ML042740027
| ML042740027 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Mcguire, Catawba, McGuire  |
| Issue date: | 09/30/2004 |
| From: | Ross-Lee M NRC/NRR/DLPM/LPD2 |
| To: | Mccollum W Duke Energy Corp |
| Olshan L N, NRR/DLPM, 415-1419 | |
| References | |
| TAC MB9674, TAC MB9675, TAC MB9676, TAC MB9677, TAC MB9678, TAC MB9679, TAC MB9680 | |
| Download: ML042740027 (16) | |
Text
September 30, 2004 Mr. William R McCollum, Jr.
VP, Nuclear Support Duke Energy Corporation P.0. Box 1006 - EC07H Charlotte, NC 28201-1006
SUBJECT:
CATAWBA NUCLEAR STATION, UNITS 1 AND 2, MCGUIRE NUCLEAR STATION, UNITS 1 AND 2, OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 AMENDED RELIEF REQUEST 03-GO-010 REQUESTING USE OF SUBSEQUENT EDITION AND ADDENDA OF THE ASME CODE FOR CLASS MC AND CC COMPONENTS (TAC NOS. MB9674 THROUGH MB9680)
Dear Mr. McCollum:
Duke Energy Corporations (Dukes) letter of June 17, 2003, as amended August 31, 2004, submitted the following requests to the U.S. Nuclear Regulatory Commission (NRC) concerning the use of alternatives to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, at the subject nuclear stations:
Approve the use of the 1998 edition, with 1999 and 2000 addenda, of the ASME Code,Section XI, for inservice inspection (ISI) activities at all facilities for the containment first and second ISI intervals. Also, adjust the ISI intervals for metal and concrete containments at all facilities during the containment first and second ISI intervals so that the intervals may be more closely aligned with ISI intervals for ASME Code Class 1, 2, and 3 components.
Approve the use of the 1998 edition, with 1999 and 2000 addenda, of the ASME Code,Section XI, for repair/replacement activities for concrete containments, metal containments and metallic shell and penetration liners of concrete containments at all facilities for the first and second ISI intervals. Also, allow the use of an alternative to the requirement of ASME Code, Subarticle IWE-5240, during the containment second ISI interval at all facilities.
For Oconee Nuclear Station, Units 1, 2, and 3, only, allow use of an alternative to the requirements of ASME Code, Subarticle IWL-2421(b) during the containment second ISI interval.
Allow use of alternatives to selected requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(4) during the containment second ISI interval at all facilities.
Duke submitted these requests pursuant to 10 CFR 50.55a(a)(3)(i) and 10 CFR 50.55a(g)(4)(iv).
W. McCollum In accordance with 10 CFR 50.55a(g)(4)(iv), the NRC staff approves Dukes use of the 1998 edition, with 1999 and 2000 addenda, of the ASME Code,Section XI, for ISI and repair/replacement activities for concrete containments, metal containments and metallic shell and penetration liners of concrete containments for the 10-year ISI intervals and facilities specified above.
The NRC staff further concludes that each of the proposed alternatives provides an acceptable level of quality and safety. Accordingly, the NRC staff authorizes Dukes proposed alternatives, in accordance with 10 CFR 50.55a(a)(3)(i), for the 10-year ISI intervals and for the facilities specified above. Enclosed is our safety evaluation.
Sincerely,
/RA/
Mary Jane Ross-Lee, Acting Chief, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-413, 50-414, 50-369, 50-370, 50-269, 50-270, and 50-287
Enclosure:
As stated cc w/encl: See next page
ML042740027 Nrr-028 OFFICE PDIII-1/PM PDII-1/PM PDII-1/LA EMEB/SC OGC PDII-1/SC(A)
NAME LPadovan LOlshan DClarke KManoly RHoefling MRoss-Lee DATE 9/30/04 9/30/04 9/30/04 9/30/04 9/30/04 9/30/04
McGuire Nuclear Station Catawba Nuclear Station Oconee Nuclear Station cc:
Ms. Lisa F. Vaughn Duke Energy Corporation 422 South Church Street Mail Code - PB05E P.O. Box 1244 Charlotte, North Carolina 28201-1244 County Manager of Mecklenburg County 720 East Fourth Street Charlotte, North Carolina 28202 Mr. C. Jeffrey Thomas, Manager Regulatory Compliance McGuire Nuclear Station Duke Energy Corporation 12700 Hagers Ferry Road Huntersville, North Carolina 28078 Anne Cottingham, Esquire Winston and Strawn 1400 L Street, NW.
