ML20210D846
| ML20210D846 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/30/1999 |
| From: | Mary Anderson, Charles Brown, Galbraith S IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | NRC (Affiliation Not Assigned) |
| Shared Package | |
| ML20210D829 | List: |
| References | |
| CON-FIN-J-2603 INEEL-EXT-99-00, INEEL-EXT-99-00415, NUDOCS 9907280046 | |
| Download: ML20210D846 (38) | |
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INEELIEXT-99-00415
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Technical Evaluation Report (Rev.1) on the Proposed Alternatives to IWEllWL' Containment inspections: ;
TU Electric, !
Comanche Peak Steam Electric Station, Units 1 and 2, Docket Numbers: 50-445 and 50-446 l l
l M. T. Anderson, C. T. Brown, S. G. Galbraith, A. M. Porter Published June 1999 Idaho National Engineering and Environmental Laboratory Materials Physics Department Lockheed Martin Idaho Technologies Company Idaho Falls, Idaho 83415 Prepared for the Division of Engineering Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 JCN No. J2603 (Task Order 006) 9907280046 990723 yDR ADocK 05000445 Attachment PDR
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e _i ABSTRACT i
This repon presents the mults of the evaluation of the proposed attematives to containment inspections, submitted February 20,1998, that are included in the licensee's requests for relief from the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Subsections IWE/IWL requirements. The proposed alternatives to IWF/IWL containment inspection are evaluated in Section 2 of this report.
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This work was funded under:
I U.S. Nuclear Regulatory Commission JCN No. J2603 Task Order 006 j Technical Assistance in Support of the NRC Inservice Inspection Program l
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SUMMARY
The licensee, TU Electric, prepared proposed alternatives to the IWE/IWL containment inspections required by 10 CFR50.55a(g)(6)(ii)(B). Essentially, the licensee proposed to use the 1998 Edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, Subsections IWE and IWL, in lieu of the 1992 Edition with 1992 Addenda, as currently specified by the Regulation for containment inspections.
Information in the Proposed Alternatives to IWE/IWL Containment Inspections, submitted February 20,1998, was reviewed. As a result of this review, a request for additional information (RAl) was prepared describing the information and/or clarification required from the licensee in order to complete the review. The licensee provided the requested information in a submittal dated March 26,1999.
Based oa the review of the licensee's original submittal and TU Electric's response to the NRC's RAI, it is concluded that, for Relief Requests E-1 and L-1, the intent of the Regulation will be satisfied at Comanche Peak Steam Electric Station, Units 1 and 2. The licensee's proposed alternative, to use the 1998 Edition of Subsections IWE/lWL, as supplemented by specific, detailed requirements conteined in the Comanche Peak Containment inspection Program, will provide an acceptable level of quality and safety. Therefore,it is recommended that the proposed alternative (s) be authorized pursuant to 10 CFR 50.55a(a)(3)(i).
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CONTENTS AB STRACT . . . . . . . . . . . . . . ... . .... . ... . .... ...... . .... .. ..... ii
SUMMARY
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- 1. INTRODUCTION . . . . ... .... ... . .. .. ... .. . . .... . .. .. .I
- 2. EVALUATION . . . . . . .... ...... .... . .... .. .. . ... . .... . . . 2 2.1 Evaluation of Relief Requests . .. .. . .... .. . .. .. .. . . . .. . .2 2.1.1 Request for Relief No. E-1, Authorization to Use ASME Section XI,1998 Edition, Subsection IWE, for Examination of Class MC and Metal Liners of Class CC Components 2 2.1.2 Request for Relief No. L-l. Authorization to Use ASME Section XI 1998 Edition, Subsection IWL. for Examination of Class CC Components . . . .. 8
- 3. CONCLUSION . ... .. . . . ... . . . . .. 11
- 4. REFERENCES .. ... . .. . .. . .. .... . . ... . 12 Appendix A . . . . . . A-1 Appendix B .... .. . .. .. .... . .. . .. .... B-1 Appendix C . . . . . . . .. .. . . . .. .... . ... ... . . . C-1 IV
p TECHNICAL EVALUATION REPORT (REV.1) ON THE PROPOSED ALTERNATIVES TO IWE/lWL CONTAINMENT INSPECTIONS:
TU ELECTRIC, COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2, DOCKET NUMBERS: 50-445 AND 50-446 1
- 1. INTRODUCTION The Code of Federal Regulations,10 CFR 50.55a(g)(6)(ii)(B)', requires containment inspections per Subsections IWE and IWL of the American Society of Mechanical Engineers (ASME),Section XI,1992 2
Edition with the 1992 Addenda , as modified by 650.55a(b)(2)(ix). Licensees of all operating nuclear power plants shall perform these examinations by September 9,2001.
By letter dated February 20,1998, the licensee, TU Electric, submitted Requests for Relief Nos. E-1 and L-1, seeking relief from the requirements of the 1992 Edition / Addenda ofIWE and IWL, respectively. These relief requests for Comanche Peak, Units 1 and 2, were submitted during the first 10-year inservice inspection (ISI) interval. In each request for relief, the licensee proposed to use the 1998 Edition of the Code in lieu of the 1992 Edition / Addenda. The licensee provided a table comparing the 1998 Edition with the 1992 Edition,1992 Addenda. The evaluation of the subject relief requests included a review and comparison of requirements found in the 1992 and 1998 Editions and a brief analysis of the changes and/or implications. In general, the Idaho National Engineering and Environmental Laboratory (INEEL) staff concurs with the licensee's analysis of the Code changes, except in the areas of visual examination method description and procedure qualification, visual examination personnel qualification, and visual examination prior to paint or coating application. These areas required clari6 cation from the licensee, and an RAI was issued. By letter dated March 26,1999, ,
the licensee submitted a response to the NRC request for additional information '. The INEEL staff's j evaluation of the subject requests for relief is in the following section. Tables showing variations ;
between Subsections IWE and IWI., in the different Code editions, and relevant comments, are included !
i as appendices.
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F I l 2. EVALUATION l The following evaluation consists of a review of the licensee's relief requests and proposed alternatives to Code requirements that the licensee has detennined will provide an acceptable level of quality and safety.
2.1 Evaluation of Relief Requests 2.1.1 Request for Relief No. E-1, Authorization to Use ASME Section XI,1998 Edition, Subsection IWE, for Examination of Class MC and Metal Uners of Class CC Components .
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Regulatory Requirernent-10 CFR 50.55a(g)(6)(ii)(B) requires that licensees implement the inservice examinations specified for the first period of the first inspection interval in Subsection IWE of the 1992 Edition with the 1992 Addenda of Section XI, Division 1 of the ASME Code.
