ML20206G645

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Safety Evaluation Authorizing Requests for Relief IR-032 to IR-035 & IR-037 to IR-040 Re Implementation of Subsections IWE & Iwl of ASME Section XI for Containment Insp
ML20206G645
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 05/03/1999
From:
NRC (Affiliation Not Assigned)
To:
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ML20206G643 List:
References
NUDOCS 9905100099
Download: ML20206G645 (24)
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Text

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NUCLEAR REGULATORY COMMIS8:ON WASHINGTON, D.C. snama m j

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION l 1

REQUESTS FOR REL!EF IMPLEMENTATION OF EQBSECTIONS IWE AND IWL OF ASME SECTION XI '

FOR CONTAINMENT INSPECTION ,

l FIRSTENERGY NUCLEAR OPERATING COMPANY '

PERRY NUCLEAR POWER PLANT. UNIT 1 DOCKET NO. 50-440

1.0 INTRODUCTION

By letter dated August 20,1998 (Ref.1), the licensee, FirstEnergy Nuclear Operating Company, submitted relief request Nos. IR-032 to IR-041, seeking relief from some of the ASME Code,Section XI. Subsections IWE and IWL requirements for the Perry Nuclear Power Plant, Unit 1.

These reliet requests apply to the inspections to be performed during the second 10-year inservice insp.ection (ISI) interval.

Pursuant to 10 CFR 50.55a(b) and (g), inservice inspection of containment must meet the requirements of the 1992 Edition,1992 Addenda of ASME Code,Section XI, Subsections IWE and IWL. Pursuant to 10 CFR 50.55a(g)(6)(ii)(B), the first period containment examinations must be completed by September 9,2001. Attematives to the requirements of 10 CFR 50.55a(g) may be authorized under 10 CFR 50.55a(a)(3), if (i) the proposed attemative provides an acceptable level of quality and safety, or (ii) compliance with the specific requirement of the Code would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

The staff, with the assistance of the Idaho National Engineering and Environmental Laboratory (INEEL), evaluated the information provided by the licensee. Based on its review, the staff adopts INEEL's conclusions and recommendations as provided in its Technical Letter Report (Enclosure 2), unless otherwise stated in the specific staff evaluation.

Enclosure 1 9905100099 990503 PDR ADOCK 05000440 P PDR

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2.0 EVALUATION Reauest for Relief No. IR-032 Code Reauirement: Table IWE-2500-1, Examination Category E-D, items E5.10 and E5.20 require VT-3 visual examination on 100% of each item. Seals and gaskets shall be examined for wear, damage, erosion, tear, surface cracks, or other defects that may violate the leak-tight integrity. Defective items shall be repaired or replaced.

Licensee's Proposed Altemative: In accordance with 10 CFR 50.55a(a)(3)(ii), the licensee proposed to perform a leak-tight integrity examination in accordance with Appendix J in lieu of the required VT-3 examinations. The licensee stated:

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"The leak-tightness of seals and gaQts will be tested in accordance with 10 CFR 50, Appendix J. The 10 CFR 50 Appendix J Type B testbg is performed at least once each 1

inspection interval." {

I Staff Evaluation The licensee proposes to use the existing 10 CFR Part 50, Appendix J, Type B testing as a verification of seal and gasket integrity, rather than disassembling the subject components for the sole purpose of examination.

1 Performing the VT-3 examinations on the subject gaskets and seals would require de- l terminating cables at electrical penetrations (if adequate cable slack is not available),

disassembly of the joint, removal and examination of the gaskets and seals, re-assembly of the joint, re-terminating the cables, post maintenance testing of the cables, and post maintenance Appendix J testing. The 1993 Addenda to ASME Code,Section XI has recognized that disassembly of joints for the sole purpose of performance of the visual examination is unwarranted. Requiring the licensee to disassemble components for the sole purpose of laspecting seals and gaskets would place a significant hardship on the licensee without a I compensating increase in quality and safety.

Therefore, the proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(ii) on the basis that compliance with the specific requirements of the Code would result in hardship without a compensating increase in the level of quality and safety. The staff finds that reasonable assurance of the functionality and integrity of the containment penetration seals and gaskets will be provided during the Type B testing required by 10 CFR Part 50, Appendix J.

Reouest for Relief No. IR-033.

Code Reauirement: IWA-2300 requires that examination personnel be qualified and certified in accordance with ANSI /ASNT CP-189.

Licensee's Proposed Alternative: In accordance with 10 CFR 50.55a(a)(3), the licensee proposed to use the qualification / certification requirements of the 1989 Code for IWE examination personnel. The licensee stated:

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" Examinations required by Subsection IWE shall be conducted by personnel qualified and certified to a written practice based on SNT-TC-1 A and the 1989 Edition of Section XI.

Visual examination personnel will receive specific training in conducting containment examinations."

Staff Evaluation Currently, the licensee conducts ISI examinations with personnel qualified and certified in accordance with the 1989 Edition of the ASME Code,Section XI for Class 1,2, and 3 components. The 1989 Edition requires the use of SNT-TC-1 A for the qualification and certification of NDE personnel. Therefore, to meet the 1992 Edition with the 1992 Addenda requirements, the licensee would need to develop a second program for qualifying and certifying NDE personnel for containment examinations. The majority of the containment examinations ,

required by Subsection IWE are VT-1 and VT-3 visual examinations. Volumetric examinations {

are required during the containment vessel augmented inspections. The licensee's current I method of qualifying and certifying NDE personnel is based on SNT-TC-1 A for all other Class 1, 2, and 3 components. Consequently, the staff agrees with the INEEL staff and finds that using NDE personnel qualified by the same means for containment examinations will not compromise the quality of the examination and will provide an acceptable level of quality and safety.

Therefore, the proposed attemative is authorized pursuant to 10 CFR 50.55a(a)(3)(i) on the basis that the licensee's proposed altemative provides an acceptable level of quality and safety.

Reauest for Relief No. IR-034 l

Code Reauirement IWE-2200(g), requires that when paint or coatings are reapplied, the l condition of the new paint or coating shall be documented in the preservice examination records.

1 Licensee's Proposed Altemative: The licensee proposed to perform visual examinations on the l reapplied paint and coatings using the PNPP nuclear coatings program. The licensee stated: I

" Reapplied paint and coatings on the containment vessel will be examined in accordance with PNPP's nuclear coatings program."

Staff Evaluation: In the basis for the relief request, the licensee states that the quality assurance requirements of Section 3 of ANSI N101.4, Quality Assurance forProtective Coatings Applied to NuclearFacilities, are imposed on the coating manufacturer through the procurement process.

Coating application procedures are developed based upon manufacturer's recommendations.