Washington, DC 20005 Senior Resident Inspector U.S. Nuclear Regulatory Commission 12700 Hagers Ferry Road Huntersville, North Carolina 28078 Mr. Peter R. Harden, IV, Vice President Customer Relations and Sales Westinghouse Electric Company 6000 Fairview Road, 12th Floor Charlotte, North Carolina 28210 Dr. John M. Barry Mecklenburg County Department of Environmental Protection 700 N. Tryon Street Charlotte, North Carolina 28202 Mr. Richard M. Fry, Director Division of Radiation Protection NC Dept. of Env., Health, & Nat. Resources 3825 Barrett Drive Raleigh, North Carolina 27609-7721 Ms. Karen E. Long, Asst. Attorney General NC Department of Justice P.O. Box 629 Raleigh, North Carolina 27602 Mr. R. L. Gill, Jr., Manager Nuclear Regulatory Issues and Industry Affairs Duke Energy Corporation 526 South Church Street - Mail Stop EC05P Charlotte, North Carolina 28202 NCEM REP Program Manager 4713 Mail Service Center Raleigh, North Carolina 27699-4713 Mr. T. Richard Puryear Owners Group (NCEMC)
Catawba Nuclear Station Duke Energy Corporation 4800 Concord Road York, South Carolina 29745 Mr. Lee Keller, Manager Regulatory Compliance Catawba Nuclear Station Duke Energy Corporation 4800 Concord Road York, South Carolina 29745 North Carolina Municipal Power Agency Number 1 1427 Meadowwood Boulevard P.O. Box 29513 Raleigh, North Carolina 27626-0513
McGuire Nuclear Station Catawba Nuclear Station Oconee Nuclear Station cc:
County Manager of York County York County Courthouse York, South Carolina 29745 Piedmont Municipal Power Agency 121 Village Drive Greer, South Carolina 29651 Saluda River Electric P.O. Box 929 Laurens, South Carolina 29360 Henry Porter, Assistant Director - DWM Bureau of Solid and Hazardous Waste Dept. of Health & Env. Control 2600 Bull Street Columbia, South Carolina 29201-1708 NC Electric Membership Corporation P.O. Box 27306 Raleigh, North Carolina 27611 Senior Resident Inspector U.S. Nuclear Regulatory Commission 4830 Concord Road York, South Carolina 29745 Manager, LIS NUS Corporation 2650 McCormick Drive, 3rd Floor Clearwater, Florida 34619-1035 Senior Resident Inspector U.S. Nuclear Regulatory Commission 7812B Rochester Highway Seneca, South Carolina 29672 Mr. Michael A. Schoppman Framatome ANP 1911 North Ft. Myer Drive Suite 705 Rosslyn, Virginia 22209 Mr. B. G. Davenport, Manager Regulatory Compliance Oconee Nuclear Site Duke Energy Corporation 7800 Rochester Highway - MS ONO3RC Seneca, South Carolina 29672 Mr. Dhiaa Jamil Vice President Catawba Nuclear Station Duke Energy Corporation 4800 Concord Road York, South Carolina 29745 Mr. G. R. Peterson, Vice President McGuire Nuclear Station Duke Energy Corporation 12700 Hagers Ferry Road Huntersville, North Carolina 28078 Mr. Ronald A. Jones, Vice President Oconee Nuclear Station Duke Energy Corporation 7800 Rochester Highway Seneca, South Carolina 29672 Ms. Mary Olson Director of the Southeast Office Nuclear Information and Resource Service 729 Haywood Road, 1-A P.O. Box 7586 Asheville, North Carolina 28802 Henry Barron Group Vice President, Nuclear Generation and Chief Nuclear Officer P.O. Box 1006-EC07H Charlotte, NC 28201-1006
ENCLOSURE SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FIRST AND SECOND 10-YEAR INTERVALS INSERVICE INSPECTION PROGRAMS RELIEF REQUEST 03-GO-010 DUKE ENERGY CORPORATION CATAWBA NUCLEAR STATION, UNITS 1 AND 2 MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 DOCKET NOS. 50-413, 50-414, 50-369, 50-370, 50-269, 50-270, AND 50-287
1.0 INTRODUCTION
Duke Energy Corporations (Dukes) letter of June 17, 2003, as amended August 31, 2004, submitted requests to the U.S. Nuclear Regulatory Commission (NRC) concerning the use of alternatives to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, Rules for Inservice Inspection [ISI] of Nuclear Power Plant Components. The requests apply to Catawba Nuclear Station, Units 1 and 2, McGuire Nuclear Station, Units 1 and 2, and Oconee Nuclear Station, Units 1, 2, and 3.
