ML083080296

Relief Request #08-002-RR, Revision 0

ML083080296
Person / Time
Site:
Issue date:	10/29/2008
From:	Young D E Progress Energy Florida
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
3F1008-03
Download: ML083080296 (39)

Text

RC Progress Energy Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 Ref: 10 CFR 50.55a October 29, 2008 3F1008-03 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 -Relief Request #08-002-RR, Revision 0

References:

(1) Crystal River Unit 3 to NRC Letter 3F0507-03, "Crystal River Unit 3 -Relief Request #07-003-RR, Revision 0," dated May 15, 2007 (2) Crystal River Unit 3 to NRC Letter 3F0907-05, "Crystal River Unit 3 -Relief Request #07-003-RR, Revision 1, and Response to Request for Additional Information," dated September 13, 2007 (3) Crystal River Unit 3 to NRC Letter 3F1007-07, "Crystal River Unit 3 -Response to Request for Additional Information Regarding Relief Request #07-003-RR, Revision 1," dated October 23, 2007 (4) NRC to Crystal River Unit 3 Letter, "Crystal River Unit 3 -Relief Request#07-003-RR Regarding Structural Weld Overlays (TAC NO. MD5552)," dated November 15, 2007

Dear Sir:

Pursuant to 10 CFR 50.55a(a)(3)(i), Florida Power Corporation (FPC), doing business as Progress Energy Florida, Inc., is hereby submitting Relief Request #08-002-RR, Revision 0, to apply a dissimilar weld metal overlay for a repair/replacement activity at Crystal River Unit 3 (CR-3) during the Fourth Ten-Year Inservice Inspection (ISI) Interval which began in August 2008. References 1 through 4 document a precedent where the NRC reviewed and approved application of a dissimilar weld metal overlay for a repair/replacement activity at CR-3 during the Third Ten-Year ISI Interval.This request contains alternative requirements for the ISI program for a scheduled preemptive full structural weld overlay (SWOL) that is planned to mitigate the potential for Primary Water Stress Corrosion Cracking (PWSCC) susceptibility at CR-3. Attachment 1 contains the proposed alternative, Relief Request #08-002-RR, Revision 0. Attachment 2 shows the comparison of the Performance Demonstration Initiative (PDI) Program modifications to ASME Code Section Xl, Appendix VIII, Supplement

11. Attachment 3 describes alternative requirements for the dissimilar metal weld overlay. Attachment 4 provides a discussion on the use of a "barrier layer" in the case where the SWOL will be deposited on a stainless steel base material with a high sulfur content.Regulatory Commitments made in this submittal are listed in Attachment 5.Progress Energy Florida, Inc.Crystal River Nuclear Plant 15760 W. Powerline Street Crystal River, FL 34428 U. S. Nuclear Regulatory Commission 3F1008-03 Page 2 of 2 FPC requests the review and approval of this proposal by September 1, 2009, to support the CR-3 1 6 th Refueling Outage scheduled to start in September 2009.If you have any questions regarding this submittal, please contact Mr. Dan Westcott, Supervisor, Licensing and Regulatory Programs at (352) 563-4796.Sincerely, Dale E. Young Vice President Crystal River Nuclear Plant DEY/dwh Attachments:

1.2.3.4.5.Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)

Performance Demonstration Initiative (PDI) Program Modifications to ASME Code Section XI, 2001 Edition, No Addenda, Appendix VIII, Supplement 11 Alternative Requirements for Dissimilar Metal Weld Overlay Barrier Layer to Prevent Hot Cracking in High Sulfur Stainless Steel List of Regulatory Commitments xc: NRR Project Manager Regional Administrator, NRC Region II Senior Resident Inspector PROGRESS ENERGY FLORIDA, INC.CRYSTAL RIVER UNIT 3 DOCKET NUMBER .50 -302 / LICENSE NUMBER DPR -72 ATTACHMENT 1 PROPROSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

U. S. Nuclear Regulatory Commission Attachment 1 3F1008-03 Page 1 of 10 USE OF WELD OVERLAY AS AN ALTERNATIVE REPAIR TECHNIQUE--Alternative Provides Acceptable Level of Quality and Safety--CR-3 INSERVICE INSPECTION RELIEF REQUEST #08-002-RR FOURTH TEN-YEAR INTERVAL REFERENCE CODE: The American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME), Section Xl, 2001 Edition, including Addenda through 2003 1.0 ASME Code Components Affected The ASME Code component associated with this request is the high safety significant (HSS)Class 1 surge pipe-to-"A" Hot Leg surge nozzle dissimilar metal weld (DMW) containing Alloy 82/182 weld metal that is believed to be susceptible to Primary Water Stress Corrosion Cracking (PWSCC). This is scheduled to have a structural weld overlay (SWOL) applied during the upcoming Crystal River Unit 3 (CR-3) 16th Refueling Outage scheduled to start in September 2009.1.1 Category and System Details: Code Class: Class 1 System Welds: Reactor Coolant System Examination Categories:

R-A**Welds are included in the Risk Informed Inservice Inspection Program 1.2 Component Descriptions:

This alternative is to apply a SWOL on the "A" hot leg surge pipe-to-surge nozzle weld. The applicable item and its identifications are as follows: "A" Hot Leg Pipe Weld Number B4.1.11 Surge Nozzle Buttering and Number B4.1.12 Surge Pipe-to-Surge Nozzle Weld 1.3 Component Materials:

The "A" Hot Leg pipe surge nozzle is carbon steel A105 Grade II (P-No. 1). The buttering and surge pipe-to-nozzle weld is Alloy 82/182 (F-No. 43). The surge piping attached to the "A" hot leg surge nozzle buttering is wrought seamless austenitic stainless steel A 376 TP 316 (P-No.8), 2.0 Applicable Code Edition and Addenda CR-3 is currently in the Fourth Ten-Year Inservice Inspection (ISI) Interval.

The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) of record for the Fourth Ten-Year ISI Interval is Section Xl, 2001 Edition, including Addenda through 2003 (Reference 1). This is also the version that will be used for the Repair/Replacement Program.ASME Code Section Xl, 2001 Edition, no Addenda, Appendix VIII (Reference

2) also applies in lieu of ASME Code Section Xl, 2001 Edition, including Addenda through 2003, Appendix VIII.

U. S. Nuclear Regulatory Commission Attachment 1 3F1008-03 Page 2 of 10 3.0 Applicable Code Requirement The applicable Code requirement for which relief is requested is ASME Code Section Xl, 2001 Edition, including Addenda through 2003 (Reference 1), IWA-4000, as listed below: IWA-4221(c) states in part the following:

.....the item may meet all or portions of the requirements of different Editions and Addenda of the Construction Code, or Section III ......IWA-4410 states in part the following:

Welding, brazing, defect removal .... and installation shall be performed in accordance with this Subarticle.

IWA-441 1 states in part the following:

Welding, brazing, and installation shall be performed in accordance with the Owner's Requirements and ...... in accordance with the Construction Code of the item.IWA-441 1(a) states in part the following:

Later editions and addenda of the Construction Code or a later different Construction Code, either in their entirety or portions thereof, and Code Cases may be used....IWA-441 1(e) states the following:

The requirements of IWA-4600(b) may be used when welding is performed without the postweld heat treatment required by the Construction Code.IWA-4412 states the following:

Defect removal shall be in accordance with the requirements of IWB-4420.IWA-4422.2.2(a) states in part the following:

Surface examination of the defect removal area shall be required prior to welding....

IWA-4422.2.2(b) states the following:

The acceptance criteria of either the Construction Code or Section Xl shall be used for the excavation.

IWA-4600(b) states the following:

When postweld heat treatment is not to be performed, the following provisions may be used.

U. S. Nuclear Regulatory Commission Attachment 1 3F1008-03 Page 3 of 10 IWA-4600(b)(1) states in part the following:

The welding methods of.....IWA-4630

..... may be used in lieu of the requirements of the Construction Code or Section III, provided the requirements of IWA-4610 are met.IWA-4610(a) states in part the following:

The area to be welded.....

shall be preheated

..... and maintained at a minimum temperature of 300 degrees F for the GTAW process during welding IWA-461 1.1 (a) states the following:

Defects shall be removed in accordance with IWA-4422.1.

A defect is considered removed when it has been reduced to an acceptable size.IWA-4611.2(a) states, in part, the following:

After final processing, the affected surfaces, including surfaces of cavities prepared for welding, shall be examined by the magnetic particle or liquid penetrant method to ensure that the indication has been reduced to an acceptable size in accordance with IWB-3500....IWA-4633.2(d) states in part the following:

After at least 3/16 inch (4.8 mm) of weld metal has been deposited, the weld area shall receive a hydrogen bakeout by maintaining it at 450 degrees -550 degrees F (232 degrees C -288 degrees C) for a minimum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in P-No. 1 materials....