L/censee's Proposed Alternative-In accordance with 10 CFR 50.55a(a)(3)(i), the licensee proposed to implement the requirements of the 1998 Edition in lieu of the 1992 Edition,1992 Addenda for Subsection IWE. In addition, in its response to the NRC's RAI, dated March 26,1999, the licensee defined specific attributes of their containment inspection program. These attributes include the details of the Owner-defined General and Detailed visual acceptance criteria and the qualification requirements for visual and ultrasonic examination personnel inspecting containment surfaces.
Licensee's Basis for Proposed Alternative (as stated)-
"The 1992 Edition with the 1992 Addenda of Subsection IWE contains requirements which impose difficulties in the transition from the current ISI program to a program that includes containment ISI examinations. Development and implementation of a meaningful containment ISI program would be facilitated by adopting the examination requirements detailed below. These alternative examinations provide for consistency with the existing programs in the qualification of nondestructive examination personnel as well as providing more practical requirements for the examination of containment bolting, seals and gaskets.
"Some specific hardships imposed by the 1992 Edition, '92 Addenda ofIWE that are not compensated for by an increased level of plant quality and safety rre as follows:
"lWA-2300 requires the use of a written practice prepared in accordance with ANSI /ASNT CP-189 for the qualification and certification of containment nondestructive examination personnel. All other CPSES NDE and ISI activities, including those performed on the reactor vessel, are performed by personnel qualified and certified to written prectices prepared in accordance with SNT-TC-1 A as j required by ASME XI 1986 Edition, No Addeada, the Code of record for ISI at CPSES. Utilizing l the '92 Addenda ofIWE would require the development of a separate written practice and the issuance and tracking of separate certifications for both TU Electric and contractors. Administration of the resulting duplicate programs could result in documentation inconsistencies and would be an l impact to resources.
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" Containment bolting requires a VT-1 examination and a bolt torque or bolt tension test per Table IWE-2500-1. Detennination of bolt torque or tension requires the performance of a l
maintenance activity to un-torque or un-tension the bolt and then to re-torque or re-tension the bolt.
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Bolted joints are currently subject to Appendix J leak testing and a visual examination to verify leak j tight and structural integrity. Other bolted joints subjected to visual examination by ASME XI, l including Code Class I bolting, do not require bolt torque or bolt tension testing. Performance of the 1 maintenance activity would be an impact to resources, increases radiation exposure and could result in damage to permanent plant equipmer,t.
" Seals and gaskets require specific VT-3 examinations per Table IWE-2500-1. Seals and gaskets are not part of the containment pressure boundary. Bolted joints and airlocks are currently subject to Appendix J leak testing and visual examinations to verify leak tight integrity. The performance of additional VT-3 examinations of seals and gaskets to detect conditions that may violate leak tight integrity is redundant, increases radiation exposure and would be an impact to resources. >
"The proposed alternative is to utilize the current ASME approved rewrite of Subsection IWE of !
Section XI [1998 Edition] in its entirety. Utilizing the entire IWE rewrite incorporates other l exceptions to the '92 addenda stated in NRC rulemaking and provides more cohesiveness than could be achieved by requesting relief on severalindividual subjects separately. The alternate examination requirements match the rewrite exactly and are included as Enclosure i of this relief request. These requirements were developed in accordance with the ASME Code committee process with input from interested parties which includeo TU Electric, other utilities, manufacturers, engineering organizations, Authorized Nuclear Inspection Agencies, EPRI and the NRC. The updating of I requirements by this consensus process is intended to ensure the continued safe operation of nuclear power plants and specifically in this case the continued leak tight and structural integrity of metallic containment components. Therefore, the overall level of plant quality and safety will not be adversely affected by utilizing the requirements of the current ASME approved IWE rewrite [i998 Code). A detailed evaluation and line by line comparison of the differences between the 1992 Edition with the 1992 Addenda of Subsection IWE and the current ASME approved rewrite is included as Enclosure 2 of this relief request.
"CPSES Unit 2 is in the second period of the first ten year ISIinterval. Based on current plant refueling outage schedules and the requirement of the new rulemaking for fullimplementation by September 9,2001, a containment ISI examination program must be established immediately.
Implementing this relief request now would reduce the overall impact to resources (both TU Electric's and the NRC's) versus incorporating the mandated edition and addenda of IWE in conjunction with this initial establishment of a containment ISI program and then updating again to a later edition and or addenda or to a series of Code Cases upon formal NRC endorsement or on the next ten year ISI plan issuance."
Evaluation- 10 CFR50.55a(g)(6)(ii)(B) requires that licensees perform the inservice examinations specified for the first period of the first inspection intervalin Subsection IWE of the 1992 Edition with the 1992 Addenda by September 9,2001. The licensee is proposing to implement the 1998 Edition of Section XI, Subsection IWE in lieu of the 1992 Edition and Addenda. The licensee prepared and submitted a table comparing both Code Editions.
Article IWE-2100 has been added to the 1998 Edition to include the IWA-2000 requirements for examination and inspection, while taking exception to certain requirements in Subsection IWA.
Specifically, in accordance with IWE-2100, to IWA-2210, Visual & amination; IWA-2300, Guahfication ofNondestructive Personnel; IWA-2500, Extent ofExamination, and IWA 2600, Weld Reference System are not mandatory for Table IWE-2500 visual examinations. It is understandable to exclude the IWA-2500 and IWA-2600 requirements from the containment inspection program. However, excluding 3
the visual examination requirements ofIWA-2210 and the personnel qualification iequirements of IWA-2300 may reduce the effectiveness of the Code.
The INEEL staff has reviewed the licensee's submittal and Subsection IWE of both the 1998 Code and the 1992 Code and Addenda. Appendix A of this report contains a comparison table, including the licensee's statements regarding the significance of Code changes and their bases for use as an alternative.
The table also includes INEEL comments. Significant differences were noted in areas of: personnel qualification, visual examination methods, containment weld inspection, paint and coating inspection, bolting inspection, seals and gasket inspection, and the requirements for successive examinations. These issues are presented in table format as Appendix C and are discussed below.
Visual Examination Methods IWE-2300 of the 1998 Edition has invoked Owner-defined visual examinations and supporting visual l personnel qualification requirements for metallic containments. The INEEL staff nou that Section XI is intentionally organized to refer to the General Requirements of Article IWA to define the type of examination to be performed (i.e., VT-1, VT-2, or VT-3) and the requirements to certify examination personnel, if a required examination method is limited in scope, IWA-2350, Limited Certification, gives licensees the flexibility to tailor the personnel qualification for the inspection activity to that specific application. Instead, the 1998 Subsection IWE/IWL has developed new examination methods (General and Detailed Visual) that are not guided by the requirements of Subsection IWA. Deferring these responsibilities to individual Owners, without specific Code guidance, creates a potential for inconsistencies with respect to ISI of containment structures. To ensure consistent application throughout the industry, it is necessary for each licensee to supplement the 1998 Code and provide specific details pertaining to visual examinations included in their Containment Inspection Program (s).
