ML19077A158

ASME Letter 2 of 2 - Enclosure

ML19077A158
Person / Time
Issue date:	03/08/2019
From:	Michael Benson NRC/RES/DE/CIB
To:
Benson M, RES/DE/CIB, 415-2425
Shared Package
ML19077A157	List: ML19077A158
References
Download: ML19077A158 (49)

Text

ASME Reviewer Comments Form Document: ASME Code Section III, Division3 through July 2009 Addenda) Reviewer: Staff Member A Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

WB-1132.2 Jurisdictional boundary descriptions, (a) thru (g), are Yes Response: Section III will consider the addition of hard to follow. Suggest to include sketches or sketches in Subsections WB/WC, similar to WD-pointers to Figures NB-1132.2-1 thru -3 to provide 1000. Addition of sketches would enable ASME visual clarity to note features that are specific to Division 3 (e.g., flat head with closure weld).

WB-3112.4 Sub-subparagraph WB-3112.4(b) is redundant and Yes Response: Section III will consider the deletion of should be removed or rewritten, given that the WB-3112.4(b) and delete the existing designator pointers, WB-3220 and WB-3230, identified in WB- (a) only and make (1) and (2) a new (a) and (b).

3114, Stress Limits, would direct the user to appropriate Code text.

WB-3221.3 Out of sequence, where are they? Yes Response: The number sequencing results from WB-3222.5 efforts to maintain consistency with existing WB-3222.8 Division 1 numbering. No change.

Table WB- How would the Note No. 4 provision of Yes Response: In Table WB-3217-1, Note 4 refers to 3217-1 Subparagraph WB-3222.7, Expansion Stress the special stress limits of WB-3227, not WB-Intensity, apply to the puncture related local 3222.7. However, WB-3222.7 was deleted from membrane and local bending stress evaluation? the 2015 Edition. No change.

What are the bases for the design stress intensity values?

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

1 of 4 7/11/17

ASME Reviewer Comments Form Document: ASME Code Section III, Division3 through July 2009 Addenda) Reviewer: Staff Member A Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

WB-6120 This subsubarticle is out of synch with the current Yes Response: This paragraph was revised for the U.S. design standard for meeting the 10 CFR Part 2013 Edition. Also note that Division 3 does not 71 requirements in that (1) A transportable dual- require containments to be pressure-retaining.

purpose canister is now considered an enclosure Division 3 does require appropriate loading to be vessel, which is not required by regulation to have considered. However,Section III will consider pressure-retaining function, and (2) The same revisions to WB/WC-6000 to achieve more enclosure vessel is designed for confinement clarification and consistency where appropriate.

(containment) function with redundant sealing, thus, See comment below.

also there is a need for leakage test for the inner or redundant closure sealing, of storage cask systems to which Subsection WC provisions may apply.

Suggest to review subsubarticle WC-6120 and to rewrite both to harmonize test protocols for the intended use and function.

WB- The subsubparagraph, as written, is misleading in Yes Response: For clarification, this comment 6222(a) that (1) It exceeds a similar NB-6221(a) provision, actually refers to WB-6221(a), not WB-6222(a).

which prescribes to test the containment not less Section III will consider appropriate revisions to than 1.25, in lieu of 1.50, times the lowest Design WB/WC-6000. There is a future effort planned to Pressure, and (2) The multiplier 1.5 appears to be generate a new nonmandatory appendix associated with the U.S. 10 CFR Part 71.85(b) addressing Division 3 Design Specification provision for which the containment system, for first development that might help clarify these issues.

time use, is required to be tested at a pressure equal or greater than 1.5 times the maximum normal operating pressure (MNOP). This subsubparagraph should be rewritten, recognizing that the MNOP could be substantially less than the Design Pressure, and, therefore, the hydrostatic test pressure specified as 1.25 times the Design Pressure should be sufficient to serve the purpose of demonstrating structural integrity of the containment system.

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

2 of 4 7/11/17

ASME Reviewer Comments Form Document: ASME Code Section III, Division3 through July 2009 Addenda) Reviewer: Staff Member A Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

WB-6321 Revise the 1.5 times test pressure requirement of Yes Response: See previous response above.

the first sentence to read, The containment shall be pneumatically tested at no less than 1.25 times Design Pressure. See also comments on WB-6222(a) above.

WB-6700 The entire subarticle, WB-6700, Leak Testing, Yes Response: WB-6710 was revised for clarity in should be removed or rewritten for clarity. The the 2010 Edition. However,Section III will helium leak test, as a unique type of operability consider additional revisions to WB/WC-6000 to testing, needs not be addressed here. ANSI N14.5, achieve more clarification and consistency where as referenced, should be the standard to which a appropriate.

Design Specification can refer directly.

WC-2130 Both subsubarticles address same concerns. Its No Response: Section III will consider revisions to WB-2130 unclear why different NCA paragraphs and/or WC-2130 to read identical to WB-2130.

subsubarticles are cited (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

3 of 4 7/11/17

ASME Reviewer Comments Form Document: ASME Code Section III, Division3 through July 2009 Addenda) Reviewer: Staff Member A Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

WC-3112.4 This subparagraph should be revised to use precise Yes Response: WC-3112.4 was revised for clarity in stress allowable terminologies as recognized also by the 2010 Edition and that revision is believed to other companion Subsections for intended use. address this concern. Allowable stress intensity Specifically, (1) The subparagraph title should be is an acceptable term to use when used revised to be identical to that of NC-3112.4 to read, appropriately (e.g., when referring to stress limits Design Allowable Stress Values, in that Design for Level D event, this would include the Stress Intensity Values and Maximum Allowable multiplier for Level D). However, the header title Stress Values are considered in the respective still contains the word Allowable. Therefore, will subsubparagraphs WC-3112.4(a) and WC-3112.4(b) consider the following potential changes:

and (2) All allowable stress intensity values 1. Delete Allowable from WC-3112.4 citations should be revised to read design stress header.

intensity values to be consistent with the Section II, 2. Search Division 3 for certain phrases like:

Part D, Tables 2A, 2B, and 4 terminologies. a. Good: allowable value of stress intensity is clear.

The above clarifications are imperative in opting for b. Bad: allowable stress intensity, a design-by-analysis evaluation approach based on especially when referring to Tables design stress intensity values 2A & 2B.

c. Also look in Section III Appendices.

WC-3211.1 In subsubparagraph WC-3211.1(c), revise impulsive Yes Response: Section III will consider changing loads to read impact loads. In WC-3211.1(d), impulsive to impact throughout Division 3.

revise WC-3350 to read WCA-3350. WC-3350 should be WA-3350, and was previously corrected in the 2010 Edition.

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

4 of 4 7/11/17

ASME Reviewer Comments Form Document: Section III, Division 3 through July 2009 Addenda Reviewer: Staff Member B Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

WC-6700 He leakage test must be mandatory for all Y Response: Section III will consider revisions to containment/confinement boundaries, NOT optional, both WB/WC-6000 addressing comment as as presently worded in WB and WC. Continued use appropriate. NRC has indicated a willingness to (or not) of pneumatic or hydro test should be clarify and expand further on potential proof considered as a separate issue and not connected testing needs to support future rule changes.

to or contingent upon He leakage test. IF a Also see responses to Staff Member A pneumatic or hydro test is required, it should be comments.

substantially improved by requiring much higher pressures that generate stresses that approach yield Note that there is nothing that prevents the user in the structure. Such a proof test (for lack of better to combine a pneumatic and leak test by using term, and to differentiate from the systems leakage helium as the pressurization gas. If the test aspect of the presently used pressure tests) pneumatic pressure is low such that (a) would would be far more appropriate in demonstrating the apply, then the pressure testing requirements structural capability of the canister, given would be easy to achieve. Pressure testing transportation hypothetical accident conditions. If insights could be discussed in a planned this concept is adopted, a pneumatic test must be nonmandatory appendix addressing the prohibited for safety reasons. Application of this development of Division 3 Design Specifications.

proof test after canister loading needs to be explored for possible adverse effects on the payload. Such proof testing would be applied twice. Shop proof testing of the canister shell, using a temporary lid would be required regardless. A second proof test after loading and lid welding should be considered after evaluating possible deleterious effects on the fuel.

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

1 of 9 7/11/17

ASME Reviewer Comments Form Document: Section III, Division 3 through July 2009 Addenda Reviewer: Staff Member B Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

WC-6700 He leakage test should be mandatory, in addition Y Response: Section III will consider revisions to to, not in lieu of hydro. If a proof test type WB/WC-6000 as appropriate, including test hydro is NOT adopted, I could support using the sequencing to not have masking of results by residual water from hydrostatic testing. Also, see He leakage test alone as I feel that a comments in response above.

conventional hydro is meaningless.

Furthermore, based upon comments from the field practitioners, execution of a hydro test before a He leakage test may only serve to hide very small leaks because of temporary leakage path blockage by residual adsorbed water molecules, leading to a false negative He leakage test result. This is NON-conservative.

