0CAN049904, Requests Authorization of Alternative Exam to Visual (VT-3C) Exam of Accessible Areas & Visual (VT-1C) of Suspect Areas Per Table IWL-2500-1,exam Category L-A,IWL-2310 & IWL-2510

Requests Authorization of Alternative Exam to Visual (VT-3C) Exam of Accessible Areas & Visual (VT-1C) of Suspect Areas Per Table IWL-2500-1,exam Category L-A,IWL-2310 & IWL-2510

ML20205G873
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/01/1999
From:	Vandergrift J ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
0CAN049904, CAN49904, NUDOCS 9904070398
Download: ML20205G873 (7)

Text

l O ~1 Entergy wperations, Inc.

1448 S R. 333 RusselM80, AR 72801 Tol 501858 5000 April 1,1999 OCAN049904 U. S. Nuclear Regulatory Commission Document Control Desk Mail Station OPI-17 Washington, DC 20555

Subject:

Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Request For ASME Code Alternative to IWL Regarding VT-lC and VT-3C Visual Examination Requirements Gentlemen:

Title 10 of the Code of Federal Regulations,10 CFR 50.55a, requires (in part) that inservice inspection of certain ASME Code Class 1,2, and 3 piping be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda, except where alternatives are authorized by the Commission pursuant to 10 CFR 50.55a(aX3Xi) or (aX3Xii). In order to obtain authorization, the licensee must demonstrate that (1) the proposed alternatives provide an acceptable level of quality and safety, or (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

In the Federal Register Dated August 8,1996 (61FR41303), the NRC amended its regulations to incorporate by reference the ASME Code,Section XI,1992 Edition, through 1992 Addenda of Subsections IWE and IWL. Subsection IWE provides the requirements for inservice inspection of Class MC (Metallic Containment components) and the metallic liner of Class CC (Concrete Containment components). Subsection IWL provides the requirements for inservice inspection of Class CC components.

I Pursuant to the provisions of 10 CFR 50.55a(aX3Xi), Entergy Operations is requesting authorization of alternative examination to the visual (VT-3C) examination of the accessible areas and a visual (VT-lC) of suspect areas per Table IWL-2500-1, Examination Category L-A (Item Nos. Ll.ll and Ll.12), IWL-2310, and IWL-2510. Additionally, authorization of alternative examination is also requested to the visual (VT-1) examination of the anchorage hardware and a visual (VT-lC) of the surrounding concrete per Table IWL-2500-1, 9904070398 990401 PDR ADOCK 05000313 P PDR n70124 C l

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1 U. S. NRC April 1,1999 OCAN049904 Page 2 Examination Category L-D (item No. L2.30), IWL-2310, and IWL-2524. The basis for

' proposed alternate examinations is discussed in the attachment to this letter.  !

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l The initial IWL inspections for ANO-1 will be performed prior to and during the IRIS 1 l ra8= Hag outage haginalag on September 10, 1999, consistent with the 25-year tendon ,

l survdll-a. These inspections are scheduled to begin in early August 1999. The initial IWL z

inspections for ANO-2 are scheduled to begin in October 1999 commensurate with the 20-year tendon surveillance. These inspections will be performed prior to and during the ANO-2 mid-cycle outage scheduled for November 1999. Therefore, in order to support the ANO-1

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inspecticns, NRC review and approval is requested on or about August 2,1999.

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This proposed authorization of alternative examination is similar to that requested by Brunswick Steam Electric Plant dated October 28,1998. As of the date of this letter, NRC Staff' approval for this requested Code altemative is pendmg Please contact me ifyou have additional questions.

1 Very truly yours, 1 Jinpf D. Vandergrift Director, Nuclear Safety JDV/sab Attachments 1

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U. S. NRC f

April 1 1999 0

OCAN049904 Page 3

' cc: ' Mr. Ellis W. Merschoff Regional Administrator l

U. S. Nuclear Regulatory Commission l RegionIV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 ,

NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 Mr. Nick Hilton NRR Project Manager Region IV/ANO-1 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Chris Nolan NRR Project Manager Region IV/ANO-2 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville, MD 20852 l

I' Attachment ts OCAN049904 Page1of4 i l

l , , Alternative Examination l 99-0-002 Comonnents for Which Alternative Examination is Reawad:

This request for authorization of alternative examination is applicable to accessible concrete surface areas subject to examination per Table IE2500-1, Examination l Category L-A (Item Nos. Lt.11 and L1.12), and tendon anchorage hardware and j surrounding concrete subject to examination per. Table' IE2500-1, Examination j Category L-B (Item No. L 2.30), at Arkansas Nuclear One, Units 1 and 2. j ASME Code.Section XI Reauirement:

I ASME Section XI,1992 Edition,1992 AddW=, Table IE2500-1, Examination l Category L-A (Item Nos. L1.11 and Ll.12), IE2310, and IE2510 requires a visual I (VT-3C) examination of the accessible areas and a visual (VT-lC) examination of suspect areas.