Licensee's Containment inspection Programs are currently not required to be submitted for review by the regulatory authorities. For these reasons, the INEEL staff believes the 1998 Edition does not provide an acceptable level of quality and safety.
However, in the March 26,1999, response to the NRC request for additional information, the licensee was asked to provide the General and Detailed visual acceptance criteria that will be used to examine general containment surfaces, containment welds, bolting, moisture barriers, dissimilar metal welds, etc.
The licensee stated;
" . . The 1998 Edition of IWE and the NRC Rulemaking remove the emphasis from weld based examinations. Therefore, containment welds and dissimilar metal welds will be examined by General Visual examination to the same criteria as general containment surfaces. For non-coated containment surfaces this criteria was developed from VT-3 procedures that are used for examination of ASME Code Class 1,2, and 3 components such as the reactor vessel interior, pump casings and valve bodies. This includes examination for cracking, discoloration, structural distonion, wear, l pitting, corrosion, gouges, dents or other surfa:e discontinuities. For coated containment surfaces the recording criteria was developed from the Comanche Peak Coatings Program. This includes examining for flaking, blistering, peeling, discoloration or other signs of distress.
" . . pressure retaining bolting will be examined by General Visual examination. The recording criteria was developed from the VT-1 procedure that is used for ASME Code Class 1 bolting. This includes examining for: nonaxial flaws greater than 1/4 inches in length; axial flaws greater than 1 inch in length; more than one deformed or sheared thread in the zone of thread engagement of bolts, studs or nuts; localized general corrosion that exceeds the thread root depth, bending, twisting or deformation of bolts or studs to the extent that assembly or disassembly is impaired; missing or loose l
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l bolts, studs, nuts or washers; fractured bolts, studs or nuts; degradation of protective coatings on bolting surfaces.
". . . moisture barriers will be examined by General Visual examination. Moisture barriers will be examined for tears, cracks or other damage that prmits intrusion of moisture through the barrier.
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" Detailed Visual examination criteria is developed from the VT-1 and VT-3 procedures that are used l for examination of ASME Code Class 1,2 and 3 components. This includes examining coated and l
non-coated containment surfaces, bolting and moisture barriers for the same attributes addressed in 3[a] above.
"The VT 3 and VT-1 inspections have been replaced by Owner (Responsible Individual) defined general and detailed visual examinati ons respectively. However, the definition of critical
- examination items and the list of crite i examination attributes have not changed. The 1998 Edition l provides specific examples of unacceptable conditions in IWE-2300 that were previously contained in IWE-3500. The general and detailed visual examinations are essentially equivalent to the VT and VT-1 examinations in terms of assessing the structural integrity and potential for degradation to the containment system. The use of owner defined examination methods allows for the involvement l
of qualified engineering personnel with backgrounds in areas such as containment coatings, Maintenance Rule, Appendix J, containment design, materials engineering and containment l degradation mechanisms. Procedures for inspection and qualification are developed by a TU Electric l NDE Level Ill. Procedures must be demonstrated to the ANIl for capability to detect flaws and degradation levels as defined in the inspection procedures."
The information provided by the licensee appears to describe a Containment inspection Program that parallels, and meets the intent of, the 1992 Edition with the 1992 Addenda. The General and Detailed
- Visual examinations in the licensee's Program have been developed to be essentially equivalent to the VT-3 and VT-1 examinations for assessing containment integrity. Therefore, an acceptable level of quality and safety will be provided.
Personnel Oualification The 1992 Addenda has incorporated ANSI /ASNT CP-189 for the qualification of examination personnel. Subsection IWE of the 1998 Edition takes exception to the certification requirements of other l Subsections of the Code and invokes plant-specific personnel certification requirements for visual examination. Subsection IWE (1998 Edition) deleted the VT-1 and VT-3 visual examination l requirements and replaced them with General and Detailed visual examinations; subsequently NDE
! personnel may not be required to perform these examinations. The 1998 Edition relies on the
! Responsible Individual to direct the containment visual examinations. The INEEL staff believes that this approach has a substantial potential for inconsistency with respect to containment ISI. For this reason, the 1998 Edition does not provide an acceptable level of quality and safety.
l However, in the March 26,1999, response to the NRC RAI, the licensee was asked to describe the qualification requirements for personnel performing containment visual examinations. The licensee stated:
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" Personnel performing containment visual examinations will be qualified to a program developed specifically for containment examinations. . . . . . .The containment visual examination program is developed from the guidelines of ASNT SNT-TC-1 A and ANSI N45.2.6 but is focused on visual examination and in particular items important to containment integrity. The SNT-TC-1 A 5
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Recommended Practice invoked by the 1986 Edition of ASME Section XI (Code of record for CPSES Units I and 2) for ASME Code Class 1,2 and 3 ISI examinations does not specifically address visual examinations. The required involvement of the Responsible Individual assures testing and qualification reviews will be performed such that personnel receiving containment visual examination certification will have a " demonstrated skill, demonstrated knowledge, documented training, and documented experience required to properly perform the duties of a specific job" as required by SNT TC-1 A. Procedures for inspection and qualification are developed by a TU Electric NDE Level 111. Procedures must be demonstrated to the ANII for capability to detect flaws and degradation levels as defined in the inspection procedures.
The information provided by the licensee appears to describe a Containment inspection Program that parallels, and meets the intent of, the 1992 Edition for examination personnel qualification requirements.
Succewive Examinations IWE-2420(c)(92 Edition / Addenda) requires areas containing flaws, areas of degradation, or repairs that were found acceptable by engineering evaluation to be reexamined during the next three inspection periods before they are removed from the augmented examination category. This is consistent with Subsection IWB-2420 requirements. The 1998 Edition has removed repairs from the list of attributes requiring acceptance by evaluation, which is consistent with Class 1,2, and 3 components. However, the later edition has reduced the observation time required before a suspect area can be removed from the augmented examination category. IWE-2420(c)(98 Edition) requires reexamination of areas containing flaws or areas of degradation that have been accepted for continued service by engineering evaluation during the next inspection period. If the suspect area is unchanged during the next period examination, the area no longer requires augmented examination. This approach is consistent with the requirements for Class 2 components. In addition, even though an area is removed from augmented examination, it ,
may be re-designated for augmented examination at any time during the interval if the Owner determines ;
that conditions that cause degradation still exist. This Code change should provide an accep.able level of '
quality and safety.
