ML20198M056
| ML20198M056 | |
| Person / Time | |
|---|---|
| Issue date: | 01/13/1998 |
| From: | Ashar H NRC (Affiliation Not Assigned) |
| To: | Bagchi G NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9801160179 | |
| Download: ML20198M056 (13) | |
Text
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.). { NUCLEAR REGULATORY COMMISSION WASHINGTON, a.C. SeeBS4WDt g*- .... January 13, 1998
. MEMORANDUM TO: Goutam Begchi, Chief I Civil Engineering and Geosciences Branch Division of Engineering THRU: Robert Rothman, Section Chief j
G.osci. noes S.ction Civil Engineering and Geosciences Branch
- acc6ptability of the generic explanation (justification) provided for each of the relief i requests. The following paragraphs explain the (hardship) issues related to the implementation of the Rule, and the generic justification for potential plant specific relief l reauests. The stafs remarks at the end of each issue are based on the discussions :
dudng the meeting and further review of the NEl/EPRI's detailed justification provided __ l st the_end of the meeting. However, the stafs remarks should not be construed as the blanket ent'orsement (or non endo;4ement) of the proposed relief requests. The merits ;
of the plant specific relief requests will be reviewed on a case by case basis. !
- 1. Seals and Gaskets: Table IWE 25001 (Examination Category E-D) of the 19g2 l E&A of Subsection IWE requires VT-3 examination of containment seals and i gaskets. The examination of seals and gaskets in most components require {
disassembly of the components. NEl/EPRI pointed out that the integrity of these ,
seals and gaskets would have been confirmed during the Appendix J testing, if
. they were found to have leakage, they would have been replaced. Thus, i L
NEl/EPRI want licensees to use the following standard words: .
, .' The visual examination of seals and gaskets in accordance with IWE-2500, l Table-2500-1 is a burden without any compensating increase in the level of ;
safety or quality.' The leak-tightness of seals and gaskets will be tested in !
accordance with 10 CFR 50, Appendix J."
. Stars remarks: The staff will make a determination on the plant spef.fic relief f requests based on the licensee's program (Appendix J, routine replacement, !
and/or maintenance) related to the integrity of the pressure retaining seals and i gaskets in the containment.
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i Section XI required the use of the American Society for Nondestructive Testing ;
(ASNT) recommended practice, SNT TC-1 A together with the additional l requirements in IWA 2000 of the Code, for qualification and certification of NDE i personnel. Licensees developed their procedures based on the recommended e practice. In the 1992 Edition, the Code adopted the use of CP 1891991. t developed by ASNT, together with some additional requirements ir. IWA 2300. !
CP 189 is a standard with mandatory requirements. NEIEPRI pointed out that l the licensees were using SNT-TC-1A for Class 1,2, and 3 components, and they l would have tp use CP-189 for containment NDE examinations. Thus, licensees !
have to have tWo separate programs for qualification and certification of NDE j personnel. The suggested standard wording by NElEPRI is: i
- Relief is requested in socordance with 10 CFR 50.55a(s)(3)(ii). Compliance :
with the specified requirements of this section (lWA-2300 of 1992 E&A) would result in hardship or unusual difficulty without a compsasating increase in the level of quality and safety. Examinations rog. ired by Subsections IWE and IWI.' j shall be conducted by personnel qualified and oortified to a written practice i based on SNT-TC 1A to the current Section XI Code of records for Subsections -
lWB, IWC, etc. If required, the written practice shall be updated to include VT- :
1C and VT 3C requirements, as specified by Paragraph IWL-2310(c) of the 1992 !
E&A of ASME Section XI."
l I
Staffs remarks: CP-18g is an ANSI approved consensus document. It is based on the experiences gained through the implementation of the recommended practice of SNT-TC-1 A. It would be effective to set up one program for all ,
components covered by 10 CFR 50.55a (Class 1,2 and 3 components, their l supports, r.nd Class CC and MC components). The staff would consider relief requests, if necessary, containing the use CP 18g in lieu of SNT-TC-1 A for Class 1,2,3 and their supports.
