ML15261A196

Summary of 980708 Meeting W/Util in Rockville,Md Re Relief Request 98-GO-003, Request to Use Alternative to ASME Boiler & Pressure Vessel Code,Section XI, .List of Attendees & Handout Matl Supplied by Util Encl

ML15261A196
Person / Time
Site:	Oconee, Mcguire, Catawba, McGuire
Issue date:	07/09/1998
From:	Labarge D NRC (Affiliation Not Assigned)
To:	NRC (Affiliation Not Assigned)
References
NUDOCS 9807240012
Download: ML15261A196 (1)

Text

PtREGI4.

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 9, 1998 LICENSEE:

Duke Energy Corporation (DEC)

FACILITIES:

Oconee Nuclear Station, Units 1, 2, and 3 Catawba Nuclear Station, Units 1 and 2 McGuire Nuclear Station, Units 1 and 2

SUMMARY

OF THE JULY 8,1998, MEETING ON RELIEF REQUEST 98-GO-003 On July 8, 1998, the NRC Division of Reactor Projects and Division of Engineering staffs met at the NRC Headquarters in Rockville, Maryland, with representatives of the Duke Energy Corporation General Office to discuss questions related to its submittal of Relief Request 98-GO-003, "Request to Use An Alternative to the ASME [American Society of Mechanical Engineers] Boiler and Pressure Vessel Code [ASME Code],Section XI," dated April 6, 1998.

This request is to allow the use of an alternative to the augmented examination requirements for surface areas of metal containments and liners of concrete containments. Enclosure 1 is a list of the individuals who attended the meeting and Enclosure 2 is the handout material that was supplied by DEC.

The topics discussed included the essential elements of the Inservice Inspection Programs for metal and concrete containments at the Oconee, McGuire, and Catawba nuclear stations; operating experience data; summary of containment degradation and aging management; application of the provisions of relief request to augmented examination of Class MC components; and other issues and supporting information concerning the proposed relief request and application of the proposed alternative to the ASME Code.

David E. LaBarge, Senior Project Manager Project Directorate 11-2 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, 50-287, 50-413, 50-414, 50-369, and 50-370

Enclosures:

1. Attendance List

2. DEC Handout cc w/encls: See next page

July 9, 1998 LICENSEE:

Duke Energy Corporation (DEC)

FACILITIES:

Oconee Nuclear Station, Units 1, 2, and 3 Catawba Nuclear Station, Units 1 and 2 McGuire Nuclear Station, Units 1 and 2

SUMMARY

OF THE JULY 8,1998, MEETING ON RELIEF REQUEST 98-GO-003 On July 8, 1998, the NRC Division of Reactor Projects and Division of Engineering staffs met at the NRC Headquarters in Rockville, Maryland, with representatives of the Duke Energy Corporation General Office to discuss questions related to its submittal of Relief Request 98-GO-003, "Request to Use An Alternative to the ASME [American Society of Mechanical Engineers] Boiler and Pressure Vessel Code [ASME Code],Section XI," dated April 6, 1998.

This request is to allow the use of an alternative to the augmented examination requirements for surface areas of metal containments and liners of concrete containments. Enclosure 1 is a list of the individuals who attended the meeting and Enclosure 2 is the handout material that was supplied by DEC.

The topics discussed included the essential elements of the Inservice Inspection Programs for metal and concrete containments at the Oconee, McGuire, and Catawba nuclear stations; operating experience data; summary of containment degradation and aging management; application of the provisions of relief request to augmented examination of Class MC components; and other issues and supporting information concerning the proposed relief request and application of the proposed alternative to the ASME Code.

original signed by:

David E. LaBarge, Senior Project Manager Project Directorate 11-2 Division of Reactor Projects - I/Il Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, 50-287, 50-413, 50-414, 50-369, and 50-370

Enclosures:

1. Attendance List

2. DEC Handout cc w/encls: See next page Document Name: G:\\OCONEE\\OCOA1 516.SUM OFFICE PDl PM/

PDII-2/LA PDII NAME D.

E L.BERRY H.B DATE 7

/98

/

98

/

/98 COPY YES NO YES O

ES NO OFFICIAL RECORD C 9807240012 980709 PDR ADOCK 05000269 P

PDR

Catawba, McGuire, Oconee Nuclear Stations cc:

Dr. John M. Barry Mr. Robert B. Borsum Mecklenburg County Framatome Technologies Department of Environmental Suite 525 Protection 1700 Rockville Pike 700 N Tryon Street Rockville, Maryland 20852 Charlotte, North Carolina 29202 Manager, LIS County Manager of Mecklenburg County NUS Corporation 720 East Fourth Street 2650 McCormick Drive, 3rd Floor Charlotte, North Carolina 28202 Clearwater, Florida 34619-1035 Mr. Michael T. Cash Senior Resident Inspector Regulatory Compliance Manager U.S. Nuclear Regulatory Commission Duke Energy Corporation 7812B Rochester Highway McGuire Nuclear Site Seneca, South Carolina 29672 12700 Hagers Ferry Road Huntersville, North Carolina 28078 Mr. G. R. Peterson Site Vice President Senior Resident Inspector Catawba Nuclear Station clo U.S. Nuclear Regulatory Duke Energy Corporation Commission 4800 Concord Road 12700 Hagers Ferry Road York, South Carolina 29745 Huntersville, North Carolina 28078 Mr. H. B. Barron Mr. Richard M. Fry, Director Vice President, McGuire Site Division of Radiation Protection Duke Energy Corporation North Carolina Department of 12700 Hagers Ferry Road Environment, Health, and Natural Huntersville, North Carolina 28078 Resources 3825 Barrett Drive Mr. William R. McCollum Raleigh, North Carolina 27609-7721 Vice President, Oconee Site Duke Energy Corporation County Supervisor of Oconee County P. 0. Box 1439 Walhalla, South Carolina 27621 Seneca, South Carolina 29679 Elaine Wathen, Lead REP Planner North Carolina Electric Membership Division of Emergency Management Corporation 116 West Jones Street P..O. Box 27306 Raleigh, North Carolina 27603-1335 Raleigh, North Carolina 27611 Mr. T. Richard Puryear Owners Group (NCEMC)

ODuke Energy Corporation 4800 Concord Road York, South Carolina 29745

Catawba, McGuire, Oconee Nuclear Stations cc:

Mr. M. S. Kitlan Saluda River Electric Cooperative, Regulatory Compliance Manager Inc.

Duke Energy Corporation P. 0. Box 929 4800 Concord Road Laurens, South Carolina 29360 York, South Carolina 29745 Senior Resident Inspector Mr. Paul R. Newton U.S. Nuclear Regulatory Commission Legal Department (PBO5E) 4830 Concord Road Duke Energy Corporation York, South Carolina 29745 422 South Church Street Charlotte, North Carolina 28242 Regional Administrator, Region II U.S. Nuclear Regulatory Commission J. Michael McGarry, Ill, Esquire Atlanta Federal Center Winston and Strawn 61 Forsyth Street, S.W., Suite 23T85 1400 L Street, NW.

Atlanta, Georgia 30303 Washington, DC 20005 Max Batavia, Chief North Carolina Municipal Power Bureau of Radiological Health Agency Number 1 South Carolina Department of Health 1427 Meadowwood Boulevard and Environmental Control P. 0. Box 29513 2600 Bull Street Raleigh, North Carolina 27626 Columbia, South Carolina 29201 Mr. Peter R. Harden, IV Ms. Karen E. Long Account Sales Manager Assistant Attorney General Westinghouse Electric Corporation North Carolina Department of Justice Power Systems Field Sales P. 0. Box 629 P. 0. Box 7288 Raleigh, North Carolina 27602 Charlotte, North Carolina 28241 L. A. Keller County Manager of York County Manager - Nuclear Regulatory York County Courthouse Licensing York, South Carolina 29745 Duke Energy Corporation 526 South Church Street Piedmont Municipal Power Agency Charlotte, North Carolina 28242-0001 121 Village Drive Greer, South Carolina 29651 Mr. Ed Burchfield Compliance Duke Energy Corporation Oconee Nuclear Site P. 0. Box 1439 Seneca, South Carolina 29679

Meeting Summary Dated:

July 9, 1998 DISTRIBUTION Hard Copy (w/encls 1 and 2)

Dodket File PUBLIC PDII-2 Reading D. LaBarge OGC ACRS Licensee and Service List E-mail (w/encl 1 only)

S. Collins/F. Miraglia (SJC1/FJM)

B. Boger (BAB2)

J. Zwolinski (JAZ)

H. Berkow (HNB)

L. Berry (LGB)

P. Tam (PST)

F. Rinaldi (FXR2)

T. Martin (SLM3)

H. Ashar (HGA)

G. Bagchi (GXB1)

R. Rothman (RLR)

R. Pichumani (RXP)

W. Norris (WEN)

M. Tschiltz (MDT)

L. Plisco, RII (LRP)

C. Ogle, Rll (CRO)

MEETING ATTENDEES MEETING JULY 8,1998 DISCUSS QUESTIONS RELATED TO DUKE ENERGY CORPORATION RELIEF REQUEST 98-GO-003 NAME AFFILIATION D. LaBarge NRC/PDII-2 Project Manager Oconee H. Ashar NRC/Division of Engineering G. Bagchi NRC/Division of Engineering R. Rothman NRC/Division of Engineering W. Norris NRC/Division of Engineering R. Pichumani NRC/Division of Engineering J. C. Herrin Duke Energy Corporation M. Ferlisi Duke Energy Corporation

Duke Energy Corporation Presentation to NRC, July 8, 1998 Summary of Presentation Information:

A. Presentation for Duke Energy Request for Alternative, Serial #98-GO-003 Section I:

Essential Elements of the Inservice Inspection Programs for Metal and Concrete Containments at Oconee, McGuire, and Catawba Nuclear Stations Section II:

Operating Experience Data Section III:

Summary of Containment Degradation and Aging Management in Accordance with ASME Section XI, Subsections IWE and IWL Section IV:

Application of Provisions of Request for Alternative, Serial Number 98-GO-003 to Augmented Examination of Class MC Components Section V:

Discussion of Additional Issues Concerning this Alternative B. Clarification and Additional Supporting Information for Duke Energy Corporation Request for Relief, Serial #98-GO-001

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 I. Essential Elements of the Inservice Inspection Programs for Metal and Concrete Containments at Oconee, McGuire, and Catawba Nuclear Stations The following essential elements of Duke Power's Containment Inservice Inspection Program are addressed in this section:

A. Implementation of Federal Regulations Specified in 10CFR50.55a B. Administrative Programs and Procedures C. Containment Inservice Inspection Plan D. Additional Details of Containment Inservice Inspection ProgramsSection I Page 1 of 13

0 Duke Energ poration Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 A. Implementation of Federal Regulations Specified in 10CFR50.55a Table 1 contains a list of requirements from 10CFR50.55a, with modifications and a limitation affecting the inservice inspection of metal and concrete containments.