Relief is also requested from the applicable Code requirement ASME Code Section Xl, 2001 Edition, no Addenda, Appendix VIII (Reference 2), Supplement

11. Appendix VIII provides requirements for performance demonstration for ultrasonic examination systems. Supplement 11 provides qualification requirements for full structural overlaid wrought austenitic piping welds.4.0 Reason for Request DMWs, primarily consisting of Alloy 82/182 weld metal, are frequently used in pressurized water reactor (PWR) construction to connect stainless steel pipe and safe ends to vessel and pipe nozzles, generally constructed of carbon or low alloy ferritic steel. These welds have shown a propensity for PWSCC degradation, especially in components subjected to higher operating temperatures, such as the hot leg pipe. See EPRI MRP-169, "Technical Basis for Preemptive Weld Overlays for Alloy 82/182 Butt Welds in PWRs," October 2005 (Reference 3).For the upcoming CR-3 16th Refueling Outage, a SWOL is scheduled to be applied to the DMW on the "A" hot leg surge pipe-to-nozzle DMW. Repair/replacement activities associated with SWOL repairs are required to address the materials, welding parameters, As Low As Reasonably Achievable (ALARA) concerns, operational constraints, examination techniques and procedure requirements for repairs.ASME Code Section Xl, 2001 Edition, including Addenda through 2003 (Reference 1), IWA-4000 does not address all the needed requirements for this type of repair since potential existing defects will not be removed or reduced in size, and weld overlay of potential existing U. S. Nuclear Regulatory Commission Attachment 1 3F17008-03 Page 4 of 10 flaws in the DMW will be performed.

Also comprehensive and generic NRC approved criteria are not currently available for application of SWOL repairs to DMWs constructed of Alloy 82/182 weld material for mitigation of potential PWSCC.In addition, ASME Code Section Xl, 2001 Edition, no Addenda, Appendix VIII (Reference 2)Supplement 11, cannot be implemented as written for ultrasonic examination of a structural weld overlay repair. Attachment 2 includes a discussion of the Performance Demonstration Initiative (PDI) Program alternatives and their bases with respect to Appendix VIII, Supplement 11, requirements.

The alternative described in Section 5.0 is proposed to permit the implementation of a SWOL at CR-3 as an alternative for the repair/replacement requirements of the ASME Code Section Xl, 2001 Edition, including Addenda through 2003 (Reference 1), IWA-4000 and ASME Code Section Xl, 2001 Edition, no Addenda, Appendix VIII (Reference 2), Supplement 11.5.0 Proposed Alternative and Basis for Use This proposal requests the use of the alternative shown in Attachment 3 for implementing a SWOL for the potentially PWSCC susceptible item. This request applies to the "A" hot leg surge pipe-to-nozzle DMW listed in Section 1.2, which is generically depicted in Figure 1 of this Attachment.

The proposed alternative is scheduled to be performed during the CR-3 16th Refueling Outage.This alternative is the result of the industry's experience with mitigative weld overlay modifications for flaws suspected or confirmed to be caused by PWSCC and directly applies to the Alloy 52M weld material that is primarily being used for this SWOL.The ultrasonic examination of the completed SWOL will be accomplished with personnel and procedures qualified in accordance with ASME Code Section Xl, 2001 Edition no Addenda Appendix VIII (Reference 2), Supplement 11, as specified in Attachment 3, Section 3, therein, with the alternatives used for complying with the PDI Program. See Attachment 2 for the PD1 Program changes to Appendix VIII, Supplement 11.5.1 SWOL Design The SWOL satisfies all the structural design requirements of the pipe as specified in the Alternative Requirements shown in Attachment 3 for the original DMW. As shown in Figure 1 of this Attachment, the SWOL will completely cover the existing DMW and extend onto the ferritic nozzle and austenitic stainless steel material on each end of the weld. The SWOL extends around the entire circumference of the nozzle. Alloy 52M and 52 filler metals are compatible with all the wrought base materials and the DMW that will be covered by the SWOL.The SWOL will be designed as a full structural overlay. Postulated 100% through-wall flaws shall be assumed as specified in 2(b)(6), Attachmnent 3, for the DMW for SWOL length and thickness sizing per 2(b)(7) of Attachment 3.There may be small remnants of austenitic weld overlay material remaining on the nozzle/DMW/pipe surface that may not be removed prior to installation of the new SWOL.Surface examination was performed thereon and accepted during Refueling Outage 15.

U. S. Nuclear Regulatory Commission Attachment 1 3F1008-03 Page 5 of 10 Since no ultrasonic examination will be performed prior to weld overlay application during the next outage, postulated 75% through-wall flaws will be assumed for flaw growth evaluations as specified in 2(a)(2)(b), Attachment 3, for the DMW. Surface examination in accordance with 1(d), Attachment 3, will be performed on all surfaces where the SWOL will be deposited.

Planar flaws detected during the final acceptance examination will be characterized and flaw growth calculations performed using the flaw(s) detected plus the assumed 75% through-wall flaws.The expected life will be determined by analysis.

Residual stress distributions will be calculated including the residual stress effects due to installing and substantially removing the flawed SWOL during Refueling Outage 15 as well as the new SWOL to be installed.

Leak-before-break is not applicable and has not been approved by NRC for the pressurizer surge line.The details surrounding the design analysis for the SWOL are being developed to support the CR-3 16th Refueling Outage. This vendor supplied analysis will be available for NRC review at the beginning of the CR-3 16th Refueling Outage.5.2 Welding The welding will be performed in accordance with Attachment 3 using a remote machine gas tungsten-arc welding (GTAW) process and using the ambient temperature temper bead method with ERNiCrFe-7A (Alloy 52M) weld metal. Manual GTAW, using ERNiCrFe-7 (Alloy 52) or Alloy 52M will be used if local repairs of weld defects are necessary or additional weld metal is required locally to form the final SWOL contour in locations at least 3/16 inch away from the carbon steel nozzles.The SWOL design will require welding on more than 100 square inches of surface area on the hot leg surge nozzle carbon steel base material, but less than 300 square inches which is permitted in Appendix 1-1(b), Attachment

3. The SWOL will extend to the transition taper of the carbon steel nozzle so that qualified ultrasonic examination of the required volume can be performed after the SWOL is applied.There have been a number of temper bead SWOLs applied to safe end-to-nozzle welds in the nuclear industry, and SWOLs having more than 100 square inch surface area on the nozzle ferritic steel surfaces have been used. The ASME Committee has indicated the inside diameter compressive stress levels remain essentially the same for both 100 square inches and 500 square inches related to SWOL applications.

The justification entitled, "Bases for 500 Square Inches Weld Overlay over Ferritic Material," was provided to the NRC staff in the January 10, 2007 meeting (Accession No. ML070470565).

Additional justification is provided in EPRI Report 1014351, "Repair and Replacement Applications Center: "Topical Report Supporting Expedited NRC Review of Code Cases for Dissimilar Metal Weld Overlay Repairs,"" December 2006 (Reference 5).The thickness of the SWOL may exceed 1/2/ the carbon steel nozzle base metal thickness as specified in Code Case N-638-1. The requirement therein applies to excavated cavities in the ferritic steel base material that are subsequently welded flush. This requirement is not applicable to the SWOL since it is applied to the nozzle surface and limited to 3/8 inch depth into the ferritic steel as specified in Attachment 3, Appendix 1, 1-1(d). Additional justification is provided in Appendix F of EPRI Report 1014351, "Repair and Replacement Applications Center: "Topical Report Supporting Expedited NRC Review of Code Cases for Dissimilar Metal Weld Overlay Repairs,"" December 2006 (Reference 5).

U. S. Nuclear Regulatory Commission Attachment 1 3F1008-03 Page 6 of 10 1-3.0(d), Appendix I, Attachment 3, specifies the maximum interpass temperature shall be limited to 350 degrees F maximum, even though the maximum interpass temperature is limited to 150 degrees F maximum for the first three layers in the test assembly specified in 1-2.1(c).This is greater than the maximum 100 degrees F interpass temperature increase permitted by ASME Code Section IX, QW-406.3.

This is a clarification of the intent of Code Case N-638-1,"Similar and Dissimilar Metal Welding Using Ambient Temperature Machine GTAW Temper Bead Technique Section Xl, Division 1," that has been included in Code Case N-638-2, "Similar and Dissimilar Metal Welding Using Ambient Temperature machine GTAW Temper Bead Technique Section XI, Division 1." The limitation on the procedure qualification maximum interpass temperature is to ensure the cooling rates achieved during procedure qualification are more severe than those encountered during field welding (are not slower than those achievable during field welding).

The higher interpass temperature is permitted during field welding because it would only result in slower cooling rates which could be helpful in producing more ductile transformation products in the ferritic steel heat affected zone (HAZ). Additional justification information is also included in Reference

5.5.3 Examination

Ultrasonic and surface examinations shall be performed on the SWOL and these examinations will be performed no sooner than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after completion of the third temper bead layer over the ferric steel nozzle.The 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> delay provides time for delayed hydrogen cracking occurrence.

Appendix I, Attachment 3, requires the machine or automatic gas tungsten arc welding (GTAW) process to be used for temper bead welding thereby eliminating the use of welding processes requiring flux for arc shielding.

