ML062860603

Request to Use Portion of Later Edition and Addenda of ASME Section XI

ML062860603
Person / Time
Site:	Surry, North Anna
Issue date:	10/09/2006
From:	Gerald Bichof Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
06-856
Download: ML062860603 (22)

Text

October 9 , 2006 United States Nuclear Regulatory Commission Serial No.: 06-856 Attention: Document Control Desk NL&OSlETS : RO Washington, D. C. 20555 Docket Nos. : 50-2801281 50-3381339 License Nos.: DPR-32/37 NPF-417 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

SURRY POWER STATION UNITS 1 AND 2 NORTH ANNA POWER STATION UNITS 1 AND 2 REQUEST TO USE PORTION OF LATER EDITION AND ADDENDAOF ASME SECTION XI Currently North Anna and Surry Power Stations Units 1 and 2 are completing their first ten-year Containment Inservice Inspection (ISI) Interval using the 1992 Edition with the 1992 Addenda of ASME Section XI (Code). The IWE portion of the Containment IS1 Plan is currently in the 3" period for all four units. The Code allowed periodlinterval extension requirements of IWA-2430(d) and IWE-2412(b) have been applied coinciding with planned outages such that the 3rd period end dates for the Containment IS1 (IWE)

Plan are as follows:

North Anna Unit 1 - 1010612007 North Anna Unit 2 - 1011112008 Surry Unit 1 - 11121I2007 Surry Unit 2 - 05/21/2008 10CFR50.55a(b) currently endorses the 2001 Edition through the 2003 Addenda of ASME Section XI. Pursuant to 10 CFR 50.55a(g)(4)(iv), Dominion requests approval to use the 2001 Edition through the 2003 Addenda of ASME Section XI, Subsection IWE, Table IWE-2500-1, Category E-A, ltem number E l .12. The use of ltem E l .12 is requested to clarify VT-3 examination methods for the IWE containment surfaces.

NRC Regulatory Issue Summary 2004-12, "Clarification on Later Use of Editions and Addenda to the ASME OM Code and Section XI," notes that if licensees choose to use only portions of the later Code, then they must meet all related requirements of the respective editions and addenda as well. Therefore, a discussion of the related Code requirements and how they will be implemented by Dominion is provided in Attachments 1, 2, and 3.

Serial No.06-856 Docket Nos. 50-2801281 and 50-3381339 Page 2 of 3 Dominion requests approval to use the above mentioned Edition and Addenda of ASME Section XI by May 31, 2007 to support implementation of the alternate Code requirements during the Surry Unit 1 and North Anna Unit 1 fall 2007 refueling outages.

A decision in processing this request by the requested date provides adequate time to obtain and qualify the remote visual VT-3 examination procedure and equipment for implementation of the current code requirements.

If you have any questions or require additional information, please contact Mr. Thomas Shaub at (804) 273-2763.

Very truly yours,

(?iLm?=~

Gerald T. Bischof Vice President - Nuclear Engineering Attachments

1. Comparison of and Compliance with ASME Code Requirements

2. Comparison of Code Requirements for IWA-2200 and IWE-3510 VT-3 Examination

3. Comparison of Code Requirements for IWA 2300 VT-3 Examiner Qualification/Certification Commitments made in this letter: None

Serial No.06-856 Docket Nos. 50-2801281 and 50-3381339 Page 3 of 3 cc:

U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, Georgia 303035 Mr. N. P. Garrett NRC Senior Resident lnspector Surry Power Station Mr. J. T. Reece NRC Senior Resident lnspector North Anna Power Station Mr. S. R. Monarque NRC Project Manager - North Anna Power Station U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 8-HI 2 Rockville, Maryland 20852-2738 Mr. S. P. Lingam NRC Project Manager - Surry Power Station U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 8 G9A Rockville, Maryland 20852-2738 Mr. R. A. Smith Authorized Nuclear lnsurance lnspector Surry Power Station Mr. M. Grace Authorized Nuclear Insurance lnspector North Anna Power Station

