric method. PRIMARY RESPONSIBILITIES In-service Inspection Program Coordinator (ISIPC) Responsibilities - NOTE I At the discretion of the SECPS, selected ISIPC responsibilities may be I delegated to aualified Enterm or contracted Dersonnel.

The detailed responsibilities of the ISlPC are as follows: 3.1.1. Provide for overall maintenance, review and coordination of the IS1 Program. 3.1.2. Review the Examination procedures for compliance with regards to the applicable edition of ASME Section XI and Plant Tech.

Specs. 3.1.3. Prepare the IS1 Program per applicable regulatory requirements and Plant Technical Specifications.

This shall include planning and scheduling of the IS1 efforts. 3.1.4. Ensure components scheduled for examination are properly prepared and accessible.

3.1.5. Ensure

components examined are properly restored.

PP 7015 Rev. 5 Page 9 of 24

3.1.6. Interface

with the cognizant department, as needed, to ensure all repairheplacement IS1 examination requirements are satisfied.

3.1.7. Ensure

the ISI records are permanently stored per AP 6807, Collection, Temporary Storage and Retrieval of QA Records. 3.1.8. Prepare and submit the OAR-1 Summary Report to the regulatory authorities and answer all inquiries.

3.1.9. Keep the SECPS informed on the progress of the IS1 task(s). 3.1.10. Ensure changes or additions to CIass 1, Class 2, and Class 3 pressure boundaries and component support classifications are incorporated into the IS1 Program. 3.1.11. Review design changes and maintenance documents, as necessary, to assess the appropriate.

impact of the proposed task upon the IS1 Program, and recommend action when Review outstanding PCRS commitment items prior to each outage and the end of ti I. I' 3.1.12. each 10-yr IS1 interval.

I - NOTE 1 T Tn.accentahle inspection results shall be reported to the ISIPC by the 1 agency or cognizant department for resolution.

The . Nuclear In-service Inspector (ANII) shall be informed of the 3.1.13. Detc-ine any additional examinations made necessary by discovery of unacceptabIe I Xns during scheduled inspections.

3.1.14. rcriodicdly review each Relief Request for continued applicability.

3.1.15. Provide technical advice on all aspects of the program. 3.1.16. Arrange for on-site services as requested by the Level III. 3.1.17. Prepare diagrams or drawings delineating the scope of the IS1 Program. 3.1.18. Ensure that cognizant departments are informed of unacceptable conditions to facilitate completion of appropriate paperwork (ERs, WRs, etc.). 3.1.19. Ensure that the IS1 Examination Database (Table 8) is properly maintained.

I 8. pr I 3.1.20. Maintain a history of all IS1 examinations (scheduled and unscheduled).

PP 7015 Rev. 5 Page 10 of 24 3.1.21. Maintain the calibration blocks, examination tool(s), arid their associated docurnentation. The calibration blocks (with a few exceptions due to size) are stored in locked cabinets located in the Reactor Building and are maintained for the life of the plant. The examination tools are also stored in secured lockers.

3.1.22. Ensure ANII has reviewed all NDE procedures and personnel qualifications, and any other applicable ASME Section XI documents.

3.1.23. Resolve any ANII comments regarding review of NDE procedures, personnel qualifications, or other ASME Section XI related issues as applicable.

Ensure that the responsibilities of Ap 0098, Appendix A, are considered as well as the responsibilities listed above.

3.1.24. 3.2. NDE Level III (Shared Resource or Contract)

The detailed responsibilities of the contracted Level m/rSI Supervisor are as follows: 3.2.1. Review the IS1 Program to become familiar with implementation requirements.

3.2.2. Notify

the ISPC to initiate changes to IS1 Program and Examination procedures, as necessary, to ensure code compliance is maintained.

3.2.3. Ensure

appropriate selection of Examination Personnel.

3.2.4. Review

and ensure all NDE Personnel qualifications are current. 3.2.5. Oversee NDE personnel indoctrination and performance demonstration.

3.2.6. Advise

ISIPC of scheduling conflicts, staffing needs, and resource availability.

3.2.7. Review

all NDE documentation to ensure IS1 examinations have been properly documented.

3.2.8. Provide

input, as necessary, to the ISPC and Design Engineering regarding examination findings.

3.2.9. Provide

input, as necessary, to aid in completion of the Summary Report (OAR-1). 3.2.10. Notify the ISIPC of any unacceptable inspection results in a timely manner.

3.3. Quality

Assurance Department (QAD) The detailed responsibilities of the QAD are as follows: 3.3.1. Surveillance of documentation pertinent to the In-service Inspection and Test Program. PP 7015 Rev. 5 Page 11 of 24

3.4. Examination

Agency The examination agency shall provide NDE personnel as specified in the specific purchase order. 3.5. Design Engineering Design Engineering will support the IS1 Program, as needed, by evaluating unacceptable I examination results. 3.6. Maintenance Department Perform Visual, or Surface examination requirements of this procedure as they pertain to repairs and replacement activities and as may be required for specific work activities.

3.7. RIMS Ensure the IS1 records are permanently stored and available for the plant lifetime.

PP 7015 Rev. 5 Page 12 of 24

4.0 PROCEDURE

I 4.1. Class 1 Scope, Examination Requirements, and Exemptions

4.1.1. Scope

..1 -. t 'I 4.1.1.1. All Class 1 pressure retaining components and their welded attachments are included in the inspection program, except for those items exempted from examination by ASME Section XI, 1989 Edition, no addenda, Subsection IWB, Article IWB-1000, paragraph IWB-1220.

For Class 1 components, Appendix By Table 1 identifies: the code categories, the code item numbers, the number of components scheduled for examination within each code category and item, and notes clarifying various code requirements. Unique Feedwater Nozzle Inner Radius examination requirements are addressed in paragraph 4.1.2.2 below. 4.1.2. Examination Requirements:

4.1.2.1. Examination and schedule requirements are identified for Class 1 components in the IS1 Database, and Table 5. Feedwater nozzle inner radius examinations as required by Code Category B-D shall be performed in accordance with VY Calculation VYC-1005, Revision 1 and GE Nuclear Energy document GE-NE-523-A7 1-0594-A, Revision 1, DRF 137-0010-7 Class II, May 2000, entitled "Alternate BWR Feedwater Nozzle Inspection Requirements." (BVY 2001-002-03) 4.1.2.2. 4.1.2.3. Magnetic particle and liquid penetrant examinations may be used interchangeably without revision to this program for ferritic steel components requiring surface exams (reference ASME Section XI, subsection WA, paragraph WA-2220).

Category B-J piping welds are selected and examined in accordance with Code Case N-560 and Relief Request ISI-02. 4.1.2.4. 4.1.2.5. Categories B-G-1 and B-G-2 bolting selection and examinations are performed in accordance with Code Case N-652 and Relief Request ISI-03. 4.1.2.6. Surface examinations for Category B-F dissimilar-metal piping welds are selected and examined in accordance with Code Case N-663 and Relief Request ISI-04. 4.1.2.7. Category B-A, Code Item No. B1.11 reactor vessel circumferential shell welds are selected and examined in accordance with Relief Request ISI-06. PP 7015 Rev. 5 Page 13 of 24 4.1.2.8. The core spray overlays (Category B-F - GL 88-01 Category E) are selected and examined in accordance with Relief Request ISI-07. 4.1.2.9. Category B-D reactor $esse1 nozzle-to-shell welds are examined in accordance with Code Case N-613 and Relief Request ISI-09. 4.1 -3. Exemptions:

4.1.3.1. Exemptions are in accordance with ASME Section XI, 1989 Edition, no addenda, Subsection IWB, Article IWB-1o00, paragraph IWB-1220. Selected specific exemptions are identified in paragraphs 4.1.3.2 through 4.1.3.3 below. 4.1.3.2. ASME Section XI, subsection IWB, paragraph IWB-l220(a) exempts Class 1 components connected to the reactor coolant system, that are of size and shape such that a postulated rupture is within the capacity of the make-up systems. Vermont Yankee Calculation No. VYC-1118 justifies exempting the following components by determining that a line break on a 1.455" ID pipe for saturated water or on a 2.375" ID pipe for saturated steam could be made up by systems operable from on-site emergency power. The following pipe lines are exempted:

a 2" head vent line off the N7 reactor nozzle (nominal 1.687" ID steam) a 2" MSD2A, B, C, and D main steam drain lines (nominal 1.687" ID steam) a 1.5" MSD420, MSD421, MSD422 main steam drain lines (nominal 1.338" ID steam) a 1.5" reactor vessel instrumentation lines off the N1 lA, N1 lB, N12A, and N12B nozzles (nominal 1.338" ID water) 4.1.3.3. ASME Section XI, subsection IWB, paragraph IWE3-1220(c) exempts vessel head connection 2 inch N.P.S. and smaller made inaccessible due to control rod drive penetrations. Thus, vessel drain nozzle, N15, and piping welds, CU400-Fl (terminal end), CU400-FW1 (dissimilar metal weld), CU400-FW2, CU400-FW3, and CU400-FW4, are exempted from examination due to CRD penetrations making these welds inaccessible.

i b. P j t PP 7015 Rev. 5 Page 14 of 24

4.2. Class

2 Scope, Examination Requirements, and Exemptions

4.2.1. Scope

4.2.1.1. All Class 2 pressure retaining components and their welded attachments are included in the inspection program, except for those lines exempted from examination by ASME Section XI, 1998 Edition, ZOO0 addenda, Article IWC-1O00, paragraph IWC-1220. For Class 2 components, Appendix B, Table 2 identifies: the code categories, the code item numbers, the number of components scheduled for examination within each code category and item, and notes clarifying various code requirements.

Appendix B, Table 5 identifies Augmented Main Steam Components (see BVY 94-1 24). 4.2.1.2. Category C-D bolting selection and examination are performed in accordance with Code Case N-652 and Relief Request ISI-03. 4.2.1.3. Surface examinations for Category C-F-1 and C-F-2 piping welds are selected and examined in accordance with Code Case N-663 and Relief Request ISI-04. 4.2.2. Examination Requirements:

4.2.2.1. Examination and schedule requirements are identified for Class 2 components in the IS1 Database, Table 6 and for Augmented Main Steam System components, see Table

9. 4.2.2.2. Magnetic particle and liquid penetrant examinations may be used interchangeably without revision to this program for ferritic steel components requiring surface exams (reference ASME Section XI, subsection IWA, paragraph TWA-2220).

4.2.3. Exemptions

4.2.3.1. ASME Section XI, subsection IWC, paragraph WC-l221(a) and (c) or IWC-l222(a) and (b) exempts components that are 4 inch N.P.S. or less for boiling water reactor plants. Exemptions are in accordance with ASME Section XI, 1998 Edition, 2000 addenda, Subsection IWC, Article IWC-lOOO, paragraph IWC-1220. Selected specific exemptions are identified in paragraphs 4.2.3.2 through 4.2.3.3 below. 4.2.3.2. ASME Section XI, subsection IWC, paragraph IWC-l222(c) exempts components that are not part of the RHR, ECC, or CHR systems, have design pressure less than 275 psig and design temperature less than 200°F. Thus, pipe line CT-3 of the Condensate Transfer System and pipe lines AC-l4A, AC-14B and AC-22 of the primary containment and atmospheric control system are exempt from examination.

PP 7015 Rev. 5 Page 15 of 24 4.2.3.3. The Condensate Storage Tank (TK-4-1A) is not included in the program. ASME Section XI, subsection IWA, paragraph IWA-1310 addresses storage tanks, however, the tank is not a pressure vessel and therefore is not addressed by any Code Category.

This examination exemption is supported by ASME Section XI Code Interpretation XI-1-89-5 I. 4.3. Class 3 Scope, Examination Requirements, and Exemptions

4.3.1. Scope

4.3.1.1. All Class 3 components and systems greater than 4 inch N.P.S. are included in the Program, excepted for those items exempted below.

All Class 3 pressure retaining components and their welded attachments in support of the below listed functions are included in the program except Edition, 2000 addenda, Subsection IWD, Article IWD-1000, paragraph IWD- 1220. for those items exempted from examination by ASME Section XI, 1998 1 I I e reactor shutdown e emergency core cooling e containment heat removal e atmosphere cleanup e reactor residual heat removal e residual heat removal from spent fuel storage pool For Class 3 components, Appendix B, Table 3 identifies:

the Code Categories, the code item numbers, the number of components scheduled various code requirements.

for examination within each code category and item, and notes clarifying

-. ~ 4.3.2. tion Requirements:

4.3.2.1. Examination and schedule requirements are identified for Class 3 components in the IS1 Database, and Table 7. PP 7015 Rev. 5 Page 16 of 24

4.3.3. Exemptions

4.3.3.1. Exemptions are in accordance with ASME Section XI, 1998 Edition, 2000 addenda, Subsection IWD, Article IWD-1000, paragraph IWD-1220 which exempts integral attachments and supports of SC3 components that are 4 inch N.P.S. or less within the bounds of examination Categories D-A, D-B, and D-C, from visual examination (VT-3). 4.3.3.2. ASME Section XI, subsection IWD, paragraph WD-1220.2 exempts integral attachments to components exceeding 4 inch N.P.S provided:

the components are not required in support of reactor residual heat removal, or containment heat removal, or emergency core cooling, and operate at a pressure less than 275 psig and at a temperature less than 200°F. Thus, the fuel pool cooling system is exempted from examination.

4.4. Component

Supports Scope, Examination Requirements, and Exemptions 1 1 4.4.1. Scope: 4.4.1.1. I I All Class 1,2,3 and MC component supports are included in the program except for those items exempted from examination by ASME Section XI, 1998 Edition, 2000 addenda, Subsection WF, Article IWF-1000, paragraph TWF-1220.

4.4.1.2. Appendix B, Table 4 identifies:

the code categories, the code item numbers, the number of components scheduled for examination within each code category and item, and notes clarifying various code requirements.

4.4.2. Examination

Requirements:

4.4.2.1. Examination and schedule requirements are identified for component supports in the IS1 Database and Table 8. PP 7015 Rev. 5 Page 17 of 24

4.4.3. Exemptions

4.4.3.1. Support exemptions are in accordance with ASME Section XI, 1998 Edition, 2000 addenda, Subsection IWF, Article IWF-1000, paragraph IWF-1220.

Selected specific exemptions are identified in paragraphs 4.4.3.2 through 4.4.3.7 below. 4.4.3.2. By ASME Section XI, subsection WB, paragraph IWB-l220(a) the following lines are exempted.

These exemptions are supported by VY Calculation No. VYC-1118, which determines that a line break on a 1.46" ID pipe for saturated water or a 2.38" ID pipe for saturated steam could be made up by systems operable Erom on-site emergency power. e e e e 2" head vent line off the N7 reactor nozzle (nominal 1.687" ID steam) 2" MSD2A, B, Cy and D main steam drain lines (nominal 1.687" ID steam) 1 .5" MSD420, MSD42 1, MSD422 main steam drain lines (nominal 1.338" ID steam) 1.5" reactor vessel instrumentation lines off the N11 A, N1 IB, N12A, and N12B nozzles (nominal 1.338" ID water) 4.4.3.3. By ASME Section XI, subsection IWB, paragraph NS7B-l220(b) components on systems 1 inch N.P.S. and smaller are exempt from examination.

4.4.3.4. By ASME Section XI, subsection WC, paragraph IWC-l221(a) and (c) or IWC-l222(a) and (b), components that are 4 inch N.P.S. or less are % exempt from examination.

b- 4.4.3.5. ASME Section XI, subsection IWC, paragraph IWC-l222(c) exempts components from examination that are not part of RHR, ECC, or CHR temperatures less than 200°F. Thus, pipeIine CT-3 of the Condensate Transfer System and pipelines AC-14A and AC-14B of the primary examination.

systems and they have design pressures less than 275 psig and design containment and atmospheric control system are exempted from I r 4.4.3.6. By ASME Section XI, subsection IWD, paragraph IWD-1220.1, components that are 4 inch N.P.S. or less are exempt from examination.

4.4.3.7. By ASME Section XI, subsection IWD, paragraph IWD-1220.2, the fuel pool cooling system is exempted from examination due to the system not being required to support reactor residual heat removal, containment heat removal, or emergency core cooling, and the system operates at a pressure less than 275 psig and at a temperature Iess than 200°F. PP 7015 Rev. 5 Page 18 of 24

4.5. Successive

Inspections (Follow-up Examinations) .J f I I 4.5.1. If flaws or relevant conditions in Class 1 components are accepted by analytical evaluation, the areas containing such flaws shall be reexamined during the next three inspection periods. Alternatively, acoustic emission may be used to monitor growth of existing flaws in accordance with paragraph IWA-2234 of the ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda. If flaws or relevant conditions remain essentially unchanged for three successive inspection periods, the component examination schedule may revert to the original schedule of successive inspections.

If welded attachments are examined as a result of identified component support deformation, and the results of these examinations exceed the acceptance standards of Table IWB-3410-1 of the ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda, successive examinations shall be performed, if determined necessary, based on an evaluation by the Vermont Yankee Design Engineering Department.

If flaws or relevant conditions in Class 2 components are accepted by analytical evaluation, the areas containing such flaws shall be reexamined during the next inspection period. Alternatively, acoustic emission may be used to monitor growth of existing flaws in accordance with ZWA-2234 of ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda. If flaws or relevant conditions remain essential1 4.5.2. d for the next inspection period, the component

• schedule may revert to the original schedule of successive inspections.

achments are examined as a result o deformation, and the results of these examinatio Table IWC-3410-1 of the ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda, successive examinations shall be performed, if determined necessary, based on an e Department.