Paint and Coatines The IWE-2500(b) requirement to examine paint or coatings prior to removal has been eliminated from the 1998 Edition. Relief from this requirement has been found acceptable when adequate provisions exist in either the licensee's Containment Inspection, Repair / replacement, Nuclear Coatings, or ISI Programs to examine the base metal for surface anomalies that could effect containment integrity, prior to re-application of the coating. The licensee has provided information addressing the visual examination prior to paint or coating application and the coordination within the Engineering Department for the Coatings Program and Containment ISI. Consequently, the Coatings Program procedural controls should ensure that base metal conditions that could challenge the structural integrity of the containment are examined by properly qualified personnel.
Weld Examinations Subsection IWE,1998 Edition, has been revised and no longer contains any specific weld
! examination requirements. There has been a gradual philosophical change in Subsection IWE from the 1989 Edition to the 1998 Edition. The containment inspection program defined in the 1992 Edition with the 1992 Addenda is still primarily " weld-based", but offered improvement over the 1989 Edition. The 1998 Edition is written to encompass the entire containmer.t surface, regardless of the existence of welds in a particular area. This approach is supported by 10 CFR 50.55a(b)(2)(x)(C), which makes the l 6 l
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examinations specified in Examination Category E-B, Pressure Retaining Welds, and Examination Category E-F. Pressure Retaining Dissimilar Metal Welds, optional. Therefore, weld examinations will be addressed during the General Visual examination required by Examination Category E-A. Based on the direction to make containment weld examinations optional, as found in the Regulations, the elimination of any direct references to containment weld examinations in the Code should be considered to provide an acceptable level of quality and safety.
Boltine. Seals. Gaskets and Moisture Barriers Examination Category E-D, Seals, Gaskets, and Moisture Barriers, and Examination Category E-G, Pressure Retaining Bolting, have been eliminated from the 1998 Code. The examination of pressure retaining bolting and moisture barriers is now included in Examination Category E-A, footnote (1)(d) and Item El.30, respectively. The NRC staff has determined that verification of containment leak-tight integrity also verifies the integrity of bolting, seals, and gaskets. The Appendix J, Type A test has been considered sufficient for determining the leak-tight integrity of the penetration. Therefore, an acceptable level of quality and safety is maintained.
Conclusion-The licensee has proposed to use the 1998 Edition of Section XI, Subsection IWE, in lieu of the 1992 Edition with the 1992 Addenda as required by 10 CFR50.55a(g)(6)(ii)(B). Preliminary review and evaluation of Subsection IWE of the 1998 Code has exposed several areas that do not appear to provide an equivalent level of quality and safety to the 1992 Addenda. Consequently, the 1998 Edition cannot be considered an acceptable alternative to the existing Regulatory requirements.
However, in a letter dated March 26,1999, the licensee provided supplemental information including specific details of their Containment Inspection Program. Based on the above discussion,it is concluded that the licensee's Proposed Altemative, to use the 1998 Edition of Subsection IWE supplemented in the areas of visual examination methods descriptions and visual examination personnel qualifications, as described in the licensee's response to the NRC's RAI, will provide an acceptable level of quality and safety and should be authorized pursuant to 10 CFR 50.55a(a)(3)(i).
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l l 2.1.2 Request for Relief No. L-1, Authorization to Use ASME Section XI,1998 Edition, Subsection IWL, for Examination of Class CC Components Regulatory Requirement- 10 CFR 50.55a(g)(6)(ii)(B) requires that licensees perform the inservice examinations corresponding to the number of years of operation that are specified in Subsection lWL of the 1992 Edition with the 1992 Addenda of Section XI Division 1, of the American Society of
, Mechanical Engineers Boiler and Pressure Vessel Code.
l l Licensee's Proposed Alternetive-In accordance with 10 CFR 50.55a(a)(3)(i), the licensee proposed l to implement the requirements of the 1998 Edition in lieu of the 1992 Edition,1992 Addenda for l Subsection IWL. In addition, in their response to the NRC's RAI, dated March 26,109, the licensee defined specific attributes of their Containment Inspection Program. These attributes included the details l of the Owner-defined General and Detailed visual acceptance criteria and qualification requirements for visual examination personnel performing inspections on concrete containment surfaces.
Licensee's Basis for Proposed Alternative-l "The 1992 Edition with the 1992 Addenda of Subsection IWL contains requirements which impose difficulties in the transition from the current ISI program to a program that includes containment ISI examinations. Development and implementation of a meaningful containment ISI program would be facilitated by adopting the examination requirements detailed below. These alternative examinations provide for consistency with the existing programs in the definition of visual examination methods l and in the qualification of visual examination personnel as well as providing more practical requirements for the performance and scheduling of examinations.
L "Some specific hardships imposed by the 1992 Edition, '92 Addenda ofIWL that are not compensated for by an increased level of plant quality and safety are as follows:
"IWA-2300 requires the use of a written practice prepared in accordance with ANSI /ASNT CP-189 for the qualification and certification of containment nondestructive examination personnel. All other CPSES NDE and ISI activities, including those performed on the reactor vessel, are performed by personnel qualified and certified to written practices prepared in accordance with SNT-TC-1 A as required by ASME XI 1986 Edition No Addenda, the Code of record for ISI at CPSES. Utilizing the '92 Addenda of IWL would require the development of a separate written practice and the issuance and tracking of separate certifications for both TU Electric and contractors. Administration of the resulting duplicate programs could result in documentation inconsistencies and would be an impact to resources.
"lWL-2310 and IWA-2210 require specific minimum illumination and maximum direct examination distances for concrete containment examinations. These requirements preclude the perfonnance of remote examination. Performance of the more stringent IWA-2210 direct examinations are not practical for much of the CPSES containment surface area, would be an impact to resources and would introduce a significant risk to personnel safety.
l "The proposed alternative is to utilize the current ASME approved rewrite [1998 Edition] of i Subsection IWL of Section XI in its entirety. Utilizing the entire IWL rewrite provides more cohesiveness than could be achieved by requesting relief on several individual subjects separately.
The alternate examination requirements match the rewrite exactly and are included as Enclosure 1 of this relief request. These requirements were developed in accordance with the ASME Code committee process with input from interested parties which included TU Electric, other utilities, manufacturers, engineering organizations, Authorized Nuclear Inspection Agencies, EPRI and the 8
NRC. The updating of requirements by this consensus process is intended to ensure the continued safe operation of nuclear power plants and specifically in this case the continued leak-tight and structural integrity of concrete containment components. Therefore, the overall level of plant quality and safety will not be adversely affected by utilizing the requirements of the current ASME approved IWL rewrite [1998 Code]. A detailed evaluation and line by line comparison of the differences between the 1992 Edition with the 1992 Addenda of Subsection IWL and the current ASME approved rewrite is included as Enclosure 2 of this relief request.