TABLE 1 Regulation Requirement Initial Containment Inservice Inspection Program 10CFR50.55a(b)(2)(vi)

Requires using the ASME BPVC,Section XI, ISI Program shall comply with this limitation and will use IWE/IWL, 1992 Edition w/1992 Addenda.

the 1992 Edition w/1992 Addenda for Subsection IWE and IWL examinations.

10CFR50.55a(b)(2)(ix)(A)

Requires accessible grease caps to be examined to ISI Program shall require 100% of accessible grease caps detect grease leakage or grease cap deformations, to be examined every five years on the same schedule as and requires caps to be removed if evidence of IWL concrete examinations. VT-3 visual examinations anchorage deterioration is detected.

are specified by Duke, and are to be performed during concrete inspections.

10CFR50.55a(b)(2)(ix)(B)

Requires an Engineering Evaluation when tendon ISI Program shall include this modification.

prestress loss is excessive.

10CFR50.55a(b)(2)(ix)(C)

Requires ISI Summary Report to document tendon ISI Program shall include this modification.

elongation measurements differing by more than 10% from that recorded during last measurement.

Section I Page 2 of 13

Duke Energooration Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE 1 Regulation Requirement Initial Containment Inservice Inspection Program IOCFR50.55a(g)(4)(v)(C)

Requires all concrete pressure retaining Concrete containments and post-tensioning system components and their integral attachments, and components at Oconee shall comply. Note that post-tensioning system components of concrete compliance with "replacement" provisions is not required containments to meet the inservice inspection and by the regulation.

repair requirements applicable for ASME Code Also, ASME Code Class CC does not apply to concrete Class CC components.

shield buildings at Catawba and McGuire.

10CFR50.55a(g)(6)(ii)(B)(1)

Specifies that IWE expedited examinations be All expedited examinations shall be completed no later completed no later than September 9, 2001.

than September 9, 2001 in accordance with the ISI Examinations required are those specified for the Program.

first period of the first inspection interval. These examinations serve as preservice examinations for operating plants.

IOCFR50.55a(g)(6)(ii)(B)(2)

Specifies that IWL expedited examinations be All expedited examinations shall be completed no later completed no later than September 9, 2001.

than September 9, 2001 in accordance with the ISI Examinations required are those corresponding to Program.

the number of years of operation specified in IWL.

These examinations serve as preservice examinations for operating plants.

IOCFR50.55a(g)(6)(ii)(B)(3)

Allows expedited examinations for Class MC Containment ISI Intervals are being established so that components to satisfy requirements for routinely expedited examinations for Class MC components shall scheduled examinations when the expedited be performed during the first period of the first examinations occur during the first containment containment inservice inspection interval.

I inspection interval.

Section I Page 5 of 13

Duke Energ p oration Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE 1 Regulation Requirement Initial Containment Inservice Inspection Program 10CFR50.55a(b)(2)(ix)(D)

Requires ISI Summary Report to document ISI Program shall include this modification, except that examination results that detect:

ISI Summary Report will document examination results

• that detect grease leakage as a result of the VT-3C exceeding 10% by weight examinations of the containment surface (IWL does not exceding10%

y weghtspecify "general visual examination" requirements for Presence of free water in tendon sheaths concrete surfaces). VT-3C examinations are conducted on 100% of the accessible concrete surfaces every 5 Difference in volume of grease removed vs.

years.

amount replaced exceeds 10% of net duct volume t

Grease leakage is detected during general visual examination of containment surface 10CFR5s.55a(b)(2)(ix)(E)

Requires licensees to evaluate the acceptability of "gn Program shall include this modification.

inaccessible areas when conditions are observed in accessible areas that could indicate the presence of or result in degradation to such inaccessible areas.

visualexaminatio(Class CC Components)

I0CFR50.55a(b)(2)(x)(A)

Requires licensees to evaluate the acceptability of ISI Program shall include this modification.

inaccessible areas when conditions are observed in accessible areas that could indicate the presence of or result in degradation to such inaccessible areas.

(Class MC Components) 10CFR50.55a(b)(2)(x)(B)

Allows variance from minimum illumination and ISI Program may utilize this modification. Duke has maximum examination distance requirements of submitted a separate Request to use an Alternative to Table IWA-2210-1 for remote visual examination IWA-2210 for all visual examinations of Class MC and of Class MC components.

CC components.

Section I Page 3 of 13

Duke Energ poration Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE 1 Regulation Requirement Initial Containment Inservice Inspection Program I OCFR50.55a(b)(2)(x)(C)

Makes optional the examination of PVV Category 151 Program shall not include these examinations.

E-B (Pressure Retaining Welds) and E-F (Pressure Retaining Dissimilar Metal Welds).

I OCFR5O.55a(b)(2)(x)(D)

Allows the use of an alternative to additional ISI Program shall include this modification.

examination requirements of IWE-2430.

I OCFR5O.55a(b)(2)(x)(F)

Requires a General Visual Examination to be ISI Program shall include this modification. This performed once each period.

modification is necessary to resolve conflict between IWE examination schedule requirements and examination schedule requirements of IOCFR50, Appendix J.

IOCFR5O.55a(g)(4)

Requires implementation of ASME Section XI ISI Program shall include applicable ISI requirements, Inservice Inspection requirements for Class MC including limitations of IOCFR50.55a(b)(2)(vi) and and CC components.

modifications of IOCFR50.55a(b)(2)(ix) and I OCFR50.55a(b)(2)(x) for inservice inspection of Class MC and Class CC components.

I OCFR5O.55a(g)(4)(v)(A)

Requires all metal containment pressure retaining Freestanding Steel Containment Vessels and their integral components and integral attachments to meet the attachments at Catawba and McGuire shall comply.

inservice inspection, repair and replacement requirements applicable for ASME Code Class MC components.

IOCFR50.55a(g)(4)(v)(B)

Requires all metallic shell and penetration liners Containment metallic shell and penetration liners which which are pressure retaining components and their are pressure retaining components at Oconee shall integral attachments to meet the inservice comply.

inspection, repair and replacement requirements applicable for ASME Code Class MC components.

Section I Page 4 of 13

Duke Energoyrporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE 1 Regulation Requirement Initial Containment Inservice Inspection Program IOCFR50.55a(g)(6)(ii)(B)(4)

Allows licensee's tendon surveillance programs This provision is to be utilized for Oconee Unit 2 only.

previously approved by the NRC to be used to Additional modifications of 10CFR50.55a(b)(2)(ix) shall satisfy the expedited examinations for post-apply when using this provision.

tensioning systems.

10CFR50.55a(g)(6)(ii)(B)(5)

Clarifies that containment ISI programs need not The first interval plans for Catawba, McGuire, and be submitted to the NRC staff for approval prior to Oconee will not be submitted for approval. ISI programs implementing the requirements of IWE and IWL.

for subsequent intervals shall be submitted to the NRC Staff for approval, although this requirement may not be clear.

Section I Page 6 of 13

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 B. Administrative Programs and Procedures The following administrative programs and procedures control Duke Power Company's Inservice Inspection Programs:

1.

Nuclear System Directive, NSD-300, "ASME Section XI Program" The purpose of this Directive is to describe the responsibilities for implementing Duke's ASME Section XI Program.

2.

Duke Power ASME Section XI Manual This manual defines how the ASME Code,Section XI requirements are implemented. Included in this manual are requirements for Administrative Organization and Responsibilities; Procurement and Handling of Code Items; Inservice Inspection and Testing; Repair, Replacement, and Maintenance Activities; Records; Control of Measuring and Test Equipment; Authorized Inspection Agency; and Audit and Surveillance Activities.

3.

Nuclear Inspection Program Manual This Manual contains procedures for preparation of inservice inspection plans, performance of visual examinations, and performance of inspections for non-Code components and equipment.

Table 2 contains a list of procedures that have been developed (or are under development) for implementation of Inservice Inspection requirements for containments.