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

2 of 9 7/11/17

ASME Reviewer Comments Form Document: Section III, Division 3 through July 2009 Addenda Reviewer: Staff Member B Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

WC-6700 There is controversy regarding the necessity of Y Response: Section III will consider revisions to performing the He leakage test over the entire WB/WC-6000 as appropriate, including boundary or just the welds. The ANSI B14.5 considerations as to what we should or should committee has taken the position that the entire not address when Division 3 references ANSI boundary must be tested. This is conservative, but N14.5, especially if future revisions of N14.5 possibly unnecessary and burdensome, depending make unanticipated changes. Also, see on the test procedure (e.g. enclosing entire vessel in comments in both responses above.

test chamber versus using a vacuum box type device). The materials engineers do not support the need to test the entire boundary when rolled plate is the base material. The fear, on the part of the materials engineers, is that the consensus national standard is being incorrectly informed based on unverified reports about He leakage occurring in various types of pressure vessels/pipe systems.

Some of the anecdotal evidence which is used by the N14.5 committee as the justification for comprehensive testing evidently involved CAST material, which WOULD be very likely to have He leakage paths. Converse to this evidence, materials engineers view wrought (e.g. forged or rolled) material as being immune to this problem.

However, the committee does not differentiate between material production methods (cast versus wrought) and concludes that any base material may be susceptible to leakage. When asked, the N14.5 committee cannot produce any supporting failure analysis reports which provide a root cause determination. (continued below)

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

3 of 9 7/11/17

ASME Reviewer Comments Form Document: Section III, Division 3 through July 2009 Addenda Reviewer: Staff Member B Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

(continued)

Hence the materials and conditions which experienced the He leakage are subject to speculation or misinformation. What is missing then is guidance regarding what types of base materials need/do not need He leakage testing. The ASME could choose to include a basis for performing/not performing a full leakage test, provided suitable materials guidance is included.

General Rules need to be developed to require DYNAMIC Y Response: The goal of Section III construction fracture mechanics design/evaluation of the Part 71 (the gamma shield overpack is not in Division 3 containment boundary and gamma shield overpack, scope) is no cracks. Cracks found after loading is (when involving ferritic steels). Of course anything an inservice issue. This is an extensive effort that fabricated from stainless is exempt. We need to is better addressed by Section XI, which is decide if dynamic fracture toughness should be currently developing a Code Case for storage extended to Part WC (storage) confinement containments.

boundaries (non-stainless). It needs to be extended to the fuel basket (non-stainless) under WB/WD, at least, and also considered for WC/WD baskets. This would cover materials such as Metamic HT.

General Use of CMTR values for material properties must Y Response: Division 3 does not specify the use of be specifically prohibited. This is a long-standing CMTRs for allowable stress intensity values or NRC/NRR position, for good reason. Stick with material properties for typical detailed stress analyses. The new strain-based acceptance using Code minimums. There are too many criteria introduced in the 2013 Edition refers to ways to play games with CMTR values and we CMTR data only to validate the material should not permit creative analyses which properties obtained from Code mandated employ possibly questionable material material testing. Division 3 WB/WC Articles 2000 properties. have been written to establish clear material requirements.

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

4 of 9 7/11/17

ASME Reviewer Comments Form Document: Section III, Division 3 through July 2009 Addenda Reviewer: Staff Member B Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

General The draft Code title, definitions, and text do not Y Response: No. ASME Section III, Division 3 recognize the terminology difference between purposely uses the term containment Part 71 containment and Part 72 confinement. throughout for both transportation and storage systems. Containment is viewed as an enclosure Everything in WB and WC is called that provides a higher degree of barrier containment. Is this an issue? assurance than that of a confinement. The Design Specification is used to specify the required leak rate, which influences and controls the design and testing of the containment.

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

5 of 9 7/11/17

ASME Reviewer Comments Form Document: Section III, Division 3 through July 2009 Addenda Reviewer: Staff Member B Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

WB and Alternative, lower-temperature-longer-time Y Response: A sound technical basis exists for WC 4600 PWHT is NOT acceptable. DELETE tables WB- performing PWHT at a lower temperature for an 4622.4(c)-1 and WC-4622.4(c)-1. This is a extended period of time - this is born out of decades of research and performance history. It widely recognized (among materials engineers) is understood that the alternative temperature-mistake in the existing ASME Code. For a time PWHT rules were incorporated to design which MUST survive severe shock accommodate a component configuration that loadings, the impaired ductility which results from could not be brought to the normal PWHT the lower temperature PWHT schedule is totally temperature. This occurred many years ago and unacceptable. PWHT equipment and technology have improved Preheat, if used, must clearly delineated and considerably since then. It is believed that all steel structures and components requiring made mandatory when employed and NEVER normal PWHT can be performed with todays made optional as per WC-4611, and other equipment and technology. Hence,Section III places. Adopt the Mandatory Minimum Preheat will consider revisions to remove the alternate table from the old ANSI B31.1, Power Piping PWHT rules from Subsections WB/WC.

Code. The B31.1 Code treated the materials with better consistency and respect. Again, this Preheating in accordance with the rules specified potentially adversely affects ductility, as per the in WC-4611 has been successfully applied for many years. The WC-4611 approach is one previous PWHT comment.

where an informed engineering decision is made based on the materials being welded and the recommended Appendix D preheat values. This, coupled with WPS qualification/confirmation by test, provides confidence that the WPS-specified preheat values are appropriate for the welding application. Hence, no change will be considered.

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

6 of 9 7/11/17

ASME Reviewer Comments Form Document: Section III, Division 3 through July 2009 Addenda Reviewer: Staff Member B Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

WB and Further comment on preheat and PWHT: If real Response: The ASME BPV Code is always WC 4600 dynamic fracture toughness (e.g. J-integral, not interested and willing to consider Code revisions drop-weight) is required for (non-stainless) based on solid technical evidence and containment/shielding/basket materials, then a experience. If the stated concerns can be more WPS/PQR, with dynamic fracture toughness fully addressed by more research in the future, measurements required of coupons, would ASME can then more appropriately consider this suffice to verify a deviation from mandatory issue on more depth. No change at this time.

preheat/PWHT requirements. Fracture toughness testing would absolutely determine whether or not a given preheat/PWHT regimen was adequate for a given application. Such testing could thus better inform the conventionally imposed mandatory times/temperatures for preheat and PWHT.

Presently, there is scant (if any) objective fracture mechanics-based data that can be related to the effect a particular pre-heat/PWHT has on the fracture toughness (not just ductility) of the material. Fracture toughness, first and foremost, is THE material parameter of concern for transportation. Everything about the welding procedure must support enhancing this property.

Extending this concept to storage should be encouraged. In order to accomplish any of this, objective (numerical) data is needed. This area needs large amounts of work. Of course, pre-heat and PWHT would remain as essential variables for any WPS.

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

7 of 9 7/11/17

ASME Reviewer Comments Form Document: Section III, Division 3 through July 2009 Addenda Reviewer: Staff Member B Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

WC-4265 Note the acceptable weld joint designs of sketch Y Response: Section III will consider a proposed WC-4265-2 for closures. This MUCH better practice, revision to Figure WC-4265-2 where the optional but in conflict with existing designs. Although I cover plate was left off of the (a) sketch.

would like to see the existing weld joint design However, these are indicated as only typical eliminated (even prohibited), I doubt if past practice Category C partial penetration welds. Other can be changed. There is real difficulty in trying to closure welds, including full penetration welds, produce the proposed joint geometry because of the are not prohibited if the component design can poor roundness of rolled-and-welded-plate canister accommodate such a weld.

shells. This is a significant fabrication difficulty.

Industry will likely lobby against this.

WB & WC WB-5245, WC-5245, WC-5250, table WC-3262- Y Response: WB/WC-5245 address Category D 1, and likely other places I missed, are NOT welds that have very limited imposed loadings acceptable for progressive PT. This is because and other controls. These are not containment shell welds like Category A and Category B, it simply states a mid-layer and is not flaw which have full volumetric and surface PT tolerance informed as per ISG15/18. examination requirements. WC-5250 and WC-3262 do address closure welds for storage canisters, which can be (but are not required to be) partial penetration welds. These requirements reflect those found in Code Case N-595. If additional requirements are believed needed, specific identified details would be helpful in order to allow the appropriate committees to consider such potential revisions.

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

8 of 9 7/11/17

ASME Reviewer Comments Form Document: Section III, Division 3 through July 2009 Addenda Reviewer: Staff Member B Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

WC WC-2530/1 discusses UT of closure weld but Y Response: WC-2530 addresses examination and fails to specify any kind of performance repair of plate (or shell), looking for laminations demonstration requirement, which is really in the material, not in the welds. See WC-5250 for closure weld examination requirements.

mandatory for this. Is this beyond the Code?

However, it was noticed that the reference in WC-2531 should be to Figure WC-4265-2. This correction is being currently addressed.