The machine GTAW temper bead process uses a welding process that is inherently free of hydrogen.

The GTAW process relies on bare welding electrodes and bare wire filler metal with no flux to absorb moisture.

An inert gas blanket provides shielding for the weld and surrounding metal, which protects the region during welding from the atmosphere and the moisture that it may contain and typically produces porosity-free welds. In accordance with the weld procedure qualification, welding grade argon is used for the inert gas blanket. To further reduce the likelihood of any hydrogen effects, specific controls will be used to ensure the welding electrodes, filler metal and weld region are free of all sources of hydrogen.In addition, the use of the machine GTAW temper bead process provides precise control of heat input, bead placement, bead size and contour. The very precise control over these factors afforded by the machine GTAW process provides effective tempering of the nozzle ferritic steel HAZ resulting in achievement of lower hardness and tempered martensite.

This further reduces susceptibility to hydrogen-induced cracking.EPRI Report 1013558, "Temper Bead Welding Applications, 48 Hour Hold Requirements for Ambient Temperature Temper Bead Welding, Technical Update," December 2006 (Reference 4), provides justification for the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> hold time on P-No. 3 Group No. 3 ferritic steel base material to start after completion of the third temper bead layer, rather than after completion of welding and return to ambient temperature, as specified in Code Case N-638-1. EPRI Report 1013558 addresses microstructural issues, hydrogen sources, tensile stress and temperature, and diffusivity and solubility of hydrogen in steels.

U. S. Nuclear Regulatory Commission Attachment 1 3F1008-03 Page 7 of 10 The base materials studied in the EPRI report are primarily P-No. 3. The "A" hot leg surge nozzle ferritic steel base material is P-No. 1. The concerns associated with hydrogen assisted cracking are generally more significant for P-No. 3 base materials than for P-No. 1 base materials due to P-No. 3 base materials increased hardenability.

Furthermore, past industry experience with the use of the machine or automatic GTAW process has resulted in no detection of hydrogen-induced cracking after the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> hold Nondestructive Examination (NDE) or subsequent in-service inspections.

ASME Section XI Code Case N-638-4, "Similar and Dissimilar Metal Welding Using Ambient Temperature Machine GTAW Temper Bead Technique Section Xl, Division 1," specifies that NDE may be performed no sooner than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after completion of the third temper bead layer.All examinations will meet the requirements of Attachment 3, excluding qualification of the ultrasonic examination for the completed SWOL. The ultrasonic examination qualification will be in accordance with ASME Code Section Xl, 2001 Edition, no Addenda Appendix VIII (Reference 2), Supplement 11, with the alternatives that are used to comply with the PDI Program. See Attachment 2 forthe PDI Program changes to Appendix VIII, Supplement 11.Within 60 days of completion of the ultrasonic examination of the weld overlays performed during the CR-3 16th Refueling Outage, a report containing the ultrasonic examination results, a discussion of any repairs to the weld overlay material and/or base material, and the reason for the repair will be submitted to the NRC. The NRC will be notified as soon as practical, but no later than exceeding Mode 4 during restart, if any cracks are detected that exceed the pre-service examination acceptance standards in ASME Code Section XI, Table IWB-3514-2.

The DMW was examined during Refueling Outage 15 after the SWOL was substantially removed. No indications of PWSCC were observed.Ultrasonic examination will not be performed on the DMW prior to the SWOL being applied.Since the structural integrity at the DMW location will be restored by the SWOL, the ultrasonic examination of the DMW prior to SWOL application is unnecessary and the increased personnel dose that would be incurred performing the examinations is also undesirable and not consistent with good ALARA practice.Ultrasonic surface examination of the 1.5T wide ferritic steel nozzle preheated band will not be performed.

Ultrasonic and surface examination of the SWOL (welded region) will be performed.

Because this is a surface application of the temper bead process, there will be minimal impact to the volume of the ferritic steel nozzles in the area surrounding the weld. Also, there is no additional useful information that can be gained by a volumetric examination of the area surrounding the SWOL. The SWOL and HAZ below will be post weld volumetrically examined to the extent possible.

This reduction in the post welding inspection will provide additional dose reduction for this repair while still ensuring a sound weld metal is deposited and that the process has not introduced flaws in the base material.

Surface examination of both the weld and 1/ inch wide adjacent band on the ferritic steel nozzle will be performed, which includes the surrounding adjacent HAZ. This is sufficient to verify that defects have not been induced in the ferritic steel nozzle material due to welding.

U. S. Nuclear Regulatory Commission Attachment 1 3F1008-03 Page 8 of 10 Later editions of Section Xl, as well as Code Case N-638-2 have deleted the requirement for the 1.5T examination band for both ultrasonic examination and surface examination.

This is consistent with the less restrictive requirements for ultrasonic examination of the ferritic nozzle because hydrogen cracking away from the temper bead weld is not considered a concern. The NDE requirements in these documents apply to any type of welding where a temper bead technique is to be employed (which includes weld repairs of excavated flaws) and is not specifically written for SWOLs. However, it is believed that for the SWOL type of repair, any ferritic steel base material cracking would occur in the HAZ directly below or adjacent to the SWOL and not in the 1.5T examination band of ferritic material beyond the SWOL. If this type of cracking were to occur, it should be detected by the NDE of the SWOL and adjacent ferritic steel surfaces.The ultrasonic examination requirements specified in NRC Regulatory Guide 1.147, Revision 15, as conditional acceptance of Code Case N-638-1, are not applicable to SWOLs. The ultrasonic examination requirements herein are based on the latest industry experience and practice and are completely satisfactory for the SWOL application.

The additional dose received due to performing these examinations would result in a hardship without a compensating increase in the level of quality and safety.5.4 Conclusion Similar NRC approved requests have been used to produce acceptable weld overlays when applied to DMWs. The proposed alternative shown in Attachment 3 has been developed to cover the most recent operating experience-and NRC-approved criteria that are associated with similar SWOL applications.

Therefore, FPC considers that the alternatives to ASME Section XI, 2001 Edition, including Addenda through 2003, as described herein and the PDI Program ultrasonic examination qualification alternative to ASME Code Section XI, 2001 Edition, no Addenda, Appendix VIII, Supplement 11, provide an acceptable level of quality and safety, consistent with provisions of 10 CFR 50.55a(a)(3)(i).

6.0 Precedents

FPC submitted a similar request on September 13, 2007 for CR-3, "Relief Request #07-003-RR, Revision 1, and Response to Request for Additional Information," (ADAMS Accession No.ML072600188) (Reference 12).NRC approval was provided on November 15, 2007, "Crystal River Unit 3 -Relief Request #07-003-RR Regarding Structural Weld Overlays (TAC No. MD5552)," (ADAMS Accession No.ML073030132) (Reference 11).Similar requests have been submitted to address the issues that are contained in this request.These include requests from the Indiana Michigan Power Company's D. C. Cook Unit 2. NRC verbal approval was received on March 23, 2006, for their request, which included the application of full SWOLs applied to their pressurizer nozzle DMWs.Virginia Electric and Power Company (Dominion) submitted a similar request on March 13, 2007, for North Anna 1 and 2, CMP-022R1 and CMP-023R1, Serial No. 06-1007A, Docket Nos.50-338/339, "Supplemental Information to Support Use of Weld Overlays as an Alternative Repair Technique," (ADAMS Accession No. ML070730563).

Verbal NRC approval was granted to Dominion on March 29, 2007.

U. S. Nuclear Regulatory Commission Attachment 1 3F1008-03 Page 9 of 10 Union Electric Company's Callaway Plant submitted a similar request on August 14, 2006, (ADAMS Accession ML062360200) for weld overlays to pressurizer nozzle welds to be performed during their Refuel 15 outage in the Spring 2007.Additionally, the following requests associated with weld overlay repairs have been approved by the NRC: AmerGen Energy Company, Three Mile Island Nuclear Station, Unit 1, on July 21, 2004 (Reference 7); Constellation Energy's Calvert Cliffs Nuclear Power Plant, Unit 2, on July 20, 2005 (Reference 8); Millstone Unit 3, on January 20, 2006 (Reference 9); and Indiana Michigan Power Company, Donald C. Cook Unit 1, on February 10, 2006 (Reference 10).7.0 Duration of Proposed Alternative The alternative requirements of this request will be applied for the Fourth Ten-Year ISI Interval which began on August 14, 2008.8.0 References