CPSES Unit 2 is in the second period of the first ten year ISI interval. Based on current plant refueling outage schedules and the requirement of the new rulemaking for full implementation by September 9,2001, a containment ISI examination program must b e established immediately.
Imp!ementing this relief request now would reduce the oveall imract to resources (both TU Electric's and the NRC's) versus incorporating the mandated edi'. ion and addenda ofIWL in conjunction with this initial establishment of a containment ISI program and then updating again to a i later edition and or addenda or to a series of Code Cases upon formal NRC endorsement or on the {
next ten year ISI plan issuance."
Evaluation- 10 CFR50.55a(g)(6)(ii)(B) requires that licensees perform the inservice examinations that correspond to the number of years of operation which are specified in Subsection IWL of the 1992 Edition with the 1992 Addenda by September 9,2001. The licensee is proposing to implement the 1998 l Edition of Section XI, Subsection IWL in lieu of the 1992 Edition and Addenda. The licensee prepared and submitted a table comparing these requirements. The INEEL staff has reviewed the licensee's submittal and Subsection IWL of the 1998 Code and compared it with the 1992 Edition with the 1992 Addenda. Appendix B of this report contains the licensee's comparison table. It includes the licensee's statements regarding the significance of Code changes and their basis for use as an attemative examination. The table also includes INEEL comments on each change. Significant differences were noted in the areas of personnel qualification and visual examination procedure qualification. These issues are presented in table format as Appendix C and are discussed below.
Visual Examination i The 1992 Edition with 1992 Addenda, Subsection IWL, used VT-lC and VT-3C to designate visual examinations to be performed on concrete containments. In addition, minimum illumination, maximum direct examination distance, and maximum procedure demonstration lower case character height are specified in IWA-2210. The licensee's proposed alternative (1998 Edition) takes exception to the IWA-2210 requirements for visual examination. Consequently, new Code examinations (General Visual and Detailed Visual) have been introduced. The definition of these new Code examinations has been left up to individual licensees. The INEEL staff considers this change to be inconsistent with other Code visual examination prerequisites, and too generic in nature. Therefore, specific details pertaining to the Containment inspection Program at Comanche Peak are required in order to establish an acceptable level of quality and safety in the proposed alternative.
Personnel Oualification The 1992 Addenda has incorporated ANSI /ASNT CP-189 for the qualification of examination personnel. Subsection IWL of the 1998 Edition, takes exception to the certification requirements of the rest of the Code and invokes plant specific personnel certification requirements for visual examination.
By deleting the VT-lC and VT-3C visual examinations, replacing them with the General and Detailed visual examinations, and excluding the personnel qualification requirements of IWA-2300, NDF personnel are not needed to perform containment visual examinations. The Subsection IWL of t& 1998 9
Edition relies on the Responsible Engineer to direct the containment visual examinations. The INEEL staff believes that this approach has the potential for inconsistency with respect to containment ISI. For this reason, the 1998 Edition does not provide an acceptable level of quality. However, in the March 26, 1999, response to the NRC RAI, the licensee was asked to describe the qualification requirements for personnel performing containment visual examinations for Subsection IWE. The licensee has indicated that Subsection IWL personnel qualification will be similar to IWE. The licensee stated:
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" Personnel performing containment visual examinations will be qualified to a program developed specifically for contair. ment examinations. . . . . .The containment visual examination program is I developed from the guidelines of ASNT SNT-TC-I A and ANSI N45.2.6 but is focused on visual l examination and in panicalar items important to containment integrity. The SNT-TC-1 A )
Recommended Practice invoked by the 1986 Edition of ASME Section XI (Code of record for l
CPSES Units 1 and 2) for ASME Code Class 1,2 and 3 ISI examinations does not specifically address visual examinations. The required involvement of the Responsible Individual assures testing and qualification reviews will be performed such that personnel receiving containment visual examination cenification will have a " demonstrated skill, demonstrated knowledge, documented training, and documented experience required to properly perform the duties of a specific job" as required by SNT-TC-1 A. Procedures for inspection and qualification are developed by a TU Electric NDE Level 111. Procedures must be demonstrated to the ANil for capability to detect flaws and degradation levels as defined in the inspection procedures.
The information provided by the licensee appears to describe a Containment Inspection Program that meets the intent of the 1992 Edition for examination personnel qualification requirements.
Conclusion-The licensee has proposed to use the 1998 Edition of Section XI, Subsection IWL, in lieu of the 1992 Edition with the 1992 Addenda as required by 10 CFR50.55a(g)(6)(ii)(B) Preliminary review and evaluation of Subsection IWL of the 1998 Code has revealed several areas that do not appear to provide an equivalent level of quality and safety when compared to the 1992 Addenda. Consequently. l the 1998 Edition cannot be considered an acceptable alternative to the Regulatory requirements.
However, in a letter dated March 26,1999, the licensee provided details of their Containment Inspection Program. Based on the above discussion,it is concluded that the licensee's proposed alternative, to use the 1998 Edition of Subsection IWL, supplemented in the areas of visual examination methods descriptions (similar to IWE) and visual examination personnel qualifications, as described in the licensee's response to the NRC's RAI, will provide an acceptable level of quality and safety and should be authorized pursuant to 10 CFR 50.55a(a)(3)(i).
I 10
< e
- 3. CONCLUSION Based on the review of the proposed alternatives to IWE/IWL Containment inspections and the TU Electric response to the NRC's request for additional information, it is concluded that, for Relief Requests E-1 and L-1, the intent of the Regulations in imposing the 1992 Edition with the 1992 Addenda will be satisfied at Comanche Peak Steam Electric Station, Units I and 2. The licensee's proposed alternatives to use the 1998 Edition of Subsections IWE/IWL, as supplemented by specific details contained in the Comanche Peak Containment inspection Program, will provide an acceptable level of quaiity and safety.
Authorization of the licensee's proposed alterr.ative should not be construed as an endorsement of the 1998 Edition, Subsections IWE/IWL. It is the INEEL staff's opinion that the 1998 Code, Subsections IWE and IWL, do not provide an acceptable level of quality and safety if exclusively implemented.
1 I
l l
I 11
o
- 4. REFERENCES
- 1. Code of Federal Regulations, Title 10, Part 50.