- 3. Remote VT of Class CC: lWL-2310 (1992 E&A) requires VT 3C examination for all accessible concrete areas.- For qualification of concrete examination ,
personnel and relevant examination attributes (maximum direct examination :
distance and minimum illumination requirements), it refers to IWA-2210. Table l IWA-22101 provides specific criteria for direct visual examination. NEIEPRI '
pointed out that for some containment buildings (the higher portion of the dome
. and the containment cylinder), the direct examination attributes would be difficult to satisfy without an extensive temporary scaffold system. The installation and i removal of these scaffolds would increase both worker radiation exposure and i personnel safety. Therefore, NElEPRI suggested the following standard words i for relief requesta: 1
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' Relief is requested in accordance with 10 CFR 50.55a(s)(3)(ii). Compliance ;
with the specified requirements of this section (lWL-2300 and IWA 2210 of the ;
igg 2 E&A) would result in hardship or unusual difficulty without a compensating ;
increase in the level of quality and safety. When performing remotely, the examinations required by Subsection lWL, Paragraph IWL 2510 (should be IWL !
2310), 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 provided that the conditions or indications for which the visual examinations performed con be detected at the chosen distance and illumination " !
l Stafs remarks: Based on a number of public comments on this subject, for i metal components, the final rule permitted the use of attemative lighting and resolution requirements for remote visual examination of the containment For remote examination of concrete conteinments, the staff will evaluate the !
adequacy of the altemative proposed on a plant specific basis. -
. requires that when paint or coatings are reapplied, the condition of the new paint i or coatings shall be documented in the preservios examination records. !
NEl/EPRI contends that the paint and coatings are not part of the containment :
pressure boundary, and the adequacy of reapplied coatings is verified through ;
the licensee's coating program. Recording of the condition of the reapplied paint !
or coatings in the preservice records will require an additional evaluation, and j would not increase the kvel of safety and quality of the containment. Therefore, 6 NEl/EPRI suggested the following standard words for relief requests: i
- Relief is requested in accordance with 10 CFR 50.55a(a)(3)(l). Coating ;
inspection programs currently provide an adequate level of quality and safety. ;
The paint and coatings in the containment will be examined in accordance with ,
the licensee's coating program, if degradation of the coating is identified, additional measures will be applied to determine if the containment pressure !
poundary is affected. Repairs to the primary containment boundary, if required, would be conducted in accordance with ASME Section XI Code rules."
7'
. Stars remarks: When paint or coatings are reapplied to ensure the integrity of the protected metal, the conditions need to be documented under IWE 2200(g).
. If the coatings are Service Level 1, the coatings will have to be design basis :
accident (DBA) quellflod under the conditions that they were applied (i.e. as ,
- repairs to an existing coating) or assumed to fail during a DBA. If the coatings are assumed to fall during a DBA, it must be demonstrated that the failure of
- these coatings will not adversely impact the proper functioning of containment system following a DBA. NEl/EPRI is in the process of preparing
- Guidelines on
G. Bagchl 5 the Elements of a Nuclear Safety Related Coatings Program." This guideline provides references for aspects of coatings maintenance including the DBA qualification testing requirements. ;
NEl/EPRI point out in this guideline, that not all utilities have a formal nuclear coatings program. Problems have been encountered at a number of facilities with inspection of the coatings in containment, and the impetus for the development of the guidelines is the absence of coating programe at nuclear facilities and, prior to this rule, no requironwnts to inspect the coatings in containment. The NRC staff has recently stated that safety related coatings are covered by the Maintenance Rule (10 CFR50.65). Based on these facts, the staff will deny such relief requests.
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- 5. VT Prior to Paint or Coating Removal: IWE 2500(b) (1992 E&A) requires that when paint or coatings tre to be removed, the paint or coatings shall be visually examined in accordance with Table 25001 prior to removal. NEl/EPRI points out that the application of this requirement when unrelated to Section XI repair or replacement is a burden without a compensating increase in quality or safety.
Therefore, NEl/EPRI suggests the following r,tandard sentences for the relief request:
- Relief is requested in accordance whh 10 CFR 50.55a(s)(3)(l). Coating inspection programs currently provide an adequate level of quality and safety.
The paint and coatings in the containment will be examined !n accordance with the licensee's coating program, if degradation of the coating is identified, additional measwes will be applied to determine if the containment pressure boundary is affected. Although repairs to paint or coatings are not subject to the repair / replacement rules of ASME Section XI, repairs to the primary containment boundary, if required, would be conducted in accordance with ASME Section XI Code rules."
Staffs remarks: Coating inspection programs do not exist at some nuclear utilities, and a number of failures of containment coatings have been identified by NRC staff. Since degradation of the coatings could lead to the failure of systems required for the safe shut-down of the reactor following a DBA, the staff will deny such relief requests.