Section 6 of ANSI N101.4 is used as the guideline in the establishment of the inspection program, which requires stringent inspection of the entire completed coating work by qualified coating inspection personnel, as well as quality assurance documentation. Additionally, the licensee states that quality control inspection personnel are qualified to the provisions of Regulatory Guide 1.58, Rev.1. The licensee's nuclear coatings program provides a conservative approach to the inspection and documentation of new coatings. The staff finds the proposed attemative adequate for protecting the inside steel surface of the containment.

Therefore, the licensee's proposed attemative is authorized pursuant to 10 CFR 50.55a(a)(3)(i) on the basis that it provides an acceptable level of quality and safety.

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4 Reauest for Relief No. IR-035 Code Reouirement 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.

Licensee's Prooosed Alternative: The licensee proposed to verify the condition of the containment vessel base material through PNPP's nuclear coatings program prior to reapplication. The licensee stated:

'The condition of the containment vessel base material will be verified through PNPP's nuclear coatings program prict to the application of new paint or coating. If degradation is identified, additional measures will be used to determine if the containment pressure  ;

boundary is affected. Repairs to the primary ccntainment boundary, if required, will be '

conducted in accordance with ASME Section XI rules."

Staff Evaluation The licensee stated that coating application procedures are developed based upon manufacturer's recommendations, and that Section 6 of ANSI N101.4 is used as the guideline in the establishment of the inspection program. Section 6 of ANSI N101.4 requires I stringent inspection of the entire completed coating work by qualified coating inspection i personnel, as well as Quality Assurance Documentation. In response to the staff's question regarding an assurance of the base metalintegrity prior to the application of a new coating, the licensee revised its coating program (Ref. 2). The licensee has stated that, as part of the

' coatings program, it will verify the condition of the base material prior to application of new paint or coating, and, if adverse conditions, including cracks and corrosion are identified, a VT-1 examination, by qualified personnel, will be performed. l Based upon the licensee's verification of sound base material prior to application of new ,

coatings, the staff considers the proposed alternative, as stated by the licensee, adequate for j protecting the inside steel surface of containment, and will provide an acceptable level of quality and safety. Therefore, the licensees proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i) on the basis that it provides an acceptable level of quality and safety.

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' Reauest for Relief No. IR-036: Withdrawn (Ref. 2) )

l Reauest for Relief No. IR-037 i Code Reauirement: Paragraph IWE-2420(b) requires that when examination results require evaluation of flaws, 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. The l reexr>minations shall be performed in accordance with Examination Category E-C and at the schedule specified in the inspection requirements of IWE-2411 or IWE-2412.

I Paragraph IWE-2420(c) states that when the reexaminations required by Paragraph IWE- l 2420(b) reveal that the flaws, areas of degradation, or repairs remain essentially unchanged for l three consecutive inspection periods, the areas containing such flaws, degradation, or repairs l I

5-no longer require augmented examination in accordance with Table IWE-2500-1, Examination Category E-C.

Licensee's Prooosed Altemative: The licensee proposed an attemative to performing successive examinations on repairs. The licensee stated:

" Successive examinations in accordance with Paragraphs IWE-2420(b) and IWE 2420(c) will be performed on containment flaws or degraded areas which are accepted by engineering evaluation but not for repairs made in accordance with Article IWA-4000.

However, repair areas subject to accelerated degradation will still receive augmented examination in accordance with Table IWE-2500-1, Category E-C."

Staff Evaluation: IWB-2420(b), IWC-2420(b), and IWD-2420(b) do not require the successive inspection of repairs as required in IWE-2420(b). Additionally, when repairs are complete, IWA-4150 requires licensees to evaluate the suitability of the repair. When a repair is required because an item fails, the evaluation shall consider the cause of failure to ensure that the repair is suitable. Considering that the failure mechanism is identified and corrected as required and

. the repair receives preservice examinations, as required, the proposed attemative will provide reasonable assurance of structuralintegrity. Performance of the successive examinations presents an unnecessary burden on the licensee w'ihout, a compensating increase in safety.

Therefore, the licensee's proposed attemative is authorized pursuant to 10 CFR 50.55a(a)(3)(ii) on the basis that compliance with the specific Code requirements would result in hardship l without a compensating increase in the level of quality and safety.

Reauest for Relief No. IR-038 Code Reauirement: Examination Category E-G, item E8 20, requires a bolt torque or tension test of bolted connections each inspection interval.

Licensee's Prooosed Attemative: The licensee proposed to perform alternative examinations in

, lieu of the required bolt torque or tension test. The licensee stated:

"The following Subsection IWE examinations and tests will ensure the structural integrity and the leak-tightness of Class MC pressure retaining bolting, without the need for bolt torque or tension test:

"(1) Exposed surfaces of bolted connections will be visually examined in accordance witn the requirements of Table IWE-2500-1, Examination Category E-G, Pressure Retaining Bolting, item No. E8.10.

"(2) Bolted connections will meet the pressure test requirements of Table IWE-2500-1, l Examination Category E-P, All Pressure Retaining Components, item E9.40 (i.e., an Appendix J, Type B Test)."

Staff Evaluation: The Code requires that pressure-retaining botting that has not been disassembled and reassembled during the inspection interval be torque or tension tested. This  !

examination is used to aid in the determination that a leak-tight seal exists and that the structural !

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integrity of the subject bolted connecton is maintained. The licensee proposed to use the 10 CFR Part 50, Appendix J, Type B test as an attemative to the Code requirement to verify the integrity of penetrations with bolted connections.

The Appendix J, Type B test, to verify the containment pressure seal; and the Code-required visual examinations, to verify penetration integrity; will provide an acceptable level of quality and safety. Therefore, the licensee's proposed attemative is authorized pursuant to 10 CFR 50.55a(s)(3)(i).

Reauest for Relief No. IR-039 Code Requirement: IWA-2210 specifies the requirements associated with visual examinations, l includF) Wumination requirements and maximum examination distances for direct and remote VT-1, v ~ 2, and VT-3 examinations. Specifically, the Code requires minimum illumination of 50 Fe, maximum direct examination distances of 4 ft. and maximum procedure demonstration characters height of 0.105 inch to perform a direct VT-3 visual examination.

Licensee's Proposed Attemative: The licensee proposed an alternative to the requirements of lWA-2210 of the 1992 Addenda. As an attemative, the licensee proposed to use the requirements of the 1989 Edition of Section XI for VT-3 visual examinations. The licensee stated:

"VT-3 visual examinations will be performed in accordance with IWA-2210 of the 1989 Edition of Section XI. The examination procedure will be demonstrated capable of detecting the general conditions or indications for which the visual examination is performed."

l Staff Evaluation: Current VT-3 visual examination of IWB, IWC, IWD and IWF compor ents are  !

performed in accordance with the requirements of the 1989 Code Edition. For the licensee to meet the requirements of the f 992 Edition,1992 Addenda of IWA-2210 for visual examination of IWE components, two separate VT-3 examination techniques would have to be incorporated.