If flaws or relevant conditions in Class 3 components are accepted by analytical evaluation, the areas containing such flaws shall be reexamined during the next inspection period. If flaws or relevant conditions remain essentially unchanged for the next inspection period, the component examination schedule may revert to the original schedule of successive inspections.

If welded attachments are examined as a result of identified component support deformation, and the results of these examinations exceed the acceptance standards of IWD-3000 of the ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda, successive examinations shall be performed, if determined necessary, based on an evduation by the Vermont Yankee Design Engineering Department.

component support e acceptance standards of by the Vermont Yankee Design Engineering 4.5.3. 4.5.4. If flaws or relevant conditions in component supports are accepted by analytical evaluation, the component support shall be reexamined during the next inspection period. If flaws or relevant conditions do not require additional corrective measures during the next inspection period, the component examination schedule may revert to the original schedule of successive inspections.

PP 7015 Rev. 5 Page 19 of 24

4.6. Additional

Examinations (Expansions)

4.6.1. Component

examinations with the exception of Examination Categories B-P, C-H and D-B, that reveal flaws or relevant conditions that exceed applicable acceptance standards, shall be extended to include additional examinations as required by WB-2430, IWC-2430, IWD-2430 or M-2430 as applicable.

4.7. Implementing

Procedures and Documents 4.7.1. ASME Section XI, 1998 Edition, 2000 Addenda Section XI outlines the rules and requirements for performing in-service inspection and in-service testing at nuclear power plants.

ASME Section XI identifies as a minimum rules and requirements for areas subject to inspection, responsibilities, provisions for accessibility, examination methods, frequency of inspections, procedures, personnel qualification, and examination documentation.

This code is not only applicable to existing components but also new construction, repairs, and replacements.

4.7.2. DP 4026 Pressure Boundary Repair Procedure The purpose of this procedure is to provide written instruction for the removal of surface indications detected during ISIs conducted in accordance with Section XI of the ASME Code. This document is limited to the removal or reduction in size of indications detected by any of the visual examination techniques in ferritic or austenitic piping. In-service inspection findings shall be evaluated and dispositioned in accordance with the requirements of EN-LI- 102, Corrective Action Process. The following Nondestructive Examination (NDE) Procedures are used to implement IS1 NDE inscl ction requirements:

4.7.3. 4.7.4. Applicable ENN-NDE Procedures NE 8042, Training for Contract NDE Personnel i r' E I PP 7015 Rev. 5 Page 20 of 24

5.0 REFERENCES

AND COMMITMENTS

5.1. Technical

Specifications and Site Documents 5.1.1. 5.1.2. T.S. Section 3.6.E 5.1.3. T.S. Section 4.6.E 5.1.4. UFSAR Section 4.2.6 QAPM, Entergy Quality Assurance Program Manual 5.2. Administrative Limits 5.2.1. None - NOTE AP 6024, Plant Housekeeping requirements, are established via the AP 0021, Work Order process. (INP093ES41MEC5) 5.3. Codes, Standards, and Regulations 5.3.1. 5.3.2. 5.3.3. 5.3.4. 5.3.5. 5.3.6. 5.3.7. ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition, including the Summer 1975 Addenda ASME Boiler and Pressure Vessel Code,Section XI, 1989 Edition, No Addenda ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda Code of Federal Regulations, 10CFR50.55a Regulatory Guide 1.58, Rev. 1, "Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel" Regulatory Guide 1.147, Rev. 13, "In-service Inspection Code Case Applicability" Regulatory Guide 1.150, Rev. I, "Ultrasonic Testing of Reactor Vessel Welds During In-service Inspection" 5.4. Commitments 5.4.1. None PP 7015 Rev. 5 Page 21 of 24 5.5. I I 6.0 6.1. 6.2. Supplemental References 5.5.1. 5.5.2. 5.5.3. 5.5.4. 5.5.5. 5.5.6. 5.5.7. 5.5.8. 5.5.9. 5.5.10. 5.5.11. 5.5.12. 5.5.13. 5.5 $. 5.5.15. 5.5.16. BVY94-12, Response to Request for Additional Information on the Vermont Yankee Third 10 Year Interval In-service Inspection (ISI) Program Plan and Associated Requests For Relief GE Nuclear Energy Document GE-Ne-523-A7 1-0594-A, Revision 1, DRF 137-0010-7 Class 11, May 2000, Titled "Alternate BWR Feedwater Nozzle Inspection Requirements" Vermont Yankee Calculation VYC-1118, "Line Size Exemptions From IS1 Section XI, IWB-1220 Examination Requirements" Vermont Yankee Calculation VYC-1005, Revision 1 Entitled "Crack Growth Evaluation of the Vermont Yankee FW Nozzles" EN-AD- 103, Document Control and Records Management Activities EN-LI-102, Corrective Action Process ENN-DC-120, ASME Section XI Code Programs AP 0021, Work Orders AP 0048, Work Planning AP 0070, ASME Section XI Repair and Replacement Procedure AP 0098, Procedure Writer's Guide OP 4101, RPV Operational System Leakage Test Ap 6024, Plant Housekeeping and Foreign Material ExclusioxdCleanliness Control PP 7024, Containment In-service Inspection Program (IWE) PP 7f7q4. In-service Inspection Pressure Test Program I 1 AP 0095, Plant Procedures I F' i-,nal IS1 Lport Preparation and Review The IS' the Fr is r-- -7 '- ' - for preparation, obtaining an independent review of, and submittal to m OAR-1, Owner's Activity Report for In-service Inspection.

Records All IS1 records including personnel certifications, equipment certifications, calibration sheets, examination data sheets, records of repairs, radiographic film, pertinent correspondence and form OAR shall be submitted to the ISIPC for filing. PP 7015 Rev. 5 Page 22 of 24 6.3. I I 7.0 7.1. 7.2. 7.4. 7.5. 7.6. 7.7. I 7.3. IS1 Closeout The following conditions must be verified after each outage and prior to IS1 closeout:

6.3.1. 6.3.2. AI1 required examinations have been completed. Final inspection results, supporting documentation, and resolution of nonconformance have been completed, compiled, reviewed, and retained.

The OAR-1 form has received an independent review, been approved by the Plant Manager or designee and the ANII, and submitted to NRC WITHIN 90 DAYS of plant startup from the applicable refuel outage.

6.3.3. ~ - NOTE Additional copies of the Final IS1 Report may be issued as "Unofficial" copies by the plant. 6.3.4. The ISIPC has received the approved copy of the Final IS1 Report for retention.

ATTACHMENTS Appendix A Relief Requests Appendix B Appendix C Deleted Appendix D Calibration Block Index Appendix E Deleted Appendix F Deleted Appendix G Deleted Selection and Bases Tables PP 7015 Rev. 5 Page 23 of 24 8.0 8.1 8.2 8.3 8.4 8.5 8.6 8.7 8.8 8.9 8.10 8.11 8.12 8.13 8.14 8.15 QA REQUIREMENTS CROSS REFERENCE Source Document ASME Section XI 1998 through 2000 A.1.d A.2.e.8 A.3.f B.1.c B.12.a B.12.b B.12.d B.12.e B.12.f B.14.a B. 14.c B.14.e B.15.a B.15.b Procedure Section 1.3 5.1.4 1.3 1.3,4.7.4 1.3,4.7.4 1 .o 1.3,3.1 1.3,3.1, 3.2 1.3,3.1, 3.2 1.3,3.2 1.3,3.1.2 1.3,3.1.2 1.3, 3.1.2 1.3, 3.7 1.3,3.7 t i' PP 7015 Rev. 5 Page 24 of 24 APPENDIX A RELIEF REQWTS LICENSEWTILITY NAME - Entergy NucIear Operations, Inc. PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEST FOR RELIEF NO. ISI-01 NOT UTILIZED Appendix A PP 7015 Rev. 5 Page 1 of 58 A- " ___ I L- -- APPENDIX A (Continued)

LICENSEEAJ'IYLITY NAME - Entergy Nuclear Operations, Inc. PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEST FOR RELIEF NO. ISI-02 Information to Support NRC Re-Approval of a 10CFR50.55a Request for Use During a New 10-Year Interval

1. Previous lOCFR50.55a Request Approved bv NRC Request proposed in Reference 1 and approved as agreed to in Reference

9. Applicable items are ASME Section XI, Class 1, Examination Categories B-J, Code Item Nos. B9.10, B9.20, and B9.30, Pressure Retaining Welds in Piping 2. Changes to the Applicable ASME Code Section For Examination Category B-J, the differences between the 1986 Edition (Third Interval) and the 1998 Edition with Addenda through 2000 (Fourth Interval) are as follows: 1) The requirement for examination of longitudinal welds has been eliminated, except as noted in Notes (4), (5), and (6) at the intersections of circumferential welds.

2) Note (l)(c) clarifies which Category B-J dissimilar metal welds are included (no technical change). These changes do not affect the use of Code Case N-560. There are no longitudinal welds in the Category B-J population at Vermont Yankee. 3. Component Aging Factors Component agmg factors are addressed in Code Case N-560, (a)(7), which states, "Modifications to the selected examination zones may be made based on relevant industry experience, changes in plant design or operation, new metaIIurgical knowledge, or prior examination results."

None of the above input factors has resulted in a change to the original examination sample selection.

At the present time, injection of hydrogen water chemistry has been delayed at Vermont Yankee. However, Vermont Yankee still intends to assure that each of the stainless steel welds in the 'e,onrv 9 -T wpulation has been mitigated against IGSCC by two methods, or addressed by other K. conducted by Stnztural Integrity Associates to determine the effectiveness of induction heating stress improvement (IHSI) applied to certain welds (Reference

13) in order to possess two mitigating methods under all scenarios of HWC and NMCA injection. Based on the decision and timing of the use of hydrogen water chemistry, Vermont Yankee will expand the population of welds to receive such an evaluation.

zted in Reference

12. As promised in Reference 12, an evaluation was I 1- I Appendix A PP 7015 Rev. 5 Page 2 of 58

4. 5- 6. 7. APPENDIX A (Continued)

ChanPes in Technolow for Inspectinp the Affected ASME Code Components Use of Code Case N-560 resulted in a change to the examination zones for each weld; however, Code Case N-560 governs selection of welds and areas for inspection, and does not address the means necessary to perform the inspection. Therefore, changes in technology are not applicable to use of this Code Case. Confirmation of Renewed ApplicabiIitv The relief granted for Vermont Yankee's Third Interval is still appIicabIe for the Fourth Interval.

The use of risk-informed methodology for selection of components for examination embodies Vermont Yankee's philosophy for Class 1 piping inspection.

Duration of Re-Apmoved lOCFR50.55a Request It is proposed to use the alternative for the duration of the Vermont Yankee Fourth Ten-Year Interval (September 1,2003 through August 31,2013).

References

1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. BVY 97-99, dated August 6, 1997, "Implementation of ASME Code Case N-560 at Vermont Yankee Nuclear Power Station" BVY 97-105, dated August 15, 1997, "Implementation of ASME Code Case N-560 at Vermont Yankee Nuclear Power Station" NVY 97-137, dated September 5,1997, "Meeting with Vermont Yankee Nuclear Power Corporation" NVY 97-163, dated October 9, 1997 "Summary of September 17, 1997, Meeting and September 23,1997, Telecon Regarding the American Society of Mechanical Engineers Code Case N-560" BVY 97-137, dated October 23, 1997, "Implementation of ASME Code Case N-560 at Vermont Yankee Nuclear Power Station - Response to NRC Questions" NVY 98-32, dated March 11, 1998, "Request for Additional Information Regarding Implementation of ASME Code Case N-560 at Vermont Yankee Nuclear Power Station (TAC No. M99389)" BVY 98-114, dated July 31, 1998, "Request for Additional Information Regarding Implementation of ASME Code Case N-560 at Vermont Yankee Nuclear Power Station" BVY 98-138, dated September 4,1998, "Submittal of Additional Information Regarding Implementation of ASME Code Case N-560 at Vermont Yankee Nuclear Power Station" NVY 98-155, dated November 9,1998, "Request to Use Code Case N-560 As an Alternative to the Requirements of ASME Code,Section XI, Table WB-2500-1 at Vermont Yankee Nuclear Power Station" NVY 98-168, dated December 30, 1998, "Request for Information Concerning Use of Code Case N-560 - Vermont Yankee Nuclear Power Station" BVY 99-26, dated March 19,1999, "Response to Request for Information Concerning Use of Code Case N-560 - Vermont Yankee Nuclear Power Station" Appendix A PP 7015 Rev. 5 Page 3 of 58 APPENDIX A (Continued)

12. 13. BVY 00-74, dated August 28,2000, "Follow-up to Request for Information Concerning Use of Code Case N-560" Structural Integrity Report No. SIR-01-161, Revision A, dated "November 19,2002", Evaluation of Effectiveness of Induction Heating Stress Improvement of Austenitic Stainless Steel Piping Welds at Vermont Yankee" Appendix A PP 7015 Rev. 5 Page 4 of 58 APPENDIX A (Continued)

• m a ,,t LICENSEEJUTILITY NAME - Entergy Nuclear Operations, hc. PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEST FOR RELIEF NO. ISI-03 Proposed Alternative In Accordance with 10CFR5055a(a)(3)(i)

--Alternative Provides Acceptable Level of QuaIity and Safety-- 1. ASME Code Componentb)

Affected ASME Section XI, Class 1, Examination Category B-G-1, Code Item Nos. B6.120, B6.150, B6.160, and B6.170; Examination Category B-G-2, Code Item Nos. B7.10, B7.40, B7.50, B7.60, and B7.70; and Examination Category C-D, Code Item No. C4.20 2. Applicable Code Edition and Addenda 1998 Edition with Addenda through 2000 3. Applicable Code Requirements

1. ASME Section XI, Category B-G-1, Code Item Nos. B6.120, B6.150, B6.180, and B6.210 requires volumetric examination of bolts and studs in heat exchangers, piping, pumps, and valves regardless of whether the bolts or studs are examined in place or removed. 2. For ASME Section XI, Category B-G-1, Code Item Nos. B6.150, B6.180, and B6.210, volumetric examinations of bolting on heat exchangers, pumps, and valves are limited to components selected for examination under Examination Categories B-B, B-J, B-L-2, and B-M-2.

3. ASME Section XI, Category B-G-1, Code Item Nos. B6.150, B6.160, and B6.170; Category B-G-2, Code Item No. B7.50; and Category C-D, Code Item No. C4.20 require inspection of 100% of bolts and studs at each bolted connection in piping selected for examination under Code Categories B-J and C-F. 4. ASME Section XI, Category B-G-2, Code Item Nos. B7.10, B7.40, B7.50, B7.60, and B7.70 require visual examination of all Class 1 bolts, studs, and nuts 2 inches and less in diameter in place under tension, when the connection is disassembled, or when the bolting is removed. 4. Reason for Request To avoid unnecessary inspections and to conserve radiological dose, while still maintaining an adequate level of quality and safety for examination of the affected bolting. Appendix A PP 7015 Rev. 5 Page 5 of 58

-___ ~ I- -~ __ APPENDIX A (Continued)

5. Proposed Alternative Bolting will be selected and examined in accordance with Code Case N-652. Specifically:

1. In accordance with Code Case N-652, Category B-G-1, Note 2, a surface examination of bolts and studs in heat exchangers, piping, pumps, and valves may be substituted for volumetric examination when the bolts or studs are removed.

2. In accordance with Code Case N-652, Category B-G-1, Note 4, volumetric examinations may be conducted on one heat exchanger, one pump, or one valve among a group of heat exchangers, pumps, or valves that are similar in design, type, and function.

In addition, when the component to be examined contains a group of bolted connections of similar design and size, such as flanged connections, examination may be conducted on one bolted connection among the group. -. -8, In accordance with Code Case N-652, Category B-G-1, Note 6; Category B-G-2, Note 3; and Category C-D, Note 4, examination of flanged piping bolting may be limited to one connection of a group of connections similar in design, size, function, and service. 4. In accordance with Code Case N-652, Category B-G-2, Note 1, bolting will only be examined when a connection is disassembled or the bolting is removed. (Effectively, the alternative only applies to piping bolting.)

Basis for Use The service experience of bolting throughout the industry is exemplary. Degradation is only associated with leakage and other provisions address examination of bolting at leaking connections.

1. New notes (Note 2 of Category B-G-1 and Note 5 of Category C-D in Code Case N-652) were added to Categories B-G-1 and C-D to allow surface examination to be substituted for volumetric examination when bolting is removed for the examination.

This recognizes that bolting failures initiate from the OD surface and that a surface exam is an acceptable technique for detection of such defects. The existing examination methods require volumetric examination of removed bolting greater than 2 inches, even when surface examination is at least an equal, and possibly a more appropriate, examination.

i I' I 1 t t : g ... i I Appendix A PP 7015 Rev. 5 Page 6 of 58 APPENDIX A (Continued)

I a 8 Code Case 307-2, in which examination of the borehole surfaces of bolts and studs was eliminated, demonstrates that cracking initiates on the outside surfaces of bolts and studs. For this reason, a qualified surface examination meeting the acceptance standards of IWB-35 15 would provide at least the sensitivity for flaw detection that an end shot ultrasonic examination would provide on bolts and studs that have been removed for examination. Consequently, when bolts or studs are removed for examination, either a surface or volumetric examination should be allowed. 2. Note 3 of Section XI Category B-G-1 was changed (Note 4 in Code Case N-652 Category B-G-1) to require heat exchangers, pumps, and valves to be grouped based on design, type, and function, and then one component among the group to be volumetrically examined during the interval.