- 6. VT-2 after Repair and Replacement or Modifications: IWE-5240 (1992 E&A) requires (through IWA-5240) a visuc' VT-2 examination fcllowing repair, replacement or modification of containments. VT-2 visual examinations are conducted to detect evidence of leakage from pressure retaining components with or without leakage collection systams. NEl/EPRI points out that Table.
2500-1 Examination Category E-P, Identifies the examination method of 10 CFR l-
G. Bagchl 6 50, Appendix J, and does not specifically identify a VT 2 visual examination.10 CFR 50, Appendix J provides requirements for testing as well as acceptable leakage criteria. These tests are performed by Appendix J " Test" personnel and utilize calibrated equipment to determine acceptability. Additionally,10 CFR 50.55a(b)(2)(x)(E) requires a general visual examination of the containment each period that would identify any structural degradation that rnay contribute to leakage. NEl/EPRI concludes that a VT-2 visual examin tion will not provide additional assurance of safety beyond that of current A' .adix J practices.
NEl/EPRI suggests the following standard sentences fui he relief request:
" Relief is requested in accordance with 10 CFR 50.5Sa(a)(3)(l). Pressure testing i in accordance with 10 CFR 50, Appendix J, provides an adequate level of quality. Testing shall be conducted in accordance with 10 CFR 50, Appendix J, in lieu of Paragraph IWE 5240 of ASME Section XI."
Staff's remarks: If the !!censee's containment inspection and testing program ;
incorporates the requirements of IWE-5221 (1992 E&A) for the pneumatic leakage test in accordance with Appendix J, Paragraph IV.A (irrespective of the Appendix J option selected) after repair, replacement or major modification, and the requirement of 10 CFR 50.55a(b)(2)(x)(E), the staff believes that the VT-2 visual exarNnation requirement of IWE-5240 is applicable for local areas affected by the activity. It is not necessary to subject the entire pressure retalning component to VT 2 visual examination.
- 7. Successive Examination after Repair: IWE-2420(b) and (c) (1992 E&A) requite that when component examination results require evaluation of flawo, evaluation of areas of degradation, or repairs in accordance with IWE 3000, 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 in accordance with Table IWE 2500-1, examination Category GC. NEl/EPRI points out that if the repair has restored the component to an acceptable condition, successive examinations are not warranted. Neither IWB-2420(b), IWC-2420(b), nor IWD 2420(b) (i.e., requirements for Class 1,2 and 3 components) requires a repair to be subjected to successive examination requirements. Thus, the successWe examination requirement of repairs in accordance with IWE-2420(b) and (c) constitute a burden without a compensating increase in qua!,cy or safety. NEl/EPRI suggest the following standard sentences for the relief request:
" Relief is requested in accordance with 10 CFR 50.55a(a)(3)(li). Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level cf quality and safety. Successive examinations in accordance with Paragraphs IWE 2420(b)
s G. Bagohl 7 .
and fWE 2420(c) are not required for repairs made in accordance with Article ;
IWA 4000." i i
t Staffs remarks: The staff believes that the successive examinations are required to monitor the flaws or degradations socepted by engineering ,
I evaluation (and not by repair). For repelred flaws evaluated and socepted by the requirements of IWA-4000, the staff does not believe that successive ,
l examinations are necessary.
- 8. Bolt Torque or Tension Testing: Table IWE 2500-1, Examination Category E-G i (1992 E&A) requires torque or tension testing on bolted connectic,ns that have not been disassembled and reassembled during the inspection interval. '
NEl/EPRI points out that the acceptable performance of bolted components during Type B testing (10 CFR 50, Appendix J) proves that the bolt torque or l tension remains adequate. Once a bolt is torquod or tensioned, it is not subject to dynamic loading that could cause it to experience significant change. l Verification of torque or tension values of bolted joints that are proven L acceptable by Appendix J testing and visual examination are adequate to '
demonstrate that the design function is met. NEl/EPRI suggests the following standard sentencos for the relief request:
I
- Relief is requested in accordance with 10 CFR 50.55a(a)(3)(ii). Compliance with the specified requirements of this section would result in hardship or
' i unut aal difficulty without a compensating increase in the level of quality and safety. The following examinations and tests required by Subsection IWE ensure the structuralintegrity and the leak tightness of Class MC pressure
-i retaining bolting, and, therefore, no additional altemative examinations are proposed:
9 (1) exposed surfaces of bolted connections sha!! be visually examined in accordance with requirements of Table 2500-1, Examination Category E-G, Pressure Retaining Botting, item E8.10; i
(2) bolted connections shall meet the pressure testing requirements of Table IWE 2500-1, Examination Category E-P, All Pressure Retaining Components, item Eg,40; and (3) a general visual examination of the entire containment once each inspection
. period shall be conducted in accordance with 10 CFR 50.55a(b)(2)(x)(E)."
