ML20195J870
| ML20195J870 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 11/23/1998 |
| From: | Alexander J BOSTON EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LTR.2.98.151, NUDOCS 9811250093 | |
| Download: ML20195J870 (15) | |
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e Boston Edison Pilgrim Nuclear Power Station Rocky Hill Road November 23, 1998 Plymouth, Massachusetts 02360-5599 BECo Ltr. 2.98.151 J. F. Alexander Nuclear Assessment Group Manager U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Docket No. 50-293 License No. DPR-35 Request for Relief from the 1992 Edition 1992 Addenda of ASME Section XI, Subsection IWE Related Containment inspection Program Pursuant to 10 CFR 50.55a(a)(3) and 10 CFR 50.55afa)S(iii) 1 Pursuant to 10 CFR 50.55a(a)(3) and 10 CFR 50.55a(g)5(iii), Boston Edison Company (BECo) hereby requests the NRC approval of the attached Pilgrim Relief Requests PRR-E1 to E6 by April 1999, in support of the Refueling Outage (RFO) #12. RFO #12 is scheduled to commence on or about April 24,1999.
The attached re!!ef requests are based upon the EPRI Report GC-110698, " Containment inspection Program Guide," and NRC approved relief requests on the EPRI lead plant Davis Besse (Docket No. 50-346, TAC No. MA0414, " Safety Evaluation by the Office of Nuclear Reactor Regulation of Relief Request from Some of the ASME Section XI Requirements as Endorsed by 10 CFR 50.55a for Containment inspection," dated June 30, 1998). Accordingly, the attached Pilgrim Relief Requests PRR-E1 to E6 fall within the scope of the previously approved relief requests for containment inspection program on Docket No 50-346 for an expeditious NRC approval to support our RFO# 12 schedule.
The code requirement, bases of the relief requests, and proposed alternative for each case are l
described in the attached PRR-E1 to E6. These relief requests meet the requirement of 10 CFR I
50.55a(a)(3)(i), in that an acceptable level of quality and safety is maintained.
Should you wish further information on this request, please contact Walter Lobo of our Licensing staff at (508) 830-7940.
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Pilgrim Station IWE lst Interval Containment inspection Plan RELIEF REOUEST NUMBER: PRR-El REVISION 0 (Page 1 of 3)
COMPONENT IDENTIFICATION Seals and gaskets of Class MC pressure retaining components, Examination Category E-D, Item Numbers E5.10 and E5.20 of IWE-2500, " Examination and Pressure Test Requirements," Table IWE-2500-1, ASME Section XI,1992 Edition,1992 Addenda.
i CODE REOUIREMENT IWE-2500, Table IWE-2500-1 requires seals and gaskets on airlocks, hatches, and other devices to be visually examined, VT-3, once each interval to assure containment leak-tight integrity. Reliefis requested from performing the Code-required visual examination, VT-3, on the above identified metal containment seals and gaskets in accordance with 10 CFR 50.55a(a)(3)(ii).
BASIS FOR RELIEF 10 CFR 50.55a was amended, as cited in the Federal Register (61 FR 41303), to require the use of the 1992 Edition,1992 Addenda, of Section XI when performing containment examinations. The penetrations discussed below contain seals and gaskets:
Electrical Penetrations Electrical penetrations include electrical power, signal, and instrument leads with the penetrating sleeves welded to the primary containment vessel. Medium voltage (600V and 5kV) power penetrations at Pilgrim Station have primary seals made of alumina-ceramic materials. The low voltage power, control and instrumentation cable and coaxial cable penetrations use a bonding resin to maintain the leaktight integrity of the containment penetrating sleeves. Each penetration is pressurized to 45 psig with dry nitrogen to maintain and monitor integrity and to prevent the intrusion of moisture into the penetration.
These seals and gaskets cannot be inspected without disassembly of the penetration to gain access to the seals and gaskets.
1 Drywell Head. Drywell Head Manway. Drywell Personnel and Eauipment Hatches. CRD Service. Torus Access and Drywell Stabilizer Access Hatches j
The Personnel hatch utilizes an inner and outer door with gasket surfaces to ensure leak tight integrity. This hatch also contains other gaskets and seals such as handwheel shaft j
seals, electrical penetrations, blank flanges, and equalizing pressure connections which j
require disassembly to gain access to the gaskets and seals.