The following requests pertained to subsections IWE, Requirements for Class MC and Metallic Liners of Class CC Components of Light-Water Cooled Power Plants, and IWL, Requirements for Class CC Concrete Components of Light-Water Cooled Power Plants, of the ASME Code:
Adjust the ISI intervals for metal and concrete containments during the containment first and second ISI intervals at all facilities so that the intervals may be more closely aligned with ISI intervals for ASME Code Class 1, 2, and 3 components.
Allow the use of an alternative to the requirement of ASME Code subarticle IWE-5240 during the containment second ISI interval.
For Oconee Nuclear Station, Units 1, 2, and 3, only, allow use of an alternative to the requirements of ASME Code subarticle IWL-2421(b) during the containment second ISI interval.
Allow use of an alternative to selected requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(4) during the containment second ISI interval at all facilities.
Duke submitted these requests pursuant to 10 CFR 50.55a(a)(3)(i).
In addition, Attachment 1 to Dukes letter of August 31, 2004, also requested NRC approval to use the 1998 edition, with 1999 and 2000 addenda, of the ASME Code,Section XI for ISI and repair/replacement activities for concrete containments, metal containments and metallic shell and penetration liners of concrete containments. Duke submitted this request pursuant to 10 CFR 50.55a(g)(4)(iv), for the containment first ISI interval.
2.0 REGULATORY EVALUATION
The ISI of ASME Code Class 1, 2, and 3 components is to be performed in accordance with Section XI of the ASME Code and applicable edition and addenda as required by 10 CFR 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). Section 50.55a(a)(3) states in part that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if the licensee demonstrates that:
(i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class MC and CC components (including their integral attachments) shall meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code,Section XI, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The applicable ASME Codes of record for the Duke plants are described in the technical evaluation below. The components (including supports) may meet the requirements set forth in subsequent editions and addenda of the ASME Code incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein and subject to Commission approval.
3.0 TECHNICAL EVALUATION
3.1 Adjust the ISI Intervals for Metal and Concrete Containments 3.1.1 Components for Which Relief Is Requested Class MC metal containment pressure retaining components and their integral attachments metallic shell and penetration liners which are pressure retaining components and their integral attachments in Class CC concrete containments Class CC concrete containment pressure retaining components and their integral attachments, and the post-tensioning systems of concrete containments 3.1.2 ASME Code Requirements The following requirements of the ASME Code,Section XI, 1992 edition, with 1992 addenda, apply to the containment first ISI interval:
IWA-2430(a) requires that IWE inservice examinations be performed in accordance with Inspection Program A of IWA-2431 or Inspection Program B of IWA-2432.
IWA-2430(b) requires that the inspection interval be determined by calendar years following placement of the plant into commercial service.
IWA-2430(d) requires that for components inspected under Program B, the inspection intervals may be extended or decreased by as much as 1 year, provided successive intervals are not altered by more than 1 year from the original pattern of intervals.
IWA-2432 requires that the first inspection interval consist of 10 years following start of plant commercial service and that subsequent inspection intervals consist of 10 years following previous inspection intervals, except as modified by IWA-2430(d).
IWE-2410 requires that the requirements of either Inspection Program A or B shall be met.