Serial No.06-856 Docket Nos. 50-2801281 and 50-3381339 Attachment 1 ATTACHMENT 1 COMPARISON OF AND COMPLIANCE WITH ASME CODE REQUIREMENTS NORTH ANNA AND SURRY POWER STATIONS UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

Serial No.06-856 Docket Nos. 50-2801281 and 50-3381339 Attachment 1 COMPARlSON OF AND COMPLIANCE WITH ASME CODE REQUIREMENTS NORTH ANNA AND SURRY POWER STATIONS UNITS 1 AND 2 Introduction North Anna and Surry Units 1 and 2 are in the 3rd period of the first ten-year Containment lnservice lnspection (ISI) Interval for ASME Section XI Subsection IWE.

Pursuant to 10CFR50.55a(g)(4)(iv), Dominion requests approval to use a portion of later editions and addenda of ASME Section XI, specifically the 2001 Edition through the 2003 Addenda, Subsection IWE, Table IWE-2500-1, Category E-A, ltem number E l .12.

The use of ltem E l .12 is requested to clarify where the VT-3 examination method is intended to be performed (i.e., wetted surfaces of submerged areas) for the IWE containment surfaces requiring examination.

The 2001 Edition through the 2003 Addenda of ASME Section XI Code limits parts (surfaces) to be examined for ltem E l .12 to wetted surfaces of submerged areas. The 1992 Edition with the 1992 Addenda of ASME Section XI requires examination of accessible surface areas similar to ltem number E l . 11 of the 1992 Edition with the 1992 Addenda ASME Section XI Code. The wetted surfaces of submerged areas was only part of the examination requirement in the 1992 Edition with the 1992 addenda of the ASME Code.

ASME Code Components Affected The North Anna and Surry containments are sub-atmospheric. The metallic liner of the concrete containment is examined under the rules of ASME Section XI, IWE (metallic liners of Class CC components). The components affected are the containment surface areas of the liner as addressed by Table IWE-2500-1, Category E-A, ltem number E l .12.

The 1992 Edition with 1992 Addenda ltem E l .12 - includes all accessible surface areas of the metallic liner including wetted surface areas of submerged areas.

The 2001 Edition through 2003 Addenda ltem E l .12 - includes only the metallic liner wetted surface areas of submerged areas.

Applicable Code Edition and Addenda

The first ten-year Containment lnservice lnspection Plan for IWE for the North Anna and Surry units is based upon the 1992 Edition with the 1992 Addenda of ASME Section XI.

The 1992 Edition with the 1992 Addenda of ASME Section XI, Subsection IWE, Table 2500-1, Category E-A, ltem number E l .12, requires a 100% visual, VT-3 examination of the accessible surface areas. The parts (surfaces) to be examined include the following Page 1 of 5

Serial No.06-856 Docket Nos. 50-2801281 and 50-3381339 Attachment 1 notes associated with the item number.

(2) Examination shall include structures that are parts of reinforcing structure, such as stiffening rings, manhole frames, and reinforcement around openings.

(4) Including the wetted surfaces of submerged areas and the portions of insulated surface areas that are necessary to meet the requirements of IWE-1231(a)(4).

(5) Examination shall include the attachment welds between structural attachments and pressure retaining boundary or reinforcing structure, except for nonstructural and temporary attachments as defined in NE-4435 and minor permanent attachments as defined in CC-4543.4. Examination shall include the weld metal and the base metal for ?hin. beyond the edge of the weld.

The VT-3 examination is required once at the end of the interval. Note 1 was applicable to the examination requirement.

(1) Examination may be made from either the inside or outside surface.

Proposed Subsequent Code Edition and Addenda The 2001 Edition through the 2003 Addenda of ASME Section XI, Subsection IWE, Table 2500-1, Category E-A, Item number E l .12, requires a 100% general visual of the wetted surfaces of submerged areas. The following note applied to the examination requirement.