TABLE 2 Procedure Title QA-140 "Quality Assurance Inspector Training" QA-142 "Vendor QC Acceptance" QA-501 "QA Review of Inspection Records, Procedures, and Work Orders"Section I Page 7 of 13

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE 2 Procedure Title QA-514 "Procedure for Discrepancies Found During Inservice Inspection Visual Examination of Supports" QA-516 "Evaluation of ISI Indications" QA-520 "Preparation and Distribution of Inservice Inspection Reports" QA-523 "Preparation and Implementation of Inservice Inspection Plans for Metal and Concrete Containments" QAB-1 "Control of Measuring and Test Equipment and Calibration Standards" QAF-1 "Specification and Documentation of QA Inspections" QAF-2 "Component/Piping Support Installation Inspection (Oconee and McGuire Nuclear Stations)"

QAF-3 "Inspection of the Application of Torque to Bolts and Studs and Inspection of Threaded Piping Connections" QAF-9 "Component/Piping Support Installation Inspection (Catawba Nuclear Station Only)"

QAI-1 "Documentation of Miscellaneous NDE" QAL-5 "Control Of Preservice And Inservice Examination Activities" QAL-13 "Inservice Inspection (ISI) Visual Examination, VT-I and VT-IC" QAL-14 "ISI Visual Examination, VT-3 and VT-3C" QAL-15 "Inservice Inspection (ISI) Visual Examination, VT-2, Pressure Test"Section I Page 8 of 13

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998

4.

Duke Power Company NDE Procedures Manual This Manual contains detailed procedures for personnel certification, control and calibration of equipment, and performance of nondestructive examinations. The following procedures are applicable for containment inservice inspection:

TABLE 3 Procedure Title NDE-A "Nondestructive Examination Program Procedure" NDE-B "Training, Qualification and Certification of Nondestructive Examination Personnel" NDE-C "Calibration/Verification of NDE Equipment" NDE-951 "Ultrasonic Thickness Measurement for Metallic Containment Surfaces"

5.

Other Procedures Procedures which control the following activities are to be referenced in the Containment Inservice Inspection Plans.

Procedures for performing General Visual Examinations in accordance with Table IWE-2500- 1, Category E-A, Item E1. 11 and 10CFR50, Appendix J

• Procedures for performing Overall Integrated Leak Rate Tests (Type A Tests) in accordance with 10CFR50, Appendix J.

• Master Procedure which lists all applicable procedures for Local Leak Rate Tests (Type B and C Tests)

• Procedures for performing post-tensioning system examinations in accordance with Plant Technical Specifications and IWL.

Section I Page,9 of 13

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 C. Containment Inservice Inspection Plan Each plant will have an inservice inspection plan which will include all applicable requirements, administrative procedures, and detailed procedures necessary for implementing and controlling the containment inservice inspection program for each unit at each plant. This Plan will contain the following information, as a minimum.

1.

Containment ISI Program Schedules Duke has elected to establish separate inspection intervals for containments as follows. (These are tentative dates):

Catawba 1 & 2 Interval 1: 9/9/1998 thru 9/9/2008 (IWE Only)

McGuire 1 & 2 Interval 1: 1/9/1999 thru 1/9/2009 (IWE Only)

Oconee 1, 2, 3 Interval 1: 9/9/1998 thru 9/9/2008 (IWE & IWL)

Note: A 10 year ISI Interval will be established for IWL Program Updates, even though Inservice Inspection Intervals are not specified by IWL. Exams shall be performed on five year schedules as required by IWL, but updates to IWL Inservice Inspection Programs should be required every 10 years as required for other Subsections of the Code.

2.

Applicable Codes and Standards

3.

Description of component/system boundaries subject to examination, including description of exemptions and inaccessible areas

4.

Description of examination requirements for each code category

5.

Description of additional requirements impose by 10CFR50.55a (modifications and limitations)

6.

Examination and inspection methods and procedures to be used for containment inservice inspection Section I Page 10 of 13

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998

7.

Description of owner specified examinations (examinations not required by either ASME Section XI or 10CFR50.55a).

Note: Because IWE contains a Category of examinations labeled "Augmented Examinations", the term "Owner Specified Examinations" will be used in the containment inservice inspection plans to distinguish between augmented examinations required by the Code and those which are specified by other requirements or the Owner.

2.

Listing of all components and parts and schedules for examination by ISI period and interval

3.

Listing and description of applicable Code Cases and approved Relief Requests

4.

List of applicable drawings detailing examination areas and component parts requiring examination

5.

List of applicable references, including federal regulations, NUREG's, Information Notices, etc.

D. Additional Details of Containment Inservice Inspection Programs

1.

Oconee Unit 2 plans to utilize Technical Specification tendon surveillance program during expedited examination period, including all provisions of 10CFR50.55a(b)(2)(ix), as permitted by 10CFR50.55a(g)(6)(ii)(B )(4). Technical Specifications now include provisions for random selection of tendons.

2.

Oconee Units 1 and 3 will implement IWL tendon surveillance programs during expedited examination period.

3.

Repair/Replacement Program requirements are implemented and controlled by Duke Power "ASME Section XI Manual", Section E, "Repair, Replacement, and Maintenance Activities".

Repair/Replacement requirements comply with the ASME Code,Section XI, 1992 Edition with 1992 Addenda.

4.

Qualification requirements for personnel performing VT and UT examinations complies with Section XI, IWA-2300, 1992 Edition with the 1992 Addenda. Procedure NDE-B addresses qualification of inspectors, including the following:

Section I Page 11 of 13

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 Allows Level II Mechanical inspectors to obtain certification to perform all VT visual examinations Allows limited certification for Level II Civil (Concrete) inspectors meeting ANSI N45.2.6 to perform VT-IC and VT-3C concrete examinations and VT-1 examinations of tendon anchorage hardware Allows limited certification of Level II Civil (Coatings) inspectors meeting ANSI N45.2.6 to perform IWE VT-1 and VT-3 examinations of containment surfaces and components.

Note: Nearly all metallic surfaces are coated.

5.

VT visual examinations procedures are to contain provisions for demonstrating resolution of remote visual examinations and minimum illumination requirements specified by Section XI, IWA-2210, 1992 Edition with the 1992 Addenda. It is Duke Power's position that Subsections IWE and IWL do not restrict the maximum remote examination distance to that specified in Table IWA-2210-1, provided illumination meets the requirements of Table IWA-2210-1 and lower case test chart characters in Table IWA-2210-1 can be resolved at the remote examination distance.

Note: We do anticipate that meeting the resolution requirements may be difficult for remote examination of both metal and concrete surfaces. As a result, nearly all concrete examinations shall be performed at close range from accessible surfaces or temporary scaffolding normally erected for tendon surveillance activities.

6.

Duke Power has an individual on staff at Oconee who is to be designated as the IWL Responsible Engineer. This Engineer has been responsible for post-tensioning system examinations, concrete containment general visual examinations, and has recently completed a reanalysis of the Oconee containments to confirm the adequacy of tendon Minimum Required Prestress Values and Predicted Limits for tendon prestress loss.

7.

The following is a list of Requests for Relief and Requests to use Alternatives to the Code for implementation of initial Containment ISI Plans (as of 6/17/98):

Serial #98-GO-001 Relief from IWE requirements to visually examine seals and gasketsSection I Page 12 of 13

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 Note: Moisture Barriers are excluded from this Request for Relief, and examination of Moisture Barriers shall be included in our ISI program. See additional discussion and clarification in Section VI.

Serial #98-GO-002 Relief from IWE requirements to perform bolt torque or tension tests Serial #98-GO-003 Alternative to IWE Augmented Examination Requirements Serial #98-GO-004 Alternative to IWE and IWA Requirements for Direct and Remote Visual Examination of Class MC and CC Components (Illumination &

Procedure Demonstration Requirements)

Serial #98-0002 Alternative to IWL-2421 (Sites with Two Plants) to allow a more appropriate examination schedule and examine a uniform number of tendons on each unit Section I Page 13 of 13

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 II. Operating Experience Data The following is a summary of Operating Experience Data related to degradation and aging of primary reactor containments.

Our review has included the following:

• Industry Events and Operating Experience Data

• Duke Operating Experience Data (including Problem Investigation Process Reports)

• Tendon Surveillance Reports and Procedures 10CFR50, Appendix J Inspection reports and procedures

• NRC Information Notices, Bulletins Table 4 contains a listing of operating experience data that has been reviewed during development of inservice inspection plans for containments at Catawba, McGuire, and Oconee Nuclear Stations.

TABLE 4 Operating Experience Data on Containment Degradation/Deficiencies Document Document Type Component Description No.

I I

2-M89-0203 Problem Investigation Steel Containment During Pre-IRLT insp of steel containment vessel Process Report (PIP)

Vessel numerous coatings failure on outside of SCV were noted above el 725'. These failures have allowed corrosion to occur.

2-M89-0204 Problem Investigation Steel Containment During the Pre-IRLT insp of the steel containment vessel Process Report (PIP)

Vessel it was noticed that the interface between the annulus concrete at el 725' and the SCV was not sealed.

2-M89-0205 Problem Investigation Steel Containment During Pre-IRLT insp of steel containment vessel coating Process Report (PIP)

Vessel failures and/or lack of coatings were noted at pens M276, M302, &M341. Corrosion of process lines and/or bellows shroud were evident.

1-M90-0093 Problem Investigation Steel Containment Pre-IRLT inspection found degradation of cork exp joint Process Report (PIP)

Vessel (el 738'+3"&766'+8"). Numerous coatings failures were observed with SCV corrosion up to 0.045".

Section II Page 1 of 5

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE 4 Operating Experience Data on Containment Degradation/Deficiencies Document Document Type Component Description No.

2-M93-0632 Problem Investigation Steel Containment Steel Containment Vessel is exposed to potential Process Report (PIP)

Vessel degradation from borated water. No caulking at top of thermal insulation in pipe chase, numerous attachments on ext of SCV not caulked, no caulking on ext at fuel transfer tube conc (caulking degraded at same location on interior).

1 -M97-1114 Problem Investigation Steel Containment Problems with coatings application and performance on Process Report (PIP)

Vessel surfaces of steel containment vessel were identified during the 10 CFR50 App J insp.