IWE-2412 requires that inservice examinations comply with the requirements of Table IWE-2412-1, and that the inspection periods may be decreased or extended by as much as 1 year to enable an inspection to coincide with a plant outage, within the limitations of IWA-2430(d).
Subarticle IWE-2420(a) of the ASME Code,Section XI, 1998 edition, with 1999 addenda, and the 2000 addenda (which is proposed for the containment second inspection interval) requires that the sequence of component examinations established during the first inspection interval shall be repeated during each successive ISI interval, to the extent practical.
3.1.3 Dukes Proposed Alternative In lieu of the ASME Code,Section XI, 1992 edition, with 1992 addenda, requirements listed above, Duke proposed the following alternative for the containment first ISI interval:
The first containment ISI interval shall end no later than September 9, 2006. For metal containments and metallic shell and penetration liners of concrete containments, the first inspection interval shall comply with requirements of Inspection Program B, except as follows:
The first inspection interval shall consist of inspection periods 1 and 2 only.
Examinations currently scheduled for Period 3 of the first inspection interval are not required to be performed.
Examinations permitted to be deferred until the end of the first inspection interval in accordance with Table IWE-2500-1 shall not be deferred, and examinations shall be performed in accordance with the percentages listed in Table IWE-2412-1, Inspection Program B for periods 1 and 2.
In lieu of the ASME Code,Section XI, 1998 edition, with 1999 addenda, and the 2000 addenda requirements listed in 3.1.2 of this safety evaluation, Duke proposed the following alternatives for the containment second ISI interval:
The start date for the second inspection interval shall be July 15, 2004, but may be extended to July 15, 2005, in accordance with the requirements of IWA-2430(d)(1).
Those bolted connections required to be examined during period 3 of the first inspection interval in accordance with Table IWE-2500-1, Category EG, Item E8.10 (1992 Edition with the 1992 Addenda), shall be examined during period 1 of the second inspection interval. These examinations shall comply with the requirement of 10 CFR 50.55a(b)(2)(ix)(G) and 10 CFR 50.55a(b)(2)(ix)(H), except as noted in Section 3.4 of this safety evaluation.
Metal containment supports (personnel airlock barrel supports) at Catawba and McGuire Nuclear Stations that are currently scheduled to be examined during period 3 of the first inspection interval shall be examined in accordance with IWF-2500, Table IWF-2500-1, Category F-A, Item F1.40 during period 1 of the second inspection interval.
The sequence of examinations established during periods 1 and 2 of the first inspection interval shall be repeated during periods 2 and 3 of the second inspection interval, to the extent practical.
3.1.4 Dukes Basis for Relief (as stated):
The first inservice inspection interval for metal and concrete containments began on September 9, 1998 and is currently scheduled to end on September 9, 2008 for Oconee Units 1, 2, and 3, McGuire Units 1 and 2 and Catawba Units 1 and 2. This inspection interval was established in order to implement the Expedited Examination requirements for metal and concrete containments imposed by 10CFR50.55a following September 9, 1996. Duke chose to establish a new inspection interval for metal and concrete containments so that the end of the first period of the first inspection interval (for IWE) coincided with the end of the Expedited Examination Period on September 9, 2001.
As a result, the inspection interval does not coincide with inspection intervals for ASME Class 1, 2, and 3 components. Because of this, different editions and addenda of Section XI are required for inservice inspection and repair/replacement activities for Class 1, 2, and 3 components, and for Class MC and CC components.
The proposed alternatives herein will allow closer alignment of the containment inservice inspection intervals Class 1, 2, and 3 components at Oconee, McGuire, and Catawba Nuclear Stations. This has distinct advantages in that there will be fewer procedures to maintain, and procedures will meet the requirements of one edition/addenda of the Code, instead of multiple editions/addenda. This also reduces the chance of applying incorrect ISI requirements for specific component examinations. Common procedures and documents can be used that will reduce the administrative burden of complying with ISI requirements without a reduction in the quality of the ISI Program.