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

9 of 9 7/11/17

ASME Reviewer Comments Form Document: Section III, Division 3 through July 2013 Addenda: Reviewer: Staff Member C Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

WB & WC There are three types of loading events: 1) Force Y Response: Section III will consider clarifying that 3000 Limited (Load Controlled) Events, 2) Energy Limited that there are three types of loadings events: (1)

(Energy Controlled) Events, and 3) Displacement Force Limited (Load Controlled) Events, (2)

Limited (Displacement Controlled) Events. The Energy Limited (Energy Controlled) Events, and Code should explain these three types of events and (3) Displacement Limited (Displacement the acceptance criteria that have been established to Controlled) Events. Options include explaining evaluate each. these in WX-3111.2 (Loading Events) with existing WX-3111 becoming WX-3111.1 The Code should state that stress-based criteria are (Loading Conditions) and the title of WX-3111 to be used to evaluate Force Limited Events, such becoming Loading Conditions and Events. WX-as internal pressure, dead load, etc. All Energy 3211.2 may be used to point to other paragraph Limited Events, such as the 30 foot drop, puncture revisions as needed.

drop, non-mechanistic tip-over, aircraft impact, etc.

should be evaluated using strain-based criteria.

WB & WC The stress based criteria separates stress Y Response: Resolution of the above comment is 3000 components at a given location into stress expected to also address this review comment, categories, such as primary membrane, primary with clarification of loading types with analysis bending, secondary, etc. The definitions of these approaches.

stress categories were constructed for and apply to Force Limited Events (see for example WB-3213.8 and WB-3213.9). These definitions make no sense when applied to Energy Limited Events. Trying to apply stress criteria to Energy Limited events creates uncertainty among applicants and reviewers as to what stress limits apply to various locations on the containment boundary.

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

1 of 3 7/11/17

ASME Reviewer Comments Form Document: Section III, Division 3 through July 2013 Addenda: Reviewer: Staff Member C Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

WC-3217.1 WC-3217.1 states that "Secondary stresses need be Y Response: Section III will consider revisions to evaluated only for Level A Service Limits." WC-3217.1 as appropriate, including addressing Secondary stresses, as currently defined in WB- this issue of concern identified. Secondary 3213.9 (They are not defined in WC.) would typically stresses must be considered as appropriate.

occur at the junction of the cylindrical shell and Remember that WC-3200 points to Appendix XIII closure lid flange in a non-mechanistic tip-over (a where definitions of terms do exist as well as Level D event) and would likely yield the highest classification of stress intensities. This concern stresses on the containment boundary. Yet the must also be addressed in Subsection WB where Code would eliminate these stresses from there is also the hypothetical fire evaluation.

evaluation. This needs to be revised to not exclude Level D events.

If stress based criteria are used to evaluate Level D events, as they would be required to for carbon steels, all locations on the containment boundary, regardless of stress category, must be evaluated.

Level D All Level D Energy Limited events should employ Y Response: Section III will consider proposed Events plastic analysis methods. For stainless steel revisions to Division 3 to address the stated containments strain-based criteria should be used, issue. Resolution of this review comment is and for ferritic steel containments the acceptance expected to be supported by the resolution of the criteria of Appendix F-1340 should be used. When above review comment for WB & WC-3000.

using F-1340 all normal stresses (membrane and bending) not classified as general primary membrane stresses should be evaluated as primary stresses in accordance with F-1341.2(b).

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

2 of 3 7/11/17

ASME Reviewer Comments Form Document: Section III, Division 3 through July 2013 Addenda: Reviewer: Staff Member C Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

WB and Strain -based criteria needs to be developed for Y Response: This may be future work for the WC 3000 ferritic steels. Committee. However, additional information needs to be considered such as the types of ferritic steels of interest (limiting?) or concerns over initiation of cracking at what strain levels.

Division 1 is currently working on their own strain-based acceptance criteria, from which additional insights may be gained.

General To enhance understanding of the Code rules, more Y Response: Many BPV III committee members do commentary needs to be added to the Code. not want non-Code requirements inserted into the Code. However, ASME does publish other documents, such as the Companion Guide that offer many insights into the deeper understanding of Section III rules. In addition, a planned nonmandatory appendix that will address the preparation of Division 3 Design Specifications could be a means to insert pertinent clarifications directly into the Code.

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

3 of 3 7/11/17

ASME Reviewer Comments Form Document: Section III, Division 3 through July 2009 Addenda Reviewer: Staff Member D Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

WB-6700, Leak testing shall be performed on the entire Y Response: Section III will consider revisions to Leak Test containment boundary which meets the guidance of WB/WC-6000 as appropriate, addressing this ANSI-14.5, the international consensus standard on concern and similar concerns mentioned by Staff leak testing of radioactive transportation packages, Member Reviewers A and B. Consistency as well as the regulations 72.236(j) & (l). between certain aspects in WB-6000 and WC-6000 will also be considered. Finally, revisions made in later editions than the one reviewed by the NRC also need to be factored into this comment.

WC-6700, Helium leak testing is NOT a substitute for the Code Y Response: Section III will consider revisions to Leak Test required pressure test. These are two separate tests WB/WC-6000 as appropriate, addressing this with two separate purposes. The NRC has accepted concern and similar concerns mentioned by Staff the results from a helium leak test as meeting the Member Reviewers A and B. Consistency pressure test acceptance criteria of no leakage from between certain aspects in WB-6000 and WC-the containment, for those vessels that were not 6000 will also be considered. Finally, revisions shop pressure tested and whose shell and bottom made in later editions than the one reviewed by are inaccessible for inspection during the field the NRC also need to be factored into this pressure test. comment.

WC-6700, No correlation should be made between design Y Response: The helium leak test is a pressure Leak Test stress values and the elimination of/substitution for test (typically one atmosphere differential the Code pressure test. The Code pressure test is pressure) so standardized leak rate values will not performed to verify the design, but is performed provide meaningful insight regarding weld to insure that fabrication was proper. A weld can be acceptability. The concern was that low Design properly designed with low design stress, but if not Pressure values (based on MNOP/MNIP) simply fabricated properly, could still fail (i.e. leak) when would not challenge the base material or welds subjected to the pressure test. Design stress values in any significant fashion so why perform such can be used to increase the pressure test value, but testing. The NRC has indicated a willingness to not to lower nor eliminate the pressure test. clarify and expand further on potential proof testing needs to support future rule changes.

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

1 of 2 7/11/17

ASME Reviewer Comments Form Document: Section III, Division 3 through July 2009 Addenda Reviewer: Staff Member D Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

WC-6700, Leak testing shall be performed on the entire Y Response: Section III is willing to consider Leak Test containment boundary except for the redundant revisions to Subsection Articles WB/WC-6000.

closure weld. This is needed to meet the guidance of Please see responses to Staff Member ANSI-14.5 for fabrication leak testing, the guidance Reviewers A and B for further details in this area.

of NUREG-1536, Rev.1 and, the requirements of 10CFR72.236 (j) & (l).

WA-8000 If vendors choose not to fully embrace Division 3, by Y Response: At this time, ASME BPV Code not stamping and consequently not using an ANI, requirements do not address compensating what other compensating effects would need to be effects. A Code requirement is a Code made to Division 3? In other words, what requirement. Future Code revisions may address considerations are inherent in the Code such issues but such decisions need to be made requirements that would be different if an inspection by other higher committees.

agreement is not required? Some suggestions would be to increase the hydro test pressure, reduce allowables, etc.

WC-6120 There should be no exclusion from pressure testing Y Response: Section III is willing to consider the closure welds of the containment boundary. revisions to Subsection Articles WB/WC-6000.

Please see responses to Staff Member Reviewers A and B for further details in this area.

WC-6000, It should be made clear that pressure testing of the Y Response: Section III is willing to consider Testing containment boundary be done before the fuel is revisions to Subsection Articles WB/WC-6000.

loaded. The only exception is pressure testing of the Please see responses to Staff Member closure weld of the canister after the fuel is loaded. Reviewers A and B for further details in this area.

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

2 of 2 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

Foreword, Change the Committees function to include structural Y Response: Efforts are currently underway to 2nd integrity of containments for transportation and storage revise the Foreword for the 2019 Edition.

Paragraph of spent fuel and high-level radioactive materials and waste.

Foreword, Change the following: In formulating the rule, The Y Response: Efforts are currently underway to 2nd Committee considers the needs of the users,.... and revise the Foreword for the 2019 Edition.

Paragraph inspectors of the pressure vessels and the containments for transportation and storage of spent fuel and high-level radioactive materials and waste.

Foreword, Change the Boiler and Pressure Vessel Committee Y Response: This paragraph no longer exists in the 6th deals with the design, fabrication, maintenance and Foreword.

Paragraph inspection of boilers, pressure vessels and containments for transportation and storage of spent fuel and high-level radioactive materials and waste.

Subsection After WA-1223 add - Equivalent Materials may be Y Response: Division 3 wording to remain as is WA, used provided they meet or exceed the form, fit and since WA-1223 addresses both AWS and ASME General function of the original specified materials. specifications and being identical is required.

Requireme nts, Scope of Division 3,

WA-1200 General Requireme nts Article WA- Change title from Welding and Subcontracting of Y Response: Based on a clarification comment 3000, Welding to Subcontracting of Welding and remove (wanting WA-3111 revised to add NRC licensees Responsibil WA-3131 Welding under Construction and certificate holders) received from the NRC, ities and Division 3 has only 3 entities responsible for Duties, Code activities (N3 Certificate Holder, NPT WA-3130 Certificate Holder, and the Owner) and hence no change is proposed.