1-M97-1126 Problem Investigation Steel Containment Component degradation and housekeeping problems Process Report (PIP)

Vessel resulting from glycol piping condensation were identified during 10 CFR50 App J insp.

1-M97-1129 Problem Investigation Steel Containment Containment degradation at insulation panel locations in Process Report (PIP)

Vessel the pipe chase and at exp joints at the Fuel Transfer Tube concrete were identified during 10 CFR50 App J insp.

1-M97-1130 Problem Investigation Steel Containment Borated water leakage and component degradation of Process Report (PIP)

Vessel components due to contact with this water were identified during the 10 CFR50 App J insp.

1-M97-1133 Problem Investigation Steel Containment Staining was observed on containment surfaces beneath Process Report (PIP)

Vessel Fuel Transfer Tube concrete during 10 CFR50 App J insp. Potential exists for degradation of inaccessible containment surfaces.

1-M97-1140 Problem Investigation Steel Containment Sealant material installed along the Fuel Transfer Tube Process Report (PIP)

Vessel concrete were observed to be separating from the containment vessel during the 10 CFR50 App J insp.

This condition can permit water to access the inaccessible surfaces of containment beneath this el 1-M97-1143 Problem Investigation Steel Containment Concerns with cork exp joint material that exists above Process Report (PIP)

Vessel the Excess Letdown HX Room and the containment vessel identified during 10 CFR50 App J insp. Staining observed beneath floor.

2-M93-0641 Problem Investigation Steel Containment Steel Containment Vessel coatings problems and Process Report (PIP)

Vessel corrosion identified during 10 CFR50 App J insp.

1-C95-0283 Problem Investigation Steel Containment Degradation of Steel Containment Vessel at various Process Report (PIP)

Vessel locations identified during 10 CFR50 App J insp.

2-C95-1464 Problem Investigation Steel Containment Problem with containment vessel corrosion was identified Process Report (PIP)

Vessel during SCV insp.

2-C95-1807 Problem Investigation Steel Containment Coatings at the base of the containment vessel in the pipe Process Report (PIP)

Vessel chase were observed to the degraded at intermittent locations around circumference. Minor corrosion identified at these locations.

Section II Page 2 of 5

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE 4 Operating Experience Data on Containment Degradation/Deficiencies Document Document Type Component Description No.

17 0-096-1163 Problem Investigation Containment Metallic Delamination of coating at polar crane girders and Process Report (PIP)

Liner delamination of top coat at reactor dome.

3-096-2415 Problem Investigation Containment Metallic Corrosion of liner plate and penetrations, structural Process Report (PIP)

Liner elements, and other electrical 0-096-2413 Problem Investigation Containment Metallic Minor rust stains on liner plate in vicinity of back to back Process Report (PIP)

Liner connections between liner plate and angles which support grating and other misc att to liner plate which are not seal

__________________welded.

0-096-2414 Problem Investigation Containment Metallic Majority of sealant along basement slab/liner plate Process Report (PIP)

Liner interface is missing or degraded.

2-096-2657 Problem Investigation Containment Large flake of paint found in RB.

Process Report (PIP) 0-098-2404 Problem Investigation Containment Metallic During Civil ILRT lnsp it was discovered in two locations Process Report (PIP)

Liner there was significant connectivity between the RB shell

_______________and internal structure.

4/18/95 Correspondence Containment Metallic Corrosion of liner plate at embedment zone at floor slab at

____________Liner Point Beach U I IN 86-99 NRC Info Notice Metal Containments Potential degradation regarding corrosion in steel containments.

IN 88-82 NRC Info Notice Metal Containments Torus shells with corrosion and degraded coatings in

____________BWR containments.

IN 88-82 S 1 NRC Info Notice Metal Containments Supplement I to IN 88-82: Torus shells with corrosion

_______________and degraded coatings in BWR containments.

IN 89-79 NRC Info Notice Steel Containment Liner plate corrosion at M cGuire and Catawba Vessels IN 97-10 NRC Info Notice Steel Containment Liner plate corrosion in concrete containments.

Vessels IN 97-13 NRC Info Notice Metal Containments Deficient conditions associated with protective coatings at nuclear power plants.

IN 97-29 NRC Info Notice Metal Containments Containment Inspection Rule.

0E2622 INPO OE Report Metal Containments Dresden Unit 3. Response to Generic Letter 87-05, measures to mitigate and/or identify potential degradation for Mark I drywells.

bE3022 INPO OE Report Metal Containments Point Beach Ul and U2, containment floor liner plate Isurveillance.

Section II Page 3 of 5

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE 4 Operating Experience Data on Containment Degradation/Deficiencies Document Document Type Component Description No.

I OE4646 INPO OE Report Metal Containments KWO Obrigheim, FRG: Corrosion findings in the transition range steel containment vessel (SVC/concrete).

OE6712 INPO OE Report Containment Defects in the form of cracks were found in the AND-I Fuel Transfer Canal liner plate.

PS 1871 INPO Plant Status Steel Containment McGuire Unit 2: Base metal corrosion of the steel Vessels containment vessel was found during pre IRLT

___________________inspection.

2-M89-0211 Problem Investigation Concrete Damaged concrete was discovered at 2 locations in the Process Report (PIP) annulus: (1) Fuel Transfer Tube shielding (2) RB wall.

1-M93-0568 Problem Investigation Concrete The sealant at the interface between the gutter and parapet Process Report (PIP) wall has failed at places allowing moisture penetration into the concrete.

1-097-4171 Problem Investigation Concrete (Tendon The concrete beneath the bearing plate for vertical tendon Process Report (PIP) anchorage) 12V28 has deteriorated. Reduction in bearing surface is

_________________approx 25%.

IN 97-11 NRC Info Notice Concrete Cement erosion from containment subfoundations at nuclear power plants.

2-092-0143 Problem Investigation Tendon Gallery There is a continuous stream of water flowing into the Process Report (PIP)

Unit 2 tendon gallery.

1-095-1450 Problem Investigation Tendons (Not Primary Secondary shield wall: The lower anchorage of vertical Process Report (PIP)

Containment) tendon V8 was found in an unacceptable condition. The anchorage had excessive corrosive pitting and one wire INPOOEReportContainmen had failed since last insp.

0-096-0512 Problem Investigation Tendons Concerns about ability of containment post-tensioning Process Report (PIP) system to provide necessary level of prestress to reinforced structure throughout life of plant.

0-096-1677 Problem Investigation Tendons Oil/grease leaking excessively from Rx Building tendon Process Report (PIP) endcaps.

8/1/80 Correspondence Tendon Gallery Large volume of water in tendon gallery 2-097-0068 Problem Investigation Tendon Gallery Water leakage into the tendon gallery is increasing.

Process Report (PIP) 0-097-2304 Problem Investigation Tendons RB tendon sheath grease testing is potentially not in Process Report (PIP) accordance with Tech Spec.

1-0 9

Problem Investigation Tendons During tendon insp, only ten gallons of grease drained out Process Report (PIP) tendon sheaths for 2D28 and 3D28. Each tendon sheath Process Report (PIP) shoudcontain approx 75 gal. The stressing washer had acoaehdecsiecrsvpitnanonwlight surface corrosion.

Section 11 Page 4 of 5

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE 4 Operating Experience Data on Containment Degradation/Deficiencies Document Document Type Component Description No.

1-097-3593 Problem Investigation Tendons Vertical tendons 23V14 and 23V16 exhibited substantial Process Report (PIP) quantities of free water, loss of filler grease and significant changes in the physical appearance of the

______________________________________grease.

1-097-4337 Problem Investigation Tendons Tendon filler grease not shown to be in compliance with Process Report (PIP) the desired specifications.

1-098-0224 Problem Investigation Tendons It has been identified that the thermometer used to verify Process Report (PIP) the temperature requirements for the tendon grease per

_________________MP/0/A11400/034 has not been calibrated.

0-098-0298 Problem Investigation Tendons Tendon cap gaskets are being cut by the cap wall when Process Report (PIP) studs are torqued to specified torque of 30 ft-lbs. Flange

______________was added to bottom of cap.

1-098-0779 Problem Investigation Tendons Filler grease leaking from tendons. New gasket material Process Report (PIP) and higher torque used to fix problem.

1-098-2465 Problem Investigation Tendons Vertical Tendon caps leaking grease Process Report (PIP)

IN 85-10 NRC Info Notice Tendons Failure of tendon anchor heads at Farley U2.

IN 91q-80.ASC NRC Info Notice Tendons Failure of anchor head threads on post-tensioning system during surveillance inspection.

0E4826 INPO OE Report Tendons Containment post-tensioning surveillance problems at

___________ONS U I.

0E874 1 INPO OE Report Tendons Calvert Cliffs UI1, degraded tendon wires were discovered in the vertical tendons.

O-G95-0332 Problem Investigation Penetration Degradation of penetration seal regarding OE 7725 for Process Report (PIP)

Rivebrbend Unit I RN 88-60 NRC Info Notice Penetration Inadequate design and installation of watertight TendonsVerticalTendopenetration seals.

IN 93-25 NRC Info Notice Penetration Electrical penetration assembly degradation.

PS2315 INPO Plant Status Penetration Trojan Unit I: Containment electrical penetration seal failure determined during leak rate test wg Section II Page 5 of 5

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 III.

Summary of Containment Degradation and Aging Management in Accordance with ASME Section XI, Subsections IWE and IWL Table 5 summarizes containment areas subject to degradation and aging which shall be managed by implementation of Subsection IWE and IWL examinations, with modifications required by 10CFR50.55a(b)(2).

Section III Page 1 of 9

Duke Energorporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE 5 No.