I
- 2. American Society of Mechanical Engineers Boiler and Pressure Vessel Code, '
Section XI, Division 1:
1992 Edition with 1992 Addenda l 1998 Edition
- 3. Letter, dated March 26,1999, C. L. Terry (TU Electric) to Document Control Desk '
(NRC), containing response to NRC request for additional information.
l 1
1 12
1 l
i I
l l
I i
1 i
l i
Appendix A IWE Comparison Table l
l l
App ndix A IWE Comparison Table Changes between IWE Licensee's statement of Paragrap 1992 Edition /1992 Addenda significance and/or basis for use h and the 1998 Edition as an alternative examination Disposition / Comments IWE- no change n/a 1100 lWE- no change n/a 1200 IWE- no change n/a 1210 IWE- Changed " containment" to non signincant Acceptable 1220 " containment system" IWE- no change n/a 1230 IWE- Removed item 3)." single welded These single welded butt joints Examination of welds is optionalin 1231 butt joints from the weld side"- as were removed as a separately listed 10 CFR 50.55a.
a specine item required to remain examination item and is now Acceptable accessible for the life of the plant. included within the stem for the pressure retaining boundary as discussed in the changes to Table IWE-2500-1 below.
Changed wordmg from "80% of Acceptable the surface area" to "80% of the The exclusions from 80%
pressure retaining boundary" and incorporate an existing Table IWE-stated exclus;ons from that 80%. 2500-1 note and clarify that areas made inaccessible during construction are also excluded.
Reworded paragraph b). Acceptable IWE- ASME XI generic change from non significar- Acceptable 1232 repair and/or replacement to repair / replacement activities.
Deleted paragraph (a)(3) Welded joints wcre removed as a Examination of u elds is optional in addressing inaccessible welded separately listed examination item 10 CFR 50.55a.
joints and are now included within the Acceptable !
item for the pressure retaining boundary as discussed in the changes to Table IWE-2500-1 below.
IWE- Added stiffeners and, by The additional areas subject to Appears to be a conservative 1240 reference to IWE 2420, flaws augmentsd examination further change.
accepted by evaluation as areas assure containment inteFrity. Acceptable requinng augmented examination.
IWE- no change n/a 2000 A2
i Ching:s betue a b)E Licensee's st:tement of Pzrrgrip 1992 Edition /1992 addendi significence and/or bisis for use h and the 1998 Edition as an alternative examination Disposition / Comments IWE- Added new Subarticle 2l00 - The additional general requirements *IWE examinations will not require 2100 " General"- to provide reference insoked by reference to IWA 2000 the visual examinations identified in to IWA 2000 with exceptions where none were referenced IWA-2210. Unacceptable, see fromIWA 2210, 2300 2500 previously further assure IWE-2310 below, ar$2600. containment integnty. The
in that related requirements have Unacceptable, see IWE-2330 below.
been incorporated into IWE-2310,- *IWA 2500 excludes repair welds 2320 and 2330. These changes are from the requirements of discussed below. exammation. Acceptable.
- lWA 2600 requires that a weld reference system be established for surface or volumetric examinations.
How eser,IWE-2500(c)(4) requires reproducible grid markings for augmented ultrasonic thickness measurement. Detailsin appropriate sections below.
Acceptable.
IWE- Deleted paragraph c) w hich The deletion of an allowance for an Appears to be a conservatne 2200 provided allowances for the use alternatise examination ensures that change.
of shop or field examinations in proper preservice enaminations are Acceptable lieu of on ute presersice performed and documented.
examinations.
Deleted paragraph g) w hich The deletion of the requirement to A preservice !.aseline inspection is required the condition of new document the condition of '~new" important w nen perfonmng coating to be documented in the non pressure-retaining coatinFs in subsequent visual examinations.
preservice examination record. the preservice examination record Utihties may not hase a sufficient provides for more efficient program bare metal visual examination in implementation without affecting their nuclear coatmgs program.
component integnty.
i ASME XI genenc change from
( repair and or replacement to Non significant Acceptable
( repair / replacement activities.
I IWE- Added new Subarticle -2300 - The paragraphs within this See bebw.
2300 " Visual Examination, Personnel subarticle are considered significant Quahfication and Responsible and contain requirements that either Individual" did not previously exist or that were contained in other areas. Placing l these requirements within Article IWE-2000 further ensures proper
" Examination and inspection" of areas imt artant to containment l inte;nty and provides consistency ,
l
=ich Subsections IWB, IWC and IWD. The specific paragraphs added are discussed below.
A-3
Chinges between IWE Licensee's st:tement of Partgrep 1992 Edition /1992 Addendi signifiernce and/or bisis for use h and the 1998 Edition as an alternative examination Disposition / Comments IWE- Added new paragraph -2310 - a) Added requirements for the Consistency with existing ISI visual 2310 " Visual Examinations"- w hich a) owner to define visual examination examination requirements could states that the owner shall define requirements provides for more proside for an ef0cient internal requirements for visual efficient containment ISI proFrarn program. Howeser, open-ended.
examination of containment implementation by allowing owner-denned visual examination surfaces; examinations that may be more requirements do not provide consistent with existing 151, uniformity and consistency containment coating, maintenance industry wide. b98 Code is rule and Appendix J programs; unacceptable.
b) and c) defines general and b) and c) The VT general detailed visual examinations: and examination is performed to Specifies owner-de0ned acceptance indicate the Feneral condition of the criteria. INEEL does not agree with containment. The VT detailed the philosophy of a new visual examination is performed to examination method for IWE determine the magnitude and extent examinations.1998 Code is of any deterioration or distress. unacceptable.
ReferrinF to visual examinations by new VT general and VT detailed terms does not adsersely affect the integnty of the contamment d) and e) provide the components examined; requirements for the conditions of areas affected by repair / replacement activities, d) and c) Presiously these The 1998 Code does not contain painted or coated areas non exammation requirements did not 2310t e M3) or (4) for bolting and coated areas, pressure retaming exist withm the Amcle IWE-2000 moisture barrier exams. Specific matenals and moisture barriers. but rather only in the acceptance entena must be addressed in the enteria of Anicle IWE-30(X). licensee's program.
Adding thest specific attnbutes here ensure proper containment exammations.
IWE- Added new paragraph 2320- a) The details for the responsible Acceptable 2320 " Responsible Indnidual"- w hich individual quahfication al states the quahtication requirements were previously requirements of the responsible contained in the acceptance indmdual and s:andards of IWE-3510.1.
The duties identified must be j b)The added detailed performed regardless of w ho is j b) defines the responsibihties of responsibilities for the responsible assigned to do them. Howeser, the i the responsible individual for the individual ensure proper 1998 philosophy gises the development of plans and performance of those related responsible individual complete procedures; instruction, training activities. Hasing an indmdual control over the program. Section and approval of visual possessmg the quahfications of a) XI consistency maintains that examination personnel; and performing the responsibihties licensee containment programs meet performance or direction of or b) increases plant quahty and the requirements of Subsection visual examinations; evaluation safety by assuring the reliable IWA.
of results and documenting detection of conditions adverse to results. containment integrity.