(1) Examination shall include all accessible interior and exterior surfaces of Class MC components, parts, and appurtenances, and metallic shell and penetration liners of Class CC components. The following items shall be considered for examination:

(a) integral attachments and structures that are parts of reinforcing structure, such as stiffening rings, manhole frames, and reinforcement around openings.

(b) surfaces of attachment welds between structural attachments and pressure retaining boundary or reinforcing structure, except for nonstructural and temporary attachments as defined in NE-4435 and minor permanent attachments as defined in CC-4543.4.

(c) surfaces of containment structural and pressure boundary welds, including longitudinal welds (Category A), circumferential welds (Category B), flange welds (Category C), and nozzle-to-shell welds (Category D) as defined in NE-3351 for Class MC and CC-3840 for Class CC; and surfaces flued head and bellows seal circumferential welds joined to the penetration.

(d) Pressure-retaining bolted connections, including bolts, studs, nuts, Page 2 of 5

Serial No.06-856 Docket Nos. 50-2801281 and 50-3381339 Attachment 1 bushings, washers, and threads in base material and flange ligaments between fastener holes. Bolted connections need not be disassembled for performance of examinations, and bolting may remain in place under tension.

The general visual examination is required once an interval and deferral of the inspection to the end of the interval is permissible.

10 CFR50.55a(b)(2)(ix) modified the use of the 2001 Edition through the 2003 Addenda with limitations. The following limitations are applicable; paragraphs (b)(2)(ix)(A),

(b)(2)(ix)(B), and (b)(2)(ix)(F) through (b)(2)(ix)(l). These are discussed.

(A) For Class MC applications, the licensee shall evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of or result in degradation to such inaccessible areas.

For each inaccessible area identified, the licensee shall provide the following in the IS1 Summary Report as required by IWA-6000:

1) A description of the type and estimated extent of degradation, and the conditions that led to the degradation;

2) An evaluation of each area, and the result of the evaluation, and;

3) A description of necessary corrective actions.

- Dominion comment: The limitation also applies to the current 1992 Edition with the 1992 Addenda, no change.

(B) When performing remotely the visual examinations required by Subsection IWE, the maximum direct examination distance specified in Table IWA-2210-1 may be extended and the minimum illumination requirements specified in Table IWA-2210-1 may be decreased provided that the conditions or indications for which the visual examination is performed can be detected at the chosen distance and illumination.

- Dominion comment: The limitation also applies to the current 1992 Edition with the 1992 Addenda, no change.

(F) VT-1 and VT-3 examinations must be conducted in accordance with IWA-2200. Personnel conducting examinations in accordance with the VT-1 or VT-3 examination method shall be qualified in accordance with IWA-2300. The "owner-defined" personnel qualification provisions in IWE-2330(a) for personnel that conduct VT-1 and VT-3 examinations are not approved for use.

- Dominion comment: Dominion performs its VT-1 and VT-3 examinations in accordance with IWA-2200, and performs its VT-1 and VT-3 personnel qualification in accordance with IWA-2300.

(G) The VT-3 examination method must be used to conduct the examinations in items E l . 12 and E l .20 of Table IW E-2500-1, and the VT-1 examination method must be used to conduct the examination in ltem 4.1 1 of Table-2500-

1. An examination of the pressure-retaining bolted connections in ltem E l .ll Page 3 of 5

Serial No.06-856 Docket Nos. 50-2801281 and 50-3381339 Attachment 1 of Table IWE-2500-1 using the VT-3 examination method must be conducted once each interval. The "owner-defined" visual examination provisions in IWE-2310(a) are not approved for use for VT-1 and VT-3 examinations.

- Dominion comment: For ltem E1.12 the limitation requires that the VT-3 examination method be used instead of a general visual examination.

Dominion will perform this examination using the visual VT-3 method using the examination provisions of IWA-2200.

(H) Limitation (bolting examinations per ltem E l . l l while disassembled) does not apply to ltem E l .12.

(I) Limitation (ultrasonic examination acceptance criteria of IWE-3511.3) does not apply to ltem E l .12.