Condition Applicability Component or Location(s)

Code Code Examination Frequency Comments to Plant/Unit Part Examined Cat.

Item Method I

Coatings Oconee 1,2,3 Accessible All Accessible E-A E1. I1 General Visual 100% Each ISI Delamination of coatings has been observed at isolated Degradation McGuire 1,2 Surfaces Locations Period locations at Oconee 1, 2, and 3. Oconee plans to remove Catawba 1,2 existing damaged coatings on dome surfaces and repair coatings EI.12 VT-3 100% Each ISI as needed. Significant delamination of coatings has not been Interval observed at Catawba or McGuire.

2.

General Corrosion Oconee 1,2,3 Accessible All Accessible E-A El. I1 General Visual 100% Each ISI McGuire 1,2 Surfaces Locations Period Catawba 1,2 El.12 VT-3 100% Each IS I Interval

3.

Corrosion of Oconee 1,2,3 Moisture Liner Plate at E-A El.I I General Visual 100% Each ISI Inaccessible Surfaces Barriers Basement Floor Period at Embedment Zones E-D E5.30 VT-3 100% Each ISI Interval

4.

Corrosion of McGuire 1,2 Moisture Embedment Zone E-A El.11 General Visual 100% Each ISI Inaccessible Surfaces Catawba 1,2 Barriers on Vessel Exterior Period at Embedment Zones (Annulus Side)

E-D E5.30 VT-3 100% Each ISI Interval

5.

Corrosion of Catawba 1,2 Moisture Embedment Zone E-A El.I I General Visual 100% Each ISI Because of accessibility, general visual exams will typically be Inaccessible Surfaces Barriers on Vessel Interior Period performed at distances of 8 -10 feet, except at locations where at Embedment Zones (Pipe Chase)

E-D E5.30 VT-3 closer access is possible. VT-3 examinations will be performed 100% Each ISI directly or remotely and may require use of optical Interval aids/cameras.

Section III Page 2 of 9

Duke Energ rporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE 5 No.

Condition Applicability Component or Location(s)

Code Code Examination Frequency Comments to Plant/Unit Part Examined Cat.

Item Method

6.

Corrosion of McGuire 1,2 Moisture Embedment Zone E-A El. 11 General Visual 100% ISI Penod Access to embedment zone is restricted by insulation which Inaccessible Surfaces Barriers o

eslItro onE-D E5.30 VT-3 100% Each 1 precludes visual examination of embedment zone. Although not at Embedment Zones (Pipe Chase) specifically required by IWE, examinations shall be performed Interval on sealant materials at top of insulation panel/vessel interface and at base of insulation panel/concrete interface. Note that McGuire is in the process of installing sealant materials at these locations. After installation, examination of these moisture barriers shall be included in the ISI Program.

E-C E4.12 Volumetric 100% Each ISI Because minor corrosion has been observed at limited locations (Ultrasonic Period along the top of the insulation panel, it is appropriate to Thickness consider performing augmented UT examination of this area Measurement) from the exterior side of the containment vessel. This area extends approximately 80 to 90% around the periphery of the containment vessel. Because of this size, it is appropriate to I

_utilize a sampling plan in lieu of 100% examination.

7.

Corrosion of Catawba 1,2 Moisture Between Walls of E-A El1 I General Visual 100% Each ISI Most of these locations have sealant applied to the expansion Inaccessible Surfaces Barriers Interior Concrete Period joint to preclude any moisture from accessing surfaces behind Behind Walls of McGuire 1,2 Structures and Steel E-D E5.30 VT-3 the expansion joint cork material. For those locations where Interior Concrete Containment 100% Each IS sealant has not been applied, these areas shall receive a general Structures Interval visual examination in accordance with E1. 11, and a VT-3 visual examination in accordance with E1.12. Degradation detected during these examinations shall be evaluated to satisfy the requirements of IOCFR50.55a(b)(2)(x)(A). Augmented examination of these surfaces is not deemed necessary since the geomtries do not permit water or moisture accumulation.

Degradation which is suspect and which requires an evaluation in accordance with IWE-2420(b) shall result in affected surfaces being added to Category E-C for augmented examination.

Section III Page 3 of 9

Duke Energ rporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE 5 No.

Condition Applicability Component or Location(s)

Code Code Examination Frequency Comments to Plant/Unit Part Examined I

Cat.

Item Method

8.

Corrosion of Metal McGuire 1,2 Accessible Between Interior E-A El. II General Visual 100% Each ISI Note: McGuire has removed nearly all expansion joint material Surfaces Behind Surfaces Concrete Structures Period between the containment vessel and floors of interior concrete Floors of Other and Steel structures. Removal of this material has made these surfaces Interior Concrete Containment at El. 12 VT-3 100% Each ISI accessible for visual examination. Expansion joint material has Structures other Interior Floor Interval not been removed between the containment vessel and interior Elevations structure concrete walls. These areas are not of a geometry that permits water accumulation. Most of these joints are sealed with moisture barrier materials (sealants).

9.

Corrosion of Metal Oconee 1,2,3 Accessible At platform E-A El.11 General Visual 100% Each 151 Degradation detected during these examinations shall be Surfaces Behind McGuire 1,2 Surfaces attachments on liner Period evaluated to satisfy the requirements of Welded Attachments Catawba 1,2

plates, IOCFR50.55a(b)(2)(x)(A). Evidence of potential degradation to Containment miscellaneous El.12 VT-3 100% Each ISI include staining (rust), orcoatings damagewith corrosionat Vessels or Liners attachments such as Interval interfaces between accessible and inaccessible surfaces.

baseplates &

componentOprtnexrineaDuespatdosntiicea suppotetcwhh significant problem with these areas, although some locations supports, etc. which may not be sealed to have been identified where attachments are neither seal-welded preclude moisture nor sealed using moisture barriers.

intrusion

10.

Corrosion of Catawba 1,2 Surfaces Beneath Ice E-C E4.12 Volumetric 100% Each ISI There is no operating experience data that suggests that these Inaccessible Metal Requiring Condensers, (Ultrasonic Period areas are subject to accelerated aging and degradation.

Surfaces Behind McGuire 1,2 Augmented Between Interior Thickness However, these areas may be subject to conditions such as Interior Ice Examination Concrete Structures Measurement) condensation, wetting, or water accumulation from ice Condenser Floors and Steel condensers. These types of conditions are described in IWE Containment at Ice 1241(a). For this reason, it is appropriate to examine these Condenser Floor surfaces. This area extends approximately 80 - 90% around the Elevation periphery of the containment vessel. UT examination of 100%

of these surfaces is impractical.

Section III Page 4 of 9

Duke Energ rporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE 5 No.

Condition Applicability Component or Location(s)

Code Code Examination Frequency Comments to Plant/Unit Part Examined Cat.

Item Method

11.

Corrosion of Oconee 1,2,3 Inaccessible Liner Plate Beneath E-C E4.12 Volumetric 100% Each ISI Operating experience data for Oconee has revealed minor Inaccessible Surfaces Surfaces Embedment Zone at (Ultrasonic Period corrosion at, and beneath, the concrete-to-liner interface. As a at Embedment Zones Basement Floor Thickness result, Oconee has planned modifications which will install Measurement) permanent access ports which will allow visual and UT examination at 3 separate locations around the periphery of the liner at the embedment zone. These access ports will be approximately 12" x 12", and will extend down from the basement floor elevation to the horizontal base liner plate. Each port is to be equipped with removable covers to permit periodic examination. After installation is completed at each unit, the ISI Plan shall be updated to include UT examination of these areas (visual examination is not sufficient as minor corrosion has already been detected at some locations). Note that observed corrosion has resulted in minimal metal loss. Areas where sealant degradation has occurred have been resealed to preclude future moisture intrusion.

Section III Page 5 of 9

Duke Energporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE 5 No.

Condition Applicability Component or Location(s)

Code Code Examination Frequency Comments to Plant/Unit Part Examined Cat.

Item Method I

12.

Corrosion of Catawba 1,2 Surfaces Between Interior E-C E4.12 Volumetric 100% Each ISI Operating experience from our Appendix J visual examinations Inaccessible Metal Requiring Concrete Structures (Ultrasonic Period of Catawba has revealed that coatings damage and minor Surfaces Behind McGuire 1,2 Augmented and Steel Thickness corrosion has been observed at these locations. Corrosion has Floors of Other Examination Containment at Measurement) typically been limited to locations near the top of expansion Interior Concrete other Interior Floor joint material where moisture can accumulate. Some coatings Structures Elevations Where degradation and corrosion has been attributed to poor Expansion Joint performance of approved sealant materials which have Material is Installed.

separated from containment surfaces. Note that approved Some Locations sealants do not typically perform as well as other materials Also Have Sealant better suited for these applications. These locations are Material Installed at sometimes subject to conditions such as wetting and drying, or Floor Elevations.

water accumulation from interior sources which could cause degradation and aging. Because these areas are typically inaccessible, it is impossible to determine from visual examinations whether accelerated aging or degradation may occur. These types of conditions are described in IWE-1241(a).

For this reason, it is appropriate to examine these otherwise inaccessible surfaces. This area extends nearly 100% around the periphery of the containment vessel. UT examination of 100% of these surfaces is impractical.

These examinations shall be required at limited locations at McGuire because nearly all of the expansion joint materials have been removed from interior floor joints, making these surfaces accessible for visual examination. (See No. 8 for additional information)

13.

Concrete Cracking, Oconee 1,2,3 Accessible Reactor Building L-A LI.1 I VT-3C Every 5 years Experience Data does not indicate a significant problem with spalling, etc.,

Concrete Exterior, including cracking, spalling, and other adverse conditions at tendon including concrete at Surfaces areas within anchorage locations. One vertical tendon anchorage on the Unit tendon anchorages adjoining structures I dome has experienced loss of concrete beneath bearing plate.