Considering that the 1989 Code requirements for visual examination are being used for all of the l other inservice inspection examination requirements, including the Class 1 VT-3 visual l examinations, the staff finds the licensee's proposed alternative provides an acceptable level of quality and safety, and therefore, it is authorized pursuant to 10 CFR 50.55a(a)(3)(i).

Reauest for Relief No 40 Code Reauirement IWE-2500(c)(3) requires that when ultrasonic thickness measurements are performed, one foot square grids shall be used. The nrSn and location of the grids shall be determined by the owner. Relief is requested from Wng o as foot square grids for augmented examination areas and the requirement to determine iM ::i.nimum wall thickness within each grid. .

Licensee's Prooosed Attemative: The licensee proposed to implement the use of Code Case N-605, Attemative to the Requirements ofIWE-2500(c) for Augmented Examination of Surface Areas, in lieu of the Code requirements. The licensee stated:

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" Code Case N-605 will be used to determine examination requirements for ultrasonic thickness measurements of areas requiring augrnented examination.

9 Staff Evaluation The attemative requirements of Code Case N-605, Altemative to the Requirements ofIWE-2500(c) for Augmented Examination of Surface Areas, is summarized in INEEL's TLR (Enclosure 2).

To meet the code requirements, the licensee would be required to perform essentially 100%

volumetric examination of each grid of the augmented examination area to determine the minimum wall thickness. For augmented examination areas, the requirement to perform 100%

volumetric examinations, may be unrealistic in terms of the size of the area to be examined and the time required to perform the examinations. Both time and size of the examinations to be

, performed would relate directly to the additional potential radiation exposure that plant personnel would be exposed to by 100% examination coverage. Subjecting the licensee to this requirement would result in a significant burden without a compensating increase in quality and safety. The staff agrees with the INEEL staff conclusion and finds that the altemative requirements of Code Case N-605 provide a sampling methodology similar to that of other Code requirements. Therefore, the licensee's proposed attemative will provide reasonable assurance of structuralintegrity and is authorized pursuant to 10 CFR 50.55a(a)(3)(ii). The use of this altemative is authorized for the second 10-year ISI interval, or until Code Case N-605 is approved for general use by reference in Regulatory Guide 1.147. After that time, the licensee must follow the conditions, if any, specified in the regulatory guide.

Reauest for Relief No. IR-041 Withdrawn (see Ref. 2)

References

1. Letter from Lee W. Myers (FENOC) to NRC, " Relief Requests for Class MC and CC Components for the Second Ten year Inspection Interval," August 20,1998.
2. Letter from Lee W. Myers (FENOC) to NRC, " Supplemental Information for Inservice Examination Relief Request IR-035 and Withdrawal of Relief Requests IR-036 and IR-041," April 1,1990.

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TECHNICAL LETTER REPORT i ON SECOND 10-YEAR INTERVAL INSERVICE INSPECTION I REQUESTS FOR RELIEF IR-032 THROUGH IR-041 EQB FirstEnerav EERRY NUCLEAR POWER PLANT DOCKET NUMBER: 50-440

1. INTRODUCTION l

By letter dated August 20,1998, the licensee, FirstEnergy, submitted Requests for Relief IR-032 through IR-041 seeking relief from the requirements of the ASME Code,Section XI, for the Perry Nuclear Power Plant during the second 10-year inservice inspection (ISI) interval. By letter dated April 1,1999, the licensee submitted a revision to Request for Relief IR-035, and withdrew Requests for Relief IR-036 and IR-041. The Idaho National Engineering and Ensironmental Laboratory (INEEL) staff's evaluations of these requests for relief are in the following section.

2. EVALUATION The information provided by FirstEnergy in support of the requests for relief from Code containment inspection requirements has been evaluated and the bases for disposition are documented below. The Code of record for the Perry Nuclear Power Plant, second 10-year ISI interval, which began November 18,1998, is the 1989 Edition of Section XI of the ASME Boiler and Pressure Vessel Code. The containment sections (IWE and IWL) of the Perry ISI program were developed in accordance with the requirements of the 1992 Edition,1992 Addenda, of Section XI, as required by 10 CFR50.55a(g)(6)(ii)(B). The following requests are seeking relief from the requirements of the 1992 Edition with the l

1992 Addenda. i A. Beauest for Relief No. IR-032. Examination Cateoorv E D. Item Numbers E5.10 and E5.20. Seals. Gaskets. and Moisture Barriars Code Reauiremer11: Examination Category E-D, items E5.10 and E5.20 require VT-3 visual examination on 100% of each item. Seals and gaskets shall be examined for wear, damage, erosion, tear, surface cracks, or other defects that may violate the leak-tight I integrity. Defective items shall be repaired or replaced.

Licensee's Prooosed Alternative: In accordance with 10 CFR 50.55a(a)(3)(ii), the licensee j proposed to perform a leak-tight integrity examination in accordance with Appendix J in l lieu of the required VI-3 examinations. I The licensee stated:

"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 I inspection interval."

Enclosure 1 I

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I Licensee's Basis for Proposed Altemative (as stated):

"10 CFR 50.55a was an6 ended in the Federal Register (61 'R 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: -

Each electrical penetration assembly manufactured by Westinghouse Electric Corporation consists of a steel transition weld ring factory-welded to header plate and field welded to the containmont vessel steel nozzle from inside containment. The electrical assembly includes conductor modules, supports, clamps, spherical washers, and o-ring seals, and leak test connections.- This assembly is welded to the transition weld ring. A single header plate design is used for the containment vessel penetration. All penetrations have double seals and are arranged to permit continuous or periodic leak detection by pressurization of the space between {

the seals. l l

"Each penetration assembly is provided with one pressure gauge and a hermetic packless j charging valve located inside the containment. This gauge and valve are designed for 1 continuous monitoring of the conductor and module seals. Each penetration is pressurized with ]

dry nitrogen to monitor integrity and to prevent the intrusion of moisture into the penetration.

l "These seals and gaskets cannot be inspected without disassembly of the penetration to gain j access to the seals and gaskets.

" Containment Personnel and Eauioment Hatches The Personnel and Equipment Hatches utilize an inner and outer door with gasket surfaces to ensure a leak-tight integrity. These hatches also contain other gaskets and seals such as the handwheel shaft seals, electrical penetrations, blank flanges, and equalizing pressure connections which require disassembly to gain access to the gaskets and seals.