The 2001 Edition through the 2003 Addenda Table IWE-2500-1, Category E-A, ltem E l .12 with applicable notes, is proposed for use with the required 10 CFR 50.55a(b)(2)(ix) limitations noted above.

Implementation of Related Requirements Table 2500-1, Category E-A, ltem number E l .12 as modified by 10 CFR 50.55a(b)(2)(ix)(F) and (G) are the related sections of the requested portion of the 2001 Edition through the 2003 Addenda of ASME Section XI.

The provisions of 10CFR50.55a(b)(2)(ix)(G) requires that a VT-3 examination be performed for ltem number E1.12, when using the 2001 Edition through the 2003 Addenda of ASME Section XI. Additionally, the provisions of IWA-2200 and IWA-2300 shall be used for the VT-3 examination method and examiner qualification as opposed to any "owner-defined program per 10CFR50.55a(b)(2)(ix)(F) and (G). These limitations for implementation of the ASME Section XI Code would be complied with.

The following clarification of Dominion's VT-3 examination and qualification procedures are provided.

1) The North Anna and Surry VT-3 examination procedure for Category E-A, ltem number E l .12 is based upon IWA-2200 and the acceptance criteria of IWE-3510 of the 1992 Edition with the 1992 Addenda of ASME Section XI. The examination requirements are essentially the same. Some of the later Code edition requirements are already incorporated in the Dominion VT-3 procedure, if more conservative. As such, the VT-3 examination procedure will not be modified due to this request. (Attachment 2 provides a comparison of the applicable code requirements found in IWA-2200 and IWE-3510 associated with the VT-3 examination, and provides an assessment of the Dominion procedure requirements.)

2) The written practice for North Anna and Surry VT-3 examination personnel qualification was previously updated by approved request to the requirements of Page 4 of 5

Serial No.06-856 Docket Nos. 50-2801281 and 50-3381339 Attachment 1 IWA-2300 in the 1998 Edition through the 2000 Addenda of ASME Section XI.

These requirements are essentially the same as the requested 2001 Edition through the 2003 Addenda of ASME Section XI. As such, the written practice for the VT-3 examination method will not be modified due to this request.

(Attachment 3 provides the differences in the applicable code requirements found in IWA-2300 associated with VT-3 examiner qualification/certification.)

All other provisions of the 1992 Edition with the 1992 Addenda of ASME Section XI as modified by approved relief request in the Containment IS1 Plan remain in affect for the first ten-year Containment IS1 Interval.

Duration of Proposed Request Approval is requested for the first Containment IS1 (IWE) ten-year interval for North Anna Units 1 and 2 and Surry Units 1 and 2.

Page 5 of 5

Serial No.06-856 Docket Nos. 50-2801281 and 50-3381339 Attachment 2 COMPARISON OF CODE REQUIREMENTS FOR IWA-2200 AND IWE-3510 VT-3 EXAMINATION NORTH ANNA AND SURRY POWER STATIONS UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

Serial No.06-856 Docket Nos. 50-2801281 and 50-3381339 Attachment 2 Comparison of Code Requirements for IWA-2200 and IWE-3510 VT-3 Examination (1992 Edition with the 1992 Addenda vs. 2001 Edition through the 2003 Addenda of ASME Section XI)

Code 1992e with 1992a 2001e through 2003a Noted Comments Paragraph differences IWA-2200(a) The three types of examinations Same None Note: 2003a used during inservice inspection IWA-2200 are defined as visual, surface, corrected by and volumetric. The erratum 12/03 examination method to be used is specified in Tables IWB-, No issue IWC- , IWD-, IWE-, IWF-, and IWL-2500-1. If a component must be examined in a high radiation area, remotely controlled equipment may be advisable.

When preparation of a surface Same None No issue for nondestructive examination is required, the preparation shall be by mechanical method. Such surfaces shall be blended into the surrounding area as may be required to perform the examination. The wall thickness shall not be reduced below the minimum thickness required by design. Non-mandatory Appendix D may be used for such surface preparation.