In addition, if the component selected for examination included more than one bolted connection, then only one of those bolted connections is required to be examined.

The note was also revised to apply only to volumetric examination as a new note was added to address visual examination of bolting for heat exchangers, pumps, and valves. Reference to examination of bolting for piping was also removed as a new note was added to address this. Previously, the Code only required bolting for heat exchangers, pumps and valves to be examined when the component was selected for examination under Categories B-B, B-L-2, or B-M-2. These Categories require the components to be selected for examination only when the component is disassembled.

There appears to be no technical justification to tie volumetric examination of bolting to component disassembly.

This change makes the Class 1 requirements for volumetric examination of bolting on these type components identical to the existing Class 2 requirements.

Under existing Section XI examination rules, Category B-G-1 volumetric examination of bolted connections in heat exchangers, pumps, and valves is required only when the major component is disassembled for maintenance, repair, or volumetric examination.

This is inconsistent with, and actually less stringent than, the requirements of Category C-D, wherein volumetric examination of a sample of bolted connections in vessels, pumps and valves is required regardless of whether the component is disassembled for maintenance or repair. Therefore, even though bolting inspection will be performed under a sample program (one connection of like connections), the change made by Code Case N-652 is more restrictive in that it will require examination of Category B-G-1 bolting regardless of whether the connection is disassembled.

3. A new note (Note 6 in Code Case N-652, Category B-G-1) was added in Category B-G-1 to clarify the requirements for examination of flange bolting in piping systems. It requires examination of one bolted connection among a group of bolted connections that are similar to design, type, function, and service. Appendix A PP 7015 Rev. 5 Page 7 of 58 APPENDIX A (Continued)

A new Note 3 was added in Code Case N-652, Category B-G-2 to clarify the requirements for examination of flange bolting in piping systems. It requires examination of one bolted connection among a group of bolted connections that are similar to design, type, function, and service. Note 2 of Category C-D was editorially revised to clarify the language.

No technical changes were made to this note. Note 3 of Category C-D was revised to clarify the requirements for examination of flange bolting in piping systems.

It requires examination of one bolted connection among a group of bolted connections that are similar to design, type, function, and service. The current code requires examination of bolting for piping when the component is selected for examination under Categories

• 3-J or C-F, which is very difficult to comprehend. For bolting Categories B-G-1 and B-G-2 the existing notes require the examination of bolted connections in piping to be tied to components selected for examination under piping examination Category B-J. For bolting Category C-D, examination of bolted connections in piping is tied to piping examination Category C-F. These notes are confusing since it is difficult to limit examination of flange bolting in piping based on the piping welds selected for examination.

Therefore, even though bolting inspection will be performed under a sample program (one connection of like connections), the change made by Code Case N-652 is more restrictive in that it will require examination of piping bolting regardless of when the piping is selected under other Categories.

4. Note 1 of Category B-G-2 was revised to state that visual examination of bolting is required only when the connection is disassembled or removed. Note 2 of Category B-G-2 was revised to clarify that visual examination of bolting for vessels, pumps, and valves is required only when the component is examined under Category B-B, B-L-2, or B-M-2. Reference to examination of bolting for piping was also removed as a new note (Note 6 in Code Case N-652) was added to address this. The existing Section XI requires visual examination of this bolting when the component is "selected for examination. Note 1 for Category B-G-2 of Code Case N-652 clarifies that examination is only required when the component is disassembled.

It also clarifies that examination of any given bolted connection is required only once during the interval. The existing Section XI Category B-G-2 Note 1 states that bolting may be examined in place under tension, when connection is disassembled, or when bolting is removed. This revision recognizes the fact that visual examination on bolting in place and under tension is not meaningful.

Furthermore, the existing Section XI Category B-G-2 rules for piping do not tie the examination to disassembly of the connection as they do for heat exchangers, pumps, and valves.

t Appendix A PP 7015 Rev. 5 Page 8 of 58 APPENDIX A (Continued) 1 I_ i -1 'I Unlike volumetric examination, performing visual examinations of bolting while in place and under tension does not provide any meaningful information on the integrity of the bolting. Typically, the only portion of the bolting visible is the nuts and stud ends or the bolt head. Also, the only red degradation mechanism for flange bolting occurs when the connection is leaking. All Class 1 piping is subjected to a leakage test after each refueling outage and IWA-5000 already requires leaking flanges to be partially disassembled and the bolting to be examined for degradation. Performing a visual examination of bolting in place and under tension once every 10 years adds little value. This requirement is also inconsistent with the Class 1 rules for visual examination of bolting associated with heat exchangers pumps and valves, wherein the examination is tied to disassembly of the component.

For these reasons it is more appropriate to tie the examination of bolted connections in piping to disassembly of the flange.

Compliance with the proposed alternatives described above will provide an adequate level of quality and safety for examination of the affected welds, and will not adversely impact the health and safety of the public. ,. 6. Duration of Proposed Alternative It is proposed to use the alternative for the duration of the Vermont Yankee Fourth Ten-Year Interval (September 1,2003 through August 31,2013).

Appendix A PP 7015 Rev. 5 Page 9 of 58

1. 2. 3. 4. 5. APPENTXX A (Continued)

LICENSEEKJTILITY NAME - Entergy Nuclear Operations, Inc. PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEST FOR RELIEF NO. ISI-04 Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(i)

--Alternative Provides Acceptable Level of Quality and Safety- ASME Code Component(s) Affected ASME Section XI, Class 1, Examination Categories B-F, C-F-1, and C-F-2, Code Item Nos. B5.10, C5.11, C5.41, C5.51, and (25.81, Pressure Retaining Dissimilar Metal Welds in Reactor Vessel Nozzle-to-Safe-End Butt Welds 4 inch NPS and larger; Pressure Retaining Circumferential Welds and Branch Connection Welds in Austenitic Stainless Steel or High Alloy Piping 4 inch NPS and larger; and Pressure Retaining Circumferential Welds and Branch Connection Welds in Carbon or Low Alloy Steel Piping 4 inch NPS and larger Apulicable Code Edition and Addenda 1998 Edition with Addenda through 2000 Applicable Code Requirements Surface examination of essentially 100% of each weld requiring examination must be performed. All Category B-F welds 4 inch NPS and larger require surface examination.

Of the total population of non-exempt Category C-F-1 and C-F-2 piping welds greater than 4 inch NPS, 7.5%, but not less than 28 welds, require surface examination.

Reason for Request

'Trs avoid unnecessary inspections and to conserve radiological dose, while still maintaining an adequate level of quality and safety for examination of the affected welds. Proposed Alternative i I t> i. 1 I P- i. i , Surface examination of the subject welds (Categories B-F, C-F-1, and C-IF-2 4 inch NPS and larger) shall be conducted in accordance with Code Case N-663. All areas of the subject welds identified as susceptible to outside surface attack shall be surface examined during the Vermont Yankee Fourth Ten-Year Interval in accordance with Code Case N-663. [Code Case N-663 aIso includes Category B-J, but Vermont Yankee will examine Category B-J in accordance with Relief Request ISI-02.1 Appendix A PP 7015 Rev. 5 Page 10 of 58 APPENDIX A (Continued)

Basis for Use The subject item numbers in ASME Section XI require a voIumetric andor surface exam on selected piping welds to ensure that generic degradation mechanisms are not active on either the inside diameter (I.D.) or the outside diameter (O.D.). However, these welds are selected using a deterministic set of requirements that are un-informed as to any possible degradation mechanisms.

ASME Code Case N-663 provides an alternative to the current ,ASME Section XI requirements for defining the number and location of surface examinations for piping components . The ASME Section XI Task Group on IS1 Optimization, Report No. 92-01-01, Evaluation of In-service Inspection Requirements for Class 1, Category B-J Pressure Retaining Welds in Piping, dated July 1995, concluded (with 50 units responding with a total of 9333 welds inspected) only 2 welds (0.02%) were found to have flaws detected by Section XI surface examinations.

These flaws were determined to be fabrication-induced. In parallel with the above, several risk-informed Code cases have been developed for use on piping welds (e.g., ASME Code Cases N-560, N-577, and N-578). One of the methods for risk-informing piping examinations is via use of EPRI TR-112657, Rev. B-A, Revised Risk-Informed In-service Inspection Evaluation Procedure (NRC SER dated 1 OESB9). Table 4- 1, Summary of Degradation-Specific Inspection Requirements and Examination Methods, of the EPRI report lists the required degradation mechanisms to be evaluated in Class 1,2, and 3 piping. It also identifies the risk-informed examination method required for each of these degradation mechanisms.

The only degradation mechanism that requires a surface examination is O.D. chloride cracking.

These two initiatives led ASME to investigate the value of surface examinations.

Code Case N-663 incorporates lessons learned from the risk-informed initiatives and industry examination experience into Section XI by requiring that an evaluation be conducted to identify locations, if any, where a surface examination would be of benefit from a generic piping degradation perspective.

The results of this evaluation identify where O.D. degradation is most Iikely to occur by reviewing plant-specific programs and practices, and operating experience.

If the potential for degradation is identified, Code Case N-663 defines examination techniques, volumes, and frequencies.

As such, implementing Code Case N-663 will identify appropriate locations for surface examination, if any, and eliminate unnecessary examinations.

Other ASME Section XI examination requirements for the subject piping welds, including volumetric examinations and pressure testing, will continue to be performed. Examination requirements for other components, including Class 1 piping less than NPS 4, will continue to meet all Section XI requirements and are not subject to this request. Code Case N-663 was approved by the ASME Boiler and Pressure Vessel Code Committee on September, 17,2002, but has not yet been included in the most recent listing of NRC approved code cases provided in Revision 12 of Regulatory Guide 1.147, "In-service Inspection Code Case Acceptability - ASME Section XI Division 1 ." Appendix A PP 7015 Rev. 5 Page 11 of 58 APPENDIX A (Continued)

Compliance with the proposed alternatives described above will provide an adequate level of quality and safety for examination of the affected welds, and will not adversely impact the health and safety of the public. 6. Duration of Proposed Alternative It is proposed to use the alternative for the duration of the Vermont Yankee Fourth Ten-Year Interval (September 1,2003 through August 31,2013).

Appendix A PP 7015 Rev. 5 Page 12 of 58 m a -1 APPENDIX A (Continued)

WCENSEEnmWTY NAME - Entergy Nuclear Operations, Inc. PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEST FOR RELIEF NO. ISI-05 Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(i)

--Alternative Provides Acceptable Level of Quality and Safety- 1. ASME Code Component(s)

Affected Pressure Retaining Piping Welds subject to examination using procedures, personnel, and equipment qualified to ASME Section XI, Appendix Vm, Supplement 10 criteria.

2. Applicable Code Edition and Addenda 1998 Edition with '. 3. Applicable Code The following paragraphs or statements are from ASME Section XI, Appendix Vm, Supplement 10 and identify the specific requirements that are included in this request for relief: Item 1 - Paragraph l.l(b) states in part - Pipe diameters within a range of 0.9 to 1.5 times a nominal diameter shall be considered equivalent.

Item 2 - Paragraph l.l(d) states - All flaws in the specimen set shall be cracks. Item 3 - Paragraph l.l(d)(l) states - At least 50% of the cracks shall be in austenitic material.

At feast 50% of the cracks in austenitic material shall be contained wholly in weld or buttering material, At least 10% of the cracks shall be in ferritic material.

The remainder of the cracks may be in either austenitic or ferritic material.

Item 4 - Paragraph 1.2(b) states in part - The number of unflawed grading units shall be at least twice the number of flawed grading units. Item 5 - Paragraph 1.2(c)(l) and 1.3(c) state in part - At Ieast Y3 of the flaws, rounded to the next higher whole number, shall have depths between 10% and 30% of the nominal pipe wall thickness.

Paragraph 1.4(b) distribution table requires 20% of the flaws to have depths between 10% and 30%. Item 6 - Paragraph

2.0 first

sentence states - The specimen inside surface and identification shall be concealed from the candidate.

Appendix A PP 7015 Rev. 5 Page 13 of 58

4. 5. APPENDIX A (Continued)

Item 7 - Paragraph 2.2(b) states in part - The regions containing a flaw to be sized shall be identified to the candidate.

Item 8 - Paragraph 2.2(c) states in part - For a separate length-sizing test, the regions of each specimen containing a flaw to be sized shall be identified to the candidate.

Item 9 - Paragraph 2.3(a) states - For the depth sizing test, 80% of the flaws shall be sized at a specific location on the surface of the specimen identified to the candidate.

Item 10 - Paragraph 2.3(b) states - For the remaining flaws, the regions of each specimen containing a flaw to be sized shall be identified to the candidate.

The candidate shall determine the maximum depth of the flaw in each region. Item 11 - Table VIII-S2-1 provides the false call criteria when the number of unflawed grading units is at least twice the number of flawed grading units. Reason for Request Section XI, Appendix Vm, Supplement 10 has not kept pace with the experience gained administering the Performance Demonstration Initiative.

The proposed alternative is based on forthcoming Code action and was generated from a PDI model prepared by EPRI. Proaosed Alternative In lieu of the requirements of ASME Section XI, 1998 Edition, 2000 Addenda, Appendix Vm, Supplement 10, the proposed alternative described in the enclosure shall be used. The proposed alternative will be implemented through the PDI Program. A copy of the proposed revision to Supplement 10 is attached. It identifies the proposed alternatives and allows them to be viewed in context. It also identifies additional clarifications and enhancements for information.

It has been submitted to the ASh4E Code for consideration and as of December 2002 had been approved by the NDE Subcommittee.

Basis for Use Item 1 - The proposed alternative to Paragraph l.l(b) states: "The specimen set shall include the minimum and maximum pipe diameters and thicknesses for which the examination procedure is applicable.

Pipe diameters within a range of 1/2 in. (13 mm) of the nominal &meter shall be considered equivalent. Pipe diameters larger than 24 in. (610 mm) shall be considered to be flat. When a range of thicknesses is to be examined, a thickness tolerance of k25% is acceptable."

c< cs 1.. ! I m5n !F L Appendix A PP 7015 Rev. 5 Page 14 of 58 W d APPENDIX A (Continued) Technical Basis - The change in the minimum pipe diameter tolerance from 0.9 times the diameter to the nominal diameter minus 0.5 inch provides tolerances more in line with industry practice. Though the alternative is less stringent for small pipe diameters they typically have a thinner wall thickness than larger diameter piping. A thinner wall thickness results in shorter sound path distances that reduce the detrimental effects of the curvature.

This change maintains consistency between Supplement 10 and the recent revision to Supplement

2. Item 2 - The proposed alternative to Paragraph l.l(d) states: "At least 60% of the flaws shall be cracks; the remainder shall be alternative flaws. Specimens with IGSCC shall be used when available. Alternative flaws, if used, shall provide crack-like reflective characteristics and shall be limited to the case where implantation of cracks produces spurious reflectors that are uncharacteristic of actual flaws. Alternative flaw mechanisms shall have a tip width of less than or equal to 0.002 in. (.05 mm). Note, to a ative modifies instances of the tern "cracks" or "cracking" to the term "flaws" because of the use of alternative flaw mechanisms." Technical Basis - As illustrated below, implanting a crack requires excavation of the base material on at least one side of the flaw.

While this may be satisfactory for ferritic materials, it does not produce a useable axial flaw in austenitic materials because the sound beam, which normally passes only through base material, must now travel through weld material on at least one side, producing an unrealistic flaw response.

In addition, it is important to preserve the dendritic structure present in field welds that would otherwise be destroyed by the implantation process. To resolve these issues, the proposed alternative allows the use of up to 40% fabricated flaws as an alternative flaw mechanism under controlled conditions.

The fabricated flaws are isostatically compressed which produces ultrasonic reflective characteristics similar to tight cracks. Item 3 - The proposed alternative to Paragraph 1 . l(d)( 1) states: "At least 80% of the flaws shall be contained wholly in weld or buttering material.

At least one and a maximum of 10% of the flaws shall be in ferritic base material.

At least one and a maximum of 10% of the flaws shall be in austenitic base material." Technical Basis - Under the current Code, as few as 25% of the flaws are contained in austenitic weld or buttering material. Recent experience has indicated that flaws contained within the weld are the likely scenarios.

The metallurgical structure of austenitic weld material is ultrasonically more challenging than either ferritic or austenitic base material. The proposed alternative is therefore more challenging than the current Code. Appendix A PP 7015 Rev. 5 Page 15 of 58 APPENDIX A (Continued)

Item 4 - The proposed alternative to Paragraph 1.2(b) states: "Detection sets shall be selected from Table Vm-SlO-1.

The number of unflawed grading units shall be at least one and a half times the number of flawed grading units."

Technical Basis - Table S10-1 provides a statistically based ratio between the number of unflawed grading units and the number of flawed grading units.

The proposed alternative reduces the ratio to 1.5 times to reduce the number of test samples to a more reasonable number from the human factors perspective. However, the statistical basis used for screening personnel and procedures is still maintained at the same level with competent personnel being successful and less skilled personnel being unsuccessful.

The acceptance criteria for the statistical basis are in Table Vm-S 10- 1. Item 5 - The proposed alternative to the flaw distribution requirements of Paragraph 1.2(c)(l) (detection) and 1.3(c) (length) is to use the Paragraph 1.4(b) (depth) distribution table (see below) for all qualifications.