" Seals and gaskets receive a 10 CFR 50 Appendix J 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 et electrical penetrations if enough cable slack is not available, disassembly of the joint, removal and examination of the seals and gaskets, re-assembly 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 tim Cont

  • ment Hatches would be similar except for the determination, re-termination, and testing of c A This imposes the risk that equipment could be damaged. The 1992 Edition,1993 Addenda, of Section XI recognizes that disassembly of joints to perform these examinations is not warranted. Note 1 for Examination Category E-D was modified to state that sealed or gasketed connections need not be disassembled solely for

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3-performance of examinations. However, without disassembly, most of the surface of the seats

.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 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 re tested. Repair or replacement of seals and gaskets is not subject to Code (1992 Edition,1992 Addenda) rules in accordance with Paragraph IWA-4111 (b) (5) of ASME Section XI.

"The visual examination of seals and gaskets in accordance with IWE-2500, Tat,!e IWE-2500-1 is a burden without any compensating increase in the level of safety or quality.

"The requirement to examine seals and gaskets 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 the 1998 Edition.

Evaluation: The Code requires that seals and gaskets on airiocks, hatches, and other devices be VT-3 visually examined once each interval to verify the condition of the gaskets and seals as well as to help assure containment leak-tight integrity.

The licensee proposes to use the existing 10 CFR 50, Appendix J, Type B testing as a ,

verification of seal and gasket integrity, rather than disassembling the subject components for l the sole purpose of examination. i Performing the VT-3 examinations on the subject gaskets and seats would require pre-maintenance Appendix J tests, de-terminating cables at electrical penetrations (if enough cable slack is not available), disassembly of the joint, removal and examination of the gaskets and seals, re-assembly of the joint, re-terminating the cables, post maintenance testing of the cables, and post maintenance Appendix J testing. The 1993 Addenda to Section XI has recognized that disassembly of joints for the sole purpose of performance of the visual examination is unwarranted. Requiring the licensee to disassemble components for the sole purpose of inspecting seals and gaskets would place a significant hardship on the licensee without a compensating increase in quality and safety. The INEEL staff believes that reasonable assurance of the functionality and integrity of the containment penetration seals and gaskets will be provided during the Type B testing required by the 10 CFR Part 50, Appendix J. Therefore, it is recommended that the proposed attemative be authorized pursuant to 10 CFR 50.55a(a)(3)(ii).

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4 B. Reauest for Relief No. IR-033. lWA-2300. Qualification of Nondestructive Examination Personnel Code Reouirement: IWA-2300 requires that examination personnel be qualified and certified in accordance with ANSI /ASNT CP-189.

Licensee's Prooosed Altemative: In accordance with 10 CFR 50.55a(s)(3), the licensee proposed to use the qualification / certification requirements of the 1989 Code for IWE examination personnel. The licensee stated:

" Examinations required by Subsection IWE shall be conducted by personnel qualified and certified to a written practice based on SNT-TC-1 A and the 1989 Edition of Section XI.

Visual examination personnel will receive specific training in conducting containment examinations."

Licensee's Basis for Prooosed Attemative (as stated):

"10 CFR 50.55a was amended 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 of Subsection lWA 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 Subarticle IWA-2300, to implement Subsection IWE duplicates efforts already in place for all other subsections. The Perry Nuclear Power Plant (PNPP) Inservice Examination Program for the second ten year inspection interval is written to meet the 1989 edition of Section XI.

Subarticle IWA-2300 of the 1989 Edition requires a written practice based on SNT-TC-1A, 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-1A are valid until recertification is required'.

"Upon completion of the second ten year inspection interval, PNPP's Inservice Examination Program will be updated to the Code, including CP-189 or other subsequent requirements, required by 10 CFR 50,55a. Until that time, Perry will continue to implement the requirements of IWA-2300 of the 1989 Edition of ASME Section (XI) for the ASME Class 1,2, and 3 components as weil as the containment examinations required by IWE.

"lWA-2300 of the 1992 Edition,1992 Addenda, of ASME Section XI requires that nondestructive examination personnel be qualified in accordance with ANSI /ASNT CP-189 as amended by IWA-2300 lWA-2313, 'NDE Methods Not listed in ANSI /ASNT CP-189,' states ' Personnel performing visual examinations or using other NDE methods not addressed in ANSI /ASNT CP-189 shall be qualified and certified to comparable levais of qualification as defined in ANSI /ASNT CP-189 and the Employers's written practice.'

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" Visual examination is the primary nondestructive examination method required by subsection IWE As noted above, CP-189 does not specifically address visual examination. This is also true of SNT-TC-1A. Therefore, the Code requires qualification and certification to comparable

- levels as defined in CP-189 or SNT-TC-1A (as applicable to the specific Edition and Addenda),

and the Employer's written practice. The requirements (i.e., experience, training hours, examinations, etc.) within CP-189 and SNT-TC-1 A, for those methods and levels that are comparable to visual examination, are virtually the same. 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. Therefore, the 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.

" Development and administration of a second, parallel qualification program would not enhance safety or quality and would serve as a burden, particularly in developing a second written practice, tracking of duplicate certifications, and unnecessary duplication of paperwork. This ,

duplication would also apply to NDE vendor programs. Updating to the 1992 Edition,1992

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Addenda, for Subsections lWB, IWC, etc., would require a similar request for relief. l i

"The requirements to comply with IWA-2300 hcVe 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 the 1998 Edition.

" Based on the above discussion, 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 unusual difficulty without a compensating increase in the level of quality and safety."

Evaluation: IWA-2300 of the 1992 Edition and Addenda of Section XI requires that examination personnel be qualified and certified in accordance with ANSI /ASNT CP-189. The licensee has proposed to conduct examinations with personnel qualified and certified to a written practice based on SNT-TC-1 A and the 1989 Edition of Section XI.

i Currently, the licensee conducts ISI examinations with personnel qualified and certified in accordance with the 1989 Edition of Section XI for Class 1,2, and 3 components. The 1989 Edition requires the use of SNT-TC-1A for the qualification and certification of NDE personnel.  ;

Therefore, the INEEL staff recognizes that to meet the 1992 Edition with the 1992 Addenda  !

requirements, the licensee would need to develop a second program for qualifying and certifying j NDE personnel for containment examinations. The majority of the containment examinations j required by Subsection IWE are VT-1 and VT-3 visual examinations. Volumetric examinations are required during the containment vessel augmented inspections. The licensee's current l method of qualifying and certifying NDE personnel is based on SNT-TC-1 A for all other Class 1,  !

2, and 3 components. Consequently, the INEEL staff believes that using NDE personnel l qualified by the same means for containment examinations will not compromise the quality of  :

the examination and will provide an acceptable level of quality and safety. l l

Therefore, based upon the above factors, it is recommended that the proposed altemative be f authorized pursuant to 10 CFR 50.55a(a)(3)(i). i I

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6-C. Reauest for Relief No. IR-034. IWE-2200(al Preservice Examination Reauirements on Containments with Reaoolied Paint or Coatinas Code Reauirement: lWE-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.

