ML20210D832

Safety Evaluation Accepting Relief Requests Re Use of 1998 Edition of Subsections IWE & Iwl of ASME Code for Containment Insp

ML20210D832
Person / Time
Site:	Comanche Peak
Issue date:	07/23/1999
From:	NRC (Affiliation Not Assigned)
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ML20210D829	List: ML20210D823 ML20210D832 ML20210D846
References
NUDOCS 9907280038
Download: ML20210D832 (5)

Text

I yucg$% . UNITED STATES

[E l* j NUCLEAR REGULATORY COMMISSION

$ 'c WASHINGTON, D.C. 20555-0001

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l SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION EVALUATION OF RELIEF REQUESTS TEXAS UTILITIES FLECTRIC COMPANY COMANCHE PEAK STEAM ELECTRIC STATION (CPSES). UNITS 1 AND 2 DOCKET NOS. 50-445 AND 50-446

1.0 INTRODUCTION

Title 10 of the Code of Federal Reaulations (10 CFR) Section 50.55a(g)(6)(ii)(B), requires containment inspections per Subsections IWE and IWL of the 1992 Edition with the 1992 Addenda (1992 Edition and Addenda) of Section XI of the American Society of Mechanical Engineers (ASME) Boiler Pressure Vessel Code (the Code), as modified by 10 CFR 50.55a(b)(2)(ix) and 10 CFR 50.55a(b)(2)(x). Ucensees of all operating nuclear power plants are required to complete the first period inspections by September 9,2001.

By letter dated February 20,1998 (Ref.1), and supplemented by letters dated March 26 (Ref. 2), June 8 (Ref. 3), and June 15,1999 (Ref. 4), Texas Utilities Electric Company (the licensee), submitted Requests for Relief Nos. E-1 and L-1, seeking relief from the requirements of Subsections IWE and IWL of the 1992 Edition and Addenda of the Code, respectively.

Instead, the licensee proposed to use the 1998 Edition of the Code pursuant to 10 CFR 50.55a(a)(3)(i). The licensee provided a table comparing the requirements of the 1998 Edition with the 1992 Edition and Addenda. This evaluation addresses the acceptability of the licensee's alternative proposal.

2.0 EVALUATION The Idaho National Engineering and Environmental Laboratory (INEEL), as contractor to the NRC, evaluated the content of the subject relief requests. The evaluation included a rev4w and comparison of Subsections IWE and IWL requirements in the 1992 Edition and Addenda and 1998 Edition, and a brief analysis of the changes and/or implications of the Code changes.

INEEL's Technical Evaluation Report (TER), contained as an attachment to this Safety Evaluation, describes the licensee's bases for requesting the two relief requests, and discusses the implication of the alternatives in terms of avality and safety related to the inspection of CPSES containments. Appendix A to the TER is a table of comparison for E-1 alternative, and Appendix B is a table of comparison for L-1 alternative. The four columns of the tables indicate the following:

Column 1 Paragraph

The paragraph (sometimes includes Articles and Subarticles)

! corresponds to the 1992 Edition and Addenda of Subsections IWE and IWL of the Code.

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j Column 2 Changes between the 1992 Edition and Addenda and 1998 Edition Column 3 Licensee's statement of significance and/or basis for use as an alternative examination Column 4 INEEL's recommended disposition / comments: INEEL's disposition is principally related to the acceptance of the requirements of 1998 Edition of the Code in

terms of quality and safety related to the containment inspection.

l Based on the review of the comparative requirements, the NRC staff identified six significant changes that required additional information from the licensee. They are discussed in the l

following paragraphs.

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3 l

l IWE 2300: The 1992 Edition and Addenda (Table 2500-1) invokes the use of IWA-2200 and j IWA-2300 for visual, surface, and volumetric examination methods, and for qualification of personnel. lWE-2300 (1998) requires the owner to define requirements for visual examination l of containment surfaces, and for qualifying the personnel performing visual examinations.

Additionally, IWE-2320 requires the owner to designate a responsible individual (RI) who will be I responsible for activities related to the containment surface visual examinations and personnel qualification. In response to the requests for additional information (RAls) (Refs. 2 and 3), the  !

licensee provided the following information:

1. " General Visual Examination" criteria are developed from VT-3 procedures that are used l

! to examine ASME Class 1,2, and 3 components, '

l

2. Pressure retaining bolting recording criteria are developed from the VT-1 procedure used for Class 1 bolting,

3. Moisture barriers are examined for tears, cracks, or damage that permits moisture to intrude, l 4. " Detailed Visual Examination" criteria are developed from VT-1 and VT-3 procedures,

! and

5. The containment visual examination procedure qualification requirement for lighting and l illumination are similar to, and developed from, the procedures used for VT-1 and VT-3 l

examinations of ASME Class 1,2, and 3 components, i

l 6. In applications where remote visual examination systems are to be used, those systems

! will be demonstrated to have a resolution capability at least equivalent to that attainable by direct visual examination.

• Containment visual examination procedures will be demonstrated to the authorized nuclear inservice inspector for capability to detect flaws and degradation levels define 0 within the procedure, and l

l I

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F .t 3-

= The containment visual examination program is developed from the guidelines of SNT-TC-1 A and ANSI N45.2.6. Certified personnel will have " demonstrated skill, demonstrated knowledge, documented training, and documented experience required to properly perform the duties of a specific job."