Staffs remarks: For the pressure-unseating bolted connections, it is necessary
- to confirm that the bolts' pretension is maintained, if their adequacy is verified t
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G. Bagchl 8 during Appendix J testing, or during routine disassembling and reassembling, the staff believes that additional torque testing as per Table IWE 2500 (E8.20) is not '
needed.
Attachments: As stated (3)
PMNS G. Millman
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oc: G. Lainas S. Treby G. Mizuno A. Murphy L Shao J. Craig K. Cozens, NEl H. Stephen, EPRI W. Norris -
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January 13. 1998
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G. Bagchi during Appendix J testing, or during routine disassembling and reassembling, the staff believes that additional torque testing as per Table IWE 2500 (E8.20) is not needed.
Attachments: As stated (3) cc: G. Lainas S. Treby L. Shao H. Stephen, EPRI G. Mizuno A. Murphy J. Craig PMNS G. Millman W. Norris K. Cozens, NEl DISIBIBUTION: FILE CENTER PDR ECGB RF DOCUMENT NAME: G:MSHAR\NEIMTGNO.TES PA#100-11J1 To receive a cop.y of this document. Indicate in the box N = No co3y CaCopy w/o attachment / enclosure E Copy with attachment / enclosure l orric ECGB:DE 6 ECGB:DE EGB: g 7 ADD RAME HAS b P0' DELL RROTHMANM/ [GBAGCHI JSTh;NIDER DATE / / 4/9% / /9% / /2/9% ' \/3/9% l/11 /9%
OFFICIAL FILE COPY d 4 i
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PUBLIC EEETIND ANNOUNCEMENT DATA INPUT O Ntw (FeJds afr9 5%ied heednps s1p mawfetery, O Rote,ED NRC MEETING CONTACT NAME COMMERCLAL TELEPHONE F/ CSIMliE TELEPHONE (AnoWe Area Code) (IncluJe Area Cose)
Goutam Bagchi, Chief. ECGB/DE/NRR (301)415 2831 (301)415 2444 MEETING DATE($) AHD TIME (S)(up to three entries)
WEETING DAiE(4) (Use WMDAYYhvman WEETING TIME (8) (CJrcle an. orp.m)
FROM TO BEGINNING ENDING O sm O sm 1CV23/97 10/21/97 1:00 M pm 4.00 M p m.
O sm O sm
(-) p m.
O pm O sm O sm p pm p pm MEETING LODATION saow .. ifKlft muass Two White Flint 11545 Rockvit8. Pike A56sITGiilm -E W Ii5 1 TITS
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T-07A1 Rockvihe, Md.
PURPOSE OF MEETING (96 cnaracters eval /able)
To discuss the issues involved in the implementation of the Rule (10 CFR 50.55s Ostea 8/9/96).
COMMENTS (96 characters avaitebte) MEETING T ,4 Rule endorses Subsections fWE. lWL of Section XI of ASME B&PV Code. " C" " >
@ PUBLIC NON-D PUBLIC t>OCKET OR PROJECT NUMBLR anwor FACILITY NAME non-docket ORGANLZATIONS IN AT*iENDANCR NRC OFFICES / REGIONS OUTSIDE PARTICIPANT 8 (Officpe only - DO NOT use Olvisions, Branches, etc) (CompanyA) censes'AgencyNames croldabbreviations)
GLelnas, GBapchi, HAshar: NRR Kurt Cozens, NEl AMurphy, GMillman, WNorris: RES Hen y Stephen,IPRI
$1reby, GMauno: OGC Others from NEl and Ucenstees Af PROVAL -popur vd for rep +,r thai 10 caencar cars advare nota) sr u tua un uh, RETURN b5 FORM TO MEETING NOTICE COORDINATOR, MAIL STOP T 6 D8 /
FACSIMILE (301) 416-5130 TELEPHONE (301)41M09:1, E MAIL
- PMNS
- '"**W N isr. .mem e, prean.e >, see p eer, perms. es
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- & AGENDA i
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.' Introduction of Attendees NRC/NEI Review Agenda NEI
! Introduction and Purpose EPRI Containment Inspection Programs EPRI i
Request for Relief EPRI/ Licensees 4
- Discussion All j l Closing Comments NRC/NEI/EPRI
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