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l Pilgrim Station IWE ist Interval Containment Inspection Plan RELIEF REOUEST NUMBER: PRR.El l
REVISION 0 (Page 2 of 3)
The other hatches listed above utilize seals and/or gaskets in Appendix J testable joints to maintain leak tight integrity. Seals and gaskets receive a 10 CFR 50 Appendix J, Type B test. As noted in 10 CFR 50 Appendix J, the purpose of Type B tests is to measure leakage of containment or penetrations whose design incorporates resilient seals, gaskets, sealant compounds, and electrical penetrations fitted with flexible metal seal assemblies.
Examination of seals and gaskets require the joints, which are proven adequate through Appendix J testing. be disassembled. For electrical penetrations, this would involve a pre-maintenance Appendix J test, determination of cables at electrical penetrations if enough cable slack is not available, disassembly of the joint, removal and examination of the seals and gaskets, reassembly of the joint, re-termination of the cables if necessary, post maintenance testing of the cables, and a post maintenance Appendix J test of the penetration.
The work required for containment hatches and other boltedjoints would be similar except for the determination, re-termination, and testing of cables. This imposes the risk that equipment could be damaged. The 1992 Edition,1993 Addenda, of ASME Section XI recognizes that disassembly ofjoints to perform these examinations is not warranted. Note 1 in Examination Category E-D was modified in the 1995 Edition of ASME Section XI to state that sealed or gasket connections need not be disassembled solely for performance of examinations. However, without disassembly, most of the surface of the seals and gaskets would be inaccessible.
For those penetrations that are routinely disassembled, a Type B test is required upon final assembly and prior to start-up. Since the Type B test will assure the leak tight integrity of primary containment, the performance of the visual examination would not increase in the level of safety or quality.
Seals and gaskets are not part of the containment pressure boundary under current Code rules (NE-1220 (b)). When the airlocks and hatches containing these materials are tested in accordance with 10 CFR 50, Appendix J, degradation of the seal or gasket material would be revealed by an increase in the leakage rate. Corrective measures would be applied and the component retested. Repair or replacement of seals and gaskets is not subject to Code (1992 Edition,1992 Addenda) rules in accordance with Paragiaph IWA-4111(b)(5) of ASME Section XI.
The visual examination of seals and gaskets in accordance with IWE-2500, Table IWE-2500-1 is a burden without any compensating increase in the level of safety or quality.
Relief is requested from performing the Code-required visual examination, VT-3, on the above identified metal containment seals and gaskets in accordance with 10 CFR l
50.55a(a)(3)(ii). Compliance with the specified requirements of this section would result in
Pilgrim Station IWE lst Interval Containment Inspection Plan RELIEF REOUEST NUMBER: PRR El REVISION 0 (Page 3 of 3) hardship or unusual difficulty without a compensating increase in the level of quality and safety. Testing the seals and gaskets in accordance with 10 CFR 50, Appendix J will provide adequate assurance of the leak-tight integrity of the seals and gaskets.
The requirement to examine seals and gaskets has been removed in the rewrite of Subsection IWE of ASME Section XI which has been approved by ASME and was published in 1998, i
PROPOSED ALTERNATIVE EXAMINATIONS The leak-tightness of seals and gaskets will be tested in accordance with 10 CFR 50, Appendix J. The 10 CFR 50, Appendix J, Type B testing is performed at least once each inspection interval.
APPLICABLE TIME PERIOD Reliefis requested for the first ten year interval of the Pilgrim Station IWE Containment Inspection Program, beginning September,6,1998.
Pilgrim Station IWE lst Interval Containment Inspection Plan RELIEF REOUEST NUMBER: PRR-E2 REVISION 0 (Page 1 of 2)
COMPONENTIDENTIFICATION All components subject to examination in accordance with Subsection IWE of the 1992 Edition,1992 Addenda of ASME Section XI.
CODE REOUIREMENT Subarticle IWA-2300, " Qualification of Nondestructive Examination Personnel," requires qualification of nondestructive examination personnel to CP-189 -1991, " Standard for Qualification and Certification of. Nondestructive Testing Personnel," as amended by the ASME Section XI.