The incorporation of these provisions in the licensee's containment inservice inspection (ISI) procedures provides adequate assurance regarding the licensee-defined visual examination and personnel qualification requirements.

IWE-2500: The requirement to examine paint or coatings prior removal was deleted in the 1998 Code Edition. The NRC staff has no objection to this deletion. However, the staff is concerned that in absence of any examination for detecting flaws or degradation in the containment base metal, the recoating may be applied to the degraded containment surface. In response to the RAI related to this subject, the licensee provided the following information (Ref. 3) as stated:

The CPSES ISI, Containment ISI, Repair / Replacement and Containment Coatings Programs are all administered by engineering personnel within the l organization of one manager. These program engineers are cognizant of each others area of responsibility. In addition to this organizational and physical proximity, procedure provisions are in place to require notification to the appropriate responsible engineer when one program is potential ly affected by the actions or results of another. In areas important to containment integrity, coatings program procedural requirements ensure that coating deficiencies identified on the containment liner are brought to the attention of the Subsection IWE Responsible Individual (Containment ISI Engineer). Prior to final disposition of the coatings deficiency by the Coatings Program Engincer, the Containment ISI Engineer has the opportunity to establish visual examination hold points for any point in the coating removal and reapplication process. These procedural ties ensure that base metal conditions that could challenge the structural integrity of the containment are examined by properly qualified personnel.

The staff believes that the implementation of the above process will ensure that the base metal degradation will be identified, and appropriate action taken, prior to recoating of the CPSES containment liners.

IWE 3510.1 and IWE 3511.1 (1998): The owner is required to define the acceptance criteria for visual examination of containment surfaces in performing Category E A and Category E-C examinations. However, the basic requirements for these examinations are provided in IWE-2310 and augmented by the licensee as described in Item 1 above. The staff believes that complying with the 1998 Edition of the Code augmented by the specific requirements in the licensee's containment ISI procedure will be adequate in identifying significant flaws and degradations during Category E-A and Category E-C examinations.

e ..

lWE-3511.3 (1998): This paragraph provides acceptance criteria for ultrasonic examination. In ,

, the 1992 Edition and Addenda of the Code, these criteria are provided in IWE-3512.3. In the 1998 Edition of the Code, these criteria are applied to Class MC pressure retaining components only. It is not applicable to metallic liners of Class CC components. In response to the staff's question (Ref. 3) on this subject, the licensee confirmed that it will use the criteria for ultrasonic >

examination of CPSES containment liners.

The response resolves the staff's concern regarding the applicability of this paragraph to the CPSES containment liners.

lWL-2310 (1998): Definitions of VT-1C and VT-3C are removed and replaced by the terms

" detailed visual examination" and " general visual examination," respectively. The owner is required to develop visual examination procedures. In response to the staff's question related to the licensee-developed examination procedure for concrete examinations, the licensee

, stated that it will use the same type of procedure qualification for remote examination of the containment concrete surfaces as that used for CPSES containment liners (see items 1 and 3 above) (Ref. 3).

In conjunction with the 1998 Code requirements in IWL 2310 and IWL-2320 (requirement for

' having a responsible engineer), the licensee's commitment related to the containment concrete visual examination procedure assures that the concrete degradations of significance will be

detected, evaluated, and appropriate corrective actions will be taken.

i Table lWL-25001: In the 1992 Edition and Addenda, Item L1.12, Suspect Areas, requires VT-1C visual examination. in the 1998 Edition, this item requires general visual examination.

This is an inadvertent change. The 1999 Addenda of the Code will correct it to be " detailed visual" examination. The I.'censee did not identify this difference in its comparison. The licensee confirmed that it will perform detailed visual examination of suspect areas as intended by the 1998 Edition of the Code (Ref. 4). This resolves the staff's concern regarding the I examination of suspect areas.

3.0 CONCLUSION

Based on the review of the licensee's submittal and responses to the staff's RAI, the staff finds l that the use of the 1998 Edition of the Code, supplemented by the licensee's commitments in j the responses to the NRC staff's RAls, will provide an acceptable leve' of quality and safety for l ensuring the pressure integrity of the CPSES containments. Therefore, the staff concludes that l the use of the proposed alternative is authorized for the first inspection interval of the CPSES, l Units 1 and 2, containments pursuant to 10 CFR 50.55a(a)(3)(i).

I i

Attachment:

Technical Evaluation Report l

Principal Contributor: H. Ashar Date: July 23, 1999 u

REFERENCES

1. Letter, TU Electric to NRC," Relief Requests E-1 and L-1 Related to CPSES Containment inservice Inspection Program," dated February 20,1999

2. Letter, TU Electric to NRC, " Response to Request for Additional information Related to Relief Requests E-1 and L-1," dated March 26,1999

3. Letter, TU Electric to NRC," Response to Request for Additionalinformation Related to Relief Requests E-1 and L-1," dated June 8,1999

4. Letter, TU Electric to NRC," Response to Request for Additional information Related to Relief Requests E-1 and L-1," dated June 15,1999 i