IWA-2430 does not address requirements for establishing inservice inspection intervals for Subsection IWL examinations. However, Duke Energy Corporation intends to establish a 120 month inspection interval for IWL for purposes of complying with the 120 month interval update requirements of 10 CFR 50.55a(b)(2)(vi) and 10 CFR 50.55a(g) (4) (ii).
The alternatives proposed in 5.1 and 5.2 [of Dukes August 31, 2004, submittal] will provide an equivalent level of quality and safety.
3.1.5 NRC Staffs Evaluation Currently, Duke is using the 1992 edition, with 1992 addenda, of Subsections IWE and IWL of Section XI of the ASME Code, except for the areas where the NRC has granted relief from the requirements of the ASME Code. The start date of the first containment inspection interval for Catawba, Units 1 and 2, McGuire, Units 1 and 2, and Oconee, Units 1, 2, and 3, was September 9, 1998. Duke plans to implement the requirements the 1998 edition through the 2000 addenda of subsections IWE and IWL of the ASME Code no later that July 15, 2005.
Thus, the first containment ISI interval will be approximately 7 years. As the NRC staff has approved the use of the 1998 edition through 2000 addenda of the ASME Code in 10 CFR 50.55a for MC and CC components and their integral attachments, with certain modifications as delineated in 10 CFR 50.55a(b)(2)(viii) and (b)(2)(ix), the use of the ASME Code edition and addenda as proposed is acceptable. The acceptability of the examinations which require reconciliation with the use of the proposed alternative are discussed in the following paragraphs:
In a telephone call on September 27, 2004, the NRC staff requested Duke to provide reconciliation information related to the proposed alternative. Duke provided this information in an email to the NRC on September 28, 2004, titled Relief Request #03-GO-010 - Additional Information to be Docketed (ADAMS Accession No. ML042740680). In Table 1, Comparison of Inspection Intervals 1 and 2 for Implementation of ASME Section XI, IWE/IWL Requirements, of this email, Duke pointed out that the first containment ISI will consist of inspection periods 1 and 2, and that the examinations currently scheduled for inspection period 3 will not be performed. As per the requirements of either 10 CFR 50.55a(b)(2)(ix)(E)
[applicable when using the 1992 edition of the ASME Code], or item E1.11, Table IWE-2500-1 of the 1998 edition of the ASME Code, a general visual examination of 100 percent of the accessible areas is required, and must be performed in inspection period 1 of the second containment ISI interval. In Table 1, Duke stated that it will perform a general visual examination of 100 percent of the accessible metal surfaces each inspection period of the second containment ISI interval. Additionally, Duke stated that the examinations permitted (by the ASME Code) to be deferred until the end of first inspection interval will not be deferred, and the examinations will be performed in accordance with the percentages listed in Table IWE-2412.1.
In Table 1, Duke provided additional information related to the augmented examinations, examinations of seals, gaskets, and moisture barriers, and some of the IWL examinations that will be carried over in the second containment ISI interval. The NRC staff finds that Dukes plan for the proposed alternative is acceptable, as it will comply with the requirements of 10 CFR 50.55a, and its implementation will provide an acceptable level of quality and safety.
Accordingly, the NRC staff authorizes Dukes proposed alternatives in accordance with 10 CFR 50.55a(a)(3)(i) for the containment ISI intervals and facilities specified above.
3.2 Use of an Alternative to the Requirement of ASME Code Subarticle IWE-5240 3.2.1 Component for Which Relief Is Requested Class MC metal containment pressure retaining components and their integral attachments metallic shell and penetration liners which are pressure retaining components and their integral attachments in Class CC concrete containments Class CC concrete containment pressure retaining components and their integral attachments, and the post-tensioning systems of concrete containments 3.2.2 ASME Code Requirements Subarticle IWE-5240 of the 1998 edition, with 1999 addenda, and the 2000 addenda, of the ASME Code (which is proposed for the containment second ISI interval) requires that during the pressure test required by IWE-5220, a detailed visual examination be performed on areas affected by repair/replacement activities.
3.2.3 Dukes Proposed Alternative In lieu of the requirements of IWE-5240, Duke proposed the following alternative:
Perform applicable nondestructive examination in accordance with Construction Code and IWA-4000.