BASIS FOR RELIEF 10 CFR 50.55a was amended, as cited in the Federal Register (61 FR 41303), to require the use of the 1992 Edition,1992 Addenda, of Section XI, when performing containment examinations. In addition to the requirements of Subsection IWE, this also imposes the requirements Subsection IWA, General Requirements, of the 1992 Edition,1992 Addenda of Section XI. Subarticle IWA-2300, requires qualification of nondestructive examination personnel to CP-189, as amended by Subarticle IWA-2300.
A written practice based on the requirements of CP-189, as amended by the requirements of the Subarticle IWA-2300, to implement Subsection IWE duplicates efforts already in place I
for all other subsections. The Pilgrim Nuclear Power Station Third Ten Year Inservice Inspection Program is written to meet the 1989 Edition of Section XI. Subarticle IWA-2300 l
of this edition requires a written practice based on SNT-TC-1 A, " Personnel Qualification j
and Certification in Nondestructive Teoing," as amended by the requirements of Subarticle IWA-2300. Further, Subarticle IWA-2300 of the 1992 Edition,1992 Addenda, states,
" Certifications based on SNT-TC-1 A are valid until recertification is required."
Visual examination is the primary nondestructive examination method required by Subsection IWE. Neither CP-189 nor SNT-TC-1 A specifically includes visual examination.
Therefore, the Code requires qualification and certification to comparable levels as defined in CP-189 or SNT-TC-1 A, as applicable, and the employer's written practice. Ultrasonic thickness examinations may also be required by Table IWE-2500-1. These examinations are relatively simple and do not require an extensive training and qualification program.
l Therefore, use of CP-189 in place of SNT-TC-1 A will not improve the capability of-examination personnel to perform the visual and ultrasonic thickness examinations required by IWE.
Pilgrim Station IWE lst Interval Containment Inspection Plan RELIEF REOUEST NUMBER: PRR-E2 REVISION 0 (Page 2 of 2)
Development and administration of a second program would not enhance safety or quality and would serve as a burden, particularly in developing a second written practice, tracking of certifications, and duplication of paperwork. This duplication would also apply to Nondestructive Examination (NDE) vendor programs.
Updating to the 1992 Edition,1992 Addenda, for Subsections ~IWB, IWC, etc., would require a similar request for relief.
Relief is requested from the provisions of Subarticle IWA-2300, " Qualification of Nondestructive Examination Personnel in accordance with 10 CFR 50.55a(a)(3)(ii). Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
The requirement to comply with IWA-2300 has been removed in the rewrite of Subsechn IWE of ASME Section XI. This rewrite has been approved by ASME and was published in 1998.
PROPOSED ALTERNATIVE EXAMINATIONS Examinations required by Subsections IWE shall be conducted by personnel qualified and certified to a written practice based on SNT-TC-1 A and the 1989 Edition of ASME Section XI. Visual examination personnel will receive specific training in conducting containment examinations.
APPLICABLE TIME PERIOD Relief is requested for the first ten year interval of the Pilgrim Station IWE Containment Inspection Program, beginning September,6,1998.
Pilgrim Station IWE lst Interval Contain. ment Inspection Plan RELIEF REOUEST NUMBER: PRR-E3 REVISION 0 (Page 1 of 2)
COMPONENT IDENTIFICATION All Class MC, Paragraphs IWE-2420(b) and IWE-2420(c) successive examination requirements for components found acceptable for continued service.
CODE REOUIREMENT Paragraphs IWE-2420(b) and IWE-2420(c) of the 1992 Edition,1992 Addenda of ASME Section XI, requires that when component examination results require evaluation of flaws, evaluation of areas of degradation, or repairs in accordance with Article IWE-3000,
" Acceptance Standards," and the component is found to be acceptable for continued service, the areas containing such flaws, degradation, or repairs shall be reexamined during the next inspection period listed in the schedule of the inspection program of Paragraph IWE-2411,
" Inspection Program A," or Paragraph IWE-2412, " Inspection Program B," in accordance with Table IWE-2500-1, Examination Category E-C. Reliefis requested from the requirement of Paragraphs IWE-2420(b) and IWE-2420(c) to perform successive examination of repairs.
