ML20209B483
| ML20209B483 | |
| Person / Time | |
|---|---|
| Site: | San Onofre, 05000363  |
| Issue date: | 06/25/1999 |
| From: | Scherer A SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-MA1778, TAC-MA1779, NUDOCS 9907070134 | |
| Download: ML20209B483 (23) | |
Text
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- h SOUIHERN CAllFORNIA
$O A. Edward Scherer E
EDISON E
g.u,,
An EDISON INTLRNATIONAL~ Company June 25,1999 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555
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Subject:
' Docket Nos. 50-361 and 50-362 j
Second Ten-Year interval inservice inspection Program San Onofre Nuclear Generating Station
' Units 2 and 3
Reference:
Letter from James W. Clifford (NRC) to Harold B. Ray (SCE) Dated November 6,1998;
Subject:
Issuance of Amendment for San Onofre Nuclear Generating Station, Unit No. 2 (Tac No. MA1778) j and Unit No. 3 (Tac No, MA1779)
Gentlemen:
j This letter requests NRC approval of six (6) Relief Requests (RRs) from AS'ME l
- Code requirements for containment inservice inspection examinations. These 6 RRs, provided as Enclosures 1 through 6, are the following:
l Enclosure Relief Reauest Summarv Descriotion 1
RR E-2-03 Visual Exam, Class MC Seals and Gaskets 2
RR E-2-04 Preservice Exams, Class MC Paint and Coatings 3
RR E-2-05 Visual Exam, Class MC Paint and Coatings 4
RR E-2-06 Successive Exams, Class MC Components 5
RR E-2-07 Pressure Retaining Bolting 6
RR E-2-08 Visual Exams, Class CC Concrete Components k
RRs E-2-03 through E-2-08 are needed at San Onofre Units 2 and 3 as a result of the change to 10 CFR 50.55a (Federal Register (61 FR 41303) August 8, l.
1996) to require licensees to meet Subsections IWE and IWL of the ASME
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i Code. RRs E-2-03 through E-2-08 seek relief from specific requirements of
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5 Subsections IWE and IWL in accordance with 10 CFR 50.55a (a)(3) because the existing program at San Onofre Units 2 and 3 provides an acceptable level Dh 9907070134 990625 PDR ADOCK 05000361 e
PDR _
P. O. Ilox I28 San Clemente, CA 92674-0128
'949-368-7501 Fax 949-368-7575
Document Control Desk June 25,1999 of quality and safety, or because compliance with the ASME Code requirement results in a hardship or unusual difficulty without a compensating increase in the level of quality and safety. The specific reasons are provided in each individual request. It is noted that all 6 of these relief requests have been approved by the i
NRC for another plant.
By the referenced letter the NRC approved 10 CFR 50 Appendix J, Option B l
testing for San Onofre Units 2 and 3. Therefore, discussions of Appendix J testing in the enclosed relief requests should be understood to mean that testing J
frequency and methods at San Onofre Units 2 and 3 comply with Appendix J, Option B requirements.
These relief requests are needed to support the Unit 2 Cycle 11 refueling outage, therefore, your timely approval would be appreciated.
If you have any questions or need addition information regarding this matter, please feel free to contact me or Jack Rainsberry at (949) 368-7420.
Sincerely, 7T Enclosures cc:
E. W. Merschoff, Regional Administrator, NRC Region IV J. A. Sloan, NRC Senior Resident inspector, San Onofre Units 2 & 3 L. Raghavan NRC Project Manager, San Onofre Units 2 and 3
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Relief Request RR E-2-03 i
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RR-E-2-03 Page 1 of 4 1.0 RELIEF REQUEST NO. RR-E-2-Q3 1.1 SYSTEM / COMPONENT (S) FOR WHICH RELIEF IS REQUESTED Seals and gaskets of Class MC pressure retaining components, Examination Category E-D, item Numbers E5.10 and E5.20 of IWE-2500, " Examination and Pressure Test Requirements," Table IWE-2500-1, ASME Section XI,1992 Edition,1992 Addenda.
1.2 CODE REQUIREMENT (S)
IWE-2500, Table IWE-2500-1 requires seals and gaskets on airlocks, hatches, and other devices to be visually examined, VT-3, once each interval to assure containment leak-tight integrity.
1.3 CODE REQUIREMENT FROM WHICH RELIEF IS REQUESTED Relief is requested from performing the Code-required visual examination, i
VT-3, on the above identified metallic liner of containment seals and gaskets.