Page 1 of 8

Serial No.06-856 Docket Nos. 50-2801281 and 50-3381339 Attachment 2 Code 1992e with 1992a 2001e through 2003a Noted Comments Paragraph differences IWA-221O(a) Visual examinations shall be lntro is the same essentially The 1992e with Subparagraphs conducted in accordance with the 1992a did (a), (b), (c), (dl, Article 9 of Section V and the not have and (e) added following. [a] A written (a) is the same subparagraphs to 1992e with procedure and report of (a), (b), (c), (dl 1992a IWA-examination results is required. or (el 2210 to

[b] For procedure (b) For procedure demonstration, facilitate demonstration, a near-distance a test chart containing text with (a) None comparison by vision chart containing text with some lower case characters Dominion lower case characters without without an ascender or (b) The later ascender or descender (e.g., a, descender (e.g., a, c, el o) code substituted (a) No issue c, e, o) meeting Table IWA- meeting Table IWA-2210-1 is a generic test 2210-1 is required. required. Measurements of the chart for a more (b) No issue Measurements of the near- test chart shall be made once specific near-distance test chart shall be before initial use with an optical distance vision made once before initial use comparator (1OX or greater) or chart. Some with an optical comparator (1OX other suitable instrument to verify minor wording or greater) or other suitable that the height of a differences also instrument to verify that the representative lower case noted.

height, of a representative lower character without an asceder or case character, for the selected descender, for the selected type type size, meets the size, meets the requirements of requirements of Table-2210-1. table IWA-2210-1.

[c] Remote examination may be (c) is the same (c) None (c) No issue substituted for direct examination. The remote examination procedure shall be demonstrated to resolve the selected test chart characters.

Page 2 of 8

Serial No.06-856 Docket Nos. 50-2801281 and 50-3381339 Attachment 2 Code 1992e with 1992a 2001e through 2003a Noted Comments Paragraph differences

[dl Alternatives to the direct (d) is the same (d) None (d) No issue visual examination distance requirements of Section V may be used as specified in Table IWA-2210-1. [el It is not (e) It is not necessary to measure (e) The later (e) The Table necessary to measure illumination levels on each code added a was implied in illumination levels on each examination surface when the specific the previous examination surface when the same portable light source or reference to code and same portable light source or similar installed lighting Table-2210-1 results in no similar installed lighting equipment is demonstrated to change to equipment is demonstrated to provide the illumination specified Dominion's provide the specified illumination in Table-2210-1 at the maximum procedure.

at the maximum examination examination distance.

distance. [f] The illumination (f) The adequacy of illumination (f) The later (f) The addition levels from battery powered levels from battery powered code added an to the later portable lights shall be checked portable lights shall be checked alternative to code before and after each before and after each the light meter incorporates examination or series of examination or series of requirements. Inquiry XI-1 examinations, not to exceed 4 examinations, not to exceed 4 hr 07, which hours between checks. between checks. In lieu of using Dominion uses a light meter, these checks may already in the be made by verifying that the examination illumination is adequate (i.e., no procedure. No discernable degradation in the change.

visual examination resolution of the procedure demonstration test chart characters).

Page 3 of 8

Serial No.06-856 Docket Nos. 50-2801281 and 50-3381339 Attachment 2 Code 1992e with 1992a 2001e through 2003a Noted Comments Paragraph differences IWA-2213 VT-3 examinations are Same None No issue conducted to determine the general mechanical and structural condition of components and their supports by verifying parameters such as clearances, settings, and physical displacements; and to detect discontinuities and imperfections, such as loss of integrity at bolted or welded connections, loose or missing parts, debris, corrosion, wear, or erosion. VT-3 includes examinations for conditions that could affect operability or functional adequacy of snubbers and constant load and spring type supports.

Surface replication methods Same None No issue may be used for VT-1 and VT-3 examinations when the surface resolution is at least equivalent to that of direct visual observation.