1. ASME Code, Section Xl, 2001 Edition, including Addenda through 2003 2. ASME Code,Section XI, 2001 Edition, No Addenda, Appendix VIII 3. EPRI MRP-169, "Technical Basis for Preemptive Weld Overlays for Alloy 82/182 Butt Welds in PWRs," October 2005 4. EPRI Report 1013558, "Temper Bead Welding Applications, 48 Hour Hold Requirements for Ambient Temperature Temper Bead Welding, Technical Update," December 2006 5. EPRI Report 1014351, "Repair and Replacement Applications Center: "Topical Report Supporting Expedited NRC Review of Code Cases for Dissimilar Metal Weld Overlay Repairs,"" December 2006 6. Deleted 7. NRC letter, "Safety Evaluation of Request for Relief from Flaw Removal, Heat Treatment and Nondestructive Examination (NDE) Requirements for the Third 10-Year Inservice Inspection Interval, Three Mile Island Nuclear Station, Unit 1 (TMI-1), Docket No. 50-289, (TAC No. MC1201)," dated: July 21, 2004, (ADAMS Accession No. ML041670510)

8. NRC letter, "Safety Evaluation for Calvert Cliffs Nuclear Power Plant, Unit No. 2, Docket No. 550-318, Relief Request for Use Weld Overlay and Associated Alternative Inspection Techniques (TAC Nos. MC6219 and MC6220)," dated July 20, 2005, (ADAMS Accession No. ML051930316)

9. NRC letter, "Safety Evaluation of Relief Request IR-2-39 Pertaining to the Repair and Inspection of Nozzle to Safe End Weld, Weld No. 03-X-5641-E-T at Millstone Power Station Unit No. 3 (MPS3) Docket No. 50-423, (TAC No. MC8609)," dated January 20, 2006, (ADAMS Accession No. ML053260012)

10. NRC letter, "Safety Evaluation of Alternative Regarding Repair of Safe-End-To-Elbow Weld 1-RC-9-01F at the Donald C. Cook Nuclear Plant Unit 1, Docket No. 50-315, (TAC No. MC8807)," dated February 10, 2006, (ADAMS Accession No. ML060240355)

11. NRC letter, "Crystal River Unit 3 -Relief Request #07-003-RR Regarding Structural Weld Overlays (TAC No. MD5552)," dated November 15, 2007 (ADAMS Accession No.ML073030132)

12. Crystal River Unit 3 letter, "Relief Request #07-003-RR, Revision 1, and Response to Request for Additional Information," dated September 13, 2007 (ADAMS Accession No.ML072600188)

U. S. Nuclear Regulatory Commission 3F1008-03 Attachment 1 Page 10 of 10 Pipe/Nozzle Weld (82/182)SWOL I Carbon Steel Nozzle (A 105 Grade II)Figure 1 -HL Pipe Surge Nozzle SWOL Configuration PROGRESS ENERGY FLORIDA, INC.CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 -302 / LICENSE NUMBER DPR -72 ATTACHMENT 2 PERFORMANCE DEMONSTRATION INITIATIVE (PDI) PROGRAM MODIFICATIONS TO ASME CODE SECTION XI, 2001 EDITION, NO ADDENDA, APPENDIX VIII, SUPPLEMENT 11 U. S. Nuclear Regulatory Commission 3F1 008-03 Attachment 2 Page 1 of 6 PDI PROGRAM MODIFICATIONS TO ASME CODE SECTION XI, 2001 EDITION, NO ADDENDA, APPENDIX ViII, SUPPLEMENT I1I Appendix ViII, Supplement 11 PDI Modification

1.0 SPECIMEN

REQUIREMENTS

__________________

1.1 General______________________(b) The specimen set shall consist of Modification: (b) The specimen set shall consist of at least three specimens having at least three specimens having different nominal different nominal pipe diameters and pipe diameters and overlay thicknesses.

They shall overlay thicknesses.

They shall include the minimum and maximum nominal pipe include the minimum and maximum diameters for which the examination procedure is nominal pipe diameters for which the applicable.

Pipe diameters within a range of 0.9 to examination procedure is applicable.

1.5 times

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

If the procedure is applicable to pipe 1.5 times a nominal diameter shall be diameters of 24 inches or larger, the specimen set considered equivalent.

If the must include at least one specimen 24 inches or procedure is applicable to pipe larger but need not include the maximum diameter.diameters of 24 inches or larger, the The specimen set shall include specimens with specimen set must include at least one overlays not thicker than 0. 1 inches more than the specimen 24 inches or larger but need minimum thickness, nor thinner than 0.25 inches of not include the maximum diameter.

the maximum nominal overlay thickness for which the The specimen set must include at least examination procedure is applicable.

one specimen with overlay thickness Basis: To avoid confusion, the overlay thickness within -0. 1 inches to +0.25 inches of tolerance contained in the last sentence was the maximum nominal overlay reworded.thickness for which the procedure is applicable.

________________________(d) Flaw Conditions

_______________________

(1) Base metal flaws. All flaws must Modification:

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

At least 70% of the flaws in the detection flaws shall not interfere with ultrasonic and sizing tests shall be cracks and the remainder detection or characterization of the shall be alternative flaws. Alternative flaw cracking.

Specimens containing mechanisms, if used, shall provide crack-like IGSCC shall be used when available, reflective characteristics and shall be limited by the following: (a) The use of alternative flaws shall be limited to when the implantation of cracks produces spurious reflectors that are uncharacteristic of actual flaws.(b) Flaws shall be semi elliptical with a tip width of less than or equal to 0.002 inches.Basis: This paragraph requires that all base metal flaws be cracks. Implanting a crack requires_____________________________excavation of the base material on at least one side U. S. Nuclear Regulatory Commission 3F1008-03 Attachment 2 Page 2 of 6 Appendix VIII, Supplement 11 PDI Modification 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.

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 implantation 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% of the flaws in the detection and sizing test shall be cracks and the remainder shall be alternative flaws. The phrase "and the remainder shall be alternative flaws" was added to the next to last sentence.(e) Detection Specimens (1) At least 20% but less than 40% of the flaws shall be oriented within +/-20 degrees 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. The rules of IWA-3300 shall be used to determine whether closely spaced flaws should be treated as single or multiple flaws.Modification:

(1) At least 20% but less than 40% of the base metal flaws shall be oriented within +/-20 degrees 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.Basis: The requirement for axially oriented overlay fabrication flaws was excluded from the PDI Program as an improbable scenario.

Weld overlays are typically applied using automated GTAW techniques with the filler metal applied 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 for using IWA-3300 for proximity flaw evaluation was excluded.

Instead, indications will be sized based on their individual merits.(2) Specimens shall be divided into Modification:

(2) Specimens shall be divided into base and overlay grading units. Each base metal and overlay fabrication grading units.specimen shall contain one or both Each specimen shall contain one'or both types of types of grading units. grading units. Flaws shall not interfere with ultrasonic detection or characterization of other flaws.(a)(1) A base grading unit shall include Modification: (a)(1) A base metal grading unit at least 3 inches of the length of the includes the overlay material and the outer 25% of overlaid weld. The base grading unit the original overlaid weld. The base metal grading includes the outer 25% of the overlaid unit shall extend circumferentially for at least 1 inch weld and base metal on both sides. and shall start at the weld centerline and be wide The base grading unit shall not include enough in the axial direction to encompass one half the inner 75% of the overlaid weld and of the original weld crown and a minimum of 0.50 inch base metal overlay material, or base of the adjacent base material.

U. S. Nuclear Regulatory Commission 3F1008-03 Attachment 2 Page 3 of 6 Appendix VIII, Supplement 11 PDI Modification metal-to-overlay interface.

Basis: 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. Modified to require that a base metal grading unit include at least 1 inch of the length of the overlaid weld, rather than 3 inches.(a)(2) When base metal cracking Modification: (a)(2) When base metal flaws penetrates into the overlay material, penetrate into the overlay material, the base metal the base grading unit shall include the grading unit shall not be used as part of any overlay overlay metal within 1 inch of the crack fabrication grading unit.location.

This portion of the overlay material shall not be used as part of any overlay grading unit.(a)(3) When a base grading unit is Modification: (a)(3) Sufficient unflawed overlaid designed to be unflawed, at least 1 weld and base metal shall exist on all sides of the inch of unflawed overlaid weld and grading unit to preclude interfering reflections from base metal shall exist on either side of adjacent flaws.the base grading unit. The segment of Basis: Modified to require sufficient unflawed weld length used in one base grading overlaid weld and base metal to exist on all sides of unit shall not be used in another base the grading unit to preclude interfering reflections grading unit. Base grading units need from adjacent flaws, rather than the 1 inch not be uniformly spaced around the requirement.

specimen.(b)(1) An overlay grading unit shall Modification: (b)(1) An overlay fabrication grading include the overlay material and the unit shall include the overlay material and the base base metal-to-overlay interface of at metal-to-overlay interface for a length of at least 1 least 6 square inches. The overlay inch.grading unit shall be rectangular, with Basis: Modified to require sufficient unflawed minimum dimensions of 2 inches. overlaid weld and base metal to exist on all sides of the grading unit to preclude interfering reflections from adjacent flaws, rather than the 2 inch requirement.(b)(2) An overlay grading unit Modification: (b)(2) Overlay fabrication grading designed to be unflawed shall be units designed to be unflawed shall be separated by surrounded by unflawed overlay unflawed overlay material and unflawed base metal-material and unflawed base metal-to-to-overlay interface for at least 1 inch at both ends.overlay interface for at least 1 inch Sufficient unflawed overlaid weld and base metal around its entire perimeter.