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1.4 BASIS FOR REllEF 10 CFR 50.55a was amended, as cited in the Federal Register (61 FR 41303),
to require the use of the 1992 Edition,1992 Addenda, of Section XI when performing containment examinations. The penetrations discussed below contain seals and gaskets:
Electrical Penetrations Electrical penetrations use a header plate attached to a containment penetration nozzle flange with redundant 0-rings between the header plate and flange face. Modules through which electrical conductors pass are installed in the header plate. The two electrical penetration assembly configurations used for all electrical conductors passing through the shell wall are the canister-type and the modular (pancake) type assemblies. The canister-type assemblies are used for the medium voltage power circuits,6900 volts. The modular-type assemblies are used ior the low-voltage power circuits,600 volts and below.
The penetration canister is a hollow cylinder bolted at one end to the steel penetration sleeve flange and closed at both ends with sealed header plate assemblies. The canister is provided with a test plug on the outside of the containment to allow test pressurization of the penetration assembly.
RR-E-2-03 Page 2 of 4 The modular-type assemblies consist of a header plate in which a group of small, interchangeable, modular penetrations are fitted. The header plate mates with the flange welded to the nozzle, which is bolted to the penetration sleeve flange. Double silicone O-rings provide a monitorable seal between the I
header plate and the flange. The header plate is provided with a monitoring hole on the outside of the containment to allow test pressurization of the penetration assembly. The method of sealing the electrical penetration assemblies depends upon the type of cable and connector assembly involved.
In general, three types are used:
Type 1 -
Medium voltage power,6900 volts (canister-type assembly) e Type 2 -
Low-voltage power and control,600 voits and below (modular-type assembly)
Type 3 -
Instrumentation, thermocouple leads, coaxial and other special wires (modular-type assembly)
Type 1 penetrations consist of insulated conductors that are passed through the header plates and are potted to effect a pressure seal. Mechanical splices within the potting compound provides gas stops. High-voltage insulating bushings and seals also are used to provide the barrier.
Type 2 and 3 penetrations have conductors that are passed through the modules and are potted to effect a pressure seal. Epoxy-encapsulated splices within the potting compound provides gas stops. The module is fitted into the header plate with the O-rings in each pressure barrier acting to make the 4
necessary pressure seal.
1 Each penetration is pressurized with ' dry nitrogen to maintain and monitor integrity and to prevent the intrusion of moisture into the penetration.
These seals and gaskets cannot be inspected without disassembly of the penetration to gain access to the seals and gaskets.
Containment Personnel and Emergency Escaoe Airlocks. and Eauioment Hatch The Personnel and Emergency Escape Airlocks utilize an inner and outer door with gasket surfaces to ensure leak tight integrity.
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RR-E-2-03 Page 3 of 4 These airlocks 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 seats. The Equipment Hatch utilizes a double gasket door to ensure leak tight integrity.
. Seals and gaskets receive a 10 CFR 50 Appendix J, Type B test. As noted in 10 CFR 50 Appendix J, the purpose of Type B tests is to measure leakage of containment or penetrations whose design incorporates resilient seals, gaskets, sealant compounds,
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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 a
pre-maintenance Appendix J test, disconnection of cables at electrical penetrations if enough cable slack is not available, disassembly of the joint, removal and examination of the seals and gaskets, reassembly of the joint, re-termination of the cables if necessary, post maintenance testing of the cables, and a post maintenance Appendix J test of the penetration.
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The work required for the Containment airlocks and hatch would be similar except for the disconnection, re-termination, and testing of cables. This imposes the risk that equipment could be damaged. The 1992 Edition,1993 Addenda, of ASME Section XI recognizes that disa:sembly of joints to perform these examinations is not warranted.
Note 1 in Examination Category E-D was modified in the 1995 Edition of ASME Section XI to state that sealed or gasket connections need not be disassembled solely for performance of examinations. However, without disassembly, most of the surface of the 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 result an increase in the level of safety or quality.
When the airlocks and hatch containing seals and gaskets are tested in accordance with 10 CFR 50, Appendix J, degradation of the seal or gasket material would be revealed by an increase in the leakage rate. Corrective measures would be applied and the component retested. Repair or replacement of seals and gaskets is not subject to Code (1992 Edition,1992 Addenda) rules in accordance with Paragraph IWA-4111(b)(5) of ASME Section XI.