Flaw Depth Minimum 10-3096 20% 3 1-60% 20% 61- 100% 20% J% Wall Thickness)

Number of Flaws Techn and .-e proposed alternative uses the depth sizing distribution for both detection iuse it provides for a better distribution of flaw sizes within the test set. .LIIILA~. .i hilows candidates to perform detection, length, and depth sizing demonstrations d,Al--Lmeously utilizing the same test set. The requirement that at least 75% of the flaws shall be i I thz rmge 3f it -9 60% of wall thickness provides an overall distribution tolerance yet the d- 4' U' n uncerty;nty decreases the possibilities for testmanship that would be inherent to a ut; Tt must be noted that it is possible to achieve the same distribution utilizing

nts, but it is preferable to make the criteria consistent.

Item 6 - Thi; pruposed alternative to Paragraph

2.0 first

sentence states:

"For qualifications from the outside surface, the specimen inside surface and identification shall be concealed from the candidate.

When qualifications are performed from the inside surface, the flaw location and specimen identification shall be obscured to maintain a "blind test"." Technical Basis - The current Code requires that the inside surface be concealed from the candidate.

This makes qualifications conducted from the inside of the pipe (e.g., PWR nozzle to safe end welds) impractical.

The proposed alternative differentiates between ID and OD scanning surfaces?

requires that they be conducted separately, and requires that flaws be concealed from the candidate.

This is consistent with the recent revision to Supplement

2. Appendix A PP 7015 Rev. 5 Page 16 of 58 APPENDIX A (Continued)

Items 7 and 8 - The proposed alternatives to Paragraph 2.2(b) and 2.2(c) state: " ... containing a flaw to be sized may be identified to the candidate." Technical Basis - The current Code requires that the regions of each specimen containing a flaw to be length sized shall be identified to the candidate.

The candidate shall determine the length of the flaw in each region (Note, that length and depth sizing use the term "regions" whiIe detection uses the term "grading units" - the two terms define different concepts and are not intended to be equal or interchangeable).

To ensure security of the samples, the proposed alternative modifies the first "shall" to a "may" to allow the test administrator the option of not identifying specifically where a flaw is located. This is consistent with the recent revision to Supplement

2. Items 9 and 10 - The proposed alternative to Paragraph 2.3(a) and 2.3 (b) states: " ... regions of each specimen containing a Technical Basis - The current Code requires that a Iarge number of flaws be sized at a specific location.

The proposed alternative changes the "shall" to a "may" which modifies this from a specific area to a more generalized region to ensure security of sampIes. This is consistent with the recent revision to Supplement

2. It also incorporates terminology from length sizing for additional clarity. -i Q B Appendix A PP7015 Rev. 5 Page 17 of 58 APPENDIX A (Continued)

Item 11 - The proposed alternative modifies the acceptance criteria of Table VucI-S2-1 as follows: TABLE VIII-S PI -1 PERFORM AN CE DEMON STRATIO N DETECTION TEST AC C E PT A N C E C R 1TE RIA Detection Test False Call Test Acceptance Critera Acceptance Criteria No. of No. of Maximum Fiawed MiniMUm U n flawed Number Grading Detection Grading of False Units Criteria Units Calk c 7A n f 13 1 -- -I AU V ir-- Y ** - I Q AL4 L 0 I LO L - . - - .- - n 9 qa - 7 I AU L. 10 8 28- 15 3-2 11 9 2p- 17 3-3 2rt- 18 3-3 26 20 4-3 14 10 28- 21 5-3 15 11 38- 23 5-3 12 32- 24 b-. 4 M- 26 +4 A 36- 27 -- 4 19 13 3 29 -4 '0 14 48- m - Technical Basis - The proposed alternative is identified as new Table S10-1 above. It was modified to reflect the reduced number of unflawed grading units and allowable false calls. As a part of ongoing Code activities, PNM, has reviewed the statistical significance of these revisions and offered the revised Table S 10-1. Compliance with the proposed alternatives described above in Items 1 through 10 will provide an adequate level of quality and safety for examination of the affected welds, and will not adversely impact the health and safety of the public.

i i I. I 1 I LC, b Appendix A PP 7015 Rev. 5 Page 18 of 58 APPENDIX A (Continued)

6. Duration of Proposed Alternative It is proposed to use the alternative for the duration of the Vermont Yankee Fourth Ten-Year I Interval (September 1,2003 through August 31,2013).

7. Precedents This proposed alternative is essentially identical to the model provided by the Performance Demonstration Initiative on the EPRI website. Appendix A PP 7015 Rev. 5 Page 19 of 58 APPENDIX A (Continued)

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPIIvi; WELDS Current Requirement I Proposed Change I Reasoning

1.0 SPECIMEN

REQUIREMENTS Qualification test specimens shall meet the requirements listed herein, unless a set of specimens is designed to accommodate specific limitations stated in the scope of the examination procedure (e.g., pipe size, weld joint configuration, access limitations).

The same specimens may be used to demonstrate both detection and sizing qualification.

1.1 General. The specimen set shall conform to the following requirements. (a) Specimens shall have sufficient volume to minimize spurious reflections that may interfere with the interpretation process. .. 1'0 SCOPE supplement 10 is applicable to dissimilar

~,etal piping welds examined from either the ii.side or outside surface. Supplement 10 is not applicable to piping welds containing supplemental corrosion resistant clad (CRC) applied to mitigate Intergranular Stress Corrosion Cracking (IGSCC).

2.0 SPECINEN

REQUIREMENTS Qualification test specimens shall meet the requirements listed herein, unless a set of specimens is designed to accommodate specific limitations stated in the scope of the examination procedure (e.g., pipe size, weld joint configuration, access limitations). The same specimens may be used to demonstrate both detection and sizing qualification.

2.1 General. The specimen set shall conform to the following requirements. (a) The minimum number of flaws in a test set shall be ten. (b) Specimens shall have sufficient volume to minimize spurious reflections that may interfere with the intemretation mocess. A scope statement provides added clarity regardlng the applicable range of each individual Supplement.

The exclusion of CRC provides consistency between Supplement 10 and the recent revision to Supplement 2 (Reference BC 00-755). Note, an additional change identifying CRC as "in course of preparation" is being processed seoaratelv.

Renumbered No Change New, changed minimum number of flaws to 10 so sample set size for detection is consistent with length and depth sizing. Renumbered Appendix A PP 7015 Rev. 5 Page 20 of 58 Current Requirement 1 Proposed Change (b) The specimen set shall include the minimum and maximum pipe diameters and thicknesses for which the examination procedure is applicable.

Pipe diameters within a range of 0.9 to 1.5 times a nominal diameter shall be considered equivalent. Pipe diameters larger than 24 in. shall be considered to be flat. When a range of thicknesses is to be examined, a thickness tolerance of k25% is acceDtable.

Reasoning (c) The specimen set shall include examples of the following fabrication condition:

(1) geometric conditions that normally require &scrimination from flaws (e.g., counterbore or weld root conditions, cladding, weld buttering, remnants of previous welds, adjacent welds in close proximity); (c) The specimen set shall include the minimum and maximum pipe diameters and thicknesses for which the examination procedure is applicable.

Pipe diameters within a range of Yi in. (13 mm) of the nominal diameter shall be considered equivalent.

Pipe diameters larger than 24 in. (610 mm) shall be considered to be flat. When a range of thicknesses is to be examined, a thickness tolerance of A258 is acceptable. (d) The specimen set shall include examples of the following fabrication conditions:

(1) geometric and material conditions that normally require discrimination from flaws (e.g., counterbore or weld root conditions, cladding, weld buttering, remnants of previous welds, adjacent welds in close proximity, and weld repair areas); Renumbered, metricated, the change in pipe diameter tolerance provides consistency between Supplement 10 and the recent revision to Supplement

2. (Reference BC 00-755) Renumbered, changed "condition" to "conditions" Clarification, some of the items listed relate to material conditions rather than geometric conditions. Weld repair areas were added as a result of recent field experiences.

Appendix A PP 7015 Rev. 5 Page 21 of 58 APPENDIX A (Continued)

SUPPLEMENT 10 - QU.4LIFICATION REQUIREMENTS FOR DISSIMILAR 1 Current Requirement Proposed Change Reasoning (2) typical limited scanning surface conditions (e.g., diametrical shrink, single-side access due to nozzle and safe end external tapers). (d) All flaws in the specimen set shall be cracks. (1) At least 50% of the cracks shall be in austenitic material.

At least 50% of the cracks in austenitic material shall be contained wholly in weld or buttering material.

At least 10% of the cracks shall be in ferritic material.

The remainder of the cracks may be in either austenitic or ferritic material.

(2) typical limited scanning surface conditions (e.g., weld crowns, diametrical shrink, single-side access due to nozzle and safe end external tapers for outside surface examinations; and internal tapers, exposed weld roots, and cladding conditions for inside surface examinations).

Qualification requirements shall be satisfied separately for outside surface and inside surface examinations.

2.2 Flaw Location.

At least 80% of the flaws shall be contained wholly in weld or buttering material.

At least one and a maximum of 10% of the flaws shall be in ferritic base material.

At least one and a maximum of 10% of the flaws shall be in austenitic base material.

Differentiates between ID and OD scanning surface limitations. Requires that ID and OD qualifications be conducted independently (Note, new paragraph 2.0 (identical to old paragraph 1 .O) provides for alternatives when "a set of specimens is designed to accommodate specific limitations stated in the scope of the examination procedure.").

Deleted this requirement, because new paragraph

2.3 below

provides for the use of "alternative flaws" in lieu of cracks. Renumbered and re-titled. Flaw location percentages redistributed because field experience inhcates that flaws contained in weld or buttering material are probable and represent the more stringent ultrasonic detection scenario.

Appendix A PP 7015 Rev. 5 Page 22 of 58 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement Proposed Change I Reasoning (2) At least 50% of the cracks in austenitic base material shalI be either IGSCC or thermal fatigue cracks.

At least 50% of the cracks in ferritic material shall be mechanically or thermally induced fatigue cracks. - (3) At least 50% of the cracks shall be coincident with areas described in (c) above. 23 Flaw Type. (a) At least 60% of the flaws shall be cracks, the remainder shall be alternative flaws. Specimens with IGSCC shall be used when available.

Alternative flaws, if used, shall provide crack-like reflective characteristics and shall be limited to the case where implantation of cracks produces spurious reflectors that are uncharacteristic of actual flaws. Alternative flaw mechanisms shall have a tip width of less than or equal to 0.002 in. t.05 tnm). (b) At least 50% of the flaws shall be coincident with areas described in 2.l(d) above. Renumbered and re-titled. Alternative flaws are required for placing axial flaws in the HAZ of the weld and other areas where implantation of a crack produces metallurgical conditions that result in an unrealistic ultrasonic response.

This is consistent with the recent revision to Supplement 2 (Reference BC 00-755). The 40% limit on alternative flaws is needed to support the requirement for up to 70% axial flaws.

Metricated Renumbered.

Due to inclusion of "alternative flaws", use of "cracks" is no longer appropriate.

Appendix A PP 7015 Rev. 5 Page 23 of 58 SUPPLEMENT 10 - "UALIFICATI~

REQUIREMENTS FOR DISSIMILAR I IWi'rAlA G WELDS -- Current Requirement P &Xr ;$OB

• mge Reasoning - 1.4 I@. A depths shall be greater ha, the Y ripe wall thickness.

Flav shall . he nominal clad hick :<en plac ladding. Fla &*e samyi, ,hall be distributed as roll< Flaw Depth Minimum [ % Wall Thickness)

Number of Flaws 10-30% 20% 31-60% 20% 61-100% 20 % At least 75% of the flaws shall be in the range Of 10 t0 60% Of Wall thiCkneSS.

1.2 Detection

Specimens.

The specimen set shall include detection specimens that meet the following requirements. (a) Specimens shall be divided into grading units. Each grading unit shall include at least 3 in. of weld length. If a grading unit is designed to be unflawed, at least 1 in. of unflawed material shall exist on either side of the grading unit. The segment of weld length used in one grading unit shall not be used in another grading unit. Grading units need not be uniformly spaced around the pipe specimen.

Moved from old paragraph 1.3(c) and 1.4 and re-titled.

Consistency between detection and sizing specimen set requirements (e.g., 20% vs. 1/3 flaw depth increments, e.g., original paragraph 1.3(c))

Renumbered and re-titled and moved to paragraph 3.l(a). No other changes Renumbered to paragraph 3.l(a)(l).

No other changes.

Appendix A PP 7015 Rev. 5 Page 24 of 58 (b) Detection sets shall be selected from Table Vm-S2-1. The number of unflawed grading units shall be at least twice the number of flawed grading units. (c) Flawed grading units shall meet the following criteria for flaw depth, orientation, and type.

(1) All flaw depths shall be greater than 10% of the nominal pipe wall thickness.

At least 113 of the flaws, rounded to the next higher whole number, shall have depths between 10% and 30% of the nominal pipe wall thickness.

However, flaw depths shall exceed the nominal clad thickness when placed in cladding.

At least 1/3 of the flaws, rounded to the next whole number, shall have depths greater than 30% of the nominal pipe wall thickness.

(2) At least 30% and no more than 70% of the flaws, rounded to the next higher whole number, shall be oriented axially.

The remainder of the flaws shall be oriented circumferential1

y. 2.5 Flaw Orientation. (a) At least 30% and no more than 70% of the flaws, rounded to the next higher whole number, shall be oriented axially.

The remainder of the flaws shall be oriented circumferentially.

Moved to new paragraph 3.l(a)(2).

Flaw depth requirements moved to new paragraph 2.4, flaw orientation requirements moved to new paragraph 2.5, flaw type requirements moved to new paragraph 2.3, "Flaw Type". Deleted, for consistency in sample sets the depth distribution is the same for detection and sizing. Note, this distribution is applicable for detection and depth sizing. Paragraph 2.5@)( 1) requires that all length- sizing flaws be oriented circumferentially. Appendix A PP 7015 Rev. 5 Page 25 of 58 APPENDIX A (Continued)

SUPPLEMENT 10 - QUALIFICATTf

'V REQUIl~ "WNTS I+ OR DISSIMILAR 1 1.3 Length Sizing Specimens.

The specimen set shall include length-sizing specimens that meet the following requirements. (a) All length sizing flaws shall be oriented circumferentiallv.

Renumbered and re-titled and moved to new paragraph 3.2 Moved, included in new paragraph 3.2(a) (b) The minimum number of flaws shall be ten. Moved, included in new paragraph

2.1 above

(c) All flaw depths shall be greater than 10% of the nominal pipe wall thickness.

At least V3 of the flaws, rounded to the next higher whole number, shall have depths between 10% and 30% of the nominal pipe wall thickness.

However, flaw depth shall exceed the nominal clad thickness when placed in cladding.

At least 1/3 of the flaws, rounded to the next whole number, shall have depths greater than 30% of the nominal pipe wall thickness.

1.4 Depth

Sizing Specimens.

The specimen set shall include depth-sizing specimens that meet the following requirements. (a) The minimum number of flaws shall be ten. (b) Flaws in the sample set shall not be wholly contained within cladding and shall be distributed as follows: Moved, included in new paragraph

2.4 above

after revision for consistency with detection distribution Moved, included in new paragraphs 2.1,2.3, 2.4 Moved, included in new paragraph 2.1 Moved, potential conflict with old paragraph 1.2(c)( 1); "However, flaw depths shall exceed the nominal clad thickness when placed in cladding.". Revised for clarity and included in new paragraph

2.4 Appendix

A PP 7015 Rev. 5 Page 26 of 58 APPENDIX A (Continued)

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement I Proposed Change I Reasoning Flaw Depth Minimum I% Wall Thickness)

Number of Haws 10-30% 20% 31-60% 20% 61-100% 20% The remaining flaws shall be in any of the above categories.

c I 2.0 CONDUCT OF PERFORMANCE DEMONSTRATION The specimen inside surface and identification shall be concealed from the candidate.

All examinations shall be completed prior to grading the results and presenting the results to the candidate.

Divulgence of particular specimen results or candidate viewing of unmasked specimens after the performance (b) Sizing Specimen sets shall meet the following requirements.

(1) All length-sizing flaws shall be oriented circumferential1 y . (2) Depth sizing flaws shall be oriented as in 2S(a). 3.0 CONDUCT OF PERFORMANCE DEMONSTRATION For qualifications from the outside surface, the specimen inside surface and identification shd be concealed from the Candidate.

When qualifications are performed from the inside surface, the haw location and specimen identification shall be obscured to maintain a "blind test", All examinations shall be completed prior to grading the results and presenting the results to the candidate.

Divulgence of particular specimen results or candidate viewing of unmasked specimens after the performance demonstration is prohibited.

Moved, included in patagraph 2.4 for consistent applicability to detection and sizing samples.

Added for clarity Moved from old paragraph 1.3(a) Included for clarity. Previously addressed by omission (i.e., length, but not depth had a specific exclusionary statement)

Renumbered Differentiate between qualifications conducted from the outside and inside surface. Appendix A PP 7015 Rev. 5 Page 27 of 58 APPENDIX A (Continued) 6 iELiP : _I -- METAL PI' 1 SUPPLEMENT 10 - QUALIFICATION 1' UIREKENT' DISSIMILAR I

• Current Requirement prop^,- .-.nange -_ __. Reasoning - ---I - 3.1 Detection Qualificatioii. (a) The specimen set shall include detection specimens that meet the following requirements.

(1) Specimens shall be divided into grading units. Each grading unit shall include at least 3 in. (76 mm) of weld length.