Licensee's Proposed Attemative: in accordance with 10 CFR 50.55a(a)(3)(i), the licensee proposed to perform visual examinations on the reapplied paint and coatings using the PNPP nuclear coatings program. The licensee stated:

" Reapplied paint and coatings on the containment vessel will be examined in accordance with PNPP's nuclear coatings program."

l Licensee's Basis for Proposed Attemative (as stated):

" Paint and coating are not part of the containment pressure boundary under current Code rules because they are not associated with the pressure retaining function of the component (Paragraph NE-2110(b)(5) of ASME Section ill). Neither paint nor coatings contribute to the structuralintegrity or leak tightness of the containment. Furthermore, the paint and coatings on the containment pressure boundary are not subject to Code rules for repair or replacement in accordance with IWA-4111(b)(5). The adequacy of applied coatings is verified through the inspections performed by PNPP's nuclear coating program.

"The coatings on the interior surface of the containment vessel are considered nuclear safety related. They are applied and inspected in accordance with PNPP's 10 CFR 50, Appendix B, Quality Assurance Program. This program is described in Chapter 17.2, PNPP's Updated Safety Analysis Report (USAR). USAR Chapter 1.8 endorses NRC Regulatory Guide 1.54, 6/77, Quality Assurance Requirements for Protective Coatings Applied to Nuclear Facilities.

The following requirements are applicab'e for coatings applied to the interior surface of the containment vessel:

"The quality assurance requirements of Section 3 of ANSI N101.4 applicable to the coating manufacturer are imposed on the coating manufacturer through the procurement process.

" Coating application procedures are developed based on the manufacturer's recommendations for application of the selected coating systems.

" Coating applicators are qualified to demonstrate their ability to satisfactorily apply coatings in accordance with the manufacturer's recommendations.

" Quality Control personnel perform inspections to verify conformance of the coating application procedures. Section 6 of ANSI N101.4 is used as a guideline in the establishment of the inspection program.

' Quality Control inspection personnel are qualified to the requirements of Regulatory Guide 1.58, Rev.1.

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' Documentation demonstrating conformance to the above is maintained.

"The general visual examination required by IWE is perfore ed each period. These periodic examinations identify evidence of flaking, blistering, peeling, discoloration, or other signs of coating distress that might be indicative of degradation of the containment structuralintegrity.

' " Recording the condition of reapplied coating in the preservice record does not substantiate the containment structuralintegrity. Should deterioration of the coating in the reapplied area occur, J

the area will require additional evaluation regardless of the preservice record. Recording the I condition of new paint or coating in preservice records does not increase the level of quality and safety of the containment.

"SECY 96-080, response to Comment 3.2 about IWE-2200(g) states, 'In the NRC's opinion, this 3

- does not mean that a visual examination must be performed with every application of paint or l coating. A visual examination of the topcoat to determine the soundness and the condition of i the topcoat should be sufficient.' This is currently accomplished though the inspections )

performed under PNPP's nuclear coatings program. (

"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 the 1998 Edition.

  • Based on the above discussion, relief is requested in accordance with 10 CFR 50,55a(a)(3)(i).

PNPP's nuclear coatings program currently provides an acceptable level of quality and safety."

Evaluation The licensee has proposed to perform paint and coating examinations in l' accordance with existing plant requirements rather than documenting the %ndition of the new paint or coating on the preservice examination report as required by IWE-2200(g).

The licensee states that the quality assurance requirements of Section 3 of ANSI N101.4, j Quality Assurance for Protective Coatings Applied to Nuclear Facilities, are imposed on the coating manufacturer through the procurement process. Coating application procedures are {

developed based upon manufacturer's recommendations. Section 6 of ANSI N101.4 is used as ,

the guideline in the establishment of the inspection program, which requires stringent inspection of the entire completed coating work by qualified coating inspection personnel, as well as Quality {

Assurance Documentation. ' Additionally, the licensee states that Quality Control inspection j personnel are qualified to the provisions of Regulatory Guide 1.58, Rev.1. It appears that the licensee's nuclear coatings program provides a conservative approach to the inspection and documentation of new coatings. The INEEL staff considers the proposed attemative, as stated by the licensee, acceptable for protecting the inside steel surface of the containment, and will

- provide an acceptable level of quality and safety. Therefore, it is recommended that the licensee's proposed alternative be autnorized pursuant to 10 CFR 50.55a(s)(3)(i). ,

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e D. Reauest for Relief No. IR-035. Revision 1. lWE-2500(bt Visual Examirge Reauirements of Paint or Coatinos Prior to Removal Code Reauirement: IWE-2500(b) requires that when paint or coatings w to b moved, the paint or coatings shall14 Wsually examined in accordance with Table W ?; 0-1 prior to removal.

Licensee's Proposed Altemative: In accordance with 10 CFR 50.55a(a)(3)(1), the licensee proposed to verify the condition of the containment vessel base material through PNPP's nuclear coatir;gs program prior to reapplication. The licensee stated:

"When paint or coatings are removed from the containment, the condition of the containment vessel base material will be verified through PNPP's nuclear coatings program prior to the application of new paint or coating. The nuclear coatings program describes the types of conditions that would warrant additional examination prior to 1

application of the new paint or coating. Examples of these conditions would be cracks or corrosion. If an adverse condition is identified, a VT-1 examination, performed by qualified personnel, will be used 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 rules."

Licensee's Basis for Proposed Altemative (as stated):

"10 CFR 50.55a was amended in the Federal Register (61 FR 41303) to require the use of the 1992 Edition,1992 Addenda, of Section XI when performing containment examinations. Paint and coatings are applied to containment to prevent rusting but they are not part of the containment pressure boundary under current Code rules because they are not associated with the pressure retaining function of the component (Paragraph NE-2110 (b)(5) of ASME Section Ill). Also, paint and coatings do not 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 originally applied and are not subject to ASME XI rules for repair or replacement in accordance with IWA-4111(b)(5). Degradation or discoloration of containment paint or coating materials may be an indicator of potential degradation of the containment pressure boundary. Additional measures would have to be empb>ed to determine the nature and extent of any degradation, if present. The application of ASME XI rules for removal of paint or coatings when unrelated to a Section XI repair or replacement activity is a burden without a

, compensatin0 increase in quality or safety.

"The requirement to inspect paint or 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 is scheduled to be published in the 1998 Edition. ~

" Based on the above discussion reliefis requested in accordance with 10 CFR 50 55a(a)(3)(i).

PNPP's nuclear coatings program currently provides an acceptable level of quality and safety."