The shall exist on both sides of the overlay fabrication specific area used in one overlay grading unit to preclude interfering reflections from grading unit shall not be used in adjacent flaws. The specific area used in one overlay another overlay grading unit. Overlay fabrication grading unit shall not be used in another grading units need not be spaced overlay fabrication grading unit. Overlay fabrication uniformly about the specimen.

grading units need not be spaced uniformly about the specimen.Basis: Paragraph 1.1 (e)(2)(b)(2) states that overlay fabrication grading units designed to be unflawed shall be separated by unflawed overlay material and U. S. Nuclear Regulatory Commission 3F1008-03 Attachment 2 Page 4 of 6 Appendix VIII, Supplement 11 PDI Modification unflawed base metal-to-overlay interface for at least 1 inch at both ends, rather than around its entire perimeter.(b)(3) Detection sets shall be selected Modification: (b)(3) Detection sets shall be selected from Table VIII-$2-1.

The minimum from Table VIII-S2-1.

The minimum detection sample detection sample set is five flawed set is five flawed base metal grading units, ten base grading units, ten unflawed base unflawed base metal grading units, five flawed grading units, five flawed overlay overlay fabrication grading units, and ten unflawed grading units, and ten unflawed overlay overlay fabrication grading units. For each type of grading units. For each type of grading grading unit, the set shall contain at least twice as unit, the set shall contain at least twice many unflawed as flawed grading units. For initial as many unflawed as flawed grading procedure qualification, detection sets shall include units. the equivalent of three personnel qualification sets.To qualify new values of essential variables, at least one personnel qualification set is required.(f) Sizing Specimen (1) The minimum number of flaws shall Modification:

(1) The minimum number of flaws be ten. At least 30% of the flaws shall shall be ten. At least 30% of the flaws shall be be overlay fabrication flaws. At least overlay fabrication flaws. At least 40% of the flaws 40% of the flaws shall be cracks open shall be open to the inside surface. Sizing sets shall to the inside surface. contain a distribution of flaw dimensions to assess sizing capabilities.

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.(3) Base metal cracking used for Modification:

(3) Base metal flaws used for length length sizing demonstrations shall be sizing demonstrations shall be oriented oriented circumferentially.

circumferentially.

(4) Depth sizing specimen sets shall Modification:

(4) Depth sizing specimen sets shall include at least two distinct locations include at least two distinct locations where a base where cracking in the base metal metal flaw extends into the overlay material by at extends into the overlay material by at least 0.1 inch in the through-wall direction.

least 0.1 inch in the through-wall direction.

2.0 CONDUCT

OF PERFORMANCE DEMONSTRATION The specimen inside surface and Modification:

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

the candidate.

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

Divulgence of particular specimen results candidate.

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

The of unmasked specimens after the overlay fabrication flaw test and the base metal flaw performance demonstration is test may be performed separately.

prohibited.

2.1 Detection

Test. Flawed and Modification:

2.1 Detection

Test. Flawed and unflawed grading units shall be unflawed grading units shall be randomly mixed.randomly mixed. Although the Although the boundaries of specific grading units U. S. Nuclear Regulatory Commission 3F1 008-03 Attachment 2 Page 5 of 6 Appendix Vill, Supplement I1I PDI Modification boundaries of specific grading units shall not be revealed to the candidate, the candidate shall not be revealed to the candidate, shall be made aware of the type or types of grading the candidate shall be made aware of units (base metal or overlay fabrication) that are the type or types of grading units (base present for each specimen.or overlay) that are present for each specimen.2.2 Length Sizing Test (d) For flaws in base grading units,' the Modification: (d) For flaws in base metal grading candidate shall estimate the length of units, the candidate shall estimate the length of that that part of the flaw that is in the outer part of the flaw that is in the outer 25% of the base 25% of the base wall thickness.

metal wall thickness.

2.3 Depth

Sizing Test. For the depth Modification:

2.3 Depth

Sizing Test.sizing test, 80% of the flaws shall be (a) The depth sizing test may be conducted sized at a specific location on the separately or in conjunction with the detection surface of the specimen identified to test.the candidate.

For the remaining flaws, (b) When the depth sizing test is conducted in the regions of each specimen conjunction with the detection test and the containing a flaw to be sized shall be detected flaws do not satisfy the requirements of identified to the candidate.

The 1. 1(f), additional specimens shall be provided to candidate shall determine the the candidate.

The regions containing a flaw to maximum depth of the flaw in each be sized shall be identified to the candidate.

The region. 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.3.0 ACCEPTANCE CRITERIA 3.1 Detection Acceptance Criteria.

Modification:

3.1 Detection

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

_____________________________

grading units.

U. S. Nuclear Regulatory Commission 3F1008-03 Attachment 2 Page 6 of 6 Appendix VIII, Supplement 11 PDI Modification

3.2 Sizing

Acceptance Criteria.(a) The RMS error of the flaw length Modification: (a) The RMS error of the flaw length measurements, as compared to the measurements, as compared to the true flaw lengths, true flaw lengths, is less than or equal is less than or equal to 0.75 inch. The length of base to 0.75 inch. The length of base metal metal flaws is measured at the 75% through-base-cracking is measured at the 75% metal position.through-base-metal position.(b) All extensions of base metal Modification:

This requirement is omitted.cracking into the overlay material by at Basis: The requirement for reporting all extensions least 0.1 inch are reported as being of cracking into the overlay is omitted from the PDI intrusions into the overlay material.

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.

PROGRESS ENERGY FLORIDA, INC.CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 -3021 LICENSE NUMBER DPR -72 ATTACHMENT 3 ALTERNATIVE REQUIREMENTS FOR DISSIMILAR METAL WELD OVERLAY U. S. Nuclear Regulatory Commission Attachment 3 3F1008-03 Page 1 of 13 ALTERNATIVE REQUIREMENTS FOR DISSIMILAR METAL WELD OVERLAYS In lieu of the requirements of IWA-4410 and IWA-4611, a defect in austenitic stainless steel or austenitic nickel alloy piping, components, or associated welds may be reduced to a flaw of acceptable size in accordance with IWB-3640 by the addition of a repair weld overlay.Alternatively, if mitigation is performed, it may also be developed by treating a postulated flaw in accordance with IWB-3640 by application of a mitigative weld overlay. The weld overlay shall be applied by deposition of weld reinforcement (weld overlay) on the outside surface of the piping, component, or associated weld, including ferritic materials when necessary, provided the following requirements are met: 1. GENERAL REQUIREMENTS (a) A full-structural weld overlay shall be applied by deposition of weld reinforcement (weld overlay) on the outside surface of circumferential welds in carbon steel (P-No. 1) steel components, including nozzles to safe ends or piping components (P-No. 8 or 43), inclusive of the UNS N06082 or W86182 welds that join the two items and Alloy 600 base material, when applicable.

The design of the overlay may be extended to include the adjacent stainless steel to stainless steel welds (P-No. 8 to P-No. 8).(b) This alternative applies to dissimilar metal welds between P-No. 8 or 43 and P-No. 1 materials.

This alternative also applies to dissimilar metal welds between P-No. 8 and P-No. 43 materials joined with austenitic F-No. 43 filler metal, and to welds between P-No. 8 and P-No. 8 materials as described in 1(a) above and Alloy 600 base material, when applicable.(c) Weld overlay filler metal shall be austenitic nickel alloy (28% Cr min., ERNiCrFe-7 or ERNiCrFe-7A) applied 360 degrees around the circumference of the item and deposited using a Welding Procedure Specification (WPS) for groove welding, qualified in accordance with the Construction Code and Owner's Requirements and identified in the Repair/Replacement Plan.(1) Appendix I may be used for ambient-temperature temper bead welding.(d) Prior to deposition of the weld overlay, the surface to be weld overlaid shall be examined using the liquid penetrant method. Indications with major dimension greater than 116 inch (1.5 mm) shall be removed, reduced in size, or weld repaired in accordance with the following requirements:

(1) One or more layers of weld metal shall be applied to seal unacceptable indications in the area to be repaired with or without excavation.

The thickness of these layers shall not be used in meeting weld reinforcement design thickness requirements.

Peening the unacceptable indication prior to welding is permitted.

For the case where the unacceptable indication(s) remain the assumed flaw depth shall be 100%through wall in both the circumferential and axial directions for flaw growth evaluations.

(2) If weld repair of indications identified in 1(d) is required, the area where the weld overlay is to be deposited, including any local weld repairs or initial weld overlay layer, shall be examined by the liquid penetrant method. The area shall contain no U. S. Nuclear Regulatory Commission Attachment 3 3F1008-03 Page 2 of 13 indications with major dimension greater than 1/16 inch (1.5 mm) prior to the application of the structural layers of the weld overlay.(e) Weld overlay deposits shall meet the following requirements:

The austenitic nickel alloy weld overlay shall consist of at least two weld layers deposited using a filler material with a Cr content of at least 28%. The first layer of weld metal deposited may not be credited toward the required thickness.