No paragraph In addition to the requirements of The later code The Dominion Section V, Article 9, when remote added remote visual visual examination is substituted visual procedure for for direct visual examination, the requirements. VT-3 provides Page 4 of 8

Serial No.06-856 Docket Nos. 50-2801281 and 50-3381339 Attachment 2 Code 1992e with 1992a 2001e through 2003a Noted Comments Paragraph differences remote visual examination requirements system shall have the capability that meet of distinguishing and Section V, differentiating between the colors Article 9 and applicable to the requirements of requires that VT-1 and VT-3 for the the remote component examinations being visual conducted. examination system have the capability of distinguishing and differentiating between the colors applicable to the requirements of VT-3 for the component examinations being conducted.

The procedure has already incorporated the later requirements.

No issue.

Page 5 of 8

Serial No.06-856 Docket Nos. 50-2801281 and 50-3381339 Attachment 2 Code 1992e with 1992a 2001e through 2003a Noted Comments Paragraph differences Table IWA- VT-3 50fc 4ft 0.105in. Same, except for metric values Later code No issue, 2210-1 (visual method, minimum and the following note. added metric Dominion has illumination, maximum direct values, and note incorporated examination distance, maximum (1) Resolution of the specified associated with inquiry, XI-l-procedure demonstration lower characters can be used in lieu of resolution of 01-07 into the case character height) illumination measurement to characters can examination verify illumination adequacy. be used in lieu procedure, of illumination which meets measurement. the same illumination requirements provided in the note.

Coated Coated and Uncoated The earlier code The Dominion The inspected area, when The condition of the inspected only addressed VT-3 painted or coated, shall be area is acceptable if there is no coated areas in examination examined for evidence of evidence of damage or IWE-3510.2. procedure flaking, blistering, peeling, degradation, which exceeds the The later code follows the discoloration, and other signs of visual examination acceptance had combined earlier code distress. Areas that are suspect criteria specified by the Owner. non-coated and requirements.

shall be accepted by Areas that are suspect shall be coated in IWE- Dominion's engineering evaluation or accepted by engineering 3510.2. The procedure corrected by repair or evaluation or corrected by later code also meets this replacement in accordance with repair/replacement activities or allows the requirement for IW E-3122. Supplemental by corrective measures in owner to the earlier VT-3 examinations in accordance with accordance with IW E-3122. develop the acceptance IWE-3200 shall be performed Supplemental examinations in visual criteria.

when specified as a result of the accordance with IWE-3200 shall examination Page 6 of 8

r Ci 0.2  != ws' .-I

11. I 0 @ No ,UO ~ u a , + - P . O I

0 , a, ,+

(

f v, u r W W ~ " " ~c 6 , ~ ~0 ~E 3- 6m B m cv 0.5.5 g fg

.g o 0 ,

gc$2 3.-

p ,3- ,3- o .Po,'

-a-a

& SoPa, E c , m ~ . E ~ - - c c 3 - 2 2.5 c s m m 6 S c ,a.=o E $.s.6m-E I 1

c .& E .:

- -Gau a22-m Z e n 8 S ~ ~o ~r n - . E om* m - . = r =

n l - C U O 0 3l- a, o o 5 c~ ~~ ~z Z~ ' r p . 8 ~

. 2 6 U m o n a, I

Serial No.06-856 Docket Nos. 50-2801281 and 50-3381339 Attachment 2 Code Paragraph 1992e with 1992a I 2001e through 2003a Noted differences Comments this request. No issue.

No paragraph Moisture barriers with wear, The earlier code Dominion is not damage, erosion, tear, surface did not address requesting the cracks, or other defects that moisture use of Item permit intrusion of moisture barriers as part number E l .30 against inaccessible areas of the of Category E- associated with pressure retaining surfaces of the A. The earlier moisture metal containment shell or liner code addressed barriers. No shall be corrected by corrective moisture issue.

measures. barriers in Category E-D.