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Evaluation: IWE-2500(b) requires that, paint or coatings be visually examined in accordance with Table IWE-2500-1 prior to removal. The INEEL staff believes that the intent of this Code requirement is to obtain evidence for potential structural degradation of the base material in the inservice condition prior to removal of the coating. The licensee has proposed to verify the condition of the containment vessel base material through PNPP's nuclear coatings program prior to the application of new paint or coating in lieu of performing a visual examination of paint i or coatings prior to removal. I The licensee stated that coating application procedures are developed based upon manufacturer's recommendations, and that Section 6 of ANSI N101.4 is used as the guideline in ,

the establishment of the inspection program. Section 6 of ANSI N101.4 requires stringent inspection of the entire completed coating work by qualified coating inspection personnel, as well as Quality Assurance Documentation. The licensee has further stated that, as part of the ,

coatings program, the licensee will verify the condition of the base material prior to application of new paint or coating, and, if adverse conditions, including cracks and corrosion are identified, a  ;

VT-1 examination performed by qualified personnel will be performed.

It appears that the licensees nuclear coatings program provides a conservative approach to the inspection and documentation of new coatings, including base metal examination prior to new coating application.

Based upon the licensee's verification of sound base material prior to application of new I coatings, the INEEL staff considers the proposed attemative, as stated by the licensee, acceptable for protecting the inside steel surface of containment, and will provide an acceptable l

!evel of quality and safety. Therefore, it is recommended that the licensees proposed attemative i be authorized pursuant to 10 CFR 50.55a(a)(3)(i). l E. Reauest for Relief No. IR-036. IWE-5000. System Pressure Tests Followino Reoair.

Modification. or Reolacement of Class MC or Class CC Components ]i Withdrawn by licensee, per letter dated April 1,1999.

F. Reauest for Relief No. IR-037. IWE-2420(b) And IWE-2420(c). Successive Examinations i After Repair l ,

Code Reauirement: Paragraph IWE-2420(b) requires that when examination results require evaluation of flaws, 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. The reexaminations shall be performed in accordance with Examination Category E-C and at the schedule specified in the inspection requirements of IWE-2411 or IWE-2412.

Paragraph IWE-2420(c) states that when the reexaminations required by Paragraph IWE-2420(b) reveal that the flaws, areas of degradation, or repairs remain essentially unchanged for three consecutive insp-ction periods, the areas containing such flaws,

..o degradation, or repairs no longer require augmented examination in accordance with Table IWE-2500-1, Examination Category E-C.

Licensee's Proposed Alternative: In accordance with 10 CFR 50.55a(a)(3)(ii), the licensee proposed an attemative to performing successive examinations on repairs. The licensee stated:

" Successive examinations in accordance with Paragraphs IWE-2420(b) and IWE-2420(c) will be l performed on containment flaws or degraded areas which are accepted by engineering l evaluation but not for repairs made in accordance with Article IWA-4000. However, repair areas j subject to accelerated degradation will still receive augmented examination in accordance with l Table IWE-2500-1, Category E-C."

Licensee's Basis for Proposed Altemative (as stated):

"10 CFR 50.55a was amended in the Federal Register (61FR41303) 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 conditions for continued service in accordance with the acceptance standards of Article IWE-3000. Paragraph IWA-4150 .

requires the Owner to conduct an evaluation of the suitability of the repair, including consideration of the cause of failure.

I "If the repair has restored the component to an acceptable condition, successive examinations I are not warranted. If the repair was not suitable, then the repair does not meet Code l 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 l 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 I with Paragraphs IWE-2420(b) and IWE-2420(c) constitutes a burden without a compensating increase in quality or safety. ]

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"In the resolution of public comment #3.3, the NRC stated, 'The purpose of IWE-2420(b) is to j manage components found to be acceptable for continued service (meaning no repair or i replacement at this time) as an Examination Category E-C component ... If the component had been repaired or replaced, then the more frequent examination would not be needed.'

"The requirement to perform successive examinations following repairs has been removed in

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the rewrite of Subsection IWE of ASME Section XI. This rewrite has been approved by ASME i and is scheduled to be published in the 1998 Edition. I

" Based on the above discussion, relief is requested in accordance with 10 CFR 50.55a(a)(3)(ii).

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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." j l

Evaluation: When the reexaminations required by IWE-2420(b) and IWE-2420(c) reveal that flaws, areas of degradation, or repairs remain essentially unchanged for three consecutive .

inspection periods, the areas no longer require augmented examination.

The licensee has proposed to perform successive examinations in accordance with Paragraphs IWE-2420(b) and IWE-2420(c) on containment flaws or degraded areas that are accepted by

. engineering evaluation but not for repairs made in accordance with Article IWA-4000. Repair areas subject to accelerated degradation will stil! receive augmented examination in accordance with Table IWE-2500-1, Category E-C.

lWB-2420(b), lWC-2420(b), and IWD-2420(b) do not require the successive inspection of repairs as required in IWE-2420(b). While the integrity of the containment is critical to nuclear plant safety, the INEEL staff believes that IWB (Class 1), lWC (Class 2), and IWD (Class 3) components are similarly as critical (in many cases more so) to plant safety. Therefore, the INEEl. staff believes that the requirement to perform successive examinations on repairs for IWE cocoonents is not justified when compared to IWB, IWC and IWD requirements.

Additionally, when repairs take place, IWA-4150 requires licensees to evaluate the suitability of the repair. When a repair is required because an item fails, the evaluation shall consider the cause of failure to ensure that the repair is suitable. Considering that the failure mechanism is identified and corrected as required and the repair receives preservice examinations, as required, the proposed alternative will provide reasonable assurance of structural integrity.

Performance of the successive examinations presents an unnecessary burden on the licensee without a compensating increase in safety. Therefore, it is recommended that the licensee's proposed alternative be authorized pursuant to 10 CFR 50.55a(a)(3)(ii).

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Reauest for Relief No. IR-038. Examination Cateaorv E-G. Item E8.20. Pressure-Retainina Boltina Code Reauirement: Examination Category E-G, item E8.20, requires a bolt torque or tension test of bolted connections each inspection interval.

Licensee's Proposed Attemative: In accordance with 10 CFR 50.55a(a)(3), the licensee proposed to perform attemative examinations in lieu of the required bolt torque or tension test. The licensee stated:

"The following Subsection IWE examinations and tests will ensure the structural integrity and the leak-tightness of Class MC pressure retaining bolting, without the need for bolt torque or tension test:

"(1) Exposed surfaces of bolted connections will be visua!!y examined in accordance with the requirements of Table IWE-2500-1, Examination Category E-G, Pressure Retaining Bolting, item No. E8.10. .

  • (2) Bolted connections will meet the pressure test requirements of Table IWE-2500-1 Examination Category E-P, All Pressure Retaining Components, item E9.40 (i.e., an

~ Appendix J, Type B Test)."

Licensee's Basis for Proposed Attemative (as stated):

  • 10 CFR 50.55a was amended in the Federal Register (61 FR 41303) to require the use of the 1992 Edition,1992 Addenda, of Section XI when performing containment examinations. Bolt l

I

s.e 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 detorqued and then retorqued or retensioned.