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

1 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

Article WA- Add Paragraph WA -3132, Subcontracting of Y Response: The 2017 Edition of Division 3 has 3000, Nondestructive Testing Services. added a new WA-3124 titled Subcontracted Responsibil Testing Services.

ities and Duties, WA-3130 Article WA- Add a paragraph (c) As minimum containments for Y Response: It is believed that NQA-1 via WA-4000,Qualit storage of spent fuel and high level radioactive 4000 satisfies this need. In addition, due to y materials and waste shall have quality assurance international needs, references to specific single Assurance, program .that meets the requirements of 10CFR Part country regulatory requirements are being WA-4100 72 Subpart G. deleted from the ASME BPV Code.

Scope and Applicability Article WA- Add a paragraph (d) As minimum containments for Y Response: It is believed that NQA-1 via WA-4000,Qualit transportation of spent fuel and high level radioactive 4000 satisfies this need. In addition, due to y materials and waste shall have quality assurance international needs, references to specific single Assurance, program .that meets the requirements of 10CFR Part country regulatory requirements are being WA-4100 72 Subpart G. deleted from the ASME BPV Code.

Scope and Applicability 2007 Delete - WB-5273,WB-5274, And WB-5275. Y Response: Based on input from industry Section III- representatives, Division 3 has already deleted Division 3 three paragraphs (WB-5274, -5275, -5276) in the 2008 Addenda but not WB-5273 - Hard Surfacing.

2007 WB-5279 Special Exceptions- Add - When the Y Response: Keeping in mind the identified scope Section III- large, multi-pass weld* joining the canister shell to the for Division 3, the specific mention of multi-pass Division 3 structural lid of an austenitic weld . to the structural lid and closure weld stainless steel spent fuel canister is executed and is believed to refer to the closure welds on examined consistent with the guidance provided in storage containments whereas this WB-5279 ISG-15 (Ref. 3), the staff has reasonable assurance addresses requirements for transportation that no flaws of significant size will exist such that they containments. Hence, no change is anticipated.

could impair the structural strength or confinement capability of this weld. For a spent nuclear fuel (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

2 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1) canister, such a flaw would be the result of improper fabrication or welding technique, as service-induced flaws under normal and off-normal conditions of storage are not credible. Any such fabrication flaws would be reasonably detectable during the in-process and post-weld examination techniques described by ISG-15.

Based on flaw size evaluation, the described techniques of ISG-15 should detect any such flaw which could lead to a failure or credible leakage of radioactive material. Therefore, the staff believes that there is reasonable assurance that no credible leakage of radioactive material would occur through the structural lid to canister shell weld of an austenitic stainless steel canister, and that helium leakage testing of this specific multi-pass weld is unnecessary provided the weld is executed and examined in accordance with ISG-15. Conversely, it is the staff position that other welds associated with the lid assemblies of spent fuel canisters must be subject to the helium leakage test of ANSI N14.5, in addition to the ASME Code Section III (Ref. 4) required pressure test and surface NDE which would demonstrate compliance with 10 CFR 72.236. This revision to ISG-18 expands the guidance to address all welds associated with the redundant closures of a spent fuel canister and describes how each individual closure weld must be considered from the overall design and testing standpoint.

Revision 1 adds discussion and staff review guidance for the:

1. Helium leakage test for closure welds.

2. Design and examination criteria to be met before (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

3 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1) any closure weld may be exempted from the helium leakage test.

3. Criteria for helium leakage testing of any closure weld which may be pressurized during the welding process.

4. ASME Code,Section III, hydrostatic test requirement.

5. ASME Code Case N-595.

6. Criteria for limiting root pass thickness.

Technical Review Guidance:

General Guidance The staff should verify that the cask design under review is in compliance with the guidance of this document.

1. This guidance only applies to canisters of all-welded construction, fabricated from austenitic stainless steel, employing redundant welds for the confinement closure.]

2. The welded canister (i.e., the confinement boundary) must be helium leakage tested in accordance with ANSI N14.5 and ISG-15, except as specified by this guidance.

3. Closure welds must conform with the guidance of ISG-15, and/or the guidance of this instruction, as appropriate.

4. Structures, systems, and components important to safety must be designed to withstand postulated accidents. [10 CFR 72.122(b)].

5. Records documenting the lid welds shall comply with the provisions of 10 CFR Part 72.174, Quality Assurance Records, and ISG-15. Records storage should comply with ANSI N45.2.9, Requirements for Collection, Storage, and Maintenance of Quality (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

4 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

Assurance Records for Nuclear Power Plants (Ref. 5).

6. Activities related to inspection, evaluation, documentation of fabrication, and lid welding shall be performed in accordance with an NRC-approved quality assurance program as required in 10 CFR Part 72, Subpart G, Quality Assurance.

Specific Guidance The use of helium leakage testing for dry cask storage was established to provide assurance that:

1. No leakage occurred after the closure welds of the cask system were executed. This was viewed as necessary since no active or passive methods are employed to confirm or monitor the presence of helium within an all-welded spent fuel canister over its licensed lifetime. No leakage in this case means measured leakage rate performed per ANSI N14.5, at a predetermined sensitivity that shows hypothetical doses would not exceed 10 CFR Part 72 limits.

2. If the weld(s) meets the criteria of ANSI N14.5, the staff has assurance that radio-nuclide leakage would not exceed the regulatory dose limits in 10 CFR Parts 72.104 and 72.106.

3. No oxygen in-leakage could occur, assuring the presence of the inert helium atmosphere which prevents oxidation and corrosion induced degradation of the spent fuel assemblies and enhances cooling of the spent fuel.

Helium Leakage Test - Large Weld Exception Criteria In order for any closure weld to be exempt from the helium leakage testing to demonstrate compliance with 10 CFR 72.236, the staff should verify that all of the following conditions are satisfied:

1. The weld must be multi-pass, with a minimum weld (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

5 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1) depth comprised of at least 3 distinct weld layers.

2. Each layer of weld may be composed of one or more adjacent weld beads.

3. The layer must be complete across the width of the weld joint.

4. If only three weld layers comprise the full thickness of the weld, each layer must be PT examined.

5. For more than three weld layers, not all weld layers need to be PT examined. The maximum weld deposit depth allowed before a PT examination is necessary is based upon flaw-tolerance calculations in accordance with ISG-15. Note: This criteria does not supersede the flaw acceptance criteria of any construction code.

Instead, this criteria is used to establish the maximum allowable weld deposit depth before an in-process PT examination is necessary.

6. Regardless of conditions (4) or (5) above, at least three different weld layers must be examined, e.g., the root pass, a mid-layer, and the cover pass.

7. The weld cannot have been executed under conditions where the root pass might have been subjected to pressurization from the helium fill in the canister itself. When executing vent and drain connection cover plate welds, it should not be assumed that the fill and drain closure valves, quick-disconnects, or similar, are leak tight. It is assumed that mechanical closure devices (e.g. a valve or quick-disconnect) permit helium leaks. Field experience has shown that such leaks occur and have been responsible for causing leak paths through the weld.

Consequently, welds potentially subjected to helium pressure (by way of leakage through a mechanical closure device) during the welding process must be (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

6 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1) subsequently helium leakage tested.

Helium Leakage-Testing of the Confinement Boundary The redundant weld requirement for the confinement system closure creates two closure boundaries. The staff should verify that at least one of the redundant boundaries is helium leakage tested, or, some closure welds leakage tested and the remaining closure welds of the same boundary designed so that the large weld exemption criteria of the preceding section are met. Only a boundary which is testable or meets the large weld exemption criteria, per this guidance, should be considered the confinement boundary of the redundant closures. Refer to sketches A and B and the following narrative for application of this criteria to two currently approved designs.

Leakage Testing a Single Lid With Cover Plate Design

- Sketch A In sketch A, the dotted line marked (1) defines one closure boundary. Starting on the left side of the sketch, the closure boundary can be traced from the canister wall, up through the large, multi-pass weld joining the canister wall to the heavy section, combined shield and structural lid. The boundary continues through the lid to the small weld joining the heavy lid to the vent-and drain port cover plate, and back to the heavy lid. The remainder of this boundary (and sketch) is assumed to be symmetrical with or similar to the half-sketch portion that is shown, for all cases. The large, canister-shell-to-lid weld is exempted from the helium leakage test. This is because the canister-shell-to-lid weld is a large, multi-pass weld meeting the flaw tolerance and other guidance of ISG-15 and the appropriate portions of this guidance. Note that this (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

7 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1) weld is executed prior to filling the canister with helium (use of purge or backing gas for welding operations is not considered filling or pressurizing).

