ML19241A348

IP 73757 Part 52 Preservice Inspection - Data Review and Evaluation

ML19241A348
Person / Time
Issue date:	09/23/2019
From:	Thomas Fredette NRC/NRO/DCIP/CIPB
To:
Webb M
Shared Package
ML9241A334, ML19266A018	List:
References
CN 19-029
Download: ML19241A348 (6)

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NRC INSPECTION MANUAL MCB INSPECTION PROCEDURE 73757 PART 52, PRESERVICE INSPECTION - DATA REVIEW AND EVALUATION PROGRAM APPLICABILITY: IMC 2504 App B 73757-01 INSPECTION OBJECTIVES To ascertain whether the reported data covers the scope of examination required for the Preservice Inspection (PSI) of general components listed in the tables of IWB-2500, IWC-2500, and IWD-2500 of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME)Section XI, as described in: the applicable ASME Code,Section III and Section XI; the technical requirements manual (TRM) and/or site director procedures manual (SDPM);

and the PSI program filed with the NRC.

To ascertain whether the reported data covers the scope of examination required for the PSI of critical ASME Class 1 components as described in: the applicable ASME Code, the TRM/SDPM, and PSI program filed with the NRC.

73757-02 INSPECTION REQUIREMENTS AND GUIDANCE General Guidance: The inspections of interest in this procedure are those nondestructive examinations (NDE) of Class 1, 2, and 3 components performed to meet the requirements of the TRM/SDPM, and the PSI program filed with the NRC. Preservice testing and Inservice testing of pumps and valves as described in the ASME Code for Operations and Maintenance of Nuclear Plants (OM Code) is not included within the scope of this procedure.

Examination data, test results, and other NDE data and records are essential to establish a baseline for comparison with future examinations as part of the history of findings and indications. Evaluation of the previous growth rate of flaws and other indications permits a realistic prediction of expected further growth based on valid examination data. It is, therefore, essential to have complete, reliable, and clear NDE data, and records for each examination.

This inspection procedure (IP) will review examination findings to assure that corrective measures are taken on adverse findings, and to ensure that the licensee has utilized an Authorized Nuclear Inservice Inspector (ANII), as required by regulation. If the ANII Code responsibilities appear to not be met, consider the Enforcement options and refer the issue to the NRC headquarters.

For the purpose of this IP, the term, PSI/ [inservice inspection] ISI program, includes the PSI/ISI plan, the repair/replacement plan, and the administrative, technical, and quality assurance programs/procedures required to implement the plan.

Issue Date: 09/23/19 1 73757

Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a, each construction permit, issued under 10 CFR Part 50, is subject to all the conditions in 10 CFR 50.55a in addition to those specified in 10 CFR 50.55.

All the provisions of 10 CFR 50.55a that are applicable to holders of construction permits for nuclear power reactors also apply to holders of combined licenses issued under 10 CFR Part 52, except that combined license holders are not subject to the conditions of paragraphs (f) and (g) of 10 CFR 50.55a until after the Commission makes the finding under 10 CFR 52.103(g).

10 CFR 50.55a(g)(3)(i) and 10 CFR 50.55a(g)(3)(ii) both require that components are designed to provide access for inservice examination and that components meet the preservice inspection requirements set forth in the Code editions and addenda applied to their construction.

10 CFR 50.55a(g)(3)(i) applies to ASME Code Class 1 components (including supports), and 10 CFR 50.55a(g)(3)(ii) applies to ASME Code Class 2 and 3 components (including supports for components that are classified as ASME Code Class 1, 2 and 3).

10 CFR 50.55a(g)(3)(v), states, All components (including supports) may meet the requirements set forth in subsequent editions of codes and addenda or portions thereof which are incorporated by reference in paragraph (b) of this section {10 CFR 50.55a}, subject to the conditions therein. This provision allows the holder of a construction permit or combined license to use later editions and addenda of the code that are incorporated by reference in paragraph (b) of 10 CFR 50.55a, for preservice inspection only, without the need for NRC approval or authorization.

02.01 General Records Review. Perform the following:

a. Obtain and review at least three preservice NDE inspection records from each examination category of tables IWB-2500 (B-F through B-O, not addressed in Section 02.02), IWC-2500 (C-A through C-G), and IWD-2500 (D-A) of ASME Section XI.

Ascertain whether the reported extent of examinations for those Class 1, 2, and 3 components and areas subject to examination meet the minimum examination requirements specified in the applicable edition and addenda of the ASME Code,Section XI.

b. Verify the selected records are consistent with the TRM/SDPM and the PSI program and contain or provide reference to the following:

Guidance: Use the following listing of required information as a checklist during the review of the selected sets of NDE records for completeness and technical adequacy.

Also verify that the actual examinations performed are consistent with what is prescribed in the Final Safety Analysis Report.