"Each penetration receives a 10 CFR 50 Appendix J Type B test in accordance with the testing frequencies specified in Appendix J. 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 torqued or tensioned, it is not subject to dynamic loading that could cause it to experience significant change. Appendix J testing and visual inspection is adequate to demonstrate that the design function is met. Torque or tension testing is not required on any other ASME Section XI, Class 1,2, or 3 bolted connections or their supports as part of the inservice inspection program.

"The requirement to perform bolt torque or tension tests has been removed in the rewrite of Subsection lWE of ASME Section XI. This rewrite has been approved by ASME and is scheduled to be published in the 1998 Edition."

Evaluation: The Code requires that pressure-retaining bolting that has.0.qt been disassembled and reassembled during the inspection interval be torque or tension tested. This examination is used to aid in the determination that a leak-tight seal exists and that the structural integrity of the subject bolted connecton is maintained. The licensee proposed to use the 10 CFR 50, Appendix J, Type B test as an alternative to the Code requirement to verify the integrity of penetrations with bcited connections.

Containment penetration integrity can be verified physically with the Code-required visual examinations, and mechanically using the Type B test. It is the opinion of the INEEL staff that bolt torque or tension testing does not provide assurance that a pressure seal exists at a containment' penetration. Type B testing of " pressure seating" connections, with the joint seal or gasket in compression, does not provide any verification of the bolt torque, but still verifies that a pressure seal exists. " Pressure unseating" connections rely on the tension of the bolting to l compress the seal or gasket and maintain a uniform seal. Therefore, an acceptable Type B test implies that the bolt tension is acceptable. In either case, the Type B test is the final verification of an acceptable pressure seal at the containment penetration and the VT-1 visua! examination verifies the integrity of the bolted connection.

The Appendix J, Type B test to verify the containment pressure seal and the Code-required

'tinual examinations to verify penetration integrity will provide an acceptable level of quality and safety; therefore, it is recommended that the licensee's proposed alternative be authorized pursuant to 10 CFR 50.55a(a)(3)(i).

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-13 H. Reauest for Relief No. IR-039. lWA-2210. Visual Examination Reauirements, of IWE Comoonents Code Reauirement: lWA-2210 specifies the requirements associated with visual examinations, including illumination requirements and maximum examination distances for direct and remote VT-1, VT 2, and W-3 examinations. Specifically, the Code requires minimum illumination of 50 Fe, maximum direct examination distances of 4 ft. and 3

maximum procedure demonstration characters height of 0.105 inch to perform a direct l

W-3 visual examination.

Licensee's Proposed Altemative: In accordance with 10 CFR 50.55a(a)(3), the licensee  !

proposed an alternative to the requirements of IWA-2210 of the 1992 Addenda. As an I attemative, the licensee proposed to use the requirements of the 1989 Edition of Section f XI for VT-3 visual examinations. The licensee stated: {

"VT-3 visual examinations will be performed in accordance with IWA-2210 of the 1989 Edition of Section XI. The examination procedure will be demonstrated capable of detecting the general conditions or indications for which the visual examination is performed." {

j Licensee's Basis for Proposed Altemative (as stated): .

"10 CFR 50.55a was amended 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 of the 1992 l Edition,1992 Addenda of Subsection IWA for containment examinations.

]

I "As noted in the Statements of Consideration for the rule change, for remote examination,10 '

CFR 50.55a(b)(2)(x)(B) was created 'to permit alternate lighting and resolution requirements.' It is intended to permit the lighting (illumination) and resolution (distance /use of a vision test chart) requirements of Table IWA-2210-1 to be relaxed Drovided that the conditions or indications for  !

which the visual examination is performed can be detected at the chosen distance and j illumination. This is recognition that the Table IWA-2210-1 VT-3 illumination and resolution requirements are not necessary to identify conditions that may effect the containment structural integrity. Additionally, when performing a VT-3 examination of coated areas, IWE-3510.2 requires the area to be inspected for evidence of flaking, blistering, peeling, discoloration, and other signs of distress. Therefore, any remote examination technique that could detect evidence of flaking, blistering, peeling, discoloration, and other signs of distress would be acceptable for coated surfaces.

"PNPP's containment vesselis coated. Approximately 23% of the accessible containment surface is within the 4 foot maximum examination distance necessary to perform a direct visual VT-3 examination in accordance with IWA-2210 of the 1992 Edition,1992 Addenda. The remainder must either be examined by remote examination or from scaffold. Where direct VT-3 examinations are performed, it is proposed that they be performed in accordance with the requirements of IWA-2210 of the 1989 Edition. This would be consistent with the VT-3 I

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w examination requirements for the Class 1,2 and 3 components in PNPP's Inservice Examination Program. The 1989 Edition does not prescribe specific lighting or resolution requirements, it only specifies that VT-3 examinations be performed to determine the general mechanical and structural condition of components and their supports. Physical displacements, corrosion, loose parts, debris and loss of integrity at bolted connections are given as examples.

Correspondingly, at PNPP, evidence of flaking, blistering, peeling, discoloration, and other signs of distress are considered to be the general conditions that would be relevant for coated surfaces.

"Therefore, performing direct VT-3 examinations in accordance with IWA-2210 of the 1989 Edition would meet the intent of IWE-3510.2 and would provide results similar to those achieved by remote examinations performed in accordance with 10 CFR 50.55a(b)(2)(x)(B).

Furthermore, ASME Subcommittee XI recognized that the requirements of the 1992 version of  ;

IWA-2210 were impractical to apply to containment structures and has eliminated the l requirement to comply with IWA -2210 in a recent rewrite of Subsection lWE. Table IWE-2500-1 l will no longer specify a VT-3 examination; rather it will specify a general visual examination. )

IWE-2310 will state that the Owner defines the requirements for examination of containment  !

surfaces. The rewrite was approved by ASME and is scheduled to be published in the 1998 l Edition.

"At PNPP, visual examinations using VT-3 certified personnel have proven to be adequate in l finding, recording and evaluating relevant containment or coating indications of degradation. l These examinations have been performed as a part of the 10 CFR 50, Appendix J, general visual examination of the accessible interior and exterior surfaces of the containment system for structural degradation that may affect the leak tight integrity. i "In order to meet the requirements of the 1992 Edition,1992 Addenda of IWA-2210, two i separate VT-3 examination techniques would have to be incorporated into PNPP's Inservice j Examination Program and examination procedures; one for VT-3 of IWB, IWC, IWD and IWF components and another for IWE components. The additional requirements for the direct VT-3 examinations of IWE components provide little additional assurance of structural integrity i

beyond that provided by performing VT-3 examinations in accordance with the 1989 Edition.