Before the remaining welds of this first closure boundary are executed, the canister is drained, dried, purged, and filled with helium to the design operating pressure. The helium line connection is closed off and the vent and drain port cover plates fitted and welded into place. Since the vent-and-drain port cover plate weld may have potentially been pressurized from underneath due to assumed leakage from the closure valve, it must be helium leakage tested in accordance with the methods described in ANSI N14.5. If there are other cover plates and welds, they shall also be helium leakage tested. This first closure boundary maintains confinement integrity because one weld meets the large weld exemption criteria and the other weld was leakage tested. Thus, this first closure boundary meets the staff guidance by ensuring at least one of the two redundant closure boundaries is leakage tested or conforms to the large weld exemption criteria. The second boundary, delineated by the dotted line 2 in Sketch A, can be traced from the canister wall on the left side of the sketch up through the cover plate fillet weld joining the canister wall to the structural lid cover plate. The boundary continues through the cover plate to the fillet weld joining the cover plate to the canister lid. The weld joining the cover plate to the canister wall and lid cannot be helium leakage tested since there is no feasible means to do so.

Since this second boundary does not meet all the criteria for a confinement boundary, it may not be designated as the confinement boundary. The first (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

8 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1) closure boundary is thereby designated the confinement boundary in this design, as it meets all the applicable criteria for a confinement boundary.

Leakage Testing a Dual Lid Design - Sketch B In sketch B, the dotted line marked (1) defines one of the redundant closure boundaries. It may be traced from the canister wall on the left side of the sketch.

The boundary proceeds through the weld joining the canister wall to the shield lid, then through the shield lid. It continues through the small weld joining the vent-and-drain port cover plate back to the shield lid again.

This closure boundary may satisfy the leakage test guidance by several methods, depending on the details of the weld design. The canister shell to shield lid weld may be designed several ways. The weld may be a small seal weld which would necessitate subsequent helium leakage testing. Conversely, it could be a large, multi-pass weld consistent with the guidance of ISG-15. In that case, the weld would qualify for the leakage test exemption. Either way, note that this weld (canister to shield lid weld) is executed prior to filling and pressurizing the canister with helium (use of purge or backing gas for welding operations is not considered filling or pressurizing).

Next, the canister is drained, dried, purged, and filled with helium to the design operating pressure. The helium line connection is closed off. The vent-and-drain port cover plates are fitted and welded into place.

Since the vent-and-drain port cover plate weld may have potentially been pressurized from underneath due to assumed leakage through the closure valve, it must be helium leakage tested with the methods described in ANSI N14.5. The vent and-drain-port (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

9 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1) cover plate welds may be tested either individually or in combination with the helium leakage test of another weld. This first closure boundary maintains confinement integrity because one weld was either tested, or, meets the large weld exemption criteria. The other weld was leakage tested. Thus, this closure boundary demonstrates compliance with regulatory requirements and is consistent with staff guidance by ensuring at least one of the two redundant closures is leakage tested or exempted by conformance to the exemption guidance of ISG-15. This cover may therefore be designated as the confinement boundary.

The secondary boundary, delineated by dotted line 2 in sketch B, can be traced from the canister wall on the left side of the sketch up through the canister wall-to-structural lid weld and into the structural lid. This large canister shell-to-lid weld is exempted from the helium leakage test, because the canister shell-to-lid weld is a large, multi-pass weld meeting the flaw tolerance and other guidance of ISG-15, and the appropriate portions of this guidance. For this lid design, the second closure also qualifies for designation as the confinement boundary, because it meets the large weld exemption criteria of this guidance and the guidance in ISG-15. In this case, the designer has the freedom to designate either of the redundant closures as the confinement boundary. However, only one of the two closures is credited as the confinement boundary.

Hydrostatic Testing Closure welds must be hydrostatically or pneumatically tested in accordance with ASME Code Section III requirements to the extent practicable.

ASME Code Case N-595-4 (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

10 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

ASME Code Case N-595-4 (and all earlier versions)

(Ref. 6) is not endorsed by the NRC staff, per Regulatory Guide (RG) 1.193 (Ref. 7), and consequently is not permitted as an alternative to the Code requirements.

Criteria for Limiting Root Pass Thickness Cask lid welding is governed in part by the limiting flaw size analysis, per the guidance in ISG- 15. The method prescribed in ISG-15 controls the depth of weld deposit for the intermediate passes before the required PT examination is performed. However, the root pass thickness is not addressed by the guidance of ISG-15, as a single layer root pass was assumed.

Occasionally, multi-layer root passes are employed to smooth the weld surface to avoid false positives from the PT. A multi-layer root pass is acceptable provided a flaw size analysis is used to limit the weld deposit depth. Stress analysts should note that the intermediate layer critical flaw size calculation assumes an internal flaw, not a surface connected flaw. For the root pass calculation, a surface connected flaw must be assumed. Surface connected flaws have a higher stress intensity factor than internal flaws. This will result in a smaller critical flaw size.

Consequently, the permissible weld deposit thickness will also be smaller than for the intermediate weld pass case.

The staff should verify that if the licensee desires to use a thicker root pass, they must limit the amount of weld deposit to the ratio of the fracture toughness K values (or, J values) for the different flaw types (buried K divided by surface K) multiplied by the maximum weld deposit depth allowed by the ISG-15 calculation (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

11 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1) method. This will limit the depth of the root pass to the critical flaw size for a surface connected flaw. Thus, if a licensee desires to use a thicker weld deposit for the root pass, then a limiting flaw size analysis establishes a structural basis that is consistent with the intent of ISG-15. Alternative approaches may be proposed. Any alternative approach must consider the flaw tolerance of the weld and limit weld deposit depth to less than the critical flaw depth so that a PT may be performed before proceeding with additional weld deposit depth.

The staff recognizes that for stainless steel, K, or even J, is not entirely correct for evaluating failure in austenitic stainless steel due to the large capacity for plastic deformation. Generally, the result is failure due to net section stress, not fracture. However, the stress intensity ratio suggested above is acceptable for this purpose.

Regulatory Basis:

The systems, structures, and components (SSCs) important to safety must be designed, fabricated, erected, and tested to quality standards commensurate with the importance to safety of the function to be performed [10 CFR 72.122(a)].

The high-level radioactive waste.....must be packaged.....without the release of radioactive materials to the environment or radiation exposures in excess of [10 CFR] part 20 limits. The package must be designed to confine the high-level radioactive waste for the duration of the license [10 CFR 72.122(h)(5)].

Radiation shielding and confinement features must be provided sufficient to meet the requirements in parts 72.104 and 72.106 [10 CFR 72.236(d)].

The spent fuel storage cask must be designed to (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

12 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1) provide sealing of confinements systems [10 CFR 72.236(e)].

The spent fuel storage cask must be inspected to ascertain that there are no cracks, pinholes, uncontrolled voids, or other defects that could significantly reduce its confinement effectiveness [10 CFR 72.236(j)].

The spent fuel storage cask and its systems important to safety must be evaluated, by appropriate tests or by other means acceptable to the NRC, to demonstrate that they will reasonably maintain confinement of radioactive material under normal, off-normal, and credible accident conditions [10 CFR 72.236(l)].

The independent spent fuel storage installation must be designed to provide conformance to Parts 72.104 and 72.106 which define criteria for radioactive material in effluents and direct radiation limits.

Applicability:

This guidance applied to dry cask storage system reviews conducted in accordance with NUREG-1536, Standard Review Plan for Dry Cask Storage Systems (January 1997); and NUREG-1567, Standard Review Plan for Spent Fuel Storage Facilities (March 2000).

2007 WB-5279 - Special Exceptions - Add Response: Keeping in mind the identified scope Section III- For designs employing austenitic lid materials and for Division 3, the specific mention of lid Division 3 welds, either volumetric or multi-pass PT inspection materials and welds is believed to refer to the methods are acceptable. For either UT or PT closure welds on storage containments whereas examination, the minimum detectable flaw size must this WB-2300 addresses requirements for be demonstrated to be less than the critical flaw size. transportation containments (where partial The critical flaw size should be calculated in penetration containment welds are not accordance with ASME Section XI methodology; permitted). Also, PT alone is not permitted for however, net section stress may be governing for containment welds, volumetric plus PT is the austenitic stainless steels, and must not violate ASME requirement. Hence, no change is anticipated.

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

13 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

Section III requirements. Flaws in austenitic stainless steels shall not exceed the thickness of one weld bead.

If using UT, the UT acceptance criteria are the same as those of NB-5332 for pre-service examination. In accordance with Code practice for supplementing volumetric examinations with a surface examination, UT examination must be performed in conjunction with a root pass and cover pass PT examination. If PT is specified in lieu of volumetric inspection, a stress reduction factor of 0.8 must be applied to the weld design.

2007 Delete - WB-5360, VISUAL ACCEPTANCE FOR Response: These paragraphs have already been Section III- BRAZED JOINTS deleted.

Division 3 Delete - WB-5380, BUBBLE FROMATION TESTING 2008a After SNT-TC-1A Add: ANSI/ASNT CP-189-2006, Y Response: Section III will consider adding Section III- ASNT Standard for Qualification and Certification of ANSI/ASNT CP-189 as an alternative to SNT-Division 3, Nondestructive Testing Personnel TC-1A.

Table WA7100-2 Standards and Specificatio ns referenced in text 2009b WA-9000 Definitions, add: Equivalent Materials - Y Response: In light of the response to the fourth Section III, Materials that can be used in lieu if the original source comment on page 1, this term will not be added Division 3, material provided these material physical and chemical to the glossary without further justification.