BASIS FOR RELIEF 10 CFR 50.55a was amended, as cited in the Federal Register (61 FR 41303), to require the use of the 1992 Edition,1992 Addenda, of Section XI, when performing containment examinations. The purpose of a repair is to restore the component to an acceptable condition for continued service in accordance with the acceptance standards of Article IWE-3000.
Paragraph IWA-4150, " Verification of Acceptability," requires the owner to conduct an evaluation of the suitability of the repair including consideration of the cause of failure.
If the repair has restored the component to an acceptable condition, successive examinations are not warranted. If the repair was not suitable, then the repair does not meet code requirements and the component is not acceptable for continued service. Neither Paragraph IWB-2420(b), Paragraph IWC-2420(b), nor Paragraph IWD-2420(b) requires a repair to be subject to successive examination requirements. Furthermore, if the repair area is subject to accelerated degradation, it would still require augmented examination in accordance with Table IWE-2500-1, Examination Category E-C.
The successive examination of repairs in accordance with Paragraphs IWE-2420(b) and IWE-2420(c) constitutes a burden without a compensating increase in quality or safety.
Pilgrim Station IWE ist Interval Containment Inspection Plan RELIEF REOUEST NUMBER: PR R-E3 l
REVISION 0 (Page 2 of 2)
Relief is requested in accordance with 10 CFR 50.55a(a)(3)(ii). Compliance with the i
specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
The requirement to perform successive examinations following repairs has been removed in the rewrite of Subsection IWE of ASME Section XI. This rewrite has been approved by ASME and was published in 1998.
l PROPOSED ALTERNATIVE EXAMINATIONS l
No alternative examinations are proposed as successive examinations in accordance with l
Paragraphs IWE-2420(b) and IWE-2420(c) are not required for repairs made in l
accordance with Article IWA-4000.
APPLICABLE TIME PERIOD Reliefis requested for the first ten year interval of the Pilgrim Station IWE Containment Inspection Program, beginning September,6,1998.
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RELIEF REOUEST NUMBER: PRR E4 REVISION 0 (Page 1 of 2) i COMPONENT IDENTIFICATION Class MC pressure retaining bolting.
i CODE REOUIREMENT ASME Section XI,1992 Edition with the 1992 Addenda, Table IWE-2500-1, Examination Category E-G, Pressure Retaining Bolting, Item E8.20. Reliefis requested from ASME Section XI 1992 Edition,1992 Addenda, Table IWE-2500-1 Examination Category E-G, Pressure Retaining Bolting, Item E8.20. Table IWE-2500-1 requires a bolt torque or tension i
test on bolted connections that have not been disassembled and reassembled during the L
inspection interval.
BASIS FOR RELIEF 10 CFR 50.55a was amended, as cited in the Federal Register (61 FR 41303), to require the use of the 1992 Edition,1992 Addenda, of ASME Section XI when perfonning containment examinations. Bolt torque or tension testing is required on bolted connections that have not been disassembled and reassembled during the inspection interval. Determination of the -
torque or tension value would require that the bolting be un-torqued and then re-torqued or retensioned.
- Each containment penetration receives a 10 CFR 50 Appendix J Type B test in accordance with the specified testing frequencies. As noted in 10 CFR 50 Appendix J, the purpose of Type B tests is to measure leakage of containment penetrations whose design incorporates resilient seals, gaskets, sealant compounds, and electrical penetrations fitted with flexible metal seal assemblies. The performance of the Type B test itself proves that the bolt torque or tension remains adequate to provide a leak rate that is within acceptable limits. The torque or tension value of bolting only becomes an issue if the leak rate'is excessive. Once a bolt is i
torqued or tensioned, it is not subject to dynamic loading that could cause it to experience significant change. Appendix J testing and visualinspection is adequate to demonstrate that the design function is met. Torque or tension testing is not required for any other ASME Section XI, Class 1,2, or 3 bolted connections or their supports as part of the inservice
- inspection program.