If a grading unit is designed to be unflawed, at least 1 in. (25 mm) of unflawed material shall exist on either side of the grading unit. The segment of weld length used in 2.1 Detection Test. Flawed and unflawed grading units shall be randomly mixed umbered, moved text to paragraph 3.1 W(3) Renumbered, moved from old paragraph 1.2. Renumbered, moved from old paragraph 1.2(a). Metricated.

No other changes. (2) Detection sets shall be selected from Table VIII-S10-1.

The number of unflawed grading units shall be at least one and a half times the number of flawed grading units. (3) flawed and unflawed grading units shall be randomly mixed. Moved from old paragraph 1.2(b). Table revised to reflect a change in the minimum sample set to 10 and the application of equivalent statistical false call parameters to the reduction in unflawed grading units.

Human factors due to large sample size. Moved from old paragraph

2.1 Appendix

A PP 7015 Rev. 5 Page 28 of 58

.d - .- &I -- -* ii .I - APPENDIX A (Continued)

SUPPLEMEWI' 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WIELDS ____ 2.2 Length Sizing Test (a) The length-sizing test may be conducted separately or in conjunction with the detection test. (b) When the length-sizing test is conducted in conjunction with the detection test, and less than ten circumferential flaws are detected, additional specimens shall be provided to the candidate such that at least ten flaws are sized. The regions containing a flaw to be sized shall be identified to the candidate.

The candidate shall determine the length of the flaw in each region. ~ (c) For a separate length-sizing test, the regions of each specimen containing a flaw to be sized shall be identified to the candidate.

The candidate shall determine the length of the flaw in each region. (b) Examination equipment and personnel are qualified for detection when personnel demonstrations satisfy the acceptance criteria of Table VIII SlO-1 for both detection and false calls. 3.2 Length Sizing Test (a) Each reported circumferential flaw in the detection test shall be length sized. (b) When the length-sizing test is conducted in conjunction with the detection test, and less than ten circumferential flaws are detected, additional specimens shall be provided to the candidate such that at least ten flaws are sized.

The regions containing a flaw to be sized may be identified to the candidate.

The candidate shall determine the length of the flaw in each region. . (c) For a separate length-sizing test, the regions of each specimen containing a flaw to be sized may be identified to the candidate.

The candidate shall determine the length of the flaw in each region. ~~ ~ ~ Moved from old paragraph

3.1. Modified

to reflect the 100% detection acceptance criteria of procedures versus personnel and equipment contained in new paragraph 4.0 and the use of 1.5X rather than 2X unflawed grading units contained in new paragraph 3.l(a)(2).

Note, the modified table maintains the screening criteria of the original Table VIII-S2-1.

Renumbered Provides consistency between Supplement 10 and the recent revision to Supplement 2 (Reference BC 00-755). Change made to ensure security of samples, consistent with the recent revision to Supplement 2 (Reference BC 00-755). Note, length and depth sizing use the term "regions" while detection uses the term "grading units". The two terms define different concepts and are not intended to be equal or interchangeable.

Change made to ensure security of samples, consistent with the recent revision to Supplement 2 (Reference BC 00-755). Appendix A PP 7015 Rev. 5 Page 29 of 58 APPEND ' \(Continued)

SUPPLEMENT 10 - QUL, IFICATiOI!

EQUIRFVENTS FOR DISSIMILAR

2.3 Depth

Sizing Test (a) For the depth-sizing test, 80% of the flaws shall be sized at a specific location on the surface of the specimen identified to the candidate. (b) For the remaining flaws, the regions of each specimen containing a flaw to be sized shall be identified to the candidate.

The candidate shall determine the maximum depth of the flaw in each region. 5, eqbtL 'nt, and yth sizing when the .xsont, '!*flL izrYrr .. flaw/ .A measurements, as con LO :e :me bngths, is less than or 3.3 4zing 'I (a s,,.,rately or in conjunction with the detection test. For a separate depth-sizing test, the regions of each specimen containing a flaw to be sized may be identified to the candidate.

The candidate shall determine the maximum depth of the flaw in each region. (b) When the depth-sizing test is conducted in conjunction with the detection test, and less than ten flaws are detected, additional specimens shall be provided to the candidate such that at least ten flaws are sized. The regions of each specimen containing a flaw to be sized may be identified to the can&date.

The candidate shall determine the maximum depth of the flaw in each region. (c) Examination procedures, equipment, and personnel are qualified for depth sizing when the RMS error of the flaw depth measurements, as compared to the true flaw depths, is less than or equal to 0.125 in. (3 mm). qua 11. (1s wpth-sizing t~:st may be conducted Moved from old paragraph 3.2(a) includes inclusion of "when" as an editorial change.

Metricated.

Renumbered Change made to ensure security of samples, consistent with the recent revision to Supplement 2 (Reference BC 00-755). Change made to be consistent with the recent revision to Supplement 2 (Reference BC 00-755). Changes made to ensure security of samples, consistent with the recent revision to Supplement 2 (Reference BC 00-755). Moved from old paragraph 3.2(b).

Metricated.

Appendix A PP 7015 Rev. 5 Page 30 of 58 .. __ fl"n . . - r-

--uw-. - -- - ill APPENDIX A (Continued)

SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR METAL PIPING WELDS Current Requirement I Proposed Change I Reasoning

3.0 ACCEPTANCE

CRITERIA 3.1 Detection Acceptance Criteria. Examination procedures, equipment, and personnel are qualified for detection when the results of the performance demonstration satisfy the acceptance criteria of Table VIII-S2- 1 for both detection and false calls. 3.2 Sizing Acceptance Criteria - (a) Examination procedures, equipment, and personnel are qualified for length sizing the RMS error of the flaw length measurements, as compared to the true flaw lengths, is less than or equal to 0.75 inch. (b) Examination procedures, equipment, and personnel are qualified for depth sizing when the RMS error of the flaw depth measurements, as compared to the true flaw depths, is less than or equal to 0.125 in. ~~ ~-~ Delete as a separate category.

Moved to new paragraph detection (3.1) and sizing 3.2 and 3.3 Moved to new paragraph 3.l(b), reference changed to Table S 10 from S2 because of the change in the minimum number of flaws and the reduction in unflawed grading units from 2X to 1.5X. Deleted as a separate category.

Moved to new paragraph on length 3.2 and depth

3.3 Moved

to new paragraph 3.2(d), included word "when" as an editorial change. Moved to new paragraph 3.3(c) Appendix A PP 7015 Rev. 5 Page 31 of 58 SUPPLEMENT 10 - QUALIFICATION REQUIREMENTS FOR DISSIMILAR 7 METAL PIPING WLDS Current Requirement I Proposed Change I Reasoning

4.0 PROCEDURE

QUALIFICATION Procedure qualifications shall include the following additional requirements. (a) The specimen set shall include the equivalent of at least three personnel sets. Successful personnel demonstrations may be combined to satisfy these requirements. (b) Detectability of ail flaws within the scope of the procedure shall be demonstrated.

Length and depth sizing shall meet the requirements of paragraph 3.2 and 3.3. (c) At least one successful personnel demonstration has been performed. (d) To qualify new values of essential variables, at least one personnel qualification set is required.

New New. Based on experience gained in conducting qualifications, the equivalent of 3 personnel sets (i.e., a minimum of 30 flaws) is required to provide enough flaws to adequately test the capabilities of the procedure.

Combining successful demonstrations allows a variety of examiners to be used to qualify the procedure.

Detectability of each flaw within the scope of the procedure is required to ensure an acceptable personnel pass rate.

The last sentence is equivalent to the previous requirements and is satisfactory for expanding the essential variables of a previously qualified procedure Appendix A PP 7015 Rev. 5 Page 32 of 58

-i u L.-r II d*IL+i APPENDIX A (Continued)

TABLE VIII-S P -1 PERFORMANCE DEMONSTRATION DETECTION TEST ACCEPTANCE C RITE RIA False Call Test Detection Test Acceptance Critera Acceptance Criteria No. of No. of Maximum Minimum U nflawed Number Fiawed Grading Detection Grading of False Units Criteria Units Calls 10 11 12 13 14 15 16 17 18 19 20 8 9 9 10 10 11 12 12 13 13 I4 28- 15 29- 17 2+ 18 26- 20 28- 21 38- 23 32- 24 34- 26 36- 27

• 29 48- 311 -2 3-3 3-3 4-3 5-3 5-3 6.4 b4 -+- 4 -4 *c Appendix A PP 7015 Rev. 5 Page 33 of 58 APPENDIX A (Continued)

LICENSEEYUTILITY NAME - Entergy Nuclear Operations, Inc. PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEsT FOR RELIEF NO. ISI-06 On hold I Appendix A PP 7015 Rev. 5 Page 34 of 58

.I !: I1 "7 APPENDIX A (Continued)

LICENSEIWTILITY NAME - Entergy Nuclear Operations, Inc. PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEST FOR RELIEF NO. ISI-07 Information to Support NRC Re-Approval of a 10CFR50.55a Request for Use During a New 10-Year Interval 1. Previous 10CFR50.55a Request Amroved bv NRC Vermont Yankee letter to USNRC, BVY 00-102, dated October 31,2000, (Reference 3 below) requested approval to use an alternate inspection frequency for Category E Weld Repair Overlays (ASME Section XI, Class 1, Examination Category B-F, Code Item No. B5.10, Pressure Retaining Dissimilar Metal Welds in Vessel Nozzles) in accordance with BWRVIP-75 (Reference 1 below) and the NRC's SE on that document (Reference 2 below). USNRC letter to Vermont Yankee, NVY 01-21, dated March 22,2001 (Reference 4 below), reviewed and approved that request. In the Final SE of BWRVIP-75, dated May 14,2001, (Reference 5 below) the USNRC only stipulated that for Category E welds the licensee include a note stating which welds are made of non-resistant materials. Per the original submittal (BVY 00-102 - Reference 3), the overlays were installed using Inconel 82, which is considered material resistant to IGSCC, as stated in Appendix A of the original USNRC SE to BWRVIP-75 (Reference 2). 2. Changes to the ApDlicable ASME Code Section 8 Neither the ASME Section XI, 1986 Edition nor the Section XI, 1998 Edition with 2000 Addenda addresses structural overlays.

3. Component AeinP Factors '1 ..I Component aging factors are addressed in the NRC's SE of BWRVIP-75, dated September 15, 2000 (Reference 2). 4. Changes in Technolow for Inspecting the Affected ASME Code Components Ultrasonic inspection of overlaid components has been conducted in accordance with techniques qualified under the auspices of the three-party NDE Coordination Plan, which the NRC endorsed in GL 88-01. These techniques have been generally improved since their initial use and help support the basis as offered in BWRVIP-75 (Reference 1). Appendix A PP 7015 Rev. 5 Page 35 of 58

5. 6. 7. I I APPENDIX A (Continued)

Confirmation of Renewed Applicability The relief granted for Vermont Yankee's Third Interval is still applicable for the Fourth Interval.

BWRVIP-75, published in October 1999, and the NRC's Safety Evaluation of BWRVIP-75 are still the current applicable guidance documents for inspection of structurally overlaid components. Duration of Re-Approved 10CFR50.55a Request It is proposed to use the alternative for the duration of the Vermont Yankee Fourth Ten-Year Interval (September 1,2003 through August 31,2013).

References

1. 2. BWRVIP-75, dated October 1999, 'Technical Basis for Revisions to Generic Letter 88-01 Inspection ScheduIes" Letter, USNRC toBWRVIP, dated September 15,2000, "Safety Evaluation of the 'BWRVIP Technical Basis for Revisions to Generic Letter 88-01 Inspection Schedules (BWRVIP-75)'

EPRI Report TR-113932, October 1999" Vermont Yankee letter to USNRC, BVY 00-102, dated October 31,2000, "Request for Alternate Inspection Frequency for Weld Repair Overlays" USNRC letter to Vermont Yankee, NVY 01-21, dated March 22,2001,"Vennont Yankee Nuclear Power Station, Review of a Request for an Alternate Inspection Frequency for Overlay Repaired Welds" Letter, USNRC toBWRVIP, dated May 14,2002, "Final Safety Evaluation of the 'BWRVIP Technical Basis for Revisions to Generic Letter 88-01 Inspection Schedules (l3WRVIP-75)'

EPRI Report TR-113932, October 1999"

3. 4. 5. ! I I Appendix A PP 7015 Rev. 5 Page 36 of 58 APPENDM A (Continued)

LICENSEEAJTILITY NAME - Entergy Nuclear Operations, Inc. PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEST FOR RELIEF NO.

ISI-OS Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(i)

-- AIternative Provides Acceptable Level of Quality and Safety- 1. ASME Code Componentk)

Affected ASME Section XI, Class 1, Examination Category B-A, Item No. B1.10 Longitudinal and Circumferential Shell Welds and B1.20 Head Welds subject to Appendix Vm, Supplement 4, examination.

2. Applicable Code Edition and Addenda 1998 Edition with Addenda through 2000 3. ADplicable Code Requirements 10CFR50.55a(b)(2) was amended to reference Section XI of the Code through the 1998 'Edition with the 2000 Addenda. lOCFR56.55a(b)(2)(xv)(C)(l) requires a depth sizing acceptance criteria of 0.15 inch root mean square (RMS) be used in lieu of the requirements of ASME Section XI, 1998 Edition with the 2000 Addenda, Appendix VIII, Supplement 4, Subparagraph 3.20). However, Supplement 4, Subparagraph 3.2(c) contains additional criteria for performance demon parameters be satisfied.

on depth sizing and requires that results be plotted and certain statistical

4. Reason for Reauest Section XI, Appendix VlII, Supplement 4 has not kept pace with the experience gained administering the Performance Demonstration Initiative.

The NRC recognized this and provided extensive verbiage in 10CFR50.55a(b)(2) to correct this shortcoming. However, this request for an alternative corrects what is perceived to be a publishing mistake in the rule.

It is based on a model prepared by EPRI for the PDI. 5. Proposed Alternative In lieu of the depth sizing requirements of ASME Section XI, 1998 Edition, 2000 Addenda, Appendix VIII, Supplement 4, Subparagraph 3.2(c), a depth sizing qualification criteria of 0.15 RMSE will be used [as stated in lOCF'R50.55a(b)(2)(xv)(C)(l)].

The proposed alternative will be implemented through the PDI Program. Appendix A PP 7015 Rev. 5 Page 37 of 58 APPENDIX A (Continued)

Basis for Use In a public meeting on October 11,2000 at NRC offices in White Flint, h4D (Reference l), the PDI identified the discrepancy between the Subparagraph 3.2(c) and the PDI program. The NRC agrees that Paragraph lOCFR50.55a(b)(2)(xv)(C)( 1) should have excluded Subparagraph 3.2(c) as a requirement.

The US. nuclear utilities created the PDI to implement demonstration requirements contained in Appendix VIJI. PDI developed a performance demonstration program for qualifying UT techniques.

In 1995, the NRC staff performed an assessment of the PDI program and reported that there were differences between Appendix Vm and the way PDI was implementing the program, but did not take exception to PDI's implementation.

The staff requested that the differences between PDI and the Code be resolved.

The solution for resolving the differences between the PDI program and the Code was for PDI to participate in development of a Code case that reflected PDI's program. The Code Case was presented to ASME for discussion and consensus building.

NRC representatives participated in this process. ASME approved the Code Case and published it as Code Case N-622, "Ultrasonic Examination of RPV and Piping, Bolts and Studs,Section XI, Division 1." Operating in parallel with the actions of PDI, the staff incorporated most of Code Case N-622 criteria in the rule published in the Federal Register, 64 FR 51370. lOCFR 50.55a(b)(2)(xv) was subsequently revised in Federal Register, 67FR187. Appendix IV to Code Case N-622 contains the proposed alternative sizing criteria, which has been authorized by the staff. The staff agrees that the inclusion of the statistical sizing parameters of Paragraph 3.2(c) of Supplement 4 to Appendix VII was an oversight.

L f Compliance with the proposed alternatives described above will provide an adequate level of quality and safety for examination of the affected welds, and will not adversely impact the health and safety of the public. 6. Duration of Proposed Alternative It is proposed to use the alternative for the duration of the Vermont Yankee Fourth Ten-Year Interval (September 1,2003 through August 31,2013).

7. Precedents This proposed alternative is derived from the model provided by the Performance Demonstration Initiative on the EPRI website.

8. References

1. USNRC Letter from D. G. Naujock to E. J. Sullivan, dated November 13,2000, "Summary of Public Meeting Held On October 1 1,2000, with PDI Representatives" Appendix A PP 7015 Rev. 5 Page 38 of 58

1. 2. 3. 4. 5. APPENDIX A (Continued)

LICENSEE/UTILITY NAME - Entergy Nuclear Operations, Inc. PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEST FOR RELIEF NO. ISI-09 Proposed Alternative In Accordance with lOCFR50.55a(a)(3)(i)

--Alternative Provides Acceptable Level of Quality and Safety- ASME Code Componentk)

Affected ASME Section XI, Class 1, Examination Category B-D, Item B3.90 - Pressure Retaining Nozzle-to-Vessel Welds Aualicable Code Edition and Addenda 1998 Edition with Addenda through 2000 Apdicable Code RequirementsSection XI, Figure IWB-2500-7(b) specifies the examination volume for nozzle-to-vessel welds. Reason for Request To decrease the amount of time performing examination of unnecessary weld volume and to conserve radiological dose, while still maintaining an adequate level of quality and safety for examination of the affected welds. Proposed Alternative In lieu of the requirements of ASME Section XI, 1998 Edition, 2000 Addenda, Figure IWB-2500-7@), it is proposed to use the alternative examination volume requirements of Code Case N-613 and its Figure 2. Basis for Use The examination volume for the reactor vessel pressure retaining nozzle-to-vessel welds extends far beyond the weld into the base metal, and is unnecessarily Iarge. This prolongs the examination time significantly, and results in no net increase in safety, as the area being examined is a base metal region which is not prone to in-service cracking and has been extensively examined before the vessel was put into service, in addition to the first, second, and third interval examinations.