RR-E-2-03 Page 4 of 4 I
The Equipment Hatch is opened during outages when necessary. Prior to final closure, the hatch gaskets and sealing surfaces are inspected for damage, cracks, cuts, or cleanliness that may affect sealing integrity. The airlock door gaskets are also inspected and cleaned prior to final closure after containment entries are performed.
Prior to establishing containment integrity, the airlocks and hatch are tested to confirm their sealing capability.
The visual examination of seals and gaskets in accordance with IWE-2500, Table IWE-2500-1 is a burden without any compensating increase in the level of safety or quality.
Relief is requested 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. Testing the seals and gaskets in accordance with 10 CFR 50, Appendix J will provide adequate assurance of the leak-tight integrity of the seals and gaskets.
The requirement to examine seals and gaskets has been removed in the rewrite of Subsection IWE of ASME Section XI. This rewrite has been approved by the ASME and published in July 1998.
1.5 ALTERNATIVE EXAMINATION l
The leak-tightness of seals and gaskets will be tested in accordance with 10 CFR 50, Appendix J.
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i Relief Request RR E-2-04 I
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RR-E-2-04 L
Page 1 of 3 2.0 RELIEF REQUEST NO. RR-E-2-04 L
l 2.1 HyJTEM/ COMPONENT (S) FOR WHICH RELIEF IS REQUESTED ~
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. All Class MC, Subarticle IWE-2200(g), preservice examination requirements of t
L reapplied painted or coated containment.
2.2 CODE REQUIREMENT (S)
ASME Section XI,1992 Edition,1992 Addenda, Subsection 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.
l 2.3 CODE REQUIREMENT FROM WHICH RELIEF IS REQUESTED Relief is requested from the requirement to perform a preservice inspection of new paint or coatings.
2.4 BASIS FOR RELIEF Paint and coatings are not part of the containment pressure boundary under current Code rules as they do not provide the pressure retaining functions of components (Paragraph NE-2110 (b)(5) of ASME Section Ill). The paint and coatings on the containment pressure boundary were not subject to Code rules when they were originally applied and are not subject to ASME Section XI rules for repair or replacement in accordance with IWA-4111(b)(5). Inside containment coatings are controlled by procedure (S023-1-1.11.1) at San Onofre. The coating procedure covers the removal, preparation, application and inspection of qualified l
coatings for use inside the containment and is performed in accordance with an
. NRC approved quality assurance program. Specific requirements include:
1.
Coating materials are pre qualified to Design Basis Accident l
environmental conditions according to ANSI N101.2 and the appeable l
portions of ANSI N5.12.
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- A coating application procedure was developed based on the manufacturer's recommendation for application of the selected coating system.
3.
Quality Assurance requirements are enforced for the coating materials and the application procedure.
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Personnel performing preparation and application are qualified by the successful completion of a qualification guide on coatings inside the containment (Ref. ANSI N101.4).
5.
Quality Control personnel perform inspections to verify conformance to i.
the coating application procedure.
6.
Documentation demonstrating conformance to the coating proceduro is -
maintained.
Recording the condition of reapplied coating in the preservice record does not substantiate the containment structural integrity. Should deterioration of the coating in the reapplied area occur, the area will require additional evaluation regardless of the preservice record. Recording the condition of new paint or coating in !he preservice records does not increase the level of quality and safety of the containment.
In SECY 96-080, " Issuance of Final Amendment to 10 CFR Section 50.55a to incorporate by Reference the ASME Boiler and Pressure Vessel Code (ASME Code),Section XI, Division 1, Subsection IWE and Subsection IWL," dated April 17,1996, response to Comment 3.2 about IWE-2200(g) states, "In the NRC's i
opinion, this does not mean that a visual examination must be performed with every application of paint or coating. A visual examination of the topcoat to determine the soundness and the condition of the topcoat should be sufficient."
This is currently accomplished through the coating inspections performed after reapplication per the San Onofre Nuclear Generating Station (SONGS) coating i
procedure for inside containment.' Also, the condition of the coatings is examined periodically in accordance with 10 CFR 50.65, " Requirements for Monitoring i
Effectiveness of Maintenance at Nuclear Power Plants," and during the general visual examination required by IWE. These periodic examinations will identify evidence of flaking, blistering, peeling, discoloration, or other signs of coating distress which might be indicative of degradation of the containment structural integrity.