A-4
I
[.
L ChInges between IWE Licznsee's strtiment of Paregrep 1992 Edition /1992 Addends significence and/or basis for use
, h and the 1998 Edition as an alternative examination Disposition / Comments I
1WE- Added new paragraph 2330- a) Adding requirements for the Personnel should be qualified in 2330 " Personnel Quahfication" which owner to define personnel accordance with Subsection IWA.
a) states that the owner is quahfication requiremer.ts provides 1998 Code is unacceptable.
responsible for defining the for more efficient containment ISI qualification requirements for program implementation by personnel performing visual permitting personnel performing examinations and containment examinations to be quahfied to written practices that are mose consistent to those used i l for other NDE personnel. l l 1998 Code is unacceptable.10 CFR l 50.55a(b)(x)(B) requires the b) provides minimum b) Providing these details in the qualification of remote visual quahfication requirements that qualification requirements examinations.
u ere previously cont 0i ned in the paragraph focuses the containment acceptance criteria of IWE- visual qualification on areas 3510.1. it.iportant to containment integrity.
IWE- no change ela 2400 IWE. no change n/a 2410 IWE- no change n/a 241I I W E- Deleted a subparagraph The deleted subparagraph Acceptable 2412 discussing decreasing and chmmates duplication with IWA-extending inspection periods. 2400. The added requirements for Added a subparagraph detailing the scheduling of added welds or requirements for the scheduhng components ensures that a of added welds or components. representative sampling of examinations is maintained.
IWE- Removed rep;eired areas as areas Repaired areas that are likely to Appears to be an acceptable 2420 requiring reexaminations during experience accelerated degradation argument regardmg removal of the next successise inspection and aging are already subject to repaired areas from the requirement.
period. augmented examinations per IWE- However, the requirement to 1241. Some repairs may be located reexamine the suspect areas for in non augmented areas and may be three consecutive inspection period necessary to correct physical has been eliminated. Is now damage caused by construction or consistent with Class 2 components. ,
craft activities. Not having to Acceptable repeat examinations of these non augmented repaired areas provides for more efficierit program implementation without adversely !
affecting component integrity. j l
I IWE- Deleted the paragraph - The changes to Table IWE-2500-1 Acceptable 2430 " Additional Examinations"- chminate several exammation whi:h discussed addmg categories. 'Ihe categories that examination items of the same remain all require 1009 category if flaws or areas of examination. Therefore no items j degradation are identified during are available for additional !
an examination. examinations.
I A-5 1
y , Changes between IWE Licznsee's statement of P:rtgrep 1992 Edition /1992 Addinda significance and/or basis for use h and the 1998 Edition as an alternative examination Disposition / Comments i IWE- Reworded the existing The reworded subparagraphs add Acceptable l 2500 subparagraphs consistent with the clanty and provide consistency j previous paragraph changes and within IWE.
i with Table IWE-2500-I changes.
1 Deleted the requirement to Elimination of the paint or coatings examine paint or coatings prior to Not having to perform ASME exam prior to removal has been removal. exammations of non pressure found acceptable provided adequate retaining coatings prior to removal provisions exist in the licensee's provides for more efficient program to examine the base metal containment ISI program prior to. reapplication of the coating, implementation without adversely 1998 Code is unacceptable, affecting the integrity of the pressure retaining base metal being exposed.
Replaced the requirement for one The recommended ultrasonic foot square Frids in thickness Fridime sample requirements measurements with a reference to The new Table IWE 2500-2 provide a more practical approach to Tab!c IWE-2500-2. provides more detailed augmented container examinations.
requirements for thickness Acceptable measurement griddmg and is discussed below.
Added a reference to IWE 5000 Acceptable for preswee tests.
The added reference to IWE-5000 provides direction for the performance of pressure test.
IWE- Deleted a sentence discussing The removal of this sentence The compatibility of paint and 2600 compatibility of paint and coating addressing "new" non pressure coating systems with the existing systems and a requirement to retaining paint and coatings system, and the examination of examine the new paint. provides for more efficient newly applied coatings, should be containment ISI program covered in the beensee's nuclear implementation without adversely coatings program, affecting component inteFrity.
I W E- Removed the word non significant Consistent wnh IWB and IWC 3100 nondestructise from the heading wording.
Acceptable IWE- no change n/a 3110 IWE- Replaced the reference to Table Table IWE-3410-1 and paragraph Under the 1998 scheme. Table 3111 IWE-3410-1 with a reference to IWE-3115 have been deleted and IWE-3410-1 probably isn't subarticleIWE-3500. Removed are discursed below, IWL3500 necessary because there are only reference to paragraph IWE- adequately captures all of the two examination categories and the 3115. information previously contained in acceptance critena are specified in the deleted table and paragraph. Table IWE-2500-1.
Acceptable IWE- Replaced the reference to Table Non significant Same as above.
3112 IWE 3410-1 with a reference to subarticle IWE 3500. ASME XI generic change from repair and or replacement to repair / replacement activities.
A-6
Ch nges betweenIWE Licensee's statIment of P:r:grep 1992 Edition /1992 Addends egnificznce tnd/or basis for use j h and the 1998 Edition as an alternative examination Disposition / Comments t
IWE- Replaced the reference to Table Non significant Same as above.
3114 IWE-3410-1 with a reference to -
subarticle IWE-3500. ASME XI l generic change from repair and or replacement to repair / replacement activities.
lWE- Deleted subparagraph which Non significant there were no The Regulations do not require the 3115 addresses repair programs and . submittal or retention requirements licensees to submit their i evaluations being subject to changed by the deletion of the containment inspection programs.
review by authorities. subparagraph. Acceptable l
IWE- Removed the word Non significant Consistent with IWB and IWC.
3120 nondestructive from the heading. Acceptable IWE. Removed the word The removal of nondestructive is Acceptable l 3121 nondestructive and deleted non significant. The referenced l references to IWE-3124 and subparagraphs did not actually IWE-3125 for the acceptance of apply to the acceptance of flaws for flaw s for continued service, continued service.
IWE- Replaced the references to Table Non significant - the changes are Acceptable 3122 IWE 2500-I and to IWE-3000 for clarity and to reconcile with a reference to subarticle paragraph numbedng. There were IWE-3500. ASME XI generic no submittal or retention change from repair and or requirements changed by the replacement to deletion of the sentence addressing l repair / replacement activities. evaluation reviews.
- Reworded several sentences.
! Deleted sentence which I
addressed evaluations being subject to review by authorities.
l IWE. Replaced the reference to Table Non significant Acceptable 3124 IWE 3410-1 with a reference to subarticle IWE-3500. ASME XI generic change from repair and or replacement to repair / replacement activities.