Appendix A PP 7015 Rev. 5 Page 39 of 58

~ L 6. 7. APPENDIX A (Continued)

Code Case N-613 reduces the examination volume next to the widest part of the weld from half of the vessel wall thickness to one-half (1/2) inch. This removes examination of the base metal that was extensively examined during construction and in three subsequent in-service inspections.

This region is not in the high residual stress region associated with the weld; cracks, should they initiate, occur in the high-stressed areas of the weld.

These high-stressed areas are contained in the volume that is defined by Code Case N-613 and are subject to examination.

Code Case N-613 also eliminates the requirement to detect flaws perpendicular to the weld-base metal interface; however, relief for this aspect of Code Case N-613 is not being sought.

Compliance with the proposed alternatives described above in the above items will provide an adequate level of quality and safety for examination of the affected welds, and will not adversely impact the health and safety of the public.

Duration of Proposed Alternative It is proposed to use the alternative for the duration of the Vermont Yankee Fourth Ten-Year Interval (September 1,2003 through August 31,2013).

Precedents This proposed alternative is essentially identical to the model provided by the Performance Demonstration Initiative on the EPRI website. I, I' Appendix A PP 7015 Rev. 5 Page 40 of 58 APPENDIX A (Continued)

LICENSEE/UTILITY NAME - Entergy Nuclear Operations, Inc. PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEST FOR RELIEF NO. ISI-10 Proposed Alternative In Accordance with lOCFR50.55a(a)(3)(i) --Alternative Provides Acceptable Level of Quality and Safety- 1. ASME Code Comwnentk)

Affected ASME Section XI, Class 1, Pressure Retaining Welds in Piping, subject to Appendix Vm, Supplement 1 1 , examination.

Aadicable Code Edition and Addenda 1998 Edition with Addenda through 2000 2. 3. Applicable Code Requirements The Code requirements for which relief is requested are all contained within Appendix Vm, Supplement

11. For example, paragraph l.l(d)(l), requires that all base metal flaws be cracks. Paragraph 1.1 (e)( 1) requires that at least 20% but less than 40% of the flaws shall be oriented within f20 deg. of the pipe axial direction. Paragraph 1.1 (e)( 1) also requires that the rules of IWA-3300 shall be. used to determine whether closely spaced flaws should be treated as single or multiple flaws.

Paragraph 1 . l(e)(Z)(a)( 1) requires that a base grading unit shall include at least 3 in. of the length of the overlaid weld. Paragraph l.l(e)(Z)(b)(l) requires that an overlay grading unit shall include the overlay material and the base metal-to-overlay interface of at least 6 sq. in. The overlay grading unit shall be rectangular, with minimum dimensions of 2 in. Paragraph 3.2(b) requires that all extensions of base metal cracking into the overlay material by at least 0.1 in. are reported as being intrusions into the overlay material.

4. Reason for Request Section XI, Appendix VIII, Supplement 11 has not kept pace with the experience gained administering the Performance Demonstration Initiative. The proposed alternative is based on forthcoming Code action and was generated from a PDI model prepared by EPRI. 5. Proposed Alternative In lieu of the requirements of ASME Section XI, 1998 Edition, 2000 Addenda, Appendix Vm, Supplement 1 1, the proposed alternative described in the enclosure shall be used. The proposed alternative will be implemented through the PDI Program. Appendix A PP 7015 Rev. 5 Page 41 of 58 APPENDIX A (Continued)

Basis for Use Paragraph 1.1 (d)( l), requires that all base metal flaws be cracks. As illustrated below, implanting a crack requires excavation of the base material on at least one side of the flaw. While this may be satisfactory for femtic materials, it does not produce a useable axial flaw in austenitic materials because the sound beam, which normally passes only through base material, must now travel through weld material on at Ieast one side, producing an unrealistic flaw response.

To resolve this issue, the PDI program revised this paragraph to allow use of alternative flaw mechanisms under controlled conditions.

For example, alternative flaws shall be limited to when impIantation of cracks precludes obtaining an effective ultrasonic response, flaws shall be semi-elliptical with a tip width of less than or equal to 0.002 inches, and at least 70 percent of the flaws in the detection and sizing test shall be cracks and the remainder shall be alternative flaws. .GllL or disc, I I ZBWR( cum 't;& 1 allow closer spacing of flaws provided they didn't interfere with detection 1 he existing specimens used to date for qualification to the Tri-party

..PRI) agreement have a flaw population density greater than allowed by the .irements. These samples have been used successfully for all previous ':k.-5: - m kr the Tri-party agreement program. To facilitate their use and provide Crrnn the Tri-party agreement program to Supplement 11, the PDI Program has :A-3300 for proximity flaw evaluation in paragraph

1. l(e)( 1) was mer& requirerk.

inbl. detect, require th, a base metal grading unit include at least 1 in. of the length of the overlaid weld, rat;-&x than 3 inches; paragraph l.l(e)(2)(a)(3) was modified to require sufficient unflawed overlaid weld and base metal to exist on all sides of the grading unit to preclude interfering reflections from adjacent flaws, rather than the I inch requirement of Supplement 11; paragraph l.l(e)(2)(b)(I) was modified to define an overlay fabrication grading unit as including the overlay material and the base metal-to-overlay interface for a length of at least 1 in, rather than the 6 sq. in. requirement of Supplement 11 ; and paragraph l.l(e)(2)(b)(2) states that overlay fabrication grading units designed to be unflawed shall be separated by unflawed overlay material and unflawed base metal-to-overlay interface for at least 1 in. at both ends, rather than around its entire perimeter. *st specimens into their weld overlay program.

For example: the '""ed, 11 - indications will be sized based on their individual merits; paragraph l.l(d)(l) .j the statement that intentional overlay fabrication flaws shall not interfere with ultrasonic r characterization of the base metal flaws; paragraph l.l(e)(2)(a)(l) was modified to [: f I i b. Appendix A PP 7015 Rev. 5 Page 42 of 58 1 d APPENDIX A (Continued)

Additionally, the requirement for axially oriented overlay fabrication flaws in paragraph l.l(e)(l) was excluded from the PDI Program as an improbable scenario. Weld overlays are typically applied using automated gas tungsten arc welding techniques with the filler metal being appIied in a circumferential direction. Because resultant fabrication induced discontinuities would also be expected to have major dimensions oriented in the circumferential direction axial overlay fabrication flaws are unrealistic.

The requirement in paragraph 3.2(b) for reporting all extensions of cracking into the overlay is omitted from the PDI Program because it is redundant to the RMS calculations performed in paragraph 3.2(c) and its presence adds confusion and ambiguity to depth sizing as required by paragraph 3.2(c).

This also makes the weld overlay program consistent with the Supplement 2 depth sizing criteria.

PDI has submitted these changes as a Code Case and they have been approved, but the Code Case will not be published until later in 2002. A detailed comparison matrix between Supplement 11, the proposed ASME Section XI Code Case N-654, and the PDI Program is enclosed as supporting documentation.

The first column identifies the current requirements in the 95 Edition and 96 Addenda of Supplement 11, while the second (middle) column identifies the changes made by the Code Case. . There are however some additional changes that were inadvertently omitted from the Code Case. The most important change is paragraph l.l(a)(l) where the phrase "and base metal on both sides", was inadvertently included in the description of a base metal grading unit. The PDI program intentionally excludes this requirement because some of the qualification samples include flaws on both sides of the weld.

To avoid confusion several instances of the term "cracks" or "cracking" were changed to the term "flaws" because of the use of alternative flaw mechanisms. Additionally, to avoid confusion, the overlay thickness tolerance contained in paragraph l.l(b) last sentence, was reworded and the phrase ad the remainder shall be altemativefluws" was added to the next to last sentence in paragraph 1 . l(d)(l). These changes are identified by bold print in the third column of the enclosure.

Compliance with the proposed alternatives described above in the above items will provide an adequate level of quality and safety for examination of the affected welds, and will not adversely impact the health and safety of the public. 6. Duration of Proposed Alternative It is proposed to use the alternative for the duration of the Vermont Yankee Fourth Ten-Year Interval (September 1,2003 through August 31,2013).

7. Precedents This proposed alternative is essentially identical to the model provided by the Performance Demonstration Initiative on the EPRI website. Appendix A PP 7015 Rev. 5 Page 43 of 58 APPENDIX A (Continued)

1.0 SPECIMEN

REQUIKEMENTS Qualification test specimens shall meet the requirements listed herein, unless a set of specimens is designed to accommodate specific limitations stated in the scope of the examination procedure (e+, pipe size, weld joint configuration, access limitations).

The same specimens may be used to demonstrate both detection and sizing qualification.

1.1 General. The specimen set shall conform to the following requirements. (a) Specimens shall have sufficient volume to minimize spurious reflections that may interfere with the interpretation process. (b) The specimen set shall consist of at least CC N-654 No Change No Change No Change No Change PDI Program No Change No Change No Change (b) The specimen set shall consist of at least three specimens having different nominal pipe diameters and overlay thicknesses. They shall include the minimum and maximum nominal pipe diameters for which the examination procedure is applicable.

Pipe diameters within a range of 0.9 to 1.5 times a nominal diameter shall be considered equivalent.

If the procedure is applicable to pipe diameters of 24 in. or larger, the specimen set must include at least one specimen 24 in. or larger but need not include the maximum diameter.

The specimen set shall include specimens with overlays not thicker than 0.1 in. more than the minimum thickness, nor thinner than 0.25 in. of the maximum nominal overlay thickness for which the examination procedure is applicable.

Appendix A PP 7015 Rev. 5 Page 44 of 58 (c) The surface condition of at least two specimens shall approximate the roughest surface condition for which the examination procedure is applicable. (d) Flaw Conditions (I) Base metalflaws.

All flaws must be cracks in or near the butt weld heat-affected zone, open to the inside surface, and extending at least 75% through the base metal wall. Flaws may extend 100% through the base metal and into the overlay material; in this case, intentional overlay fabrication flaws shall not interfere with ultrasonic detection or characterization of the cracking.

Specimens containing IGSCC shall be used when available.

APPENDIX A (Continued)

No Change (1) Base metal flaws. All flaws must be in or near the butt weld heat-affected zone, open to the inside surface, and extending at least 75 % through the base metal wall. Intentional overlay fabrication flaws shall not interfere with ultrasonic detection or characterization of the cracking. Specimens containing IGSCC shall be used when available.

At least 70 percent of the flaws in the detection and sizing tests shall be cracks. Alternative flaw mechanisms, if used, shall provide crack-like reflective characteristics and shall be Limited by the following: (a) Flaws shall be limited to when implantation of cracks precludes obtaining a realistic ultrasonic response. (b) Flaws shall be semielliptical with a tip width of less than or equal to 0.002 inches. No Change PDI Program (1) Base metal flaws.

All flaws must be in or near the butt weld heat-affected zone, open to the inside surface, and extending at least 75% through the base metal wall. Intentional overlay fabrication flaws shall not interfere with ultrasonic detection or characterization of the base metal flaws. Specimens containing IGSCC shall be used when available.

At least 70 percent of the flaws in the detection and sizing tests shall be cracks and the remainder shall be alternative flaws. Alternative flaw mechanisms, if used, shall provide crack-like reflective characteristics and shall be limited by the following: (a) Flaws shall be limited to the cases where implantation of cracks produces spurious reflectors that are uncharacteristic of actual flaws. (b) Flaws shall be semielliptical with a tip width of less than or equal to 0.002 inches. Appendix A PP 7015 Rev. 5 Page 45 of 58 APPENDIX A (Continued)

(2) Overlay fabrication flilws. At least 40% of the flaws shall be non-crack fabrication flaws (e.g., sidewall lack of fusion or laminar lack of bond) in the overlay or the pipe-to-overlay interface.

At least 20% of the flaws shall be cracks. The balance of the flaws shall be of either type. (e) Detection Specimens (1) At least 20% but less than 40% of the flaws shall be oriented within rt20 deg. of the pipe axial direction.

The remainder shall be oriented circumferentially.

Flaws shall not be open to any surface to which the canddate has physical or visual access. The rules of IWA-3300 shall be used to determine whether closely spaced flaws should be treated as single or multiple flaws. (2) Specimens shall be divided into base and over-lay grading units. Each specimen shall contain one or both types of grading units. (u)(Z) A base grading unit shall include at least 3 in. of the length of the overlaid weld. The base grading unit includes the outer 25% of the overlaid weld and base metal on both sides. The base grading unit shall not include the inner 75% of the overlaid weld and base metal overlay material, or base metal-to-overlay interface.

No Change (1) At least 20% but less than 40% of the base metal flaws shall be oriented within &20 deg. of the pipe axial direction. The remainder shall be oriented circumferentially.

Flaws shall not be open to any surface to which the candidate has physical or visual access. (2) Specimens shall be divided into base metal and overlay fabrication grading units. Each specimen shall contain one or both types of grading units. Flaws shall not interfere with ultrasonic detection or characterization of other flaws. (u)(l) A base metal grading unit shall include at least 1 in. of the length of the overlaid weld. The base metal grading unit includes the outer 25% of the overlaid weld and base metal on both sides. The base metal grading unit shall not include the inner 75% of the overlaid weld and base metal overlay material, or base metal-to-overlay interface.

No Change PDI Program (1) At least 20% but less than 40% of the base metal flaws shall be oriented within SO deg. of the pipe axial direction.

The remainder shall be oriented circumferentially.

Flaws shall not be open to any surface to which the candidate has physical or visual access. (2) Specimens shall be divided into base metal and overlay fabrication grading units. Each specimen shall contain one or both types of grading units. Flaws shall not interfere with ultrasonic detection or characterization of other flaws. (a)( 1) A base metal grading unit includes tbe overlay material and the outer 25 % of the original overlaid weld. The base metal grading unit shall extend circumferentially for at least 1 in. and shall start at the weld centerline and be wide enough in the axial direction to encompass one half of the original weld crown and a minimum of 0.50" of the adjacent base material.

Appendix A PP 7015 Rev. 5 Page 46 of 58 P' 'i:

APPENDIX A (Continued)

~ (a)(2) When base metal craclung penetrates into the overlay material, the base grading unit shall include the overlay metal within 1 in. of the crack location.

This portion of the overlay material shall not be used as part of any overlay grading unit. (a)(3) When a base gradmg unit is designed to be unflawed, at least 1 in. of unflawed overlaid weld and base metal shall exist on either side of the base grading unit. The segment of weld length used in one base grading unit shall not be used in another base grading unit. Base grading units need not be uniformly spaced around the specimen. (b)(l) An overlay grading unit shall include the overlay material and the base metal-to-overlay interface of at least 6 sq. in. The overlay grading unit shall be rectangular, with minimum dimensions of (a)(2) When base metal cracking penetrates into the overlay material, the base metal grading unit shall not be used as part of any overlay fabrication grading unit. (a)(3) Sufficient unflawed overlaid weld and base metal shall exist on all sides of the grading unit to preclude interfering reflections from adjacent flaws. (b)(l) An overlay fabrication grading unit shall include the overlay material and the base metal-to-overlay interface for a length of at least 1 in. (a)(2) When base metal flaws penetrate into the overlay material, the base metal grading unit shall not be used as part of any overlay fabrication grading unit. (a)(3) Sufficient unflawed overlaid weld and base metal shall exist on all sides of the grading unit to preclude interfering reflections from adjacent flaws. (b)(l) An overlay fabrication gradmg unit shall include the overlay material and the base metal-to-overlay interface for a length of at least 1 in. Appendix A PP 7015 Rev. 5 Page 47 of 58 APPENDIX A (Continued) (b)(2) An overlay grading unit des, gned to be unflawed shall be surrounded by unflawed overlay material and unflawed base metal-to-overlay interface for at least 1 in. around its entire perimeter.

The specific area used in one overlay grading unit shall not be used in another overlay grading unit. Overlay grading units need not be spaced uniformly about the specimen. (b)(3) Detection sets shall be selected from Table VIII-S2- 1. The minimum detection sample set is five flawed base grading units, ten unflawed base grading units, five flawed overlay grading units, and ten unflawed overlay grading units. For each type of grading unit, the set shall contain at least twice as many unflawed as flawed grading units. (b)(2) Overlay fabrication grading units designed to be urdlawed shall be separated by unflawed overlay material and unflawed base metal-to-overlay interface for at least 1 in. at both ends.

Sufficient unflawed overlaid weld and base metal shall exist on both sides of the overlay fabrication grading unit to preclude interfering reflections from adjacent flaws. The specific area used in one overlay fabrication grading unit shall not be used in another overlay fabrication grading unit. Overlay fabrication grading units need not be spaced uniformly about the specimen. (b)(3) Detection sets shall be selected from Table VIII-S2-1.

The minimum detection sample set is five flawed base metal grading units, ten unflawed base metal grading units, five flawed overlay fabrication grading units, and ten unflawed overlay fabrication grading units. For each type of grading unit, the set shall contain at least twice as many unflawed as flawed grading units. For initial procedure qualification, detection sets shall include the equivalent of three personnel qualification sets.

