ML20198D716
| ML20198D716 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 12/15/1998 |
| From: | Passwater A UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ULNRC-3934, NUDOCS 9812230185 | |
| Download: ML20198D716 (6) | |
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,4 Union 0:ctric One Ameren Plaza i
1901 Chouteau Asenue N ikx 66149 St. Louis, MO 6066-6149 3K621.3222 December 15,1998 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 Gentlemen:
ULNRC-3934
[4 DOCKET NUMBER 50-483
]gg CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.
FACILITY OPERATING LICENSE NPF-30 REQUEST FOR RELIEF FROM CERTAIN AMERICAN SOCIETY OF MECHANICAL ENGINEERS CODE REQUIREMENTS FOR INSERVICE INSPECTION OF THE CALLAWAY PLANT UNIT 1 CONTAINMENT BUILDING Pursuant to the provisions of 10 CFR Part 50.55a (Codes and Standards),
AmerenUE (Union Electric Co.) hereby proposes alternatives to certain requirements of the American Society ofMechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, Subsection IWL,1992 Edition and 1992 Addenda.
In the Federal Register, dated August 8,1996, (Vol. 61, No.154,41303) the Nuclear Regulatory Commission (NRC) amended its regulations to incorporate by reference the AShE Code,Section XI, Subsection IWL,1992 Edition, through the 1992 Addenda. Subsection IWL is titled Requirements For Class CC Concrete Components ofLight-Water CooledPlants. Subsection IWL provides the requirements for inservice inspection of concrete containment components.
The Callaway Plant Unit I containment building is an ungrouted, post-tensioned concrete structure.
I Details concerning the requested relief are provided in Attachment 1. Attachment
/
1 requests relief from AShE,Section XI,1992 Edition,1992 Addenda, subarticle IWA-2210, " Visual Examination," which lists requirements for minimum illumination and maximum direct examination distance of Class CC components g Dg{}.
under paragraph IWL-2310, " Visual Examination and Personnel Qualification."
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When remotely performing the visual examinations required by Subsection IWL, Paragraph IWL-2510, the maximum direct examination distance specified in 9812230185 981215
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U.S. Nuclear Regulatory Commission December 15,1998 Page 2 Table IWA-2210-1 may be extended, and the minirnum iUumination requirements specified in Table IWA-2210-1 may be decreased provided that the techniques are qualified to detect the required conditions and indications.
The next scheduled containment building inspection for Callaway Plant is May 1,1999. Based on this date we request expedited review of this relief request in order to complete development of plans and procedures for the examinations required by Subsection IWL.
Very truly yours,
/
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/ rn G wm Alan C. Passwater Manager, Corporate Nuclear Services BFH/jdg Enclosure l
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STATE OF MISSOURI )
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1 Alan C.
Passwater, of lawful age, being first duly
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sworn upon oath says that he is Manager, Corporate Nuclear 1
Services for Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
By
- N Alan C.
Passwater l
Manager, Corporate Nuclear Services SUBSCR BED and sworn to before me this b[
day of Defin h'1
, 1998.
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M.'H.; Fletcher-Professional Nuclear Consulting, Inc.
~19041 Raines Drive
'Derwood, MD 20855-2432
. Regional Administrator U.S.: Nuclear Regulatory. Commission Region IV 611 Ryan Plaza Drive Suite 400 Arlington,~TX 76011-8064 Senior Resident Inspector
-Callaway Resident Office U.S. Nuclear Regulatory Commission 8201.NRC Road Steedman, MO 65077' Mr. Mel Gray (2)
Office of Nuclear Reactor Regulation U.S.. Nuclear Regulatory-Commission 1 White Flint,cNorth, Mail Stop 13E16 11555-Rockville Pike Rockville, MD -20852-2738 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 l
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.4 ULNRC 3934
' Attachment 1 RELIEF REQUEST ALTERNATIVE INSPECTION OF CONTAINMENT CONCRETE SURFACES SYSTEM (SVCOMPONENTS(S) FOR WHICH RELIEF IS REOUESTED; This relief request applies to the exterior portion of Callaway Plant's Unit 1 Containment Building constructed of concrete. The concrete portion of the Unit 1 Containment Building is subject to the rules and requirements for Inservice Inspection of Class CC (Concrete Containment) components, as applicable to IWL-2310, " Visual Examination and Personnel Qualification," and IWA-2210, " Visual Examinations."