Article WA- requirements meet or exceed the original source 9000, materials.

Glossary (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

14 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

Nonmandat Add the ASNT CP-189 as an alternate guideline for Y Response: The nonmandatory appendix referred ory Qualification and Certification of Nondestructive to by the reviewer was added by the ASME Appendix Personnel Editors and subsequently deleted by the BPV III A, Committee. See related response to comment on A5- ASNT previous page.

STANDAR D

2008a Add a new topic to identify Fracture Toughness for Lid Y Response: Keeping in mind the identified scope Section III- to Shell Weld joints using ISG-15 verbiage. for Division 3, the Article WB-2000 already Division 3, addresses a variety of material considerations for WB-2300 transportation containments, The specific Facture mention of lid to shell weld joints is believed to Toughness refer to the closure welds on storage containments whereas this WB-2300 addresses requirements for transportation containments (where partial penetration containment welds are not permitted). Hence, no change is anticipated by this review comment.

2009b Delete - WB-2344 Tubular Products and Fittings Y Response: Division 3 needs to permit a variety of Section III- potential designs of components under its stated Division 3 scope. Division 3 rules should not be restricted to just U.S. needs or just commercial power needs but be able to address all needs.

2009b Delete - And Brazing Y Response: If referring to WB-2400, the wording Section III- has already been deleted.

Division 3 2008a IWA-2300 QUALIFICATIONS OF Response: Section III will consider adding Section III- NONDESTRUCTIVE ANSI/ASNT CP-189 as an alternative to SNT-Division 3, EXAMINATION PERSONNEL TC-1A.

Subsection IWA-2310 GENERAL WB Class (a) Personnel performing nondestructive examinations (NDE)

TC shall be qualified and certified using a written practice prepared in Transportat accordance with ANSI/ASNT CP-189, Standard for Qualification ion and Certification of Nondestructive Testing Personnel, as amended (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

15 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

Containme by the requirements of this Division. Certifications based on SNT-nts TC-1A, ANSI N45.2.6, or earlier editions of ANSI/ASNT CP-189 are valid until recertification is required. Recertification shall be in accordance with the edition of ANSI/ASNT CP-189 referenced in IWA-1600 as amended by the requirements of this Division.

Outside agencies, as defined in Appendix VII, may be used to qualify NDE personnel; however, the Employer shall be solely responsible for the certification of Levels I, II, and III personnel.

Nondestructive and visual examination personnel qualified and certified in accordance with the requirements of this Division are qualified and certified to perform examinations in accordance with the requirements of previous Editions and Addenda.

(b) As an alternative to a personnel qualification program based on CP-189, the ASNT Central Certification Program (ACCP) may be used. The supplemental requirements of this Division shall apply to qualification of personnel in accordance with the ACCP.

IWA-2311 Written Practice (a) The Employer shall prepare a written practice in accordance with ANSI/ASNT CP-189.

(b) The written practice shall specify the duties and responsibilities of the Principal Level III.

IWA-2312 NDE Methods Listed in ANSI/ASNT CP-189 (a) Qualifications shall be based on the methods, techniques, procedures, and equipment used for the NDE required by this Division.

(b) Training, qualification, and certification of ultrasonic examination personnel shall also comply with the requirements of Appendix VII.

(c) Training, qualification, and certification of visual examination personnel shall comply with the requirements of Appendix VI.

(d) The visual examination training and experience hours specified in ANSI/ASNT CP-189 shall be applied to the combined certification of an individual for VT-1, VT-2, and VT-3 visual examination. Certification in only one of the VT techniques is a limited certification, and the requirements of IWA-2350 apply.

(e) Personnel certified in an NDE method, and whose training and (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

16 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1) experience in that method met the requirements of an edition of ASNT SNT-TC-1A or ANSI/ASNT CP-189 referenced by a previous edition or addenda of this Division, do not require additional training or experience hours when being certified or recertified to the same level by an employer, except as specified in IWA-2312(b).

IWA-2313 NDE Methods Not Listed in ANSI/ASNT CP-189 Personnel using NDE methods not addressed in ANSI/ASNT CP-189 shall be qualified as defined in ANSI/ASNT CP-189 or the ACCP and the Employers written practice.

IWA-2314 Certification and Recertification (a) Personnel shall be qualified by examination and shall be certified in accordance with ANSI/ASNT CP-189, except that the ASNT Level III certificate is not required. Level I, II, and III personnel shall be recertified by qualification examinations every 5 years.

(b) Personnel qualified in accordance with the ACCP shall be recertified by examination every 5 years.

(c) An ACCP certificate with current endorsements obtained by examination satisfies the General and Practical Examination requirements for Levels I and II NDE personnel.

(d) Level I, II, and III NDE personnel may be certified or recertified without additional training or experience hours when (1) certification or recertification is to the same level, and (2) the candidates training and experience in the NDE method met the requirements of an edition of ASNT SNT-TC-1A or ANSI/ASNT CP-189 referenced by a previous edition or addenda of this Division.

IWA-2315 Personnel Requirements for Eddy Current Examination of Steam Generator Tubing Personnel performing analysis or evaluation of data shall be qualified by examination to perform analysis of multifrequency data and to use multiparameter signal combination techniques. The qualification shall include a practical examination that includes techniques used and the types of flaws that may be found during examination of steam generator tubing.

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

17 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

IWA-2316 Alternative Qualifications of VT-2 Visual Examination Personnel (a) For system leakage tests and hydrostatic tests performed in accordance with IWA-5211(a) and (b), in lieu of the requirements of IWA-2310 through IWA-2314, VT-2 visual examination personnel may be qualified by satisfying the following requirements:

(1) at least 40 hr plant walkdown experience, such as that gained by licensed and nonlicensed operators, local leak rate personnel, system engineers, quality control personnel, and nondestructive examination personnel (2) at least 4 hr of training in the Section XI requirements and plant-specific procedures for VT-2 visual examination (3) the vision test requirements of IWA-2321 (b) Personnel qualified in accordance with these alternative requirements shall not perform VT-2 functions other than examinations (e.g., verifying adequacy of procedures, training VT-2 personnel).

(c) These alternative qualification requirements shall be described in the Employers written practice.

IWA-2317 Alternative Qualifications of VT-3 Visual Examination Personnel (a) In lieu of the requirements of IWA-2310 through IWA-2314, VT-3 visual examination personnel may be qualified by satisfying the following requirements:

(1) at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> plant experience, such as that gained by plant personnel involved in installation, maintenance, or examination of pumps, valves, and supports, quality control personnel, and nondestructive examination personnel (2) at least 8 hr of training in the Section XI requirements and plant-specific procedures for VT-3 visual examination (3) the vision test requirements of IWA-2321 (4) for initial qualification, and at least every 3 years thereafter, pass a written examination of at least 30 questions covering VT-3 examination attributes, VT-3 examination requirements, and plant-specific VT-3 procedures.

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

18 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

TABLE IWA-2322-1 NEAR-DISTANCE ACUITY TEST DISTANCES AND CHARACTER HEIGHTS Maximum Lower Case Test Distance, Character Height, in. (mm) in. (mm) 12 (300) 0.022 (0.56) 13 (330) 0.024 (0.61) 14 (350) 0.025 (0.64) 15 (380) 0.027 (0.69) 16 (400) 0.029 (0.74)

GENERAL NOTE: The test distances (eye to chart) and corresponding character heights provide a visual angle of 6.25 minutes, which is equivalent to a Snellen fraction of 20/25.

(b) The alternative qualification requirements shall be described in the Employers written practice.

IWA-2320 QUALIFICATION EXAMINATIONS IWA-2321 Vision Tests The following tests shall be administered annually to NDE personnel:

(a) Personnel shall demonstrate natural or corrected near-distance acuity of 20/25 or greater Snellen fraction, with at least one eye, by reading words or identifying characters on a near-distance test chart, such as a Jaeger chart, that meets the requirements of IWA-2322. Equivalent measures of near-distance acuity may be used. In addition, personnel performing VT-2 or VT-3 visual examinations shall demonstrate natural or corrected far-distance acuity of 20/30 or greater Snellen fraction or equivalent with at least one eye.

(b) As an alternative to the visual acuity demonstration requirements of (a), any vision test administered by an optometrist, ophthalmologist, or other healthcare professional who administers vision tests and documents compliance with the acuity requirements of (a) is acceptable.

(c) Personnel shall demonstrate the capability to distinguish the colors applicable to the NDE methods for which certified and to differentiate contrast between these colors.

IWA-2322 Near-Distance Test Chart Qualification A measurement of one of the near-distance test chart characters (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

19 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1) shall be made once before initial use, with an optical comparator (10X or greater) or other suitable instrument, to verify that the height of a representative lower case character, without an ascender or descender (e.g., a, c, e, o), for the selected type size, meets the requirements of Table IWA-2322-1. This measurement shall be documented and traceable to the test chart.

IWA-2323 Level III Personnel The qualifications of Level III NDE personnel shall be evaluated using written examinations and a Demonstration Examination. The written examinations shall cover the Basic, Method, Specific, and Practical areas of knowledge as defined in IWA-2323(a), (b), (c),

and (d). The Demonstration Examination shall be in accordance with ANSI/ASNT CP-189, Level II Practical Examination rules.