Relief is requested in accordance with 10 CFR 50.55a(a)(3)(ii). Un-torquing and subsequent re-torquing (or other torque testing methods) of bolted connections which are verified not to
1 Pilgrim Station IWE ist Interval Containment Inspection Plan RELIEF REOUEST NUMBER: PRR.E4 REVISION 0 (Page 2 of 2) experience unacceptable leakage through 10 CFR 50 Appendix J, Type B testing results in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
The requirement to perform bolt torque or tension tests has been removed in the rewrite of Subsection IWE of ASME Section XI which has been approved by ASME and was published in 1998.
1 PROPOSED ALTERNATE EXAMINATION (S) 1 The following examinations and tests required by Subr im IWE ensure the structural integrity and the leak-tightness of Class MC pressure o o eg bolting, and, therefore, no i
additional alternative examinations are proposed:
Exposed surfaces of bolted connections shall be visually examined in accordance with requirements of Table IWE-2500-1, Examination Category E-G, Pressure Retaining Bolting, Item No. E8.10, and Bolted connections shall meet the pressure test requirements of Table IWE-2500-1, Examination Category E-P, All Pressure Retaining Components, Item E9.40.
APPLICABLE TIME PERIOD Reliefis requested for the first ten year interval of the Pilgrim Station IWE Containment Inspection Program, beginning September,6,1998.
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RELIEF REOUEST NUMBER: PRR-E5 REVISION 0 (Page 1 of 2) i COMPONENT IDENTIFICATION All Class MC, Subarticle IWE-2500(b) visual examinations per Table IWE-2500-1 of painted or coated containment components prior to removal of paint or coatings.
CODE REOUIREMENT(S)
ASME Section XI,1992 Edition,1992 Addenda, Subarticle IWE-2500(b) requires that when paint or coatings are to be removed, the paint or coatings shall be visually examined in accordance with Table IWE-2500-1 prior to removal.
BASIS FOR RELIEF 10 CFR 50.55a was amended, as cited in the Federal Register (61 FR 41303), to require the use of the 1992 Edition,1992 Addenda, of ASME Section XI when perfonning containment examinations. Paint and coatings are not part of the containment pressure boundary under current Code rules as they are not associated with the pressure retaining function of the component (Paragraph NE-2110 (b)(5) of ASME Section III). The containment interior surfaces at Pilgrim Station are painted to prevent rusting and are exposed to an inert atmosphere at all times except during refuel or maintenance outages. The exterior surfaces of the torus, vent system and drywell head are also painted and exist in a controlled atmosphere (secondary containment). Neither paint nor coatings contribute to the structural integrity or leak tightness of the containment. Furthermore the paint and coatings on the containment pressure boundary were not subject to Code rules when they were originally applied and are not subject to ASME Section XI rules for repair or replacement in accordance with IWA-4111(b)(5). Degradation or discoloration of the paint or coating materials on containment would be an indicator of potential degradation of the containment pressure boundary. Additional measures would have to be employed to determine the nature and extent of any degradation,if present. The application of ASME Section XI rules for removal of paint or coatings when unrelated to an ASME Section XI repair or replacement activity is a burden without a compensating increase in quality or safety.
Reliefis requested in accordance with 10 CFR 50.55a(a)(3)(i). PNPS Specifications C-98A, M530 and M531 currently control containment coating activities at PNPS and provide an adequate level of quality and safety as they conform to Regulatory Guide 1.54, ANSI Standards N101.4 and N5.12. All containment coating work at PNPS is performed by qualified vendors approved to provide coating services subject to 10 CFR 50 Appendix B controls on Special Processes. Additionally, the General Visual Walkdown required by
i Pilgrim Station IWE ist Interval Containment Inspection Plan RELIEF REOUEST NUMBER: PRR-E5 REVISION 0 (Page 2 of 2) subsection IWE to be performed once every inspection period will provide an adequate periodic assessment of the condition of containment coatings.
The requirement to inspect coatings prior to removal has been removed in the rewrite of Subsection IWE of ASME Section XI. This rewrite has been approved by ASME and was published in 1998.