Perform a leakage test in accordance with IWE-5221.
Perform a visual, VT-1 examination on affected surface areas following repair/replacement activities. For repair/replacement activities other than those minor repair/replacement activities identified in IWE-5222, this visual, VT-1 examination shall be performed either during or upon completion of the pneumatic leakage test required be IWE-5221.
3.2.4 Dukes Basis for Relief (as stated):
The proposed alternative for the second containment inservice inspection interval is essentially identical to the alternative documented in Duke Energy Corporation Request for Relief 00-GO-001 dated November 21, 2000 and approved by the NRC for use during the first containment inservice inspection interval (letter dated May 17, 2001 to Mr. M. S. Tuckman, Executive Vice President, Nuclear Generation, Duke Energy Corporation).
The justification for the proposed alternative is essentially identical to that documented in the Safety Evaluation Report referenced above.
The following minor changes to the previously approved alternative have been made due to changes in the Code requirements and terminology:
1.
The proposed alternative is to be used in lieu of the detailed visual examination required by IWE-5240 of the ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition with the 1999 Addenda and the 2000 Addenda. During the containment first inservice inspection interval, this alternative was approved for use in lieu of the VT-2 visual examination required by IWE-5240 of the ASME Boiler and Pressure Vessel Code,Section XI, 1992 Edition with the 1992 Addenda.
2.
The proposed alternative now refers to repair/replacement activities in lieu of repairs replacements, or modifications due to a change in terminology from that used in the 1992 Edition with the 1992 Addenda.
Because the alternative referenced above is essentially identical to that previously approved by the NRC for use during the first containment inservice inspection interval, this alternative is considered acceptable for use during the second containment inservice inspection interval and will provide an equivalent level of quality and safety.
3.2.5 NRC Staffs Evaluation The 1992 edition of Subsection IWE required VT-2 examination after repair/replacement (R/R) of the containment pressure boundary components. In relief request 00-GO-001 dated November 21, 2000, Duke sought relief from this requirement and proposed to perform a VT-1 examination, instead. In Table 1, Comparison of Inspection Intervals 1 and 2 for Implementation of ASME Section XI, IWE/IWL Requirements (ADAMS Accession No. ML042740680), Duke further explains that for minor R/R activities as defined in IWE-5222, under the proposed alternative, it will perform VT-1 examination after completing the R/R activity. In the 1998 edition through the 2000 addenda, IWE-5240 requires detailed visual examination after completing the R/R activities. In incorporating the 1998 edition through the 2000 addenda of the ASME Code in 10 CFR 50.55a, the NRC reinstated the use of VT-1, and VT-3 examination in lieu of the general and detailed visual examinations used in Subsection IWE of the ASME Code. Duke plans to use the same requirements as that approved by the NRC staff in its safety evaluation of May 17, 2001, in the second containment ISI interval. The NRC staff finds that the proposed alternative provides an acceptable level of quality and safety.
Accordingly, the NRC staff authorizes Dukes proposed alternative in accordance with 10 CFR 50.55a(a)(3)(i) for the containment second ISI interval and for all facilities.
3.3 Use of an Alternative to the Requirements of ASME Code Subarticle IWl-2421(b)
For Oconee Nuclear Station, Units 1, 2, and 3 3.3.1 Component for Which Relief Is Requested Class CC concrete containment pressure retaining components and their integral attachments, and the post-tensioning systems of concrete containments.
3.3.2 ASME Code Requirements Subarticle IWL-2421 of the 1998 edition, with 1999 addenda, and the 2000 addenda, of the ASME Code (which is proposed for the containment second ISI interval) provides alternative examination requirements for sites with multiple plants that meet the conditions identified in IWL-2421(a).
3.3.3 Dukes Proposed Alternative In lieu of the requirements of IWL-2421(b)(1) and IWL-2421(b)(2), Duke proposed the alternative below for the containment second ISI interval at Oconee Nuclear Station, Units 1, 2, and 3.