(a) The Basic Examination shall consist of at least 65 questions (required only once if certification is sought in more than one method).

(1) at least twenty questions related to understanding of ANSI/ASNT CP-189 (2) at least thirty questions related to applicable materials, fabrication, and product technology (3) at least fifteen questions that are similar to published Level II questions for other NDT methods (b) The Method Examination shall consist of at least 65 questions.

(1) at least thirty questions related to fundamentals and principles that are similar to published ASNT Level III questions for each method (2) at least fifteen questions related to application and establishment of procedures and techniques that are similar to published ASNT Level III questions for each method (3) at least twenty questions related to capability for interpreting codes, standards, and specifications related to the method (c) The Specific Examination shall contain at least 30 questions covering equipment, techniques, procedures, and administration of the Employers written practice. The Specific Examination shall also cover the NDE requirements of this Division, including acceptance standards and referenced codes and standards.

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

20 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

(d) The Practical Examination shall be in accordance with ANSI/ASNT CP-189 requirements.

(e) An ASNT Level III certificate with current endorsements obtained by examination for the applicable method satisfies the Basic and Method Examination requirements.

(f) When an outside agency administers the examination and only a pass or fail grade is issued, the Employer shall assign a grade of 80% for a pass grade.

(g) Level III personnel shall be recertified using the written Method, Specific, and Practical Examinations and the Demonstration Examination. Alternatively, Level III personnel may be recertified using only the written Method and Specific Examinations, provided the following conditions are met.

(1) The Level III candidate was previously certified or recertified using all the written examinations and the Demonstration Examination.

(2) The Level III candidate is not being recertified due to interrupted service as defined in the Employers written practice.

(3) The Level III candidate is not being certified by a new Employer.

(h) For initial certification, the grades for the Basic, Method, Specific, Practical, and Demonstration Examinations shall be averaged to determine the overall grade. For recertification, the grades of applicable examinations administered in accordance with IWA-2323(g) shall be averaged to determine the overall grade.

(i) An ACCP certificate with current endorsements obtained by examination satisfies the Basic, Method, Practical, and Demonstration examination requirements for Level III NDE personnel.

IWA-2330 LEVEL I RESPONSIBILITIES Level I personnel shall use written procedures when performing specific setups, calibrations, and examinations and when recording data. These activities shall be conducted under the guidance of Level II or Level III personnel. Level I personnel shall not evaluate or accept the results of a nondestructive examination.

IWA-2340 LEVEL III EDUCATION (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

21 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

Level III candidates shall have high school or equivalent education.

IWA-2350 LIMITED CERTIFICATION Limited certification in a method is permitted for personnel who are restricted to performing examinations of limited scope, i.e.,

limited operations or limited techniques within the method. Topics that are not relevant to the limited certification may be deleted from the ANSI/ASNT CP-189, Appendix VI, or Appendix VII training outline and may be accompanied by a corresponding reduction in training hours, examination content, and number of examination questions. Only questions related to the limited training are required. In addition, the required experience may be reduced by a corresponding amount. The specific methods and techniques covered by limited certification and the training, examination, and experience requirements for limited certification shall be defined in the written practice and documented in the individuals certification records.

IWA-2360 LEVEL I AND LEVEL II TRAINING AND EXPERIENCE (a) A candidate may be qualified directly to Level II with no time as a Level I provided the required training and experience consists of the sum of the hours required for Level I and Level II certification.

(b) NDE training course outlines and materials shall be approved by a Level III. Previous training and experience may be accepted if verified by a Level III. The method of verification shall be documented in the candidates certification records.

IWA-2370 LEVEL III EXPERIENCE Candidates for Level III certification shall meet one of the following criteria:

(a) Graduate of a 4-year accredited engineering or science college or university with a degree in engineering or science, plus 1 year experience in NDE in an assignment comparable to that of a Level II in the examination method.

(b) Completion with a passing grade of at least the equivalent of 2 full years of engineering or science study at a university, college, (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

22 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1) or technical school, plus 2 years experience in an assignment comparable to that of a Level II in the examination method.

(c) Four years experience in an assignment comparable to that of a Level II in the examination method.

IWA-2380 NDE INSTRUCTOR In lieu of the requirements of CP-189, a candidate being considered for qualification as an NDE Instructor shall satisfy the Level III Basic and Method Examination requirements of IWA-2323 and shall meet one of the following requirements:

(a) maintain a current teacher or vocational instruction certificate issued by a state, municipal, provincial, or federal authority; or (b) complete a minimum of 40 hr instruction in training and teaching techniques.

IWA-2400 INSPECTION PROGRAM IWA-2410 APPLICATION OF CODE EDITION AND ADDENDA The Code Edition and Addenda for preservice inspection and for initial and successive inservice inspection intervals shall be as required by the regulatory authority having jurisdiction at the plant site.

IWA-2300 QUALIFICATIONS OF NONDESTRUCTIVE EXAMINATION PERSONNEL IWA-2310 GENERAL (a) Personnel performing nondestructive examinations (NDE) shall be qualified and certified using a written practice prepared in accordance with ANSI/ASNT CP-189, Standard for Qualification and Certification of Nondestructive Testing Personnel, as amended by the requirements of this Division. Certifications based on SNT-TC-1A, ANSI N45.2.6, or earlier editions of ANSI/ASNT CP-189 are valid until recertification is required. Recertification shall be in accordance with the edition of ANSI/ASNT CP-189 referenced in IWA-1600 as amended by the requirements of this Division.

Outside agencies, as defined in Appendix VII, may be used to qualify NDE personnel; however, the Employer shall be solely responsible for the certification of Levels I, II, and III personnel.

Nondestructive and visual examination personnel qualified and (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

23 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1) certified in accordance with the requirements of this Division are qualified and certified to perform examinations in accordance with the requirements of previous Editions and Addenda.

(b) As an alternative to a personnel qualification program based on CP-189, the ASNT Central Certification Program (ACCP) may be used. The supplemental requirements of this Division shall apply to qualification of personnel in accordance with the ACCP.

IWA-2311 Written Practice (a) The Employer shall prepare a written practice in accordance with ANSI/ASNT CP-189.

(b) The written practice shall specify the duties and responsibilities of the Principal Level III.

IWA-2312 NDE Methods Listed in ANSI/ASNT CP-189 (a) Qualifications shall be based on the methods, techniques, procedures, and equipment used for the NDE required by this Division.

(b) Training, qualification, and certification of ultrasonic examination personnel shall also comply with the requirements of Appendix VII.

(c) Training, qualification, and certification of visual examination personnel shall comply with the requirements of Appendix VI.

(d) The visual examination training and experience hours specified in ANSI/ASNT CP-189 shall be applied to the combined certification of an individual for VT-1, VT-2, and VT-3 visual examination. Certification in only one of the VT techniques is a limited certification, and the requirements of IWA-2350 apply.

(e) Personnel certified in an NDE method, and whose training and experience in that method met the requirements of an edition of ASNT SNT-TC-1A or ANSI/ASNT CP-189 referenced by a previous edition or addenda of this Division, do not require additional training or experience hours when being certified or recertified to the same level by an employer, except as specified in IWA-2312(b).

IWA-2313 NDE Methods Not Listed in ANSI/ASNT CP-189 Personnel using NDE methods not addressed in ANSI/ASNT CP-189 shall be qualified as defined in ANSI/ASNT CP-189 or the (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

24 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

ACCP and the Employers written practice.

IWA-2314 Certification and Recertification (a) Personnel shall be qualified by examination and shall be certified in accordance with ANSI/ASNT CP-189, except that the ASNT Level III certificate is not required. Level I, II, and III personnel shall be recertified by qualification examinations every 5 years.

(b) Personnel qualified in accordance with the ACCP shall be recertified by examination every 5 years.

(c) An ACCP certificate with current endorsements obtained by examination satisfies the General and Practical Examination requirements for Levels I and II NDE personnel.

(d) Level I, II, and III NDE personnel may be certified or recertified without additional training or experience hours when (1) certification or recertification is to the same level, and (2) the candidates training and experience in the NDE method met the requirements of an edition of ASNT SNT-TC-1A or ANSI/ASNT CP-189 referenced by a previous edition or addenda of this Division.

IWA-2315 Personnel Requirements for Eddy Current Examination of Steam Generator Tubing Personnel performing analysis or evaluation of data shall be qualified by examination to perform analysis of multifrequency data and to use multiparameter signal combination techniques. The qualification shall include a practical examination that includes techniques used and the types of flaws that may be found during examination of steam generator tubing.

IWA-2316 Alternative Qualifications of VT-2 Visual Examination Personnel (a) For system leakage tests and hydrostatic tests performed in accordance with IWA-5211(a) and (b), in lieu of the requirements of IWA-2310 through IWA-2314, VT-2 visual examination personnel may be qualified by satisfying the following requirements:

(1) at least 40 hr plant walkdown experience, such as that gained by licensed and nonlicensed operators, local leak rate personnel, (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

25 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1) system engineers, quality control personnel, and nondestructive examination personnel (2) at least 4 hr of training in the Section XI requirements and plant-specific procedures for VT-2 visual examination (3) the vision test requirements of IWA-2321 (b) Personnel qualified in accordance with these alternative requirements shall not perform VT-2 functions other than examinations (e.g., verifying adequacy of procedures, training VT-2 personnel).

