ML20196F818

Forwards RAI Re 990111 Request for Relief from Certain ASME Code ISI Requirements for Containment Liners.Response Requested within 30 Days from Date of Agreement

ML20196F818
Person / Time
Site:	Callaway
Issue date:	06/24/1999
From:	Donohew J NRC (Affiliation Not Assigned)
To:	Randolph G UNION ELECTRIC CO.
References
TAC-MA4598, NUDOCS 9906290313
Download: ML20196F818 (5)

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June 24,1999 y.

Mr. Garry L. Randolph .

Vice President and Chief Nuclear Officer Union Electric Company Post Office Box 620.

Fulton, MO 65251

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAl)- UNION ELECTRIC COMPANY - CALLAWAY PLANT, UNIT 1 (TAC NO. MA4598)

Dear Mr. Randolph:

i The NRC staff has reviewed Union Electric Company's request for relief from certain American Society of Mechanical Engineers (ASME) Code inservice inspection requirements for  !

containment liners submitted by letter dated January 11,1999. The staff has determined that additional information is needed to complete our review. The information required is detailed in

' the enclosure.

This information request was discussed with UE staff members on June 17,1999. A 30-day response time from this date was agreed upon.

if you have any questions, please contact me at (301) 415-3021.

ly,

)

d Jack N.

ono ew, Senior Project Manager, Section 2 Project Directorate IV & Decommissioning Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-483

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% # June 24, 1999 Mr. Garry L. Randolph Vice President and Chief Nuclear Officer Union Electric Company Post Office Box 620 Fulton, MO 65251

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI)- UNION ELECTRIC COMPANY - CALLAWAY PLANT, UNIT 1 (TAC NO. MA4598)

Dear Mr. Randolph:

The NRC staff has reviewed Union Electric Company's request for relief from certain American Society of Mechanical Engineers (ASME) Code inservice inspection requirements for containment liners submitted by letter dated January 11,1999. The staff has determined that additionalinformation is needed to complete our review. The information required is detailed in the enclosure.

This information request was discussed with UE staff members on June 17,1999. A 30-day response time from this date was agreed upon. ,

if you have any questions, please contact me at (301) 415-3021.

Sincerely,

) . 1 D

• Jack N. Donohew, Senior Projec Manager, Section 2 Project Directorate IV & Decommissioning Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosure:

Request for Additional Information cc w/ encl: See next page 1

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1 i

1

I Q l .

Callaway Plant, Unit 1 l

l cc: l Professional Nuclear Mr. Otto L. Maynard Consulting, Inc.

President and Chief Executive Officer 19041 Raines Drive Wolf Creek Nuclear Operating Corporation Derwood, Maryland 20855 Post Office Box 411 Burlington, Kansas 66839 John O'Neill, Esq.

Shaw, Pittman, Potts & Trowbridge Mr. Dan I. Bolef, President 2306 N. Street, N.W. Kay Drey, Representative Washington, D.C. 20037 j Board of Directors Coalition j for the Environment '

Mr. H. D. Bono 6267 Delmar Boulevard Supervising Engineer University City, Missouri 63130 Quality Assurance Regulatory Support j Union Electric Company Mr. Lee Fritz j Post Office Box 620 Presiding Commissioner l Fulton, Missouri 65251 Callaway County Court House 10 East Fifth Street U.S. Nuclear Regulatory Commission Fulton, Missouri 65151 Resident inspector Office 8201 NRC Road Mr. Alan C. Passwater, Manager j Steedman, Missouri 65077-1302 Licensing and Fuels Union Electric Company Mr. J. V. Laux, Manager Post Office Box 66149 Quality Assurance St. Louis, Missouri 63166-6149 Union Electric Company Post Office Box 620 Fulton, Missouri 65251 l Manager- Electric Department Missouri Public Service Cornmission 301 W. High Post Office Box 360 Jefferson City, Missouri 65102 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower & Pavilion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064

! l j Mr. Ronald A. Kucera, Deputy Director  !

l Department of Natural Resources j i

P.O. Box 176 ,

Jefferson City, Missouri 65102 i

, 4

s REQUEST FOR ADDITIONAL INFORMATION UNION ELECTRIC COMPANY CALLAWAY PLANT. UNIT 1 DOCKET NO. 50-483 By I.etter dated January 11,1999, Union Electric Company (UE) submitted for staff review a request for relief from certain ASME Code inservice inspection requirements for containment

. liners. Specifically, UE requested approval to use the 1998 Edition of ASME XI, Subsection IWE, "Requirerhents For Class MC and Metallic Liners of Class CC Components of Light-Water Cooled Plants,"in lieu of the 1992 Edition and 1992 Addenda of the ASME Code. The following questions are in regard to this request.