When the conditions of IWL-2421(a) are met, the examination requirements and schedules may be modified for examinations commencing 10 years following completion of the containment structural integrity test, and for subsequent examinations, as follows:
The examinations required by IWL-2522 need only be performed at 10 years and every 10 years thereafter. Alternatively, an equivalent number of IWL-2522 examinations may be distributed among and performed during two consecutive 5-year examinations (in accordance with IWL-2420) every 10 years, except that common tendons need only be examined at 10 years and every 10 years thereafter.
The examinations required by IWL-2523 need only be performed at 10 years and every 10 years thereafter.
The examinations required by IWL-2524 and IWL-2525 shall be performed at 10 years and every 5 years thereafter.
3.3.4 Dukes Basis for Relief (as stated):
The alternative will require examination of an equivalent number of tendons as that required by IWL-2421, but will allow these examinations to be distributed among consecutive 5 year examinations, rather than requiring certain examinations to be performed on a 10 year schedule. As such, this alternative provides an equivalent level of quality and safety.
3.3.5 NRC Staffs Evaluation This relief request pertains to the examination of prestressing tendons in Oconee 1, 2, and 3.
In the 1992 edition of the ASME Code, it did not address the examination requirements for more than two prestressed concrete containments at a site. For the three units at Oconee, Duke proposed a program for examining prestressing tendons. The NRC staff approved the use of the proposed plan. The 1998 edition of the ASME Code provided requirements for prestressing tendon examinations for sites having more than two prestressed concrete containments. In implementing the 1998 edition through the 2000 addenda of Subsection IWL for the examination of prestressing tendons, Dukes proposed alternative will examine the same number of tendons as that would be required be the ASME Code, but it will allow Duke to distribute these examinations equally among each Oconee unit every 5 years. In Table 1, Comparison of Inspection Intervals 1 and 2 for Implementation of ASME Section XI, IWE/IWL Requirements (ADAMS Accession No. ML042740680), Duke provided a summary of total number of tendons examined under IWL-2522, IWL-2523, IWL-2524, and IWL-2525 for all the units. The NRC staff finds the tendon distribution scheme in the proposed alternative to be better than that would be obtained by following the distribution scheme of IWL-2421, as it will distribute the tendon examinations for each unit on a equivalent basis. The NRC staff finds that the proposed alternative provides an acceptable level of quality and safety. Accordingly, the NRC staff authorizes Dukes proposed alternative in accordance with 10 CFR 50.55a(a)(3)(i) for the containment second ISI interval for the Oconee facilities.
3.4 Use of an Alternative to Selected Requirements of 10 CFR 50.55a(g)(4) 3.4.1 Component for Which Relief Is Requested Class MC metal containment pressure retaining components and their integral attachments metallic shell and penetration liners which are pressure retaining components and their integral attachments in Class CC concrete containments Class CC concrete containment pressure retaining components and their integral attachments, and the post-tensioning systems of concrete containments 3.4.2 ASME Code Requirements The requirements apply to the containment second ISI interval for Oconee Nuclear Station, Units 1, 2 and 3, McGuire Nuclear Station, Units 1 and 2, and Catawba Nuclear Station, Units 1 and 2. The 1998 edition of the ASME Code, with 1999 addenda, and the 2000 addenda, as modified by 10 CFR 50.55a(b)(2)(ix)(G) and 10 CFR 50.55a(b)(2)(ix)(H) is proposed for the containment second ISI interval. Section 50.55a(g)(4) of 10 CFR requires, in part, that the modifications listed in paragraph (b)(2)(ix) apply to components classified as Class MC and metallic shell and penetration liners of Class CC components. Section 50.55a(b)(2)(ix)(G) of 10 CFR requires, in part, that An examination of the pressure-retaining bolted connections in Item E1.11 of Table IWE-2500-1 using the VT-3 examination method must be conducted once each interval. Section 50.55a(b)(2)(ix)(H) of 10 CFR requires, in part, that Containment bolted connections that are disassembled during the scheduled performance of the examinations in Item E1.11 of Table IWE-2500-1 must be examined using the VT-3 examination method.