Alternatively, for PWR applications, a first diluted layer may be credited toward the required thickness, provided the portion of the layer over the austenitic base material, austenitic filler material weld and the associated dilution zone from an adjacent ferritic base material contain at least 24% Cr and the Cr content of the deposited weld metal is determined by chemical analysis of the production weld or of a representative coupon taken from a mockup prepared in accordance with the WPS for the production weld. Alternatively, for BWR applications, a diluted first layer may be credited toward the required thickness, provided the portion of the layer over the austenitic base material, austenitic filler material weld and the associated dilution zone from an adjacent ferritic base material contain at least 20% Cr, and the Cr content of the deposited weld metal is determined by chemical analysis of the production weld or of a representative coupon taken from a mockup prepared in accordance with the WPS for the production weld.(f) This alternative is only for welding in applications predicted not to have exceeded thermal neutron fluence of 1 x 1017 (E < 0.5 eV) neutrons per cm 2 prior to welding.(g) A new weld overlay shall not be installed over the top of an existing weld overlay containing service-related surface defects.2. CRACK GROWTH AND DESIGN (a) Crack Growth Calculation of Flaws in the Original Weld. The size of all flaws detected or postulated in the original weld shall be used to define the life of the overlay. In no case shall the inspection interval be longer than the life of the overlay. The inspection interval shall be as specified in 3(c). Crack growth in the original weld, due to both stress corrosion and fatigue, shall be evaluated.

Flaw characterization and evaluation shall be based on the ultrasonic examination results, if applicable, or the postulated flaw, if ultrasonic examination of the weldment is not performed.

(1) For repair overlays, the initial flaw size for crack growth in the original weld shall be based on the as-found flaw or postulated flaw, if no pre-overlay ultrasonic examination is performed.

(2) For postulated flaws in the original weld or base metal, the axial flaw length shall be set at 1.5 inches (38 mm) or the combined width of the weld plus buttering, whichever is greater. The circumferential flaw length shall be assumed to be 360 degrees.(a) If an examination is performed prior to application of the overlay, which is qualified in accordance with Appendix VIII, Supplement 10 or Supplement 2, and no inside-surface-connected planar flaws are discovered, initial flaws originated from the inside surface of the weldment equal to 10% of the original U. S. Nuclear Regulatory Commission Attachment 3 3F1008-03 Page 3 of 13 wall thickness shall be assumed in both the axial and circumferential directions.

Overlays shall be considered mitigative.(b) If no examination is performed prior to application of the overlay, initial inside-surface-connected planar flaws equal to at least 75% through the original wall thickness shall be assumed, in both the axial and circumferential directions, consistent with the overlay examination volume in Figure 2.(c) There may be circumstances in which an overlay examination is performed using an ultrasonic examination procedure qualified in accordance with Appendix VIII, Supplement 11 for depths greater than the outer 25% of the original wall thickness (Figure 2). For such cases, initial flaw depths shall be assumed to be the detected depth consistent with the depth to which the examination procedure is qualified and the available coverage, plus the worst-case flaw in the inner region of the pipe wall thickness that is not qualified for ultrasonic examination.(d) In determining the expected life of the overlay, any inside-surface-connected planar flaw found by the overlay preservice inspection of 3(b) that exceeds the depth of (2)(a), (b) or (c) above shall be used as part of the initial flaw depth.The flaw depth assumed is the detected flaw depth plus the postulated worst-case flaw depth in the unqualified ultrasonic examination region of the pipe wall thickness.

An overlay meeting this condition shall be considered a repair.(b) Structural Design and Sizing of the Overlay. The design of the weld overlay shall satisfy the following, using the assumptions and flaw characterization restrictions in 2(a). The following design analysis shall be completed in accordance with IWA-431 1: (1) The axial length and end slope of the weld overlay shall cover the weld and heat-affected zones on each side of the weld and shall provide for load redistribution from the item into the weld overlay and back into the item without violating applicable stress limits of NB-3200 or the Construction Code. Any laminar flaws in the weld overlay shall be evaluated in the analysis to ensure that load redistribution complies with the above. These requirements will usually be satisfied if the weld overlay design-thickness length extends axially beyond the projected flaw by at least where R is the outer radius of the item and t is the nominal wall thickness of the item.(2) Unless specifically analyzed in accordance with 2(b)(1), the end transition taper of the overlay shall not exceed 30 degrees. A slope of not more than 1:3 is recommended.

(3) For determining the combined length of circumferentially oriented flaws in the underlying weld, multiple flaws shall be treated as one flaw of length equal to the sum of the lengths of the individual flaws characterized in accordance with IWA-3300.(4) For circumferentially oriented flaws, in the underlying weld, the flaws shall be assumed to be 100% through the original wall thickness for the entire circumference.

U. S. Nuclear Regulatory Commission Attachment 3 3F1008-03 Page 4 of 13 (5) For axial flaws in the underlying weld, the flaws shall be assumed to be 100%through the original wall thickness of the item for the entire axial length of the flaw or combined flaws, as applicable.

(6) For full structural overlays, when ultrasonic examination is not performed prior to installation of the weld overlay the assumed flaw in the underlying weld shall be based on the limiting case of the two below: (a) 100% through-wall for the entire circumference, or (b) 100% through-wall for 1.5 inches (38 mm) or the combined width of the weld plus buttering, whichever is greater in the axial direction.

(7) The overlay design thickness shall be verified using only the weld overlay thickness conforming to the deposit analysis requirements of 1(e). The combined wall thickness at the weld overlay and the effects of any discontinuities (e.g., another weld overlay or reinforcement for a branch connection) within a distance of 2.5V-from the toes of the weld overlay, including the flaw size assumptions defined in 2(b)(4), (5), or (6) above, shall be evaluated and meet the requirements of IWB-3640.(8) The effects of any changes in applied loads, as a result of weld shrinkage from the entire overlay, on other items in the piping system (e.g., support loads and clearances, nozzle loads, and changes in system flexibility and weight due to the weld overlay) shall be evaluated.

Existing flaws previously accepted by analytical evaluation shall be evaluated in accordance with IWB-3640, IWC-3640, or IWD-3640, as applicable.

3. EXAMINATION In lieu of all other examination requirements, the examination requirements herein shall be met through at least the first specified inservice examination of the weld overlay. Nondestructive examination methods shall be in accordance with IWA-2200, except as specified herein.Nondestructive examination personnel shall be qualified in accordance with IWA-2300.Ultrasonic examination procedures and personnel shall be qualified in accordance with Appendix VIII, Supplement 11.(a) Acceptance Examination (1) The weld overlay shall have a surface finish of 250 micro-inches (6.3 micrometers)

RMS or better and a contour that provides for ultrasonic examination in accordance with procedures qualified in accordance with Appendix VIII. The weld overlay shall be inspected to verify acceptable configuration.

(2) The weld overlay and the adjacent base material for at least 1/2 inch (13 mm) from each side of the weld shall be examined using the liquid penetrant method. Surface examination shall be performed on thermocouple removal areas in accordance with NB-4435(b)(3).

The weld overlay shall satisfy the surface examination acceptance criteria for welds of the Construction Code or NB-5300. The adjacent base metal shall satisfy the surface examination acceptance criteria for base material of the U. S. Nuclear Regulatory Commission Attachment 3 3F1008-03 Page 5 of 13 Construction Code or NB-2500. If ambient-temperature temper bead welding is required, the liquid penetrant examination of the completed weld overlay shall be conducted after the three tempering layers (i.e., layers 1, 2, and 3) have been in place for at least 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after completion of the third temper bead layer over the ferritic steel.(3) The acceptance examination volume A-B-C-D in Figure 1(a), plus the heat-affected zone beneath the fusion zone C-D, shall be ultrasonically examined to assure adequate fusion (i.e., adequate bond) with the base metal and to detect flaws, such as interbead lack of fusion, inclusions, or cracks. If ambient-temperature temper bead welding is required, the ultrasonic examination of the completed weld overlay shall be conducted after the three tempering layers (i.e., layers 1, 2, and 3) have been in place for at least 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after completion of the third temper bead layer over the ferritic steel.Planar flaws detected in the weld overlay acceptance examination shall meet the preservice examination acceptance standards of Table IWB-3514-2.