1. Examination results and data sheets;

2. Examination equipment data;

3. Calibration data sheets;

4. Examination evaluation data; Issue Date: 09/23/19 2 73757

5. Records on extent of examination;

6. Records on deviation from program and procedures including justification for deviation;

7. Records on disposition of findings. Evaluation of indications complies with the criteria of the NDE procedure and ASME Code Section III or XI;

8. Re-examination data after repair work;

9. Identification of NDE material such as penetrant, penetrant cleaner, couplant, films, tapes, etc;

10. Following the disposition, acceptance or rejection, of findings by the NDE examiner (qualified NDE technician), evaluation of examination data is performed by a Level II or Level III examiner;

11. Design and access provisions are sufficient to enable the performance of preservice examinations including the coverage specified by ASME Section III or XI;

12. Incomplete examinations and results were repeated to permit full evaluation, if applicable; and

13. Review by the ANII.

c. For preservice inspections of components for which shop or field examinations serve as the preservice examinations in lieu of on-site preservice examinations, verify:

1. For vessels, the examination was performed after the hydrostatic test - which is required by the construction code - was completed.

2. Examinations are conducted under conditions and with equipment and techniques equivalent to those expected to be employed for subsequent inservice examinations.

3. Records are, or can be, documented and identified in a form consistent with the requirements in ASME Section XI, IWA-6000.

Guidance: Shop examinations are those performed in the component fabrication shop.

Field examinations are those performed at a field facility or field location prior to the arrival of the component on-site. Once the component has been received on-site, then all examinations are considered to be on-site exams.

02.02 ASME Class 1 Records Review. Perform the following:

a. Obtain and review at least one site preservice NDE inspection record from each item number in examination categories B-A through B-D in tables IWB-2500, preservice NDE inspection records for a sample of SG tubes (Category B-Q, pressurized water reactors (PWRs) only) and a sample of dissimilar metal butt welds NPS 4 and larger in categories B-F and B-J.

Issue Date: 09/23/19 3 73757

b. Verify that the following requirements are met:

1. The method, extent, and technique of examination comply with ASME Section III or XI, the licensees preservice inspection program requirements, and applicable NDE procedure.

2. The examination data are within the acceptance criteria as outlined in the applicable NDE procedure and applicable Code requirements.

3. The recording, evaluating, and dispositioning of findings are in compliance with the applicable NDE procedure and applicable Code requirements.

4. The method used for NDE was sufficient to determine the full extent of indication or acceptance.

73757-03 RESOURCE ESTIMATE Total resource estimate is between 400 and 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br />, depending on the type of unit inspected, the type of construction materials used and the size of the unit.

Review of the general components under Section 02.01 would involve approximately 60 NDE reports. This is estimated to take approximately 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br />.

Review of the Class 1 components would involve approximately 30 NDE reports for a PWR (less for a boiling water reactor since there is no pressurizer or separate steam generator) plus the NDE reports associated with the dissimilar metal welds, which could be on the order of 12 to 36, depending upon the construction materials used. These reviews are anticipated to be more involved than those of Section 02.01. In total, these reviews are estimated to take between 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> to 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br />.

73757-04 REFERENCES ASME Code Section III, Rules for Construction of Nuclear Facility Components.

ASME Code Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components.

Electric Power Research Institute, Steam Generator Management Program - Pressurized Water Reactor Steam Generator Examination Guidelines, Revision 7, October 2007 (ADAMS Accession: ML080450582)

Regulatory Guide 1.147, Inservice Inspection Code Case Acceptability - ASME Section XI Division 1.

10 CFR 50.55a, Codes and Standards 10 CFR 52.99, Inspection During Construction Issue Date: 09/23/19 4 73757

73757-05 PROCEDURE COMPLETION The goal of the inspections conducted in Sections 02.01 and 02.02 is to ensure that licensee has adequately implemented its PSI/ISI program by verifying that the records developed from its nondestructive examinations cover the scope of examination required by the ASME Code, the PSI program on file, and the regulations. Complete, clear, and reliable NDE data and records are essential when establishing a baseline for comparison with future inservice examinations.

This procedure is considered complete when the appropriate number of NDE records have been reviewed.

END

Attachment:

Revision History for IP 73757 Issue Date: 09/23/19 5 73757

Attachment 1 - Revision History for IP 73757 Commitment Accession Number Description of Comment Tracking Issue Date Training Required Resolution and Number Change Notice and Completion Closed Feedback Description of Change Date Form Accession Number (Pre-Decisional, Non-Public Information)

Initial issue to support inspections of operational programs described in Inspection Manual Chapter (IMC) 2504, Construction Inspection Program -

ML073440401 Inspection of Construction and Operational N/A 04/18/08 None ML070920429 Programs.

CN 08-012 Completed 4-year search of historical CNs, no commitments found.

ML13346A089 Revised to update references to the regulations, N/A 02/07/14 update ASME and other references, and to make None ML13346A088 CN 14-005 other editorial changes.

ML19241A348 Revised to make minor editorial changes regarding 09/23/19 sample selection and other typographical edits. None None CN 19-029 Issue Date: 09/23/19 Att1-1 73757