To qualify new values of essential variables, at least one personnel qualification set is required. (b)(2) Overlay fabrication gradmg units designed to be unflawed shall be separated by unflawed overlay material and unflawed base metal-to-overlay interface for at least 1 in. at both ends. Sufficient unflawed overlaid weld and base metal shall exist on both sides of the overlay fabrication grading unit to preclude interfering reflections from adjacent flaws. The specific area used in one overlay fabrication gralng unit shall not be used in another overlay fabrication grading unit. Overlay fabrication grading units need not be sDaced uniformlv about the smirnen. (b)(3) Detection sets shall be selected from Table VIII-S2-1.

The minimum detection sample set is five flawed base metal grading units, ten unflawed base metal grading units, five flawed overlay fabrication grading units, and ten unflawed overlay fabrication grading units. For each type of grading unit, the set shall contain at least twice as many unflawed as flawed grading units. For initial procedure qualification, detection sets shall include the equivalent of three personnel qualification sets. To qualify new values of essential variables, at least one personnel qualification set is required.

Appendix A PP 7015 Rev. 5 Page 48 of 58 APPENDIX A (Continued) equivalent of three personnel qualification sets. To qualify new values of essential variables, at least one personnel qualification cf) Sizing Specimen (1) The minimum number of flaws shall be ten. At least 30% of the flaws shall be overlay fabrication flaws. At least 40% of the flaws shall be cracks open to the inside surface. No Change (2) At least 20% but less than 40% of the flaws shall be oriented axially. The remainder shall be oriented circumferentially. Flaws shall not be open to any surface to which the candidate has physical or visual access. (3) Base metal cracking used for length sizing demonstrations shall be oriented circumferentiallv.

set is required.

No Change (4) Depth sizing specimen sets shall include at least two distinct locations where cracking in the base metal extends into the overlay material by at least 0.1 in. in the throuch-wall direction.

(1) The minimum number of flaws shall be ten. At least 30% of the flaws shall be overlay fabrication flaws. At least 40% of the flaws shall be cracks open to the inside surface.

For initial procedure qualification, sizing sets shall include the equivalent of three personnel qualification sets. To qualify new values of essential variables, at least one personnel qualification set is required.

No Change No Change ~~ (3) Base metal flaws used for length sizing demonstrations shall be oriented circumferentiall y . (4) Depth sizing specimen sets shall include at least two distinct locations where flaws in the base metal extend into the overlay material by at least 0.1 in. in the through-wall direction.

Appendix A PP 7015 Rev. 5 Page 49 of 58 APPENDIX A (Continued)

~~ 2.0 CONDUCT OF PERFORMANCE-DEMONSTRATION The specimen inside surface and identification shall be concealed from the candidate.

All examinations shall be completed prior to grading the results and presenting the results to the candidate.

Divulgence of particular specimen results or candidate viewing of unmasked specimens after the performance demonstration is prohibited.

2.1 Detection

Test. Flawed and unflawed grading units shall be randomly mixed.

Although the boundaries of specific grading units shall not be revealed to the candidate, the candidate shall be made aware of the type or types of grading units (base or overlay) that are present for each specimen.

2.2 Length

Sizing Test (a) The length sizing test may be conducted separately or in conjunction with the detection test.

CC N-654 The specimen inside surface and identification shall be concealed from the canddate.

All examinations shall be completed prior to grading the results and presenting the results to the candidate.

Divulgence of particular specimen results or candidate viewing of unmasked specimens after the performance demonstration is prohibited.

The overlay fabrication flaw test and the base metal flaw test may be performed separately.

Flawed and unflawed grading units shall be randomly mixed. Although the boundaries of specific grading units shall not be revealed to the cancfidate, the candidate shall be made aware of the type or types of grading units (base metal or overlay fabrication) that are present for each mecimen. No Change PDI Program The specimen inside surface and identification shall be concealed from the candidate.

All examinations shall be completed prior to grading the results and presenting the results to the candidate.

Divulgence of particular specimen results or candidate viewing of unmasked specimens after the performance demonstration is prohibited.

The overlay fabrication flaw test and the base metal flaw test may be performed separately.

PDI Proeram Hawed and unflawed grading units shall be randomly mixed. Although the boundaries of specific grading units shall not be revealed to the candidate, the candidate shall be made aware of the type or types of grading units (base metal or overlay fabrication) that are present for each specimen.

PDI Program Appendix A PP 7015 Rev. 5 Page 50 of 58 mi ---- --- (d) For flaws in base metal grading units, the candidate shall estimate the length of that I part of the flaw that is in the outer 25% of the base metal wall thickness.

APPENDIX A (Continued) (d) For flaws in base metal grading units, the candidate shall estimate the length of that part of the flaw that is in the outer 25% of the base metal wall thickness. (b) When the length sizing test is conducted in conjunction with the detection test and the detected flaws do not satisfy the requirements of 1.1 (f), additional specimens shall be provided to the candidate.

The regions containing a flaw to be sized shall be identified to the candidate.

The candidate shall determine the length of the flaw in each region. (c) For a separate length sizing test, the regions of each specimen containing a flaw to be sized shall be identified to the canddate. The candidate shall determine the length of the flaw in each region. (d) For flaws in base grading units, the candidate shall estimate the length of that part of the flaw that is in the outer 25% of the base wall thickness.

No Change No Change No Change No Change Appendix A PP 7015 Rev. 5 Page 51 of 58 APPENDIX A (Continued)

2.3 Depth

Sizing Test. For the depth sizing test, 80% of the flaws shall be sized at a specific location on the surface of the specimen identified to the candidate.

For the remaining flaws, the regions of each specimen containing a flaw to be sized shall be identified to the candidate.

The candidate shall determine the maximum depth of the flaw in each region. The candidate shall determine the depth of the flaw in each region.

PDI Program 2.3 Depth Sizing Test (a) The depth sizing test may be conducted separately or in conjunction with the detection test. (b) When the depth sizing test is conducted in conjunction with the detection test and the detected flaws do not satisfy the requirements of l.l(f), additional specimens shall be provided to the candidate.

The regions containing a flaw to be sized shall be identified to the candidate.

The candidate shall determine the maximum depth of the flaw in each region. (c) For a separate depth sizing test, the regions of each specimen containing a flaw to be sized shall be identified to the candidate.

The candidate shall determine the maximum depth of the flaw in each region. Appendix A PP 7015 Rev. 5 Page 52 of 58 as .---- ..-. i--.r - APPENDIX A (Continued)

3.0 ACCEPTANCE

CRITERIA

3.1 Detection

Acceptance Criteria. Examination procedures, equipment, and personnel are qualified for detection when the results of the performance demonstration satisfy the acceptance criteria of Table Vm-S2-1 for both detection and false calls. The criteria shall be satisfied separately by the demonstration results for base grading units and for overlay grading units. 3.2 Sizing Acceptance Criteria. Examination procedures, equipment, and personnel are qualified for sizing when the results of the performance demonstration satisfy the following criteria. (a) The RMS error of the flaw length measurements, as compared to the true flaw lengths, is less than or equal to 0.75 inch. The length of base metal cracking is measured at the 75% through-base-metal position.

CC N-654 Examination procedures are qualified for detection when all flaws within the scope of the procedure are detected and the results of the performance demonstration satisfy the acceptance criteria of Table VIII-S2-1 for false calls. Examination equipment and personnel are qualified for detection when the results of the performance demonstration satisfy the acceptance criteria of Table VIII-S2-1 for both detection and false calls. The criteria shall be satisfied separately by the demonstration results for base metal grading units and for overlay fabrication grading units. ~~~ No Change No Change PDI Program 8) Examination procedures are qualified

• or detection when; All flaws within the scope of the procedure are detected and the results of the performance demonstration satisfy the acceptance criteria of Table VIII-S2-1 for *alse calls.

At least one successful personnel demonstration has been performed meeting the acceptance criteria defined in (b). b) Examination equipment and personnel are qualified for detection when the results of the performance demonstration satisfy the acceptance criteria of Table VIII-S2-1 for both detection and false calls. (c) The criteria in (a), (b) shall be satisfied separately by the demonstration results for base metal grading units and for overlay fabrication grading units.

PDI Program No Change (a) The RMS error of the flaw length measurements, as compared to the true flaw lengths, is less than or equal to 0.75 inch. The length of base metal flaws is measured at the 75 % through- base-metal position.

Appendix A PP 7015 Rev. 5 Page 53 of 58 APPENDIX A (Continued) (b) All extensions of base metal craclung into the overlay material by at least 0.1 in. are reported as being intrusions into the overlay material. (c) The RMS error of the flaw depth measurements, as compared to the true flaw depths, is less than or equal to 0.125 in. This requirement is omitted. (6) The RMS error of the flaw depth measurements, as compared to the true flaw depths, is less than or equal to 0.125 in. This requirement is omitted. (b) The RMS error of the flaw depth measurements, as compared to the true flaw depths, is less than or equal to 0.125 in. Appendix A PP 7015 Rev. 5 Page 54 of 58 APPENDIX A (Continued)

1. 2. 3. 4. 5. LICENSEE/UTILITY NAME - Entergy Nuclear Operations, Inc.

PLANT NAME, UNIT - Vermont Yankee 10-YEAR INTERVAL - Fourth Interval REQUEST FOR RELIEF NO. ISI-11 Proposed Alternative In Accordance with lOCFR50.55a(a)(3)(i)

--Alternative Provides Acceptable Level of Quality and Safety- ASME Code Component(s)

Affected ASME Section XI, Class 1, Examination Category E-A, Code Item No. B 1.30 - Applicable Code Edition and Addenda 1998 Edition with Addenda through 2000 ASME Section XI, 1998 Edition with Addend 1-21 lo@) requires that ultrasonic examination conducted in accordance with Article 4 of ASME Section V, supplemented by the requirements of Table 1-2000-1.

In addition, Regulatory Guide 1.150, Revision 1, "Ultrasonic Testing of Reactor Vessel Welds During Preservice and In-service Examinations,"

serves as regulatory guidance for the UT examination of RPV welds. gh 2000, Appendix I, Subparagraph of reactor vessel flange-to-shell welds be Reason for Reauest To gain ultrasonic technique and requirement synergy with the examination of the other RPV shell welds and to conserve radiological dose, while still maintaining an adequate level of quality and safety for examination of the affected weld. Proposed Alternative It is proposed to use a Performance Demonstration Initiative (PDI) qualified procedure to complete the UT of the RPV vessel-to-flange weld in accordance with ASME Section XI, 1998 Edition with Addenda through 2000, Appendix VIII Supplements 4 and 6 as amended by the Federd Register Notice 67FIi187, dated September 26,2002. Appendix A PP 7015 Rev. 5 Page 55 of 58 APPENDIX A (Continued)

Basis for Use Federal Register Notice 67FB187, dated September 26,2002, requires that ASME Section XI, Appendix Vm, Supplement 4, "Qualification Requirements for the Clad/Base Metal Interface of Reactor Vessel", and Supplement 6, "Qualification Requirements for Reactor Vessel Welds other than Clad/Base Metal Interface", be implemented for most of the RPV welds, starting November 22,2000. Per ASME Section XI, Appendix I, Subparagraph 1-21 lo@), reactor vessel-to-flange and head-to-flange welds are the only reactor vessel pressure boundary welds not included in Appendix VIII. During the upcoming ten-year RPV weld examinations

[due during the First Period of the Fourth Interval per 10CFR50.55a(g)], Vermont Yankee will be employing personnel, procedures, and equipment, demonstrated and qualified by the PDI and in accordance with ASME Code,Section XI, 1998 Edition, with Addenda through 2000, Appendix VIII, Supplements 4 and 6 as amended by the FederaI Register Notice 67FR187, dated September 26,2002 for examination of RPV shell welds.

Appendix Vllz was developed to ensure the effectiveness of UT examinations within the nuclear industry by means of a rigorous item-specific performance demonstration.

The performance demonstration is conducted on an RPV mockup containing flaws of various sizes and locations. The demonstration establishes the capability of equipment, procedures, and personnel to find flaws that could be detrimental to the integrity of the RPV. Although Appendix VITI is not a requirement for this weld, the qualification process to Appendix Vm criteria demonstrates that the examination and evaluation techniques are equal or surpass the requirements of Appendix I, Subparagraph 21 lo@), ASME Section V, Article 4, and the guidance in RG 1.150. A comparison between the ASME Section V, ArticIe 4 based UT methods and the procedures developed to satisfy the PDI and Appendix VIII can be best described as a comparison between a compliance-based procedure (ASME Section V, Article 4) and a results-based procedure (PDUAppendix vm). ASh4E Section V, Article 4 procedures use an amplitude-based technique and a known reflector. The proposed alternate UT method was estabIished independently from the acceptance standards for flaw size found in ASME Section XI. i m &" 1 I f A PDI-qualified sizing method is considered more accurate than the method used in ASME Code,Section V, Article 4. The proposed alternate UT examination technique provides an acceptable level of quality and examination repeatability as compared to the Article 4 requirements.

Appendix A PP 7015 Rev. 5 Page 56 of 58 APPENDIX A (Continued) i .I .f I a Vermont Yankee will obtain the examination vendor's Performance Demonstration Qualification Sheet (PDQS), which will attest that their procedure is in compliance with the detection and sizing tolerance requirements of Appendix VIE The PDI qualification method is based on a group of samples, which validate the acceptable flaw sizes in ASME Section XI. The sensitivity necessary to detect these flaws is considered to be equal to or better than the sensitivity obtained through ASME Section V, Article 4, because sensitivity necessary to detect implanted cracks is generally better than that necessary to calibrate on a machined notch. The examination and sizing procedures for all potential qualified examination vendors use echo-dynamic motion and tip diffraction characteristics of the flaw instead of the amplitude characteristics required by ASME Section V, Article

4. The search units are required to interrogate the same examination volume as depicted by ASME Section XI, Figure IWB-2500-4 for the shell-to-flange weld joint. Procedures used for satisfying the requirements of ASME Section V, Article 4 for the UT examination of the RFV-to-flange weld has not undergone such a rigorous demonstration or received the same qualifications as a PDI qualified procedure.

The Vermont Yankee shell-to-flange geometry compares very favorably with the geometry of the PDI qualification specimens.

The inside diameter surface (the scan surface) of the shell-to-flange weld and adjacent base material is theoretically a cylinder; there is no taper associated with this joint on the RPV ID at Vermont Yankee. The shell base material thickness (excluding clad) is 5 5/16". The flange thickness (excluding clad) within the extremity of the required examination volume is 10 5/8". Vermont Yankee will require that the vendor's PDQS bound this thickness range. It is expected that an examination will be able to be performed from both the shell and the flange sides of the weld.

The shell-to-flange weld was examined radiographically and ultrasonically as a part of the RPV fabrication.

During the second ten-year in-service inspection interval this weld was re-examined.

In 1996, the weld was examined by remote automated inspection per 10CFRSOa(g) during the first period of the third ten-year in-service inspection interval.

This last examination was conducted in accordance with Appendix VIII using PDI-demonstrated procedures, even though Appendix Vm was not mandatory at the time.

If Vermont Yankee were to conduct examination of the RPV vessel-to-flange weld in accordance with ASME Section V, Article 4 and RG 1.150, it is expected that the examination would be performed using manual techniques from the vessel OD inside the drywell at the top of the bio-shield wall, and also from the vessel flange mating surface in the reactor refueling cavity.

The use of Appendix VIII Supplements 4 and 6 for examination of this weld using remote automated inspection tooling is expected to significantly reduce personnel radiation exposure.

Compliance with the proposed alternatives described above will provide an adequate level of quality and safety for examination of the affected welds, and will not adversely impact the heaIth and safety of the public. Appendix A PP 70 15 Rev. 5 Page 57 of 58 APPENDIX A (Continued)

6. Duration of Proposed Alternative It is proposed to use the alternative for the Vermont Yankee Fourth Ten-Year Interval (September 1,2003 through August 31,2013).

7. Precedents The ,VRC has granted similar relief to SaIem Generating Station, Unit 1 (Reference l), Comanche Peak Steam Electric Station, Unit 2 (Reference 2), Point Beach Unit 2 (Reference 3), Cooper Nuclear Station (Reference 4), and San Onofre Nuclear Generating Station, Unit 3 (Reference 5). 8. References Letter from J. Clifford (NRC) to H. W. Keiser (PSEG Nuclear) dated May 3,2001, "Salem Nuclear Generating Station, Unit No. l-Relief from ASME Code Requirements Related to the In-service Inspection Program, Second 10-Year Interval, Relief Request RR-B1 1 (TAC No. MB 1234) Letter from Robert A. Gramm (NRC) to C. Lance Terry (TXV Generation Company) dated April 16,2002, "Comanche Peak Steam Electric Station (CPSES), Unit-2, Re: First 10-Year In-service Inspection (ISI) Interval Request for Relief from the Requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) concerning Relief Requests A-4, Revision 1; A-5, Revision 2; A-6, A-7 and A-8 (TAC No. MB3039) i r Appendix A PP 7015 Rev. 5 Page 58 of 58

.---- Category Item NumberIComments ASME Section XI, Table IWB-2500-1 and Vermont Yankee B-A B1.ll B1.12 B1.21 B1.22 B1.30 B1.40 B1.51 Pressure Retaining Request for Relief # IS1 05 bases. In accordance with the Final Welds In Reactor 4 8 2 16 1 1 0 Safety Evaluation of BWRVIP-05 a volumetric examination of APPENDIX B Totals - B-A 32 SELECTION AND BASES TABLES Vessel Basis Scheduled B-B 100% 100% 100% 100% 100% NIA See Comment 0 8 2 16 1 1 0 B2.21 B2.22 B2.51 B2.52 B2.60 B2.70 132.80 welds at their intersections, will be performed.