In applying the acceptance standards to planar indications within the volume E-F-G-H, in Figure 1(b), the thickness "t 1" shall be used as the nominal wall thickness in Table IWB-3514-2. For planar indications outside this examination volume, the nominal wall thickness shall be "t 2" as shown in Figure 1(c), for volumes A-E-H-D and F-B-C-G.Laminar flaws in the weld overlay shall meet the following: (a) Laminar flaws shall meet the acceptance standards of Table IWB-3514-3 with the additional limitation that the total laminar flaw shall not exceed 10% of the weld surface area and that no linear dimension of the laminar flaw area exceeds 3.0 inches (76 mm) or 10% of the nominal pipe circumference, whichever is greater.(b) The reduction in coverage of the examination volume A-B-C-D in Figure 1(a), due to laminar flaws, shall be less than 10%. The uninspectable volume is the volume in the weld overlay underneath the laminar flaws for which coverage cannot be achieved with angle beam examination.(c) Any uninspectable volume in the weld overlay shall be assumed to contain the largest radial planar flaw that could exist within that volume. This assumed flaw shall meet the preservice examination acceptance standards of Table IWB-3514-2, with nominal wall thickness as defined above for planar flaws. Both axial and circumferential planar flaws shall be assumed.(4) After completion of all welding activities, affected restraints, supports, and snubbers shall be VT-3 visually examined to verify that design tolerances are met.(b) Preservice Inspection (1) The examination volume in Figure 2 shall be ultrasonically examined.

The angle beam shall be directed perpendicular and parallel to the piping axis, with scanning performed in four directions, to locate and size any planar flaws that might exist or may have propagated into the outer 25% of the base material or into the weld U. S. Nuclear Regulatory Commission Attachment 3 3F1008-03 Page 6 of 13 overlay. Any uninspectable volume in the outer 25% of the underlying weld, as shown in Figure 2, shall be assumed to contain the largest planar flaw within that volume for flaw growth evaluation.

(2) The preservice examination acceptance standards of Table IWB-3514-2 shall be met for the weld overlay. In applying the acceptance standards, wall thickness, tw, shall be the thickness of the weld overlay. Planar flaws in the outer 25% of the base metal thickness shall meet the design analysis requirements of 2(b).(3) The flaw evaluation requirements of IWB-3640 shall not be applied to planar flaws identified during preservice examination in the weld overlay, that exceed the preservice examination acceptance standards of Table IWB-3514-2.

Planar flaws detected in the outer 25% of the base material shall be evaluated in accordance with IWB-3640.(c) Inservice Inspection (1) The weld overlay examination volume in Figure 2 shall be added to the inspection plan. The weld overlay inspection interval shall not be greater than specified in 3(c)(2). Inservice examination requirements beyond the interval specified in 3(c)(2)shall be in accordance with the applicable regulations in effect at that time.(2) The weld overlay shall be ultrasonically examined during the first or second refueling outage following application.

(3) The weld overlay examination volume in Figure 2 shall be ultrasonically examined to determine if any new or existing planar flaws have propagated into the outer 25%of the base metal thickness or into the overlay. The angle beam shall be directed perpendicular and parallel to the piping axis, with scanning performed in four directions.

(4) The inservice examination acceptance standards of Table IWB-3514-2 shall be met for the weld overlay. If the acceptance standards of Table IWB-3514-2 cannot be met, the weld overlay shall meet the acceptance criteria of IWB-3600.

Planar flaws in the outer 25% of the base metal thickness shall meet the design analysis requirements of Paragraph 2(b). Flaws due to stress corrosion cracking in the weld overlay shall result in removal of the weld overlay and the item shall be repaired or replaced.(5) Weld overlay examination volumes in Figure 2 that show no indication of planar flaw growth or new planar flaws shall be placed into a population to be examined on a sample basis, except as required by 3(c)(1). Twenty-five percent of this population shall be examined at least once during each inspection interval.(6) If inservice examinations reveal planar flaw growth, or new planar flaws that meet the acceptance standards of IWB-3514 or the acceptance criteria of IWB-3600, the weld overlay examination volume shall be reexamined during the first or second refueling outage following discovery of the growth or new planar flaws.(7) For weld overlay examination volumes with unacceptable indications in accordance U. S. Nuclear Regulatory Commission Attachment 3 3F1008-03 Page 7 of 13 with 3(c)(4), the weld overlay shall be removed, including the original defective weld, and the item shall be corrected by a repair/replacement activity in accordance with IWA-4000.(d) Additional Examinations.

If inservice examinations reveal an unacceptable indication according to 3(c)(4), planar flaw growth into the weld overlay design thickness, or axial flaw growth beyond the specified examination volume, additional weld overlay examination volumes, equal to the number scheduled for the current inspection period, shall be examined prior to return to service. If additional unacceptable indications are found in the second sample, 50% of the total population of weld overlay examination volumes shall be examined prior to return to service. If additional unacceptable indications are found, the entire remaining population of weld overlay examination volumes shall be examined prior to return to service.4. PRESSURE TESTING A system leakage test shall be performed in accordance with IWA-5000.5. DOCUMENTATION Use of this alternative shall be documented on Form NIS-2.

U. S. Nuclear Regulatory Commission 3F1008-03 Attachment 3 Page 8 of 13 a. Acceptance Examination Volume A-B-C-D 1/2 in. (min.) .1/2 in. (min.)(Note 1)4--------------

xxjxxxx 1 Nýti H G b. Thickness (t ) for Table IWB-3514-2

c. Thickness (t ) for Table IWB-3514-2 Figure 1 -Acceptance Examination Volume and Thickness Definitions Notes: (1) For axial or circumferential flaws, the axial extent of the examination volume shall extend at least 1/2 inch (13 mm) beyond the toes of the original weld.(2) The weld includes the weld end butter, where applied.

U. S. Nuclear Regulatory Commission 3F1008-03 112 in. (min.)112 in. (min.)(Note 1)Attachment 3 Page 9 of 13 t\"4 Examination Volume A-B-C-D Notes: Figure 2 -Preservice and Inservice Examination Volume (1) For axial or circumferential flaws, the axial extent of the examination volume shall extend at least Y2 inch (13 mm) beyond the as-found flaw and at least 1/2 inch (13 mm) beyond the toes of the original weld.(2) The weld includes weld end butter, where applied.

U. S. Nuclear Regulatory Commission Attachment 3 3F1008-03 Page 10 of 13 MANDATORY APPENDIX I AMBIENT TEMPERATURE TEMPER BEAD WELDING I-1 GENERAL REQUIREMENTS (a) This Appendix applies to dissimilar austenitic filler metal welds between P-No. 1 materials and their associated welds and welds joining P-Nos. 8 or 43 materials to P-No. 1 materials.(b) The maximum area of an individual weld overlay based on the finished surface over the ferritic base material shall be 300 inches 2 (195,000 mm 2).(c) Repair/replacement activities on a dissimilar-metal weld in accordance with this Appendix are limited to those along the fusion line of a nonferritic weld to ferritic base material on which WS inch (3 mm) or less of nonferritic weld deposit exists above the original fusion line.(d) If a defect penetrates into the ferritic base material, repair of the base material, using a nonferritic weld filler material, may be performed in accordance with this Appendix, provided the depth of repair in the base material does not exceed 3H8 inch (10 mm).(e) Prior to welding, the area to be welded and a band around the area of at least 11/2 times the component thickness or 5 inch (130 mm), whichever is less, shall be at least 50 degrees F (10 degrees C).(f) Welding materials shall meet the Owner's Requirements and the Construction Code and Cases specified in the Repair/Replacement Plan. Welding materials shall be controlled so that they are identified as acceptable until consumed.(g) Peening may be used, except on the initial and final layers.1-2 WELDING QUALIFICATIONS The welding procedures and operators shall be qualified in accordance with Section IX and the requirements of 1-2.1 and 1-2.2.1-2.1 Procedure Qualification (a) The base materials for the welding procedure qualification shall be of the same P-Number and Group Number as the materials to be welded. The materials shall be postweld heat treated to at least the time and temperature that was applied to the materials being welded.(b) The root width and included angle of the cavity in the test assembly shall be no greater than the minimum specified for the repair.(c) The maximum interpass temperature for the first three layers of the test assembly shall be 150 degrees F (66 degrees C).

U. S. Nuclear Regulatory Commission 3F1008-03 Attachment 3 Page 11 of 13 (d) The weld overlay shall be qualified using a groove weld coupon. The test assembly groove depth shall be at least 1 inch (25 mm). The test assembly thickness shall be at least twice the test assembly groove depth. The test assembly shall be large enough to permit removal of the required test specimens.

The test assembly dimensions on either side of the groove shall be at least 6 inches (150 mm). The Qualification test plate shall be prepared in accordance with Figure I-1.Discard Transve Reducec Transvei Transve Reduce(Transvei Discard rse Side Bend d Section Tensile rse Side Bend rse Side Bend Section Tensile rse Side Bend-Weld metal General Note: Base metal Charpy impact specimens are not shown.Figure. I-1 QUALIFICATION TEST PLATE (e) Ferritic base material for the procedure qualification test shall meet the impact test requirements of the Construction Code and Owner's Requirements.

If such requirements are not in the Construction Code and Owner's Requirements, the impact properties shall be determined by Charpy V-notch impact tests of the procedure qualification base material at or below the lowest service temperature of the item to be repaired.

The location and orientation of the test specimens shall be similar to those required in 1-2.1 (f) below, but shall be in the base metal.