(c) These alternative qualification requirements shall be described in the Employers written practice.

IWA-2317 Alternative Qualifications of VT-3 Visual Examination Personnel (a) In lieu of the requirements of IWA-2310 through IWA-2314, VT-3 visual examination personnel may be qualified by satisfying the following requirements:

(1) at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> plant experience, such as that gained by plant personnel involved in installation, maintenance, or examination of pumps, valves, and supports, quality control personnel, and nondestructive examination personnel (2) at least 8 hr of training in the Section XI requirements and plant-specific procedures for VT-3 visual examination (3) the vision test requirements of IWA-2321 (4) for initial qualification, and at least every 3 years thereafter, pass a written examination of at least 30 questions covering VT-3 examination attributes, VT-3 examination requirements, and plant-specific VT-3 procedures.

TABLE IWA-2322-1 NEAR-DISTANCE ACUITY TEST DISTANCES AND CHARACTER HEIGHTS Maximum Lower Case Test Distance, Character Height, in. (mm) in. (mm) 12 (300) 0.022 (0.56) 13 (330) 0.024 (0.61) 14 (350) 0.025 (0.64) 15 (380) 0.027 (0.69) 16 (400) 0.029 (0.74)

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

26 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

GENERAL NOTE: The test distances (eye to chart) and corresponding character heights provide a visual angle of 6.25 minutes, which is equivalent to a Snellen fraction of 20/25.

(b) The alternative qualification requirements shall be described in the Employers written practice.

IWA-2320 QUALIFICATION EXAMINATIONS IWA-2321 Vision Tests The following tests shall be administered annually to NDE personnel:

(a) Personnel shall demonstrate natural or corrected near-distance acuity of 20/25 or greater Snellen fraction, with at least one eye, by reading words or identifying characters on a near-distance test chart, such as a Jaeger chart, that meets the requirements of IWA-2322. Equivalent measures of near-distance acuity may be used. In addition, personnel performing VT-2 or VT-3 visual examinations shall demonstrate natural or corrected far-distance acuity of 20/30 or greater Snellen fraction or equivalent with at least one eye.

(b) As an alternative to the visual acuity demonstration requirements of (a), any vision test administered by an optometrist, ophthalmologist, or other healthcare professional who administers vision tests and documents compliance with the acuity requirements of (a) is acceptable.

(c) Personnel shall demonstrate the capability to distinguish the colors applicable to the NDE methods for which certified and to differentiate contrast between these colors.

IWA-2322 Near-Distance Test Chart Qualification A measurement of one of the near-distance test chart characters shall be made once before initial use, with an optical comparator (10X or greater) or other suitable instrument, to verify that the height of a representative lower case character, without an ascender or descender (e.g., a, c, e, o), for the selected type size, meets the requirements of Table IWA-2322-1. This measurement shall be documented and traceable to the test chart.

IWA-2323 Level III Personnel The qualifications of Level III NDE personnel shall be evaluated using written examinations and a Demonstration Examination. The (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

27 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1) written examinations shall cover the Basic, Method, Specific, and Practical areas of knowledge as defined in IWA-2323(a), (b), (c),

and (d). The Demonstration Examination shall be in accordance with ANSI/ASNT CP-189, Level II Practical Examination rules.

(a) The Basic Examination shall consist of at least 65 questions (required only once if certification is sought in more than one method).

(1) at least twenty questions related to understanding of ANSI/ASNT CP-189 (2) at least thirty questions related to applicable materials, fabrication, and product technology (3) at least fifteen questions that are similar to published Level II questions for other NDT methods (b) The Method Examination shall consist of at least 65 questions.

(1) at least thirty questions related to fundamentals and principles that are similar to published ASNT Level III questions for each method (2) at least fifteen questions related to application and establishment of procedures and techniques that are similar to published ASNT Level III questions for each method (3) at least twenty questions related to capability for interpreting codes, standards, and specifications related to the method (c) The Specific Examination shall contain at least 30 questions covering equipment, techniques, procedures, and administration of the Employers written practice. The Specific Examination shall also cover the NDE requirements of this Division, including acceptance standards and referenced codes and standards.

(d) The Practical Examination shall be in accordance with ANSI/ASNT CP-189 requirements.

(e) An ASNT Level III certificate with current endorsements obtained by examination for the applicable method satisfies the Basic and Method Examination requirements.

(f) When an outside agency administers the examination and only a pass or fail grade is issued, the Employer shall assign a grade of 80% for a pass grade.

(g) Level III personnel shall be recertified using the written (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

28 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1)

Method, Specific, and Practical Examinations and the Demonstration Examination. Alternatively, Level III personnel may be recertified using only the written Method and Specific Examinations, provided the following conditions are met.

(1) The Level III candidate was previously certified or recertified using all the written examinations and the Demonstration Examination.

(2) The Level III candidate is not being recertified due to interrupted service as defined in the Employers written practice.

(3) The Level III candidate is not being certified by a new Employer.

(h) For initial certification, the grades for the Basic, Method, Specific, Practical, and Demonstration Examinations shall be averaged to determine the overall grade.

For recertification, the grades of applicable examinations administered in accordance with IWA-2323(g) shall be averaged to determine the overall grade.

(i) An ACCP certificate with current endorsements obtained by examination satisfies the Basic, Method, Practical, and Demonstration examination requirements for Level III NDE personnel.

IWA-2330 LEVEL I RESPONSIBILITIES Level I personnel shall use written procedures when performing specific setups, calibrations, and examinations and when recording data. These activities shall be conducted under the guidance of Level II or Level III personnel. Level I personnel shall not evaluate or accept the results of a nondestructive examination.

IWA-2340 LEVEL III EDUCATION Level III candidates shall have high school or equivalent education.

IWA-2350 LIMITED CERTIFICATION Limited certification in a method is permitted for personnel who are restricted to performing examinations of limited scope, i.e.,

limited operations or limited techniques within the method. Topics that are not relevant to the limited certification may be deleted from the ANSI/ASNT CP-189, Appendix VI, or Appendix VII (1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

29 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1) training outline and may be accompanied by a corresponding reduction in training hours, examination content, and number of examination questions. Only questions related to the limited training are required. In addition, the required experience may be reduced by a corresponding amount. The specific methods and techniques covered by limited certification and the training, examination, and experience requirements for limited certification shall be defined in the written practice and documented in the individuals certification records.

IWA-2360 LEVEL I AND LEVEL II TRAINING AND EXPERIENCE (a) A candidate may be qualified directly to Level II with no time as a Level I provided the required training and experience consists of the sum of the hours required for Level I and Level II certification.

(b) NDE training course outlines and materials shall be approved by a Level III. Previous training and experience may be accepted if verified by a Level III. The method of verification shall be documented in the candidates certification records.

IWA-2370 LEVEL III EXPERIENCE Candidates for Level III certification shall meet one of the following criteria:

(a) Graduate of a 4-year accredited engineering or science college or university with a degree in engineering or science, plus 1 year experience in NDE in an assignment comparable to that of a Level II in the examination method.

(b) Completion with a passing grade of at least the equivalent of 2 full years of engineering or science study at a university, college, or technical school, plus 2 years experience in an assignment comparable to that of a Level II in the examination method.

(c) Four years experience in an assignment comparable to that of a Level II in the examination method.

IWA-2380 NDE INSTRUCTOR In lieu of the requirements of CP-189, a candidate being considered for qualification as an NDE Instructor shall satisfy the Level III Basic and Method Examination requirements of IWA-(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

30 of 31 7/11/17

ASME Reviewer Comments Form Document: Section III Division 3 through July 2009 Addenda Reviewer: Staff Member E Article NRC Reviewer's Comment ASME Comment Clarification Response Section Response Accepted by Required NRC?

(Y/N)? (Y/N)(1) 2323 and shall meet one of the following requirements:

(a) maintain a current teacher or vocational instruction certificate issued by a state, municipal, provincial, or federal authority; or (b) complete a minimum of 40 hr instruction in training and teaching techniques.

IWA-2400 INSPECTION PROGRAM IWA-2410 APPLICATION OF CODE EDITION AND ADDENDA The Code Edition and Addenda for preservice inspection and for initial and successive inservice inspection intervals shall be as required by the regulatory authority having jurisdiction at the plant site.

critical flaw size: the flaw size that will cause failure under a Response: The goal of Division 3 construction is specified load calculated using fracture mechanics. The minimum no cracks. Therefore, this term is not applicable critical flaw size for normal or upset conditions (Service Level A to Division 3. Future Section XI efforts may and B) is ac; the minimum critical initiation flaw size for address critical flaw size for inservice emergency and faulted conditions is ai.

inspections.

(1) Column does not reflect that any proposed change has been reviewed and approved via the Section III ASME consensus process.

31 of 31 7/11/17