Page 8 of 8

Serial No.06-856 Docket Nos. 50-2801281 and 50-3381339 Attachment 3 ATTACHMENT 3 COMPARISON OF CODE REQUIREMENTS FOR IWA 2300 VT-3 EXAMINER QUALIFICATION/CERTIFlCATlON NORTH ANNA AND SURRY POWER STATIONS UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

Serial No.06-856 Docket Nos. 50-2801281 and 50-3381339 Attachment 3 Comparison of Code Requirements for IWA 2300 VT-3 Examiner Qualification/Certification (1998 Edition through the 2000 Addenda vs. 2001 Edition through the 2003 Addenda of ASME Section XI)

(Only addresses the differences, if paragraph not included, they are the same.)

Code Paragraph 1998e throuah 2000a 2001e through 2003a Noted differences Comments Table IWA-2322-1 Near - Distance Acuity Same Added metric values No issue Test Distances and Character Heights The basic examination The basic examination The later code Not seen as shall consist of at least shall consist of at least removes percentage significant. Basic 50 questions (required 50 questions (required requirements. exam not required for only once if only once if Number of required Level Ill recertification.

certification is sought certification is sought questions shifted in in more than one in more than one areas to be method): (1) 20% to method): (1) At least addressed.

30% of the questions 20 questions related shall cover ANSl / to understanding of ASNT CP-189. (2) ANSl /ASNT CP-189.

30% to 50% of the (2) At least 30 questions shall be questions related to similar to the Level II applicable materials, questions published fabrication, and by ASNT for the NDE product technology.

methods referenced in (3) At least 15 ANSl / ASNT CP-189. questions that are (3) 20% to 30% of the similar to published questions shall cover Level II questions for applicable materials, other NDT methods.

Page 1 of 3

Serial No.06-856 Docket Nos. 50-2801281 and 50-3381339 Attachment 3 Code Paragraph 1998e through 2000a 2001 e through 2003a Noted differences Comments products, and fabrication technology.

The Method The Method The later code Not seen as Examination shall Examination shall removes percentage significant.Section XI consist of at least 65 consist of at least 65 requirements. in IWA-2310(a) questions: (1) 20% to questions: (1) At least Number of required accepts earlier code 40% of the questions 30 questions related questions shifted in certifications until shall cover to fundamentals and areas to be recertification is fundamentals and principles that are addressed. required. As such, a principles of the similar to published Level III may be method and shall be ASNT Level III certified for some time similar to published questions for each period to an earlier ASNT Level III method. (2) At least code within the questions. (2) 30% to 15 questions related subsequent interval.

50% of the questions to application and shall cover establishment of applications and procedures and establishment of techniques that are procedures and similar to published techniques and shall ASNT Level Ill be similar to published questions for each ASNT Level Ill method. (3) At least questions. (3) 20% to 20 questions related 30% of the questions to capability for shall cover the interpreting codes, capability to interpret standards, and codes, standards, and specifications related specifications for the to the method.

method.

NDE Instructors shall In lieu of the The later code moved No issue.

Page 2 of 3

Serial No.06-856 Docket Nos. 50-2801281 and 50-3381339 Attachment 3 Code ~ a r a a r a ~ h 1998e through 2000a 2001e through 2003a Noted differences Comments meet the requirements requirements of CP- the location of these of Appendix VII. 189, a candidate requirements. The (V11-4140 - A being considered for requirements remain candidate being qualification as an the same.

considered for NDE lnstructor shall qualification as an satisfy the Level Ill NDE Instructor shall Basic and Method satisfy the Level III Examination Basic and Method requirements of IWA-Examination 2323 and shall meet requirements of IWA- one of the following 2300 and shall also requirements: (a) meet one of the maintain a current following teacher or vocational requirements: (a) the instructor certificate candidate shall issued by a state, maintain a current municipal, provincial, teacher or vocational or federal authority; or instructor certificate (b) complete a issued by a state, minimum of 40 hr municipal, provincial, instruction in training or federal authority; or and teaching (b)the candidate shall techniques.

complete a minimum of 40 hr instruction in training and teaching techniques.

Page 3 of 3