Table IE2500-1, Evamination Category L-B (Item No. L2.30), IE2310, and IE 2524 requires a visual (VT-1) examination of the anchorage hardware and a visual (VT-IC) examination of surrounding concrete.  ;

l Requested Alternative Examination:

Authorization of alternative examination is requested from performing the visual (VT-3C) .

examination of the accessible areas and a visual (VT-IC) of suspect areas per Table IE 2500-1, Examination Category L-A (Item Nos. Ll.ll and Ll.12), IE2310, and IE 2510. Alternative is also requested on the visual (VT-1) examination of the anchorage hardware and a visual (VT-lC) of the surrounding concrete per Table IE2500-1, l Examination Category L-B (Item No. L2.30), IE2310, and IE2524.  !

Ba=le for Alternative Eymmination:

In accordance with 10CFR50.55a(a)(3)(i), Arkansas Nuclear One (ANO) is requesting approval to implement alternative examination methods to those specified in Table IE i 2500-1, Examination Category L-A (Item Nos. Ll.11 and L1.12), IE2310, and IE 2510. ANO proposes to perform a general visual examination of the accessible areas and a detailed visual examination of those areas determined to be suspect.

l In accordance with 10CFR50.55a(a)(3)(i), ANO is also reques:N approval to implement alternative examination methods to those specified in Table IWL-2500-1, Examination Category L-B (Item No. L2.30), IE2310, and IE2524. ANO proposes to perform a detailed visual examination of both the anchorage hardware and the surrounding concrete.

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Attachment ts 0CAN049904 Page 2 of 4 The proposed alternative examination methods have been evaluated by ANO, and have  !

' determined that the implementation of the alternative methods will provide an acceptable level of quality and safety for the following reasons:

1. The visual examination methods (VT-lC & VT-3C) specified in Examination  !

Category I A and the visual examination methods (VT-1 and VT-1C) specified in Examination Category E-B requires that the visual examination and qualification of the j examiners meet the applicable requirements of IWA-2210 and IWA-2300. The i requirements specified in these ASME Code,Section XI provisions for the VT-3C and VT-lC examinations were developed for detecting flaws in metal components and for j this reason, are more stringent than those that would be required for the detection of l degradation on a concrete stmeture. The requirements ofIWA 2210 and IWA 2300 l were first introduced in Subsection IWL in the 1992 Addenda. Until the issuance of this Addenda to Subsection IWL, Examination Categories I A & L-B only required 3 visual examination performed by or under direction of the Responsible Engineer, who i is a Registered Professional Engineer. As stated in the NRC's response to Public Comment 2.3 in Attachment 6, Part III to SECY-96-080, Issuance of Final Amendment to 10CFR50.55a to Incorporate by Reference the ASME Boiler and

1. essure Vessel Code, Section 2, Division 1, Subsection iWE and Subsection IWL, j

" Comments received from ASME members on the containment committee indicate l that the newer more stringent requirements ofIWA-2210 were not intended to be used l for the examination of containments and were inadvertently included in Subsection IWL." In the 1997 Addenda, the requirements of IWA-2210 and IU-2300 were removed. In evaluating the requirements of these ASME Code,Section XI provisions, ANO concluded that these requirements are not warranted for the examination of ,

concrete surfaces nor the anchorage hardware and its surrounding concrete surfaces and would not provide a compensating increase in quality and safety.

2. Degradation mechanisms for a concrete structure are different from the degradation mechanisms of Class 1,2, and 3 components to which the at: " 9 le requirements of IWA-2210 and IWA-2300 were developed. Concrete deter. - u. rnd distress, as defined in ACI 201.1, Guidefor Makin;- a Condition Survey oj Joncrete in Service, can be effectively identified by the performance of a general visual examination. As such, ANO has established controls for the performance of s general visual examination of the concrete structure. The general visual examination performed by ANO will be a thorough examination of the accessible areas as will the detailed visual examination of the tendon anchorage hardware and its surrounding concrete and will be performed by certified and properly trained examiners. If an area is determined to be suspect during the general visual examination, ANO will take additional actions to ensure the magnitude and extent of deterioration and/or distress is properly characterized for evaluation. To ensure the controls and techniques meet this expectation, the Ruponsible Engineer will periodically witness the performance of these exarrdnations.