1 Relief is requested in accordance with 10 CFR 50.55a(a)(3)(i). The San Onofre i
Nuclear Generating Station (SONGS) coating program for inside containment currently provides an adequate level of quality and safety.
The requirement to perform a preservice examination when paint or coatings are reapplied has been removed in the rewrite of Subsection lWE of ASME Section 4
XI. This rewrite has been approved and published by ASME in July 1998.
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RR-E-2-04 Page 3 of 3
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2.5 ALTERNATE EXAMINATIONS Reapplied paint and coatings on the containment vessel will be examined in accordance with the SONGS coating program for inside containment. Although 3
l repairs to paint or coatings are not subject to the repair / replacement rules of ASME XI (Inquiry 97-22), repairs to the primary containment boundary, if required, would be conducted in accordance with ASME Section XI Code rules.
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Relief Request RR E-2-05 i
RR-E-2-05 Page 1 of 2 l
'3.0 REllEF REQUEST NO. RR-E-2-05 3.1 SYSTEM / COMPONENT (S) FOR WHICH RELIEF IS REQUESTED
. All Class MC, Subarticle IWE-2500(b) visual examinations per Table IWE-2500-1 of painted or coated containment components prior to removal of paint or coatings.
3.2 CODE REOUIREMENT(S)
ASME Section XI,1992 Edition,1992 Addenda, Subarticle IWE-2500(b) requires that when paint or coatings are to be removed, the paint or coatings shall be visually examined in accordance with Table IWE-2500-1 prior to removal.
3.3 CODE REQUIREMENT FROM WHICH RELIEF IS REQUESTED Subarticle IWE-2500(b) requires that when paint or coatings are to be removed, the paint or coatings shall be visually examined in accordance with Table IWE-2500-1 prior to removal.
3.4 BASIS FOR RELIEF 10 CFR 50.55a was amended, as cited in the Federa/ Register (61 FR 41303), to require the use of the 1992 Edition,1992 Addenda, of ASME Section XI when performing containment examinations. Paint and coatings are not part of the containment pressure boundary under current Code rules as they do not provide the pressure retaining functions of components (Paragraph NE-2110 (b)(5) of ASME Section 111). The interiors of containment are painted to prevent corrosion.
Neither paint nor coatings contribute to the structural integrity or leak tightness of the containment. Furthermore, the paint and coatings on the containment pressure boundary were not subject to Code rules when they were originally applied and are~not subject to ASME Section XI rules for repair or replacement in accordance with IWA-4111(b)(5). Degradation or discoloration of the paint or coating materials on containment would be an indicator of potential degradation of the containment pressure boundary. Additional measures would have to be employed to determine the nature and extent of any degradation, if present. The application of ASME Section XI rules for removal of paint or coatings when unrelated to an ASME Section XI repair or replacement activity is a burden without a compensating increase in quality or safety.
RR-E-2-05 Page 2 of 2 Relief is requested in accordance with 10 CFR 50.55a(a)(3)(i). The SONGS coating program for inside containment currently provides an adequate level of quality and safety.
The requirement to inspect coatings prior to removal has been removed in the rewrite of Subsection IWE of ASME Section XI. This rewrite has been approved and published by ASME in July 1998.
3.5 ALTERNATE EXAMINATIONS The condition of the containment vessel base material will be verified prior to the I
application of new paint or coating as required by the SONGS coating procedure for inside containment. If degradation is identified, additional measures will be applied to determine if the containment pressure boundary is affected. Repairs to the primary containment boundary, if required, will be conducted in accordance with ASME Section XI Code rules.
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RR-E-2-06 Page 1 of 2 4.0 REllEF BERVEST NO. RR-E-2-06 4.1 SYSTEM / COMPONENT (S) FOR WHICH RELIEF IS REQUESTED All Class MC, Paragraphs IWE-2420(b) and IWE-2420(c) successive examination requirements for components found acceptable for continued service.
4.2 CODE REQUIREMENT (S)
Paragraphs IWE-2420(b) and IWE-2420(c) of the 1992 Edition,1992 Addenda of ASME Section XI, requires that when component examination results require evaluation of flaws, evaluation of areas of degradation, or repairs in accordance with Article IWE-3000, " Acceptance Standards," and the component is found to be-acceptable for continued service, the areas containing such flaws, degradation, or-repairs shall be reexamined during the next inspection period listed in the schedule of the inspection program of Paragraph IWE-2411, " Inspection Program
- A," or Paragraph IWE-2412, " Inspection Program B," in accordance with Table IWE-2500-1, Examination Category E-C.