Corrective actions are planned for the near future, and the condition has been assessed by engineering.

Section III Page 6 of 9

Duke Energporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLES No.

Condition Applicability Component or Location(s)

Code Code Examination Frequency Comments to Plant/Unit Part Examined Cat.

Item Method

14.

Concrete Cracking, Oconee 1,2,3 Accessible Reactor Building L-A Ll. 12 VT-IC Every 5 years No such areas have been yet been identified for these spalling, etc.

Suspect Exterior, including examinations. However, additional areas shall be added to this Concrete areas within category if VT-3C examinations detect conditions which Surfaces adjoining structures warrant more detailed examination.

15.

Concrete Cracking, Oconee.1,2,3 Concrete Selected sample L-B L2.30 VT-IC Every 5 years Random sampling plan will determine which tendon anchorage spalling, loss of surrounding tendon locations locations shall be examined.

material at tendon tendon anchorages.

anchorages

16.

Deterioration of Oconee 1,2,3 Shims, bearing Selected sample L-B L2.30 VT-I Every 5 years One incidence of thread damage on stressing washer Tendon Anchorage

plates, tendon locations (anchorhead) has resulted in this anchor no longer being tested Hardware buttonheads, for safety reasons.

anchorheads

17.

Deterioration of Oconee 1,2,3 Tendon Caps All Accessible N/A N/A VT-3 (Specified by Every 5 years Required per IOCFR50.55a(b)(2)(ix)(A).

Tendon Anchorage Tendon Caps Duke Power)

Hardware

18.

Loss of tendon Oconee 1,2,3 Tendon Selected sample L-B L2.10 Lift-off Tests Every 5 years Adverse trends in tendon prestress loss have been detected.

prestress tendons Containment reanalysis has been performed to establish new minimum required prestress forces and establish new curves for predicted lower limits of prestress. These revised curves shall be used for future tendon surveillances.

19.

Corrosion or damage Oconee 1,2,3 Wire One tendon of each L-B L2.20 VT-I Every 5 years Operating experience data has documented minor corrosion of to tendon wires type from selected tendon wires on Unit I during 1997 tendon surveillance.

sample tendons Attributed to lack of complete grease coverage.

IWL does not specify what type of visual examination (VT-1, VT-3, general, etc. Is required for these examinations).

Section III Page 7 of 9

Duke Energporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE 5 No.

Condition Applicability Component or Location(s)

Code Code Examination Frequency Comments to Plant/Unit Part Examined Cat.

Item Method

20.

Change in wire Oconee 1,2,3 Wire One tendon of each L-B L2.20 Tension tests on 3 Every 5 years No adverse experience data has been observed.

material properties type from selected samples of each sample tendons wire removed

21.

Corrosion of tendon Oconee 1,2,3 Corrosion Selected sample L-B L2.40 Chemical Analyses Every 5 years Operating experience data has documented chemical properties wires protection tendons outside of limits during 1997 Unit I tendon surveillance. No medium correlation to wire material loss or prestress loss was recorded.

(grease)

22.

Corrosion of tendon Oconee 1,2,3 Corrosion Selected sample L-B L2.40 Analyses of Free Every 5 years Free water in significant quantities was observed during 1997 wires protection tendons Water, if any Unit I tendon surveillance. Units 2 and 3 have been assessed medium and have been found to have similar conditions. Note that (grease) presence of water has not resulted in degradation of any wires.

Inspection of other vertical tendon anchorages has been performed to verify acceptability of anchorage hardware.

Numerous tendons have been regreased so far on units I and 2.

Work on Unit 3 has not been initiated to regrease tendons.

23.

Corrosion or loss of Oconee 1,2,3 Tendon One tendon of each N/A N/A Elongation Every 5 years Required by 10CFR50.55a(b)(2)(ix)(D) tendon wires type from selected Measurement sample tendons during retensioning

24.

Loss of tendon Oconee 1,2,3 All accessible Reactor Building N/A N/A VT-3C Every 5 years Examination is to detect any through wall grease leakage.

corrosion protection concrete Exterior, including Operating experience data has documented through wall grease medium surfaces areas within leakage at several locations, primarily at cold joints at original adjoining structures, construction openings where tendon sheaths were spliced.

and tendon galleriesSection III Page 8 of 9

Duke Energ rporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE5 No.

Condition Applicability Component or Location(s)

Code Code Examination Frequency Comments to Plant/Unit Part Examined Cat.

Item Method

25.

Loss of tendon Oconee 1,2,3 Tendon Caps All Accessible N/A N/A VT-3 Every 5 years Required by IOCFR50.55a(b)(2)(ix)(A). However, type of corrosion protection Tendon Caps visual examination required is not specified. Examination shall medium be performed to detect grease leakage from tendon caps.

Operating experience data has documented grease leakage from caps. Because of grease formulation, it has been assessed that constituent parts of grease have separated, resulting in loss of less viscous material. However, more viscous part of grease continues to protect tendons.

26.

Loss of tendon Oconee 1,2,3 Tendons Selected sample N/A N/A VT-3 Every 5 years I OCFR5O.55a(b)(2)(ix)(D) requires measurement of the corrosion protection tendons difference in volume of grease removed vs. amount replaced.

medium This examination is performed to ensure that sufficient grease has been installed in tendon to completely cover tendon wires and hardware. Also performed to determine whether tendons have experienced significant grease loss.

Operating experience data has documented grease loss exceeding 10% of the net duct volume for unit I tendons examined in 1997. An assessment of grease loss was performed on unit I and additional grease has been added to refill vertical tendon sheaths. Work has progressed to unit 2, but not all vertical tendons have been regreased. Unit 3 tendons have not been regreased.

Section III Page 9 of 9

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 IV.

Application of Provisions of Request for Alternative, Serial Number 98-GO-003 to Augmented Examination of Class MC Components Table 6 provides information that addresses application of provisions of this Request to areas subject to Augmented Examination at Catawba, McGuire, and Oconee in accordance with IWE-2500, Table IWE-2500-1, Examination Category E-C, Surfaces Requiring Augmented Examination.

Section IV Page 1 of 7

Duke Energporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE 6 No.

Code Code Requirement Applicability Location(s)/Area(s)

Discussion of Code Comments/Application of Requested Paragraph to Plant &

Requirement Alternative Unit

1.

IWE-2500(c)(1)

Surface areas Oconee 1,2,3 None. However, suspect Because 1WE-2500(c)(I)

If an area is potentially subject to conditions accessible from both areas detected during the restricts VT-I examinations to which, at some future date, could cause sides shall be performance of visual surface areas accessible from accelerated aging and degradation, an Owner visually examined examinations that require both sides, VT-I examinations would be required to perform UT in using a VT-I visual engineering evaluation cannot be performed on liner accordance with IWE-2500(c)(2), even when a examination method shall be added to the plate areas of containment since VT-I examination would be sufficient to augmented examination these areas are accessible from determine whether there is any problem with Category E-C as required only one side. These the identified area, by e iE-2420.

examinations could be The provisions of our Alternative to IWE Therefore, this issue is performed on surfaces of 2500(c)(1) would allow us to perform a VT-I primarily of concern for airlock bulkheads, equipment examination first on suspect areas. If these future applications when hthcvradoerras areas exhibit conditions which warrant further surface areas require where access is possible from evaluation or NDE, the provisions of WE augmented examination, both sides, although no areas on 3200 shall require these supplemental these component parts are exmntos currently planned forexmntos augmented examination.

Section IV Page 2 of 7

Duke Energ rporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE 6 No.

Code Code Requirement Applicability Location(s)/Area(s)

Discussion of Code Comments/Application of Requested Paragraph to Plant &

Requirement Alternative Unit

2.

IWE-2500(c)(1)

Surface areas Catawba 1,2 None. However, suspect If degradation is detected on an The provisions of our Alternative to IWE accessible from both McGuire 1,2 areas detected during the exterior surface of the 2500(c)(1) would allow us to perform a VT-I sides shall be performance of visual containment vessel shell plate, examination first on suspect areas. If these visually examined examinations that require for example, and the area areas exhibit conditions which warrant further using a VT-I visual engineering evaluation requires augmented evaluation or NDE, the provisions of LWE examination method shall be added to the examination in accordance with 3200 shall require these supplemental augmented examination IWE-2420, then the Code examinations. Typically, these supplemental Category E-C as required requires a VT-I visual examinations would be UT.

by IWE-2420.

examination to be performed on Note: Some experience data has indicated Therefore, this issue is both sides of the surface. Our potential problems at embedment zones. As primarily of concern for experience has shown that the suhitmybprdntoeqreV-Ivua examiationmetho ononhallofth schei mydedruendt rqureVTIhisa future applications when eniomn noesd fte examination of these areas. However, we surface areas require doiffeent rom e

that onte vey believe that examination of moisture barriers augmented examination.

otee

. As h, the at embedment zones to ensure continued oppi protection of the embedded inaccessible areas requirement to also examine the is sufficient in lieu of specifying augmented opposite side is of little or no visual examinations of these areas.

benefit.

3.

IWE-2500(c)(2)

Surface areas Oconee 1,2,3 None. However, suspect If a surface area on the liner Augmented examination using a UT method accessible from one areas detected during the plate requires augmented is unnecessary for the following reasons:

side only shall be performance of visual examination in accordance with

1. When an area requires engineering examined for wall examinations that require IWE-2420, the Code requires a evaluaionsa a reslt ofvisua thinning using an engineering evaluation UT examination. While this examination, WE-3200 REQUIRES ultrasonic thickness shall be added to the may be appropriate for initial supplemental NDE to be performed.

measurement augmented examination evaluation of such areas, it is method in Category E-C as required completely unnecessary when

2. If supplemental NDE is performed in Section IV Page 3 of 7

Duke Energporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE 6 No.