" Based on the above discussion, 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 unusua!

difficulty without a compensating increase in the level of quality and safety." i Evaluation: To comply with the expedited examination of containment requirements of 10 CFR 50.55a(g)(6)(ii)(B), licensees must visually examine Class MC and Metallic Liners of Class CC Concrete Components of Light-Water Cooled Plants per the requirements of IWE. Thess examinations are to be performed to the requirements of the 1992 Edition with the 1992 Addenda of ASME XI. The licensee has proposed the use of the IWA-2210 VT-3 requirements from the 1989 Edition of ASME Section XI in lieu of the 1992 Edition,1992 Addenda requirements.

Current VT-3 visual examination requirements on IWB, IWC, IWD and IWF components are in accordance with the requirements of the 1989 Code Edition. For the licensee to meet the requirements of the 1992 Edition,1992 Addenda of IWA-2210, two separate VT-3 examination j i

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F x.a techniques would have to be incorporated. Considering that the 1989 Code requirements for visual examination are being used for all of the other inservice inspection examination requirements, including the Class 1 VT-3 visual examinations, the INEEL staff believes that the licensee's proposed alternative provides an acceptable level of quality and safety and should be authorized pursuant to 10 CFR 50.55a(a)(3)(i).

l. Reauest for Relief No. IR-040. Use of Code Case N-605. Altemative to the Reauirements ofIWE-2500(c) for Auamented Examination of Surface Areas Code Reauirement: IWE-2500(c)(3) requires that when ultrasonic thickness measurements are performed, one foot square grids shall be used. The number and location of the grids shall be determined by the owner. Relief is requested from using one !

foot square grids for augmented examination areas and the requirement to determine the minimum wall thickness within each grid.

l Licensee's Proposed Altemative: In accordance with 10 CFR 50.55a(a)(3), the licensee proposed to implement the use of Code Case N-605, Altemative to the Requirements of IWE-2500(c) for Augmented Examination of Surface Areas, in lieu of the Code requirements. The licensee stated:

" Code Case N-605 will be used to determine examination requirements for ultrasonic thickness measurements of areas requiring augmented examination."

Licensee's Basis for Proposed Alternative (as stated):

"Subarticles IWE-2500(c)(3) and IWE-2500(c)(4) of the 1992 Edition,1992 Addenda of ASME Section XI requires that the minimum thickness within each one foot square grid of surface l areas requiring augmented examination be marked such that periodic reexamination of that location can be performed. Thickness readings are point of contact readings, so numerous readings may be necessary to identify the minimum thickness within each grid. Subsequent examinations of minimum thickness points only monitor those points which may not be the areas that are most susceptible to accelerated degradation.

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" Code Case N-605 provides an attemative to the one foot square grid area required by IWE-2500(c)(3). Code Case N-605 requires examination at the grid line intersections, the dimensions of which may not exceed 12 inches and may be as small as 2 inches.

'For sample areas greater than 100 square feet, Code Case N-605 reqijires that sufficient points  ;

be monitored to ensure at least a 95% confidence level that the thickness of the base metalis reduced by no more than 10% of the nominal plate thickness at 95% of the grid line intersections. Code Case N-605 also requires additional examinations when any measurements reveal that wsfl thickness has been reduced by more than 10% of the nominal plate thickness.

Evaluation: IWE-2500(c)(3) requires that when ultrasonic thickness measurements are performed, one foot square grids shall be used. The number and location of the grids shall be determined by the owner. Additionally, IWE-2500(c)(4), requires that ultrasonic measurements be used to determine the minimum wall thickness within each grid (this essentially requires

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100% volumetric examination coverage). The location of the minimum wall thickness shall be J marked such that periodic reexamination of that location can be performed. f i

The licensee has proposed the use of Code Case N-605, Altemative to the Requirements of j IWE-2500(c) for Augmented Examination of Surface Areas. Code Case N-605 requires that i when ultrasonic thickness measurements are performed, grids shall be used and ultrasonic  !

examinations shall be performed at the grid line intersections. Grid line spacing shall not I exceed 12 inches and need not be less than 2 inches. For examination areas less than 100 l square feet, grid line spacing shall be selected such that a minimum of 100 measurements are obtained, unless this requires selecting a grid line spacing of less than 2 inches. For l examination areas greater than 100 square feet, the Code Case requires that sufficient points j be monitored to ensure at least a 95% confidence level that the thickness of the base metalis reduced by no more than 10% of the nominal plate thickness at 95% of the grid line  ;

intersections. Additionally, when an ultrasonic measurement performed at a grid line intersection reveals that the thickness of the base metalis reduced by more than 10% of the nominal plate thickness, the minimum wall thickness shall be determined and located within each adjoining grid.

To meet the code requirements, the licensee would be required to perform essentially 100% I volumetric examination of each grid of the augmented examination area to determine the l

minimum wall thickness. On augmented examination areas, the requirement to perform 100% )

volumetric examinations, could prove to be unrealistic in terms of the size of the area to be examined and the time required to perform the examinations.' Both time and the size of the examina*Jons to be performed would relate directly to the additional potential radiation exposure

, that plant personnel would be exposed to by 100% examination coverage. Subjecting the licensee to this requirement would result in a significant burden without a compensating increase in quality and safety. The INEEL staff believes that the requirements of Code Case N-605 provide a sampling methodology similar to that of other Code requirements, and other erosion / corrosion monitoring programs used throughout the industry. Therefore, it is concluded that the licensee's proposed altemative will provide reasonable assurance of structural integrity and should be authorized pursuant to 10 CFR 50.55a(a)(3)(ii). The use of this alternative should be authorized for the second 10-year interval, or until Code Case N-605 is approved for general use by reference in Regulatory Guide 1.147. After that time, the licensee must follow the conditions, if any, specified in the regulatory guide.

J. Reauest for Relief No. IR-041. IWA-4000. Reoair/Reolacement Prooram Withdrawn by licensee, per letter dated April 1,1999. .

3. QQNCLUSION The INEEL staff has reviewed the licensee's submittal and concludes that for Requests for Relief Nos. IR-033, IR-034, IR-035, IR-038, and IR-039 the licensee's proposed alternatives will provide an acceptable level of quality and safety. Therefore, it is recommended that these proposed altematives be authorized for the second 10-year . interval pursuant to 10 CFR 50.55a(a)(3)(i). t i

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For Requests for Relief Nos. IR-032, IR-037, and IR-040, it is concluded that compliance with the Code requirements would result in a burden without a compensating increase in the level of quality and safety and that the licensee's proposed alternatives will provide reasonable assurance of structuralintegrity. Therefore, it is recommended that these proposed alternatives be authorized for the second 10-year interval pursuant to 10 CFR 50.55a(a)(3)(li).

Requests for Relief IR-036 and IR-041 were withdrawn by licensee, per letter dated April 1, 1999.

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