4.3 CODE REQUIREMENT FROM WHICH RELIEF IS REQUESTED
' Relief is requested from the requirement of Paragraphs IWE-2420(b) and IWE-2420(c) to perform successive examination of repairs.
4.4 BASIS FOR REllEF
'10 CFR 50.55a was amended, as cited in the FederaIRegister(61 FR 41303), to require the use of the 1992 Edition,1992 Addenda, of Section XI, when performing containment examinations. The purpose of a repair is to restore the component to an acceptable condition for continued service in accordance with the acceptance standards of Article IWE-3000. Paragraph IWA-4150, " Verification of Acceptability," requires the owner to conduct an evaluation of the suitability of the repair including consideration of the cause of failure.
if the repair has restored the component to an acceptable condition, successive examinations are not warranted. If the repair was not suitable, then the repair does not meet code requirements and the component is not acceptable for continued service. Neither Paragraph IWB-2420(b), Paragraph IWC-2420(b), nor Paragraph IWD-2420(b) requires a repair to be subject to successive examination requirements. Furthermore, if the repair area is subject to accelerated degradation, it would still require augmented examination in accordance with Table IWE-2500-1, Examination Category E-C.
n RR-E-2-06 Page 2 of 2 The successive examination of repairs in accordance with Paragraphs IWE-2420(b) and IWE-2420(c) constitutes a burden without a compensating increase in quality or safety, in SECY 96-080, " Issuance of Final Amendment to 10 CFR Section 50.55a to incorporate by Reference the ASME Boller and Pressure Vessel Code (ASME Code),Section XI, Division 1, Subsection IWE and Subsection IWL," dated April 17,1996, response to comment # 3.3 states "The purpose of IWE-2420(b) is to manage components found to be acceptable for continued service (meaning no repair or replacement at this time) as an Examination Category E-C component...
If the component had been repcired or replaced, then the more frequent examination would not be needed." -
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.
The requirement to perform successive examinations following repairs has been removed in the rewrite of Subsection IWE of ASME Section XI. This rewrite has been approved and published by the ASME in July 1998.
4.5 ALTERNATE EXAMINATIONS Successive examinations in accordance with Paragraphs IWE-2420(b) and IWE-2420(c) are net required for repairs made in accordance with Article IWA-4000.
Relief Request RR E-2-07
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RR-E-2-07 Page 1 of 2 5.0 RELIEF REQUEST NO. RR E-2-07 5.1 SYSTEMS / COMPONENTS FOR WHICH RELIEF IS REQUESTED Class MC pressure retaining bolting.
5.2 CODE REQUIREMENT (S)
ASME Section XI,1992 Edition with the 1992 Addenda, Table IWE-2500-1, Examination Category E-G, Pressure Retaining Bolting, Item 8.20.
5.3 CODE REQUIREMENT FROM WHICH REllEF IS REQUESTED Relief is requested from ASME Section XI 1992 Edition,1992 Addenda, Table IWE-2500-1 Examination Category E-G, Pressure Retaining Bolting, item 8.20.
Table IWE-2500-1 requires a bolt torque or tension test on bolted connections that have not been disassembled and reassembled during the inspection interval.
5.4 BASIS FOR REllEF 10 CFR 50.55a was amended, as cited in the Federa/ Register (61 FR 41303), to require the use of the 1992 Edition,1992 Addenda, of ASME Section XI when performing containment examinations. Bolt torque or tension testing is required on bolted connections that have not been disassembled and reassembled during the inspection interval. Determination of the torque or tension value would require that the bolting be loosened and then re-torqued or retensioned.
Each containment penetration receives a 10 CFR 50 Appendix J, Type B test in accordance with the specified testing frequencies. As noted in 10 CFR 50 Appendix J, the purpose of Type B tests is to mea:ure 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 for any other ASME Section XI, Class 1,2, or 3 bolted connections or their supports as part of the inservice inspection program.