PROPOSED ALTERNATIVE EXAMINATIONS The condition of the containment vessel base material will be verified prior to the application of new paint or coating as required by PNPS Specifications C-98A, M530 and M531. If degradation is identified, additional measures will be applied to determine if the containment pressure boundary is affected. Repairs to the primary containment boundary, if required, will be conducted in accordance with ASME Section XI Code rules.
APPLICABLE TIME PERIOD Relief is requested for the first ten year interval of the Pilgrim Station IWE Containment Inspection Program, beginning September,6,1998.
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RELIEF REOUEST NUMBER: PRR.E6 REVISION 0 (Page 1 of 2)
COMPONENT IDENTIFICATION All Class MC, Subarticle IWE-2200(g), preservice examination requirements of reapplied painted or coated containments.
l CODE REOUIREMENT ASME Section XI,1992 Edition,1992 Addenda, Subsection IWE-2200(g) requires that when paint or coatings are reapplied, the condition of the new paint or coating shall be documented in the preservice examination records. Reliefis requested from the requirement to perform a preservice inspection of new paint or coatings.
j BASIS FOR RELIEF Paint and coatings are not part of the containment pressure boundary under current Code rules as they are not associated with the pressure retaining function of the component (Paragraph NE-2110 (b)(5) of ASME Section III). Neither paint nor coatings contribute to the structural integrity or leak tightness of the containment. Furthermore, the paint and coatings on the containment pressure boundary were not subject to Code rules when they were originally applied and are not subject to ASME Section XI rules for repair or replacement in accordance with IWA-4111(b)(5). The adequacy of applied coatings is verified through the inspections and tests performed by qualified vendors approved by Boston Edison to provide coating services at PNPS subject to 10 CFR 50 Appendix B controls on Special Processes. Primary containment coating activities at PNPS are currently controlled by Boston Edison Specifications C-98A, M530 and M531 which conform to Regulatory Guide 1.54 and ANSI Standards N101.4 and N5.12. Additionally, the General i
Visual Walkdown required by subsection IWE to be performed once each inspection period will provide an adequate periodic assessment of the condition of containment coatings.
Recording the condition of reapplied coating in the preservice record does not substantiate the containment structural integrity. Should deterioration of the coating in the reapplied area occur, the area will require additional evaluation regardless of the preservice record.
Recording the condition of new paint or coating in the preservice records does not increase the level of quality and safety of the containment.
In SECY 96-080, " Issuance of Final Amendment to 10 CFR Section 50.55a to Incorporate i
by Reference the ASME Boiler and Pressure Vessel Code (ASME Code),Section XI, Division 1, Subsection IWE and Subsection IWL," dated April 17,1996, response to Comment 3.2 about IWE-2200(g) states, "In the NRC's opinion, this does not mean that a
Pilgrim Station IWE lst Interval Containment Inspection Plan RELIEF REOUEST NUMBER: PRR-E6 REVISION 0 (Page 2 of 2) visual examination must be performed with every application of paint or coating. A visual examination of the topcoat to determine the soundness and the condition of the topcoat should be sufficient." This is currently accomplished through the inspections required by Specifications C-98A, M530 and M531 and perfonned by qualified vendors approved to provide coating services at PNPS subject to 10 CFR 50 Appendix B controls.
Relief is requested in accordance with 10 CFR 50.55a(a)(3)(i). The inspections and tests performed in accordance with PNPS Specifications C-98A, M530 and M531 provide an adequate level of quality and safety since the specifications conform to Regulatory Guide 1.54 and ANSI Standards N101.4 and N5.12. The requirement to perform a preservice examination when paint or coatings are reapplied has been removed in the rewrite of Subsection IWE of ASME Section XI. This rewrite has been approved by ASME and is scheduled to be published in 1998.
PROPOSED ALTERNATE EXAMINATIONS Reapplied paint and coatings on the containment vessel will be examined in accordance with the requirements of PNPS Specifications C-98A, M530 and M531. Although repairs to paint or coatings are not subject to the repair / replacement rules of ASME XI (Inquiry 97-22), repairs to the primary containment boundary, if required, will be conducted in accordance with ASME Section XI Code rules.
APPLICAHLE TIME PERIOD Reliefis requested for the first ten year interval of the Pilgrim Station IWE Containment Inspection Program, i
beginning September,6,1998.
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