Code Code Requirement Applicability Location(s)/Area(s)

Discussion of Code Comments/Application of Requested Paragraph to Plant &

Requirement Alternative Unit accordance with by IWE-2420.

such areas have been recoated accordance with IWE-3200, and the area Section V, T-544.

to prevent future recurrence of is recoated to protect against continued such degradation, and when a degradation, augmented examination VT-1 visual examination is using a VT-1 examination method is sufficient to ensure that the sufficient.

repaired coatings continue to perform acceptably during future inspections.

4.

IWE-2500(c)(2)

Surface areas Catawba 1,2 Areas identified in Table 5, The Code does not contain These are areas where accelerated aging and accessible from one McGuire 1,2 Condition No. 10 (behind provisions for sampling degradation have not been observed.

side only shall be ice condenser floors).

potentially large areas.

However, conditions in these areas are such examined for wall Therefore, 100% of these areas that inclusion in Category E-C examination is thinning using an shall be examined if subject to appropriate in light of provisions in IWE ultrasonic thickness examination in accordance with 1241.

measurement CaeoyE-C.

Category Note: The Code requires that areas likely to method min acodc it experience accelerated aging and degradation Section V, T-544.

shall be subject to augmented examination.

Because of lack of experience data, it is unknown whether these areas fall into this category. For this reason, it is prudent to examine these areas in accordance with IWE.

However, it is an excessive requirement to perform 100% examination on these areas, due to their size.

Section IV Page 4 of 7

Duke Energporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE 6 No.

Code Code Requirement Applicability Location(s)/Area(s)

Discussion of Code Comments/Application of Requested Paragraph to Plant &

Requirement Alternative Unit

5.

IWE-2500(c)(2)

Surface areas Catawba 1,2 Areas identified in Table5, The Code does not contain These are areas where accelerated aging and accessible from one Condition No. 12 (behind provisions for sampling degradation have not been observed.

side only shall be interior structure concrete potentially large areas.

However, some corrosion has been observed examined for wall floors where expansion Therefore, 100% of these areas at the top interface of the expansion joint thinning using an joint material exists).

shall be examined if subject to material and the containment vessel.

ultrasonic thickness examination in accordance with Significant metal loss has not been observed at measurement Category E-C.

these locations.

method in accordance Note: The Code requires that areas likely to SecAorans i

e Cto e

experience accelerated aging and degradation Condition No. 12. (shall be subject to augmented examination.

Because these areas have geometries that permit water and moisture accumulation, they may be subject to conditions which could cause accelerated aging and degradation. For this reason, it is prudent to examine these areas in accordance with IWE. However, it is an excessive requirement to perform 100%

examination on these areas, due to their size.

6.

IWE-2500(c)(2)

Surface areas McGuire 1,2 Areas identified in Table 5, The Code does not contain These are areas where accelerated aging and accessible from one Condition No. 6 (behind provisions for sampling degradation have not been observed.

side only shall be insulation panel attachment potentially large areas.

However, some corrosion has been observed examined for wall angle-to-containment Therefore, 100% of these areas at the top interface of the expansion joint thinning using an vessel) shall be examined if subject to material and the containment vessel.

ultrasonic thickness examination in accordance with Significant metal loss has not been observed at measurement Category E-C.

these locations.

Section IV Page 5 of 7

Duke Energ rporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE 6 No.

Code Code Requirement Applicability Location(s)/Area(s)

Discussion of Code Comments/Application of Requested Paragraph to Plant &

Requirement Alternative Unit method in acodc it Note: The Code requires that areas likely to Sectoanc wit 4.experience accelerated aging and degradation shall be subject to augmented examination.

Because these areas have geometries that permit water and moisture accumulation, they may be subject to conditions which could cause accelerated aging and degradation. For this reason, it is prudent to examine these areas in accordance with IWE. However, it is an excessive requirement to perform 100%

examination on these areas, due to their size.

7.

IWE-2500(c)(2)

Surface areas Oconee 1,2,3 Areas identified in Table 5, Note:

The Code does not These are areas where minor corrosion has accessible from one Condition No. 11 require examination of been noted. Resolution of Problem side only shall be (containment liner plate exempted embedded areas.

Investigation Process Reports require that examined for wall interior, inaccessible areas However, as a result of permanent access ports be installed at thinning using an below basement floor operating experience at Oconee, locations around the periphery of the liner ultrasonic thickness elevation) continued assessment of these plate embedment zone so that access for future measurement areas is warranted because of examinations will be possible. After method in corrosion noted at the installation, our containment ISI program shall accordance with embedment zones.

be revised to include examination of these Section V, T-544.

areas. Although 100% examination of embedment areas is not possible, examination of these areas will provide evidence as to the acceptability of adjacent areas where similar conditions exist. Please note that significant metal loss has not been observed at Section IV Page 6 of 7

Duke Energ rporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 TABLE 6 No.

Code Code Requirement Applicability Location(s)/Area(s)

Discussion of Code Comments/Application of Requested Paragraph to Plant &

Requirement Alternative Unit embedment zones.

After these access ports make these areas accessible, they shall be examined in accordance with Category E-C. Although our Alternative may allow visual examinations to be performed in lieu of UT on these areas, UT shall be performed because degradation has been noted at some of these locations. Our alternative will allow a sampling plan to be used to select surfaces from within each access port for examination. Since these access ports will each expose a relatively small area, the sampling plan will require examination of approximately 40 50%

of the exposed area.

Section IV Page 7 of 7

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 V. Discussion of Additional Issues Concerning this Alternative

1.

Requested Date for NRC Response to this Request for Alternative Duke Energy's letter to the NRC, dated April 6, 1998 requested a response from the NRC by July 1, 1998, so that Inservice Inspection Plans, which are under development, can be amended prior to implementation of inservice inspection plans this Summer and prior to initiating inservice inspections starting in September, 1998. Because a response to this request has not been received (as of July 8, 1998), it is unlikely that our ISI Plans can be revised to incorporate these provisions prior to the September, 1998 outages.

Although we would like to begin augmented examinations at the earliest opportunity, we have determined that IWE augmented examinations need not be performed during either the Catawba Unit 2 Outage (EOC9) or the Oconee Unit 3 Outage (EOC 17) tentatively scheduled for completion by late October.

Therefore, a response is requested at the Staff's earliest opportunity, but is desired no later than October 31, 1998, if possible.

2.

Discussion of Specific Questions/Concerns Related to This Requested Alternative Question #1:

How can Duke Power be certain that a particular side of a component will not permanently need augmented examination? How can the omission of a VT-1 examination of that side be justified?

Response

We understand and agree that some surfaces requiring augmented visual examination may need permanent augmented examination. However, the Code allows VT-I visual examinations of these surfaces to be discontinued if the areas remain essentially unchanged for 3 consecutive periods, as stated in Table IWE-2500-1, Examination Category E-C, Footnote (2). Duke Power believes that the intent of the Code is to permit these examinations to be discontinued after 3 consecutive periods because the service conditions in that area have been demonstrated not to cause accelerated aging and degradation. If any area subject to augmented visual examination does not remain Section V Page 1 of 7

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 essentially unchanged after 3 consecutive periods, that area shall continue to be examined in accordance with Category E-C.

Our alternative would allow us to exempt the opposite side of a component from augmented visual examination (VT-1) if the conditions on that side are different from those on the examined side, and if the conditions on the opposite side are such that accelerated aging and degradation is not likely.

Please note that all accessible surfaces (including surfaces on both sides of a component) are required to be examined once each period using a general visual examination in accordance with Table IWE-2500-1, Examination Category E-A, Item E1. 11, as modified by 10CFR50.55a(b)(2)(x)(E).

Please note that, although Table IWE-2500-1, Category E A, footnote (1) permits these examinations to be performed from either the inside or the outside surface, we intend to use these examinations to satisfy both 10CFR50, Appendix J and IWE. Since 10CFR50, Appendix J requires both sides to be examined, our general visual examinations shall be performed on both sides. These surfaces are also required to be examined once each interval using a VT-3 visual examination in accordance with Table IWE-2500-1, Examination Category E-A, Item E1.12. If conditions on the opposite side of a component are causing accelerated aging and degradation, or may be capable of causing accelerated aging and degradation, then that side shall also be subject to augmented examination in accordance with Category E-C.

Question #2:

Why is it appropriate to perform a VT-1 visual examination in lieu of UT, when only the accessible side is subject to conditions which warrant augmented examination? Which surface areas have been identified where a visual, VT-1 examination is proposed in lieu of UT measurements required by IWE-2500(c)(2)?

Response

1.

IWE-1241 requires that surface areas subject to conditions which are likely to cause accelerated Section V Page 2 of 7

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 aging and degradation require augmented examination. These areas may, or may not, be experiencing any degradation. For areas where accelerated aging and degradation could occur, it is possible to determine this solely by performing a visual, VT-1 examination. For areas that are subject to conditions causing accelerated aging and degradation, UT examination may be appropriate, depending on the type and extent of degradation. In either case, if visual examinations detect conditions which require engineering evaluation in accordance with IWE-3200, supplemental examinations are required by the Code. In most cases, UT would be the NDE method chosen to evaluate the acceptability of any metal loss. Furthermore, if a coated area has experienced accelerated aging and degradation, and the coating has been repaired, there is no benefit to performing UT examinations when a VT-I examination can confirm that the area is no longer experiencing accelerated aging and degradation.