CODE REOUIREMENTS FOR WHICH RELIEF IS REOUESTED:
American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV)
Code,Section XI,1992 Edition 1992 Addenda, requirement IWL 2310," Visual Examination and Personnel Qualification," and IWA-2210, " Visual Examinations" require specific minimum illumination and maximum direct examination distance for all concrete surfaces.
PROPOSED ALTERNATIVE:
Perform the concrete surface inspection remotely as required by Subsection IWL, Paragraph IWL-2510, extending the maximum direct examination distance, and reducing the minimum illumination requirements specified in Table IWA-2210-1, BASIS FOR RELIEF:
Title 10 CFR 50.55a was amended in the Federal Register (Vol. 61, No.154, 41303) to require the use of the ASME B&PV Code,Section XI,1992 Edition,1992 Addenda, when performing containment examinations. In addition to the requirements of Subsection IWL, the rulemaking also imposes the requirements of ASME B&PV Code,Section XI,1992 Edition,1992 Addenda, Subsection IWA for minimum illumination and maximum direct examination distance of Class CC (Concrete Containment) compomnts, specifically for the examination of concrete under Paragraph IWL-2510.
In accordance with IWA-2210, when remotely performing the visual examinations required by Subsection IWL, Paragraph IWL-2510, using remote techniques, the maximum direct examination distance specified in Table IWA-2210 may be extended, and the minimum illumination requirements specified in Table IWA-2210-1 may be decreased.
The change in examination and illumination requirements are allowed provided the remote examination procedure is demonstrated to resolve the required test chart characters in Table IWA-2210-1. In lieu of using the Table IWA-2210-1 test chart characters, the Responsible Engineer will use a combination of character and workmanship-based samples to determine the resolution required to ensure that indications ofinterest are detectable.
The Responsible Engineer will also identify the minimum size for indications ofinterest.
For remote visual examination, the procedure and equipment to be used will be demonstrated capable of resolving these minimum indications to the satisfaction of the Page1of2
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ULNRC 3934 Responsible Engineer. The record of demonstration will be available to regulatory authorities.
In order to conform with Section XI, IWA-2000 requirements for visual examination, Subsection IWL referenced VT-1 and VT-3 examinations, but designated them VT-IC and VT-3C to signify that these were examinations of a concrete structure. The original VT-1 and VT-3 examinations in Subsection IWA were designed for use on metal surfaces.
Flaw detection on metal surfaces requires the ability to resolve a much smaller indication than that required on concrete due to the small grain size of a metal surface in comparison to the much larger grain size of a cast concrete surface. The visual examination requirements for illumination levels and examination distances prevent the ability to demonstrate that the remote visual examination is equivalent to direct visual examination when performing examinations of concrete surfaces. The visual examination of a concrete containment is intended to uncover indications of significant conditions over a large vea in a generally benign environment.
In subsequent editions after 1992 of the ASME Code the requirements for a VT-lC examination have been replaced with a " detailed visual examination," and the requirements for a VT-3C examination have been replaced with a " general visual examination." The general visual examination of a concrete surface is performed under the direction of the Responsible Professional Engineer (RPE) to indicate the general structural condition of the containment. IWL-2000 references ACI-201.1 R-68 for guidelines used to determine concrete deterioration and distress. If the general visual examination detects any deterioration, the detailed visual examination is performed, again under the direction of the RPE, to determine the magnitude and extent of the deterioration. Also, alternative lighting and resolution requirements have been added to later editions of Subsection IWL to be used in lieu of the requirements ofIWA-2000. AmerenUE will follow the requirements of this version of the code and this relief request in the May,1999 examinations.
Reliefis requested in accordance with 10 CFR Part 50.55a(a)(3)(i). Inspecting the
- oncrete surfaces using increased distances and decreased illumination requirements, approved by the Responsible Engineer, will still allow the detection of flaws of a size sufficient to present a structural problem with the concrete structure.
IMPLEMENTATION SCHEDULE:
The IWL program plan, of which this relief request is a part, will be implemented prior to the next scheduled containment inspection beginning in May,1999.
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