IWE- Delet.:d subparagraph which Non significant there were no Acceptable 3125 addressed repair programs and submittal or retention requirements reexamination resuhs being changed by the deletion of the subject to review by authorities. subparagraph.
IWE- no change n/a 3130 IWE. Added a statement to the end of The adde j statement clarifies Acceptable 3200 the paragraph that states requirements and climinates supplemental surface or potential duplication or volumetric examinations are contradiction of requirements in required w hen specified by stating that the engineering engineering evaluation. evaluation requirements of IWE-3122 determine what and when supplemental examinations are required.
A-7
Ch nges between IWE Licensee's st:tement of Pirzgrep 1992 Edition /1992 Addinds significince end/or buis for use h and the 1998 Edition as an alternative examination Disposition / Comments IWE- Replaced the reference to Table Non significant Acceptable 3410 IWE-3410-1 with a reference to subarticle IWE-3500.
IWE- no change n/a 3430 I
IWE- no change n/a 3500 l
IWE- Reconciled acceptance standards Previously, examination !
3510 with the IWE-2300 changes requirements were contained in the discussed above and the Table acceptance standards of IWE-3500. ,
IWE 2500-1 changes discussed This has been corrected by the l below by: addition of IWE-2300 as discussed ;
above. Owner defined visual examination l requirements do not provide Adding the requirement that the a) This change directly corresponds uniformity and cor.sistency owner shall define acceptance to the addition of IWE-2310(a) industry-wide.1998 Code is enteria for visual examination of discussed above. unacceptable.
containment surfaces:
Acceptable Remosed the wording for This change directly corresponds to responsible individual and for the addition of IWE-2330 discussed personnel quahfications; abose.
Acceptable Combined 3510.2 and 3510.3 and These changes directly correspond removed specific VT 1 and VT-3 to the addition of IWE-2310<e)(1) examination attnbute wordmg; and (2) discussed above.
and Acceptable incorporated IWE-3511; 3513. These changes correspond to the 3514. and 3515 with changes into changes in the examination IWE-3510. cateFories of Table IWE-2500-1 as discussed below and to the removal of examination requirements from the acceptance standards paragraphs Acceptable per the addition of IWE-2310(e)(3) l and (4) as discussed above. ,
i By the incorporation of 3515 the '
acceptance standards for bolting The resulting acceptance standards were changed from referencing for botting provide more practical material specs and torque or containment 151 program tension limits to conditions implemet tation without adversely affecting leak tight or structural affecting containment leak tight or integrity, structural integrity.
IWE-~ Deleted subparagraph which Examination Category E B has Acceptable l 3511 addressed examination category been incorporated into Examination E-B. Category E-A per the changes to Table IWE-2500-1 discussed below.
A-8 l
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l: Chinges between IWE License 2's statement of hr grep 1992 Edition /1992 Addenda significtnca end/or basis for use h and the 1998 Edition as an ahernative examination Disposition / Comments IWE- Renumbered subparagraph to The subparagraph was renumbered Acceptable 3512 IWE-3511. Reconciled based on the deletion of previous acceptance standards with the IWE-3511 as discussed above.
IWE.2300 changes discussed Previously examination above and the Table IWE-2500-1 requirements were contained in the changes discussed below, acceptance standards of IWE-3500.
This has been corrected by the addition ofIWE-2300 as discussed l above. Owner defined acceptance criteria
- do not provide consistency through Added the requirement that the out the industry.1998 Code is a owner shall define acceptance This change directly corresponds to unacceptable.
criteria for visual examination of the addition of IWE-2310(a) containment surfaces; discussed above.
Acceptable Combined 3512.2 and 3512.3 with changes into 3511.2 and These changes directly correspond removed specific VT-1 to the addition of IWE-2310(e)(1) examination attribute wordmg; and (2) discussed above and and eliminate potential duplication or Acceptable contradiction of requirements.
Reworded ultrasonic examination This change is fr.: latity and is paragraph. non-significant.
IWE- Deleted subparagraphs IWE- Examination Categories E D, E-F Acceptable 3513 3513,-3514, and -3515 m hich and E-G have been incorporated IWE- addressed examination Categories into Examination Category E A per 3514 E-D, E-F, and E-G respectively. the changes to Table IWE-2500-1 .
IWE- discussed below. -
3515 IWE- no change n/a 4100
)
IWE- no change n/a
$200 i l
IWE- no change n/a j 5210 IWE- ASME XI generic change from Non significant Acceptable 5220 repair and or replacement to repair / replacement activities.
IWE- ASME XI generic change from Non significant the requirement to Acceptable 5221 repair and or replacement to meet the requirements of Appendix
! repair / replacement activities. J paragryu referenced is not Removed the quotation of 10 affected by removing the quoted CFR 50 Appendix J paragraph App J paragraph.
IV.A.
IWE- ASME XI generic change from Non significant Acceptable 5222 repair and or replacement to repair / replacement activities.
l A-9 l
l 3
Chinges bet *een IWE - Licensee's statement of P.tr:grap 1992 Edition /1992 Addends significince c d/or basis for use h and the 1998 Edition as an alternative examination Disposition / Comments IWE- Replaced a reference to IWA. The addition of specific IWE Acceptable 5240 5240 with requirements to examination requirements during perform detailed visual pressure testing in lieu of examination of referencing IWA general repair / replacement areas during requirements focuses requirements pressure tests. on issues specific to containment integrity and therefore provides added assurance of the integrity of repaired / replaced areas.
IWE. Changed Corrective Measures to Non significant Acceptable 5250 Corrective Action in the heading.
ASME XI generic change from repair and or replacement to repair / replacement activities. ,
IWE- no change n/a 7100 Table no chanFe n/a IWE-2411-1 .
Table Replaced the separate entries for Non significant The previous Acceptable IWE- l' and successise intervals with requirements for the 1" and 2412-1 one entry for Allintervals. successise intervals were identical.
Therefore. combining the entries does not affect any requirements.
I A-10
r Chingis between IWE Licznsee's striement of P regrap 1992 Edition /1992 Addends significance and/or hisis for use h and the 1998 Edition as an altunative examination Disposition / Comments Table Revised all examination IWE- categories.
2500-1 Removing the requirement to Acceptable. Appendix J, Option A.
Examinat item El.ll: Revised frequency coordinate examinations with Type requires periodic (one each period) ion of examination from " prior to A tests allows for more efficient Type A tests. Appendix J Option Category each type A test" to "1009e" containment 151 program d,is based on historical l E-A during each period". implementation without adversely performance and requires periodic affecting containment integrity. visual inspection for Type