In other words, if the augmented examination surface is accessible, use a VT-1 examination method. If it is inaccessible for visual examination, perform a UT examination. If a surface is accessible, and is experiencing degradation which warrants evaluation, perform NDE on the accessible surface, as required by IWE-3200.

2.

Because the Containment ISI Programs are under development and have not been completed, a detailed list of these areas cannot be provided at this time. However, based on operating experience at our plants, we do not anticipate initially performing any VT-I examinations in lieu of UT.

The provision of this request to use VT-I in lieu of UT was made primarily to address component surfaces which, during the course of implementing Section V Page 3 of 7

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 examinations required by the Code, are found to warrant augmented examination. Suspect areas detected by visual examination which require evaluation in accordance with IWE-3200 shall be added to the augmented examination program in accordance with IWE-2420(b).

An example of where this alternative could be applied is if visual examinations on the exterior shell surface of a containment vessel at Catawba or McGuire reveal that corrosion is occurring as a result of coatings damage and exposure to condensation from glycol piping in the Annulus area. In this example, the opposite side of the shell plate (on the containment interior) would not likely have any coatings damage, and would not be exposed to condensation from glycol piping.

Therefore, the opposite side does not warrant a VT-1 visual examination. Furthermore, if an engineering evaluation is required to assess the condition of a component, this evaluation should address the extent of degradation and the potential for degradation to occur on other surfaces, including the opposite side. If the engineering evaluation determines that the opposite side is subject to similar conditions, then that side would also require augmented examination.

Question #3:

What is the nominal plate thickness and undertolerance limit which may determine the extent of additional examinations required for McGuire Units 1 and 2 and Catawba Units 1 and 2?

Response

Duke Power believes that areas identified at Catawba and McGuire which should be examined under Category E-C have a nominal plate thickness of " and 1". For this plate thickness, the material specifications allow an underthickness tolerance of 0.01" (0.99" minimum plate thickness). This limit is obtained from Table Al. I of Section V Page 4 of 7

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 ASTM A20/A 20M, which specifies a "permissible variation under specified thickness, 0.01 in."

For areas where the nominal plate thickness is equal to 3/4", our alternative shall require additional examinations if the measured plate thickness is less than 0.95 x (3/4" 0.01") = 0.70". For areas where the nominal plate thickness is equal to 1", our alternative shall require additional examinations if the measured plate thickness is less than 0.95 x (1" - 0.01") = 0.94". If additional areas are added to the augmented examination Category as a result of inservice inspections, a similar approach shall be used, and shall be based on the nominal thickness of the examined material.

The 95% limit proposed is intended to provide reasonable assurance that the thickness measurements obtained are due to metal loss, and not the result of measuring locally thin areas of plate which otherwise meets the material specification thickness requirements. Please note that ASTM A20/A 20M does not require that plate thickness be measured at various locations across the plate, therefore local thin areas within the plate are possible.

Question #4:

What is the basis for your selection of the sample size for each lot size? How are lot sizes determined?

Response

This issue is discussed in Section IV of our Request.

1.

The sample sizes are obtained from Table 2-1 of EPRI NP-7218, "Guideline for the Utilization of Sampling Plans for Commercial-Grade Item Acceptance (NCIG-19)", Project Q101-07, Final Report, June 1992. The NRC has endorsed the sampling plans in this document which are used to accept the quality of nuclear-safety-related component parts for use in nuclear power plants.

The following reasons are provided to support the basis for selecting sample sizes for each lot:

Section V Page 5 of 7

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 Each lot is selected on the basis of service conditions. For UT examination of areas behind interior concrete structure floors at Catawba, these locations have similar geometry which permit water accumulation.

The critical characteristic is easily measured.

Other methods are utilized in conjunction with these examinations to confirm the adequacy of the containment, including performance of Type A tests, and visual examination of conditions in adjacent areas which may provide evidence of degradation in these inaccessible areas.

Our operating experience has shown that these areas have not yet been subject to accelerated aging and degradation.

However, a complete examination of all of these areas has not been performed and is not possible. Note that some areas have had expansion joint material removed to allow for direct visual inspection at Catawba, and that these inspections have not revealed significant degradation.

Based on operating experience, we believe that the risk of experiencing accelerated aging and degradation is low, although there remains some risk as long as expansion joint material remains and areas are occasionally exposed to water and moisture.

Most of the areas identified by Duke for UT examination have not experienced "substantial corrosion and pitting" or "excessive wear" as indicated in IWE-1241.

However, since some corrosion has been identified at some of these areas, Duke is taking a slightly more conservative approach and would like to utilize a reasonable sampling plan to examine these areas. Other Section V Page 6 of 7

Duke Energy Corporation Presentation on Containment Inservice Inspection Program, Operating Experience, and Application of Provisions of Request for Alternative Serial #98-GO-003 to IWE Augmented Examinations July 8, 1998 Owners might elect to exempt all of these types of areas from UT examination, based solely on operating experience that has shown that accelerated aging and degradation have not yet occurred.

Section V Page 7 of 7

Duke Energ rporation Clarification and Additional Supporting Information for Duke Energy Corporation Request for Relief, Serial Number 98-GO-001 July 8, 1998 This Request proposes that relief be granted from performing visual, VT-3 examinations on seals and gaskets, as required by the ASME Boiler and Pressure Vessel Code,Section XI, Subsection IWE, 1992 Edition with the 1992 Addenda. This request was submitted to the NRC in a letter dated April 6, 1998. The following clarification and additional information is provided to assist the NRC in evaluating this request.

1. Paragraph I, on Page 1 of our Request defines the scope of the request and indicates that relief is requested for seals and gaskets of Class MC pressure retaining components and metallic liners of Class CC components, Examination Category E-D, Item Numbers E5.10 and E5.20 of IWE-2500, Table IWE-2500-1, ASME Section XI, 1992 Edition, 1992 Addenda.

Paragraph III, on Page 2 of our Request for Relief indicates that "Relief is requested from performing the Code required visual examination, VT-3, on the above identified metal containment seals and gaskets." Although the scope of this request was clearly defined in Paragraph I, Paragraph III should have indicated that relief is requested for seals and gaskets on metal containments and metallic liners of concrete containments.

2. Moisture barriers are not included in the scope of this request. All examinations required by Table IWE-2500- 1, Item E5.30 are to be included in the inservice inspection programs for containments at all units at Oconee, McGuire, and Catawba.

3. Information on replacement schedules, inspections, and aging management for seals/gaskets on Emergency Personnel Air Locks (Oconee only), Equipment Hatches, and Personnel Air Locks (Oconee, McGuire, and Catawba).

The following table provides a summary of inspection/testing and replacement of door and hatch seals on Air Locks and Equipment Hatches at Oconee, McGuire, and Catawba:

Page 1 of 3

Duke Energorporation Clarification and Additional Supporting Information for Duke Energy Corporation Request for Relief, Serial Number 98-GO-001 July 8, 1998 Plant Unit Component Inspection Schedule Test Schedule Replacement Schedule Comments Oconee 1,2,3 Emergency At least once on each T.S. 4.4.1.5 requires overall N/A. These are not replaced on an Personnel Air Lock seal every refueling leak rate testing every 6 months established schedule.

seals, Personnel Air outage.

and local leak rate tests within Lock seals 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after opening (when operability is required).

Oconee 1,2,3 Equipment Hatch At least once on each T.S. 4.4.1.2 requires local leak Oconee is considering replacement 32 years of service for seals seal every refueling rate tests every refueling outage by year 2000 for all 3 units. This these seals will expire outage.

after reclosing hatches.

decision is based on seals having a 32 around year 2000.

year shelf life, and based on EPRI study. Duke Power also evaluated these materials in calculation #DPC 1381.05-00-0006.

McGuire 1,2 Personnel Air Lock Currently inspected T.S. 4.6.1.3 requires overall N/A. These are not replaced on an Newer design seals were inflatable seals every 6 months.

leak rate testing every 6 months established schedule. However, installed after 1992/1993.

and local leak rate tests within engineering evaluates inspection and Performance has improved.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after opening (when leak rate test data to decide operability is required).

appropriate replacement schedule.

In-house engineering studies support a 20 year replacement schedule.

McGuire 1,2 Equipment Hatch Seals and seal surfaces T.S. 4.6.1.1 requires local leak N/A. These are not replaced on an seals are cleaned, inspected, rate tests every refueling outage established schedule. McGuire is and lubricated every after reclosing hatches.

considering establishing a controlled outage.

replacement schedule for these seals.

In-house engineering studies support a 20 year replacement schedule.

Page 2 of 3

Duke Energo rporation Clarification and Additional Supporting Information for Duke Energy Corporation Request for Relief, Serial Number 98-GO-001 July 8, 1998 Plant Unit Component Inspection Schedule Test Schedule Replacement Schedule Comments Catawba 1,2 Personnel Air Lock Currently inspected and T.S. 4.6.1.3 requires overall N/A. These are not replaced on an Newer design seals were inflatable seals lubricated at least once leak rate testing every 6 months established schedule. However, in-installed in 1992/1993.

every refueling outage.

and local leak rate tests within house engineering studies support a Performance has improved.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after opening (when 20 year replacement schedule. Seals operability is required).

are replaced as needed, based on seal condition determined by inspections.

Catawba 1,2 Equipment Hatch Currently replaced T.S. 4.6.1.1 requires local leak Currently replaced every outage.

Catawba has chosen a very seals every outage. Sealing rate tests every refueling outage Sealing surfaces are also inspected.

conservative approach to surfaces are also after reclosing hatches.

seal replacement.

inspected.

Additional Comments:

1. All airlock and equipment hatch seals are examined at a frequency which is much greater than that specified by IWE. There is little or no expected benefit from performing the IWE visual examinations on these seals.

Page 3 of 3