No B-B Category welds exist at Vermont Yankee Pressure Retaining Welds In Vessels Other Than Reactor 28 - B-B SW Comment See Comment Vessels B-D Full Penetration Welded Nozzles In Vessels Basis Scheduled Scheduled t- essentially 100% of the weld length of all axial pressure retaining shell welds, Item B 1.12, including those portions of the circumferential shell welds that would be examined with the axial I ASME Section XI, Table IWB-2500-1 bases. - B-D B3.90 B3.100 B3.150 B3.160 29 29 0 0 In accordance with Request for Relief # IS1 09 Code Case N-6 13 is used for examination of Item 58 B3.90 welds in the axial direction only. 10096 100% NIA NiA Scheduled 29 29 0 0 Code Case N-552 is used for Item B3.100 nozzle inner radius modeling . 58 Appendix B PP 7015 Rev. 5 Page 1 of 10 APPENDIX B (Continued) B5.110 B5.120 0 0 NIA NIA 0 0 Table 1 Class 1 - Schedule Selection and Bases ASME Section XI, Table IWB-2500-1 bases. and Vermont Yankee Request for Relief # IS1 04 which allows the use of Code Case N-663 which eliminates surface examination for Item B5.10 welds. NSB-SE Overlay Examination removed from exam schedule per NVYOI-21.

Request for Relief

1. IS1 06 allows the use of BWRVIP-75 for examination frequency for overlaid piping. Request for Relief # IS1 10 grants the use of PDl for Supplement 10 qualification.

Request for Relief # IS1 09 grants the use of PDI for Supplement 1 1 Category B-F Pressure Retaining Dissimilar Metal Welds In Vessel Nozzles 0 NIA 0 ~ Basis 0 NIA 0 Scheduled B6.50 64 100% B-G- 1 Pressure Retaining Bolting, Greater Than 2" In Diameter 1 B6.190 B6.180 32 2 100% 100%

Basis Scheduled Note 1,2 - B5.10 17 100% 17 B6.10 64 100% 64 - B5.20 5 100% 5 B6.20 64 100% 64 =F- F- Zomment Whe n Rem oved 64 16 When Disass- embled I I palification.

136.200 32 100% When Disass- embled Item numbers B6.120, B6.130, B6.140, B6.150, B6.160, B6.170, B2.10, B2.20 and B2.30 are not applicable to Vermont Yankee. In accordance with Request for Relief

1. 1. IS1 03 Code Case N-652 is used for examination method and selection criteria. Item number B6.30 does not exist in Code Case N-652. Appendix B PP 7015 Rev. 5 Page 2 of 10 Totals - B-F 22 Scheduled 22 - B-G-1 322 Scheduled 208

-- mi .I L a, b- -A w L-- APPENDIX B (Continued)

Table I I dule Selection and Bases B-G-2 B7.80 ASME Section XI, Table IWB-2500-1 bases. The B7.80 Item is eliminated from the ASME Section VT-1 examination is required when the connection is disassembled by the 10CFR50.55a Rulemaking, Volume 66, No. 150. 89 XI 1998 Edition through 2000 Addenda, however, the 135 Scheduled 100% When Disass-embled In accordance with Request for Relief

1. IS1 03 Code 0 Case N-652 is used for examination method and selection criteria. - BJ ASMJ3 Section XI, Table JWB-2500-1 bases. The Item B9.11, B9.18 and "None" selections are done in accordance with Code Case N-560 10% selection criteria. "None" are items that in accordance with Code Case N-560 no degradation mechanism was identified but are included in the selection population.

Item B9.40, socket welds, are not included in the Code Case N-560 population, they are selected in accordance with the ASME Section XI, 1998 Edition through 2000 Addenda 25% selection criteria.

Request for Relief # IS1 02 approves the use of Code Case N-560. 5 14 Scheduled 65 I 1 4 B-G-2 B7.10 B7.40 Pressure Retaining Less In Diameter Bolting, 2" and 0 0 Basis NIA NIA Scheduled 0 0 B9.11 I B9.18 I None I B9.32 I B9.40 I I B7.50 B7.60 B7.70 3 0 43 100% NIA 100% When When Disass- 0 Disass- embled embled I I WeldsbPiping I 432 3 82 Y Basis 10% 10% 25% Scheduled 43 I 21 r Appendix B PP 7015 Rev. 5 Page 3 of 10 APPENDIX B (Continued)

Category B-K Welded Attachments For Pumps And Valves Basis Vessels, Piping, Table 1 1 B1O.10 B 10.20 B 10.30 B 10.40 5 7 0 0 See Comment 10% NIA N/A Class 1 - Schedule Selection and Bases em NumberIComments ASME Section XI, Table IWB-2500-1 bases. In accordance with ASME Section XI, 1998 Edition, through 2000 Addenda, Table IW-2500-1, Category B-K, Item B 10.10. Note 4 states: "For multiple vessels of similar design, function and service, only one welded attachment of only one of the multiple vessels shall be selected for examination. Item B 10.20, Note 5 states "For piping, pumps, and valves, a sample of 10% of the welded attachments associated with the component supports selected for examination under IWF-2510 shall be examined." Also, ASh4E Section XI, 1998 Edition through 2000 Addenda, Item

1. B1O.lO, allows single sided surface examination, however, the 10 CFR 50.55a Rulemaking, Vol. 66 requires both sides be examined.

No B-L-1 Category welds exist at Vermont Yankee B-L-2 B 12.20 Pump Casings Basis Scheduled See Comment In accordance with ASME Section XI, 1998 Edition. through 2000 Addenda, Table IWB-2500-1, Category B-L-2, Item B 12.20, Notes 1 and 2 only one (1) pump in a group of pumps are required to be examined and then only when disassembled for maintenance, repair, or volumetric examination.

._ .... c -I I- Appendix B PP 7015 Rev. 5 Page 4 of 10 -' 7 Totals B-K: 12 Scheduled 3 - B-L-1 See Comment - B-L-2 2 Scheduled St% Comment B-M- 1 B 12.30 I B12.40 No B-M-1 Category welds exist at Vermont Yankee Pressure Retaining Welds See Comment In Valve Bodies In accordance with ASME Section XI. 1998 Edition, through 2000 Addenda, Table IWB-2500-1, Category B-M-2, Item B 12.50 "Examination is required only when a pump or valve is disassembled for maintenance, repair, or volumetric examination." B-M-2 B 12.50 Basis 100% B13.10 Valve Bodies 43 Scheduled 0 - B-N- 1 The examination requirements for Category B-N- 1 are defined in Program Procedure PP 7027 "Reactor Vessel Interior Of Reactor Vessel See Comment Internals Inspection Program".

B-M- 1 See Comment 43 Scheduled 0 B-N- 1 See Comment B-M-2 WeldedCore I I I B13.20 Support Structures and Interior Attachments To Reactor Vessels B13.30 I B13.40 B-N-2 See Comment The examination requirements for Category B-N-2 are defined in Program Procedure PP 7027 "Reactor Vessel Intemals Inspection Program".

See Comment B-0 Pressure Retaining Welds In Control Rod Housings Basis Scheduled B-P All Pressure Retaining Appendix B PP 7015 Rev. 5 Page 5 of 10 I B 14.10 - B-0 56 ASME Section XI, Table IWB-2500-1 bases.

56 10% Scheduled 6 6 B-P The examination selection and frequency for Category B-P is defined in Program Procedure PP 7034 "In-service Inspection Pressure Test Program".

See Note APPENDIX B (Continued)

Table 2 c2.2 1 c2.22 C2.31 Class 2 - Schedule Selection and Bases C2.32 C2.33 c1.10 0 0 4 C-A 0 4 Scheduled c2.11 C3.20 .C Io ASME Section XI, 1998 Edition, through 2000 Addenda, Table IWC-2500-I, Category C-C, Note 4 states: "For multiple vessels of similar design, function and C3.30 C3.40 n r. Basis Scheduled 13 See Comment 2 C3.10 c-c IT service, only one welded attachment of only one of the multiple vessels shall be selected for examination." Note 5 states: "For piping, pumps, and valves, a sample of 10% of the welded attachments associated with the component supports selected for examination under IWF-25 10 shall be examined." Also, Note 6 states: "Examination is required whenever component support member deformation, e.g. broken, bent, or pulled out parts, is identified during operation, refueling, maintenance, examination or testing." L U NIA See Comment 1 0 Basis I Cozent Item NumberIComments I I c1.20 C1.30 In accordance with ASME Section XI, 1998 Edition, through 2000 Addenda, Table IWC-2500-1, Category C-A examinations may be limited to one vessel or distributed among multiple similar vessels. Item C1.10 is limited to gross structural discontinuities only. Comment N/A 1 NIA I see 1 NIA I see I Comment Comment O I O 12 101 I In accordance with ASME Section XI, 1998 Edition, through 2000 Addenda, Table IWC-2500-1, Category C-B examinations may be limited to one vessel or distributed among multiple similar vessels. The two Item C2.33 examinations are performed in accordance with Program Procedure PP 7034 "In-service Inspection Pressure Test Program".

Scheduled I 2 Appendix B PP 7015 Rev. 5 Page 6 of 10 Totals _C-A 8 Scheduled 4 - C-B 8 Scheduled 2 c-c 26 Scheduled 5

r. mil <. L L b-. APPENDIX B (Continued)

Table 2 (continued)

C-D C4.10 C4.20 C4.30 C4.40 No Category C-D bolting exists at Vermont Yankee. See Comment C-F- 1 C-F-2 C5.11 C5.21 C5.30 C5.41 No Category C-F-1 welds exist at Vermont Yankee. See Comment Basis C5.51 C5.61 (25.70 * ~ Scheduled I ' 62 0 0 1 t C5.81 15 7.5% 7.5% I NIA 1 NIA Section XI, Table IWC-25OO-1 bases, including Vermont Yankee Request for Relief # IS1 04 which allows the use of Code Case N-662 which eliminates surface examination for Item C5.51 and C5.81 welds. C-G C-H C6.10 C6.20 See Comment No Category C-G welds exist at Vermont Yankee.

The examination selection and frequency for Category C-H is defined in Program Procedure PP 7034 "In-service Inspection Pressure Test Program".

I - C-D See Comment C-F- 1 See Comment -~ C-F-2 835 -~ Scheduled 63 - C-G 0 - C-H St% Comment Appendix B PP 7015 Rev. 5 Page 7 of 10 APPENDIX B (Continued)

Category D-A Basis Scheduled D-B -I__ - Number. .tS Totals -. D1.10 D1.20 D1.30 D1.40 <;,ME SGLLIL,. ;,IC IWD-2500-1 bases. - D-A 2 76 6 0 ASME Sect 198 L rough 200u tiucienda, Table IWD-2500-1, Category D-A Note 3 84 states: ..'I! Water sy only OL <,, &e multiple vessels shall be selected for examination.

For welded attachments of piping, pumps and valves, a 10% sample shall be selected for examination. This percentage sample shall be proportional to the total number of nonexempt welded attachments connected to the piping, pumps and valves in each system subject to these examinations." i attachm dted for examination shall be those most subject to corrosion, as 10% 10% 10% 10% determi: Qwfi., .,UC <velded attachments of the Service Water or Emergency Service Scheduled For inultlple vessel: imilar design, function and service, the welded attachments of 10 1 8 1 - D-*3 The examination selection and frequency for Category D-B is defined in Program Procedure PP 7034 "In-service Inspection Pressure Test ROgram". See Comment Appendix B PP 7015 Rev. 5 Page 8 of 10 APPENDIX 3 (Continued)

Table 4 Item Number F1.10 F1.20 F1.30 F1.40 Category F- A Comments Basis 25% Scheduled F1.40, Note 3 states: "For multiple components other than piping, within a system of similar design, function, and service, the supports of only one of the multiple components are required to be examined See 15% 10% comment 25 34 25 Section XI, Table IWF-2500-1 bases. 45 ~1 ASME Section XI, 1998 Edition, through 2000 Addenda, Table IWF-2500-1, Category F-A, Item Totals - F-A 622 Scheduled 129 Appendix B PP 7015 Rev. 5 Page 9 of 10 APPE?NDLX B (Continued)

L Table 5 Category AUG Item Number Comments Welds Supports BVY 94-124, Response to Request for Additional Information on the Vermont Yankee Third 10-Year Interval In-service Inspection (ISI) Program Plan and Associated Requests for Relief. 75 38 Paragraph A. (6) Basis Scheduled Appendix B PP 7015 Rev. 5 Page 10of 10 7.5% 15% Augmented Examination of Main Steam Piping from the Outermost Containment Isolation Valves to the Turbine Stop and By-Pass Valves. Vermont Yankee performs examinations of these piping welds and piping supports in accordance with the requirements of ASME Section XI, Table IWC-2500-1, Code Category C-F-2 and Code Case N-491, Table 2500-1, Code Item No. F1.20. A sample of 7.5% of the circumferential welds are examined every 10 year interval and a sample of 15% of the piping supports are examined every 10 year interval.

8 7 Totals AUG 113 Scheduled 15 .- ---..--I APPENDIX D cuw- 1 NZL- 1 NZL- 10 NZL- 10-SE NZL-2 NZL-2m NZL-4 NZL-5 NZL-5-SE NZL- 8-SE RPB-1 RPB-2 RPB-3 CALIBRATION BLOCK INDEX Reducer 120 4.00" .438" A312 Type 316L NIA 28.875" ODX 1.37511 A508 CL II Clad N/A 3.6875" OD x .875" A508 CL 11 Clad NIA 3.6875"OD x

.875" A336 F8 Clad NfA 15.50 OD x .875" A508 CL II Clad NIA .818" A376 Type 3 16 NIA .625" A508 CL II A508 CL 11 N/A N/A .844" B168 LNC N/A .875" A336 F8 NIA 2.50" x 12.50" N/A A193 26.125" ID 1.9375" ID 1.9375" ID 13.75" ID 12.985" OD x 1 1.349" ID 12.00" OD x 10.75" ID 11.75" ID 13.4375" OD x 1 1.75" ID 5.5625" OD x 3.8125" ID 13.4375" OD x .8&ii NIA 5.75" x 24.25" NIA A540 GRB-23 NIA 1.125" x 8.50" NIA A540 GRB-23 1 I Appendix D PP 7015 Rev. 5 Page 1 of 6 i w-15 VY-2 VY-20 VY-21 _L c- 80 4.00" 0.337" A451 Type CPF8M 80 8 .00" 0.500" A106 GR B 160 2.50" 0.375 A106 GR C 100 8.00" 0.594" A312 Type 316L 80 2.50" 0.27 6" A376 Type 304 A I I Appendix D PP 7015 Rev. 5 Page 2 of 6 APPENDIX D (Continued)

VY-27 VY-28 VY-29 VY-3 VY-30 VY-3 1 VY-32 VY-33 VY-34 VY-35 VY-36 VY-37 VY-38 80 20.00" 1.03 1 I' A106 GR B 80 24.00" 1.219" A106 GR B 80 10.00" 0.594 A106 GR B 80 3 .OO 0.300" A3 12-304 N/A 15.406" OD 0.875" A336 CI F8 N/A 12.84" 0.667" A336 CI F8 NiA 20.00" 1.095" A358 Type 304 80 22.00" 1.125" A358 Type 304 N/A 24.00" 1.312" A358 Type 304 N/A 25.87" ID 1.13 8" A358 Type 304 N/A 28.00" 2.00" A358 Type 304 A312 Type 304 A376 Type 304 120 4.00" 0.437" 160 6 .OOg 0.7 18" A106 GR B Appendix D PP 7015 Rev. 5 Page 3 of 6 APPENDIX D (Continued)

I Appendix D PP 7015 Rev. 5 Page 4 of 6

1. VY-68 NIA 28.00" 1.235" A376 Type 316 VY-69 NIA 28.00" 1.140" A376 Type 3 16 VY-70 NiA 24.00" 1.140" A376 Type 316 VY-71 NfA 22.00" 0.990" A376 Type 316 VY-72 N/A 20.00" 0.985" A376 Type 3 16 VY-73 N/A 12.00" 0.690" A376 Type 316 VY-75 120 4.0" 0.438" A106 GR B - VY-78 N/A 8.00" 0.97 5" A 167-82 A480-83 Clad A24O-8 84A VY-79 N/A 8.00" 1.50" A167-82 A262-8 1 VY-8 160 10.00" 1.125" A106 GR B A167-82 A240-82C vY-81A/B NIA 3.00" x 9.00" 1.125" VY-82 NIA 13.44" 0.939" VY-83 N/A 13.44" 0.939" VY-85 40 6.00" ,280" A106 GRB VY-86 40 16 .OO" .500" A106 GRB SA508lSB 167 Inconel 82 overlay SA508/SB 167 Inconel 82 overlay Appendix D PP 7015 Rev. 5 Page 5 of 6 APPENDIX D (Continued)

Thickness VY-87 30 VY-88 20 Material VY-89 I+ VY-90 120 VY-N3-IR N/A VY-N4-IR NIA DiametedSize 18.00" 20 .oo " 4.00" 12.00" 14.00" 10.75" x 6.125" 10.75" x 6.125" .438" A106 GFU3 + .375" A106 GRB ,337" A312 GRB + 0.687" A3 12-304 1.094" A106 GRB 2.3 125" A508 CL I1 2.3125" I A508 CLII Appendix D PP 7015 Rev. 5 Page 6 of 6