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RR-E-2-07 Page 2 of 2 Relief is requested in accordance with 10 CFR 50.55a(a)(3)(ii). Examination of bolt torque or tension requires the joints be disassembled. For electrical '
penetrations, this would involve a pre-maintenance Appendix J test, disconnection of cables at electrical penetrations if enough cable slack is not available, disassembly of the joint, removal and examination of the seals and gaskets, reassembly of the joint, re-termination of the cables if necessary, post' maintenance testing of the cables, and a post maintenance Appendix J test of the penetration. Relieving bolt torque and subsequent re-torquing of bolted connections which are verified not to experience unacceptable leakage through 10 CFR 50, Appendix J, Type B testing results in hardship or unusual difficulty.
without a compensating increase in the level of quality and safety.
The requirement to perform bolt torque or tension tests has been removed in the rewrite of Subsection lWE of ASME Section XI. This rewrite has been approved and published by the ASME in July 1998.
5.5 ALTERNATE EXAMINATION (S)
The following examinations and tests required by Subsection IWE ensure the structural integrity and the leak-tightness of Class MC pressure retaining bolting, and, therefore, no additional alternative examinations are proposed:
'(1)
Exposed surfaces of bolted connections shall be visually examined in accordance with requirements of Table IWE-2500-1, Examination Category E-G, Pressure Retaining Bolting, Item No. E8.10, and (2)
Bolted connections shall meet the pressure test requirements of Table IWE-2500-1, Examination Category E-P, All Pressure Retaining Components, item E9.40.
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RR-E-2-08 Page 1 of 2 6.0 RELIEF REQUEST NO. RR-E-2-08 6.1 SYSTEM / COMPONENT (S) FOR WHICH RELIEF IS REQUESTED All components subject to the requirements for Inservice Inspection of Class CC Concrete Components, Examination Category L-A, Concrete, item L.1.11 as applicable to IWL-2310, Visual Examination and Personnel Qualification and IWA-2210, Visual Examinations.
6.2 CODE REQUIREMENTS ASME Section XI,1992 Edition,1992 Addenda, IWL-2310, Visual Examination and Personnel Qualification and IWA-2210, Visual Examinations requires specific minimum illumination and maximum direct examination distance for all concrete 1'
surfaces.
6.3 CODE REQUIREMENTS FROM WHICH RELIEF IS REQUESTED Relief is requested for Paragraph IWA-2210, Visual Examination Requirements for minimum illumination and maximum direct examination distance of Class CC components under Paragraph IWL-2310.
6.4 BASIS FOR REllEF 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. In addition to the requirements of Subsection IWL, the rulemaking also imposes the requirements of Subsection IWA of the 1992 Edition, 1992 Addendum, of ASME Section XI for minimum illumination and maximum direct examination distance of Class CC components, specifically for the i
examination of concrete under Paragraph IWL-2510.
Accessibility to higher portions of the containment structure makes it a hardship to obtain the maximum direct examination distance and minimum illumination requirements. The installation of extensive temporary scaffold systems or a climbing scaffold system to access these portions of the containment would be necessary. These scaffolds would provide limited access due to containment geometry restrictions as well as structural and equipment interferences. The installation and removal of these scaffolds would increase both risk to personnel safety and safety related systems in order to meet Paragraph IWA-2210 requirements.
D RR-E-2-08 Page 2 of 2 The NRC staff received seven comments that were consolidated into Public Comment # 2.3 in Part lil of Attachment 6A to SECY-96-080. The Staff response to these concerns is as follows: " Comments received from ASME members on the containment committees indicate that the newer, more stringent requirements of IWA-2210 were not intended to be used for the examination of conteinment and were inadvertently included in Subsection IWL. The NRC agrees that remote examinations are the only practical method for inspecting much of the containment surface area. 9 50.55a(b) (2) (x) (B) has been added to the final rule which contains alternative lighting and resolution requirements which may be used in lieu of the requirements contained in IWA-2210-1."
However, as specified within @ 50.55a(b) (2) (x) (B) of the final rule, this alternative applies only to Subsection IWE.
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 4
difficulty without a compensating increase in the level of quality and safety.
2 The requirement to comply with IWA-2210 has been removed in the rewrite of Subsection IWE of ASME Section XI. This rewrite has been approved and published by ASME in July 1998.
6.5 ALTERNATIVE EXAMINATIONS When the visual examinations required by Subsection IWL, Paragraph IWL-2510, I
are performed remotely, the maximum direct examination distance specified in Table IWA-2210-1 may be extended, and the minimum illumination requirements spocified in Table IWA-2210-1 may be decreased. The remote visual examinations will be demonstrated at the chosen distance and illumination to be capable of detecting the conditions or indications for which the visual examination is performed.
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