3. The general visual examination of the concrete surfaces and the detailed visual examination of the suspect areas detected by the general visual examination and the

l Atteh to l OCAN049904 l Page 3 of4 tendon snchorage hardware and its :urrounding concrete will be performed in accordance with an ANO approved procedure. The examination methods outlined in this procedure will be written to be consistent with the methods approved in the rewrite of Subsection IWL (1997 Addenda) and will be approved by the Responsible Engineer. These approved methods will delineate the awa y controls for ensuring these examinations are performed in a manner sufficient to detect evidence of degradation. When the examiner detects evidence of degradation, the procedure also i

requires a detailed visual examination to be performed and compared to established reporting and acceptance criteria. The reporting criteria, along with acceptance criteria, will be approved by the Responsible Engineer and will be consistent with the guidance outlined in the American Concrete Institute (ACI) Standard 349.3R-%,

Ensluation of Existing Nuclear Safety-Related Concrete Structure. IC the detailed visual examination cannot be performed for some reason (e.g., access limitation),

ANO will evaluate the acceptability of the suspect area. This engineering evaluation i will assume the suspect area is inaccessible and will address the requirements outlined in 10CFR50.55a(b)(2)(ix)(E). The engineering evaluation will be approved by the Responsible Engineer.

4. The general and/or detailed visual examination will be performed by certiSed and  !

properly trained personnel. Personnel performing these visual examinations will be certified in accordance with ANSI N45.2.6, Quahfication ofInspection, Examination, i i

and Testing Personnelfor Nuclear Power Plants, and by ANO procedure. This level of certification will ensure the capability and visual acuity of the examiners is sufficient j to detect evidence of degradation of the concrete structure or the post tensioning j system. Prior to performing the examinations, the examiners will be required to successfully complete ANO approved training (i.e., training developed by the Electric Power Research Institute or equivalent) on the proper techniques for examining components subject to the requirements of Subsection IWL. In addition, the l

i examiners will receive site speci6c training regarding the methods outlined in the l

approved plant procedute. The. site-specific training will be conducted under the l direction of the Responsible Engineer and will be held at the beginning of each l subsequent inservice inspection used to satisfy the applicable requirements ofIWL-l 2410. Successful completion of the above training will ensure the examiners have a

! basic working knowledge of the components being examined and the types of degradation to be detected.

5. The ASME Main Conunittee and the Board ofNuclear Codes and Standards have also determined that Code provisions outlined in IWA-2210 and IWAe2300 were not warranted for the visual examination of concrete surfaces or post tensioning system anchorage hardware or surrounding concrete. Both organizations have approved the i rewrite of Subsection IWL that eliminated the requirement of IWA-2210 and lWA-  !

2300. This rewrite of Subsection IWL was published in the 1997 Addenda of the ASME Code,Section XI. The alternative examination methods proposed by ANO is consistent with the approved rewrite of Subsection IWL and will provide an acceptable level of quality and safety.

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. Attachment to OCAN049904 Page 4 of4 i

Pronosed Alternative:

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l To satisfy the requirements of Evamination Category L-A (Item Nos. Ll.ll and .LI.12) J and Examination Categoiy L-B (Item No. L.2.30), ANO will perform the following:

A general visual examination of the accessible concrete surfaces, and a detailed visual examination of the suspect areas detected by the general visual examination i and the tendon anchorage hardware and its surranading concrete, as applicable,  !

during the ANO-1 and ANO-2 Grst containment inspection intervals. For the first containment inspection interval, ANO will establish the beginning of the ANO-1 twenty-five year tendon surveillance and the beginning of the ANO-2 twenty year tendon surveillance as the effective start date of the first containment inspection interval for IWL-related activities. When evidence of degradation is detected by the examiners on the accessible concrete surfaces, ANO will perform a detailed visual examination. If a detailed visual examination cannot be performed, an engineering evaluation approved by the Responsible Engineer will be provided which will evaluate the suspect area. To ensure the controls and techniques are adequate for detecting evidence of degradation the Responsible Engineer will periodically witness the performance of these examinations. In addition, each examiner will successfully complete ANO approved training, including site specific, to ensure they have a basic working knowledge of the components being examined and the types of degradation to be detected.

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