1. The 1998 Edition of the ASME Code (the code),Section XI generally refers to IWA-2000,

" Examination and inspection," when defining the general requirements for examinations to be performed, and for the qualification of examination personnel. The proposed altemative removes the IWA-2300 requirement to certify NDE personnel to CP-189. In addition, new Code examinations (General Visual and Detailed Visual) have been introduced in Subsection IWE of the 1998 Edition of the code. The definition of the new Code examinations has been left up to individual licensees, and a licensee would be allowed to define how personnel performing these examinations are to be qualified. To establish that the attemative provides an acceptable level of quality and safety, additional information on the general and detailed visual examination is needed. Please provide a description of your plant specific visual examination program, including attributes such as: Details of the owner-defined general visual examination, acceptance criteria, that will be used to examine containment liner surfaces, containment welds, pressure retaining bolting, moisture barriers, and dissimilar metal welds, etc.

2. UE letter dated January 11,1999, states "AmerenUE would employ a detailed visual examination such as a VT-1 or VT-3 depending on the conditions to assure structural integrity of the pressure boundary." Will the detailed visual examination incorporate existing VT-1 and VT-3 examination requirements? If so, will the personnel performing these examinations be VT-1 or VT-3 qualified? If existing VT-1 or VT-3 requirements will not be used, describe the detailed visual criteria used to address augmented examinations.

Please discuss how these examinations will provide an equivalent level of quality and safety - !

that is provided by the VT-1 and VT-3 examinations required by the 1992 Edition and '

Addenda.

3.~ Describe the qualification requirements for personnel performing containment visual examinations.

4. Describe the requirements for qualifying IWE visual examination procedures to be performed and how illumination and resolution requirements will be established and implemented consistently.

I ENCLOSURE

l

5. The IWE-2500(b) requirement to examine paint or coatings prior to removal has been eliminated from the 1998 Edition of the Code. Alternatives to this requirement have been found acceptable when adequate provisions exist, in either the licensee's containment inspection, repair / replacement, nuclear coatings, or ISI programs, to examine the base ,

metal for surface anomalies that may indicate underlying conditions which could challenge )

the structural lntegrity of containment. The examinations should be performed prior to I re-application of the coating, and should invoke detailed visual examinations (e.g., VT-1 or VT-3) or augmented ultrasonic examination, as necessary. In addition, the base metal examination should be performed by qualified inspection personnel. Please provide information addressing the base metal examination prior to paint or coating application.

6. UE letter dated January 11,1999, states that metallic liners of Class CC pressure retaining components are not subject to the same requirements as Class MC containments (IWE 3511.3,1998 Edition of the Code), therefore, the 10% material loss is not significant.

However, altemative acceptance criteria, based on the discontinuity effects of thickness differences and anchor spacing, have not been defined. Does UE intend not to document or perform supplemental examinations of the liner when loss of material has been detected?

Please describe when and how the supplemental examination (as required by IWE-3200) of the liner will be performed and the associated acceptance criteria that will be used. Please refer to NRC Information Notice 97-10, " Liner Plate Corrosion in Concrete Containments," I for relevant information.  ;

7, in the 1998 Edition of the Code, Examination Category E-G, " Pressure Retaining Bolting,"

has been removed from Table IWE-2500-1. The 1992 Edition required VT-1 visual examination of bolting when a connection was disassembled. The 1998 Edition requires a general visual examination, with no requirement when the joint is disassembled. As a basis, UE indicates that when bolted connections are disassembled, they would have a VT-1  ;

inspection and a bolt torque or bolt tension test performed as required by both ASME Code i Editions. In the comparison table, UE states, " bolted connections that are disassembled g anytime during the period are still subject to VT-3 inspections, which is unchanged from the i 1992 Code." It is not clear what examinations will be performed on disassembled bolted connections. If VT-1 examinations are not intended, please discuss how not performing a VT-1 visual examination of the bolting, when disassembled, provides an acceptable level of quality and safety.

8. Since the UE submittal dated January 11,1999, does not provide information regarding the examination of concrete surfaces and post-tensioning tendon system, the staff believes that UE plans to use the 1992 E&A of Subsection lWL supplemented by 10 CFR 50.55a for this purpose. Please confirm this. ,

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