3.4.3 Dukes Proposed Alternative In lieu of the requirement of 10 CFR 50.55a(g)(4) to apply the modifications in 10 CFR 50.55a(b)(2)(ix)(G) and 10 CFR 50.55a(b)(2)(ix)(H) when using the 1998 edition with the 1999 addenda and 2000 addenda, Duke proposed that the requirements of 10 CFR 50.55a(b)(2)(ix) shall be met, except that the following requirements may be used in lieu of the requirements of 10 CFR 50.55a(b)(2)(ix)(G) and 10 CFR 50.55a(b)(2)(ix)(H):
For 10 CFR50.55a(b)(2)(ix)(G), the VT-3 examination method must be used to conduct the examinations in Items E1.12 and E1.20 of Table IWE-2500-1, and the VT-1 examination method must be used to conduct the examination in Item E4.11 of Table IWE-2500-1. An examination of the pressure retaining, bolted connections in Item E1.11 of Table IWE-2500-1 using the VT-1 examination method must be conducted once each interval and may be performed with the connection assembled and bolting in place under tension, provided the connection is not disassembled during the interval. If the bolted connection is disassembled for any reason during the interval, the VT-1 examination shall be performed with the connection disassembled. The owner-defined visual examination provisions in IWE-2310(a) are not approved for use for VT-1 and VT-3 examinations.
For 10 CFR 50.55a(b)(2)(ix)(H), the criteria in the material specification or IWB-3517.1 must be used to evaluate containment bolting flaws or degradation.
3.4.4 Dukes Basis for Relief (as stated):
- 1. A VT-1 visual examination method is more detailed and is conducted at higher resolution than a VT-3 examination method.
- 2. 10 CFR 50.55a(b)(2)(ix)(H) does not require that a bolted connection be visually examined when it is disassembled, if the connection is disassembled at times other than during the performance of Item E1.11 examinations. The proposed alternative is acceptable because it will require that a visual examination be performed with the connection disassembled, if the connection is disassembled for any reason during the interval.
- 3. General visual examinations required by Table IWE-2500-1, Item E1.11 every period, and-VT-1 visual examinations proposed by this alternative, are essentially identical to those examinations required by the ASME Code,Section XI, 1992 Edition with the 1992 Addenda.
The proposed alternative provides an equivalent level of quality and safety, for the reasons stated above.
3.4.5 NRC Staffs Evaluation 10 CFR 50.55a incorporates, by reference, the 1998 edition through the 2000 addenda of Subsection IWE of the ASME Code. The modifications in 10 CFR 50.55a(b)(2)(ix)(H) and (G) provide specific requirements for the examination of pressure retaining bolts. For the bolted connections disassembled during a scheduled examination, the NRC requires the use of VT-3 examination method. If flaws or degradation are identified during the VT-3 examination, the NRC requires VT-1 examination. Duke proposes to use the VT-1 examination method whenever the bolted connections are disassembled. Thus, Duke is proposing a more stringent requirement for all facilities.
For the bolted connections disassembled during the times other than the scheduled examination, 10 CFR 50.55a(b)(2)(ix)(G) optionally requires the use of VT-3 examination method, allowing the use of some equivalent method. Duke proposes to use VT-1 examination method, whenever the bolted connections are disassembled. Duke is proposing a more stringent requirement. The NRC staff finds that the proposed alternative provides an acceptable level of quality and safety. Accordingly, the NRC staff authorizes Dukes proposed alternative in accordance with 10 CFR 50.55a(a)(3)(i) for the containment second ISI interval and for all facilities.
4.0 CONCLUSION
The NRC staff approves the use of the 1998 edition, with 1999 and 2000 addenda, of the ASME Code,Section XI, for ISI of concrete containments, metal containments and metallic shell and penetration liners of concrete containments for the facilities and 10-year ISI intervals specified in the evaluation above. The NRC staff further concludes that each of the proposed alternatives provides an acceptable level of quality and safety. Accordingly, the NRC staff authorizes Dukes proposed alternatives in accordance with 10 CFR 50.55a(a)(3)(i) for the 10-year ISI intervals and facilities specified in the evaluations above. All other ASME Code Section XI requirements for which relief was not specifically requested and approved in this relief request remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.
Principal Contributors: L. Padovan H. Ashar Date: September 30, 2004