U. S. Nuclear Regulatory Commission Attachment 3 3F1008-03 Page 12 of 13 (f) Charpy V-notch tests of the ferritic heat-affected zone (HAZ) shall be performed at the same temperature as the base metal test of 1-2.1(d) above. Number, location, and orientation of test specimens shall be as follows: (1) The specimens shall be removed from a location as near as practical to a depth of one-half the thickness of the deposited weld metal. The coupons for HAZ impact specimens shall be taken transverse to the axis of the weld and etched to define the HAZ. The notch of the Charpy V-notch specimen shall be cut approximately normal to the material surface in such a manner as to include as much HAZ as possible in the resulting fracture.

When the material thickness permits, the axis of a specimen shall be inclined to allow the root of the notch to be aligned parallel to the fusion line.(2) If the test material is in the form of a plate or forging, the axis of the weld shall be oriented parallel to the principal direction of rolling or forging.(g) The Charpy V-notch test shall be performed in accordance with SA-370.Specimens shall be in accordance with SA-370, Figure 11, Type A. The test shall consist of a set of three full-size 10 mm x 10 mm specimens.

The lateral expansion, percent shear, absorbed energy, test temperature, orientation, and location of all test specimens shall be reported in the Procedure Qualification Record.(h) The average lateral expansion value of the three HAZ Charpy V-notch specimens shall be equal to or greater than the average lateral expansion value of the three unaffected base metal specimens.

1-2.2 Performance Qualification Welding operators shall be qualified in accordance with Section IX.1-3 WELDING PROCEDURE REQUIREMENTS The welding procedure shall include the following requirements: (a) The weld metal shall be deposited by the automatic or machine GTAW process.(b) Dissimilar metal welds shall be made using A-No. 8 weld metal (ASME Code Section IX QW-442) for P-No. 8 to P-No. 1 weld joints or F-No. 43 weld metal (QW-'432) for P-No. 8 to P-No. 1 weld joints.(c) The area to be welded shall be buttered with a deposit of at least three layers to achieve at least 1/8 inch (3 mm) overlay thickness with the heat input for each layer controlled to within +/-10% of that used in the procedure qualification test. The heat input of the first three layers shall not exceed 45 kJ/inch (1.8 kJ/mm) under any conditions.

Particular care shall be taken in the placement of the weld layers of the austenitic overlay filler material at the toe of the overlay to ensure that the HAZ and ferritic base metal are tempered.

Subsequent layers shall be deposited with a heat input not exceeding that used for layers beyond the third layer in the procedure qualification.

U. S. Nuclear Regulatory Commission Attachment 3 3F1008-03 Page 13 of 13 (d) The maximum interpass temperature for field applications shall be 350 degrees (180 degrees C) for all weld layers regardless of the interpass temperature used during qualification.

The interpass temperature limitation of QW-406.3 need not be applied.(1) The interpass temperature shall be measured using thermocouples.(e) Particular care shall be given to ensure that the weld region is free of all potential sources of hydrogen.

The surfaces to be welded, filler metal, and shielding gas shall be suitably controlled.

PROGRESS ENERGY FLORIDA, INC.CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 -302 / LICENSE NUMBER DPR -72 ATTACHMENT 4 BARRIER LAYER TO PREVENT HOT CRACKING IN HIGH SULFUR STAINLESS STEEL U. S. Nuclear Regulatory Commission Attachment 4 3F1008-03 Page 1 of 2 BARRIER LAYER TO PREVENT HOT CRACKING IN HIGH SULFUR STAINLESS STEEL Background During some recent dissimilar metal weld (DMW) overlay activities, where use of ERNiCrFe-7A (Alloy 52M) and ERNiCrFe-7 (Alloy 52) has been used for the filler metal, flaws in the first layer have occurred in the portion of the overlay deposited on the austenitic stainless steel portions (safe ends, pipe etc.) of the assemblies.

The applicable stainless steel base material at Crystal River Unit 3 (CR-3), where the full structural weld overlay (SWOL) will be deposited, is as follows: Piping attached to the "A" hot leg surge nozzle buttering is wrought seamless austenitic stainless steel A 376 TP 316 Discussion The flaw characteristics observed above are indicative of hot cracking.

This phenomenon has not been observed on the ferritic steel or ENiCrFe-3 (Alloy 182) DMW portions of the assemblies when welding Alloy 52M thereon.Further studies have determined that this problem may occur when using Alloy 52M filler metal on austenitic stainless steel materials with high sulfur content.Limited tests and evaluations recently performed have resulted in the conclusion that welding with Alloy 52M on stainless steel base material with 0.020 wt% sulfur results in cracking while welding on stainless steel base materials with less than 0.010 wt% have resulted in no cracking.To reduce the susceptibility of hot cracking occurrence due to welding Alloy 52M on the stainless steel base materials with high sulfur, ER309L filler metal has been selected as the preferred filler metal to provide a barrier layer between the Alloy 52M and the high sulfur stainless steel base material.

This filler metal is compatible with the base material and promotes primary weld metal solidification as ferrite rather than austenite.

The ferrite is more accommodating of residual elements therein and in the underlying base material, thereby significantly reducing the susceptibility to hot cracking.

ER309L is also compatible with the Alloy 52M subsequently welded thereon. However, the barrier layer will consist of ERNiCr-3 (Alloy 82) being used locally at the interface between the Alloy 182 DMW and the stainless steel item.ER309L welding on Alloy 182 may result in cracking of the ER309L weld. Welding on high sulfur stainless steel with Alloy 82 has not been a concern relevant to hot cracking occurrence.

A mockup was welded to evaluate the interactive effects, such as hot cracking and lack of fusion between the Alloy 182 DMW, the stainless steel base material, the ER309L and Alloy 82 barrier layer, and the subsequent Alloy 52M weld overlay. The mockup assembly consisted of a stainless steel pipe (0.020 wt% sulfur) with an Alloy 182 groove weld performed therein. The barrier layer and overlay were welded in the same sequence as performed in the field (barrier layer ER309L, and Alloy 82 and then two layers of Alloy 52M overlay).

The barrier layer and overlay welding parameters used in the mockup were similar to those used in the field however, slightly reduced wire feed rates were used for conservatism.

U. S. Nuclear Regulatory Commission Attachment 4 3F17008-03 Page 2 of 2 The following examinations were performed on the final mockup and no recordable indications were detected: Pressure Testing (PT) was performed on the:* High sulfur stainless steel base material* Alloy 182 Groove Weld* ER309L Barrier Layer* Alloy 82 Barrier Layer* Alloy 52M Overlay Limited Performance Demonstration Initiative (PDI) Ultrasonic Testing (UT)* 0 degreeTransducer with Full Coverage* 45 degree Transducer with Full Coverage* OD Creeper Transducer with Full Coverage* 60 degree Transducer with limited coverage, (focal depth exceeded UT procedure allowable in places due to overlay being of insufficient thickness.

Only two layers of Alloy 52M were deposited)

Metallography has been performed on eight specimens that were removed in approximate 45 degree circumferential increments around the pipe searching for any discontinuities, flaws or other anomalies.

No conditions causing concern were observed on any of the specimens.

Conclusion More tests and evaluations would be necessary to accurately determine the threshold where the base metal sulfur content would require barrier layer welding.CR-3 will use the barrier layer on the stainless steel surge pipe prior to overlay since it has a sulfur content greater than 0.010 wt%. The barrier layer will use ER309L on the stainless steel and Alloy 82 on the stainless steel near the DMW to stainless steel fusion zone only.Structural credit will not be assumed for the barrier layer in determining the required minimum overlay thickness.

The barrier layer welding will be performed in accordance with ASME Section IX qualified welding procedure specification(s).

PT will be performed on the barrier layer surface and its volume will be included in the final UT acceptance examination of the overlay.

PROGRESS ENERGY FLORIDA, INC.CRYSTAL RIVER -UNIT 3 DOCKET NUMBER 50 -302 / LICENSE NUMBER DPR -72 ATTACHMENT 5 LIST OF REGULATORY COMMITMENTS U. S. Nuclear Regulatory Commission 3F1008-03 Attachment 5 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Florida Power Corporation (FPC) in this document.

Any other actions discussed in the submittal represent intended or planned actions by FPC. They are described to the NRC for the NRC's information and are not regulatory commitments.

Please notify the Supervisor, Licensing and Regulatory Programs of any questions regarding this document or any associated regulatory commitments.

Commitment Due Date The details surrounding the design analysis for the This vendor supplied analysis will SWOL are being developed to support the CR-3 16th be available for NRC review at the Refueling Outage. beginning of the CR-3 16th Refueling Outage After completion of the ultrasonic examination of the Within 60 days of completion of weld overlays, a report containing the ultrasonic the ultrasonic examination of the examination results, a discussion of any repairs to the weld overlays performed during weld overlay material and/or base metal, and reason for the CR-3 16th in Refueling Outage the repair will be submitted to the NRC.The NRC will be notified as soon as practical, but no Prior to Mode 4 during restart from later than Mode 4 during restart, if any cracks are the CR-3 16th Refueling Outage, if detected that exceed the pre-service examination required acceptance standards in ASME Code Section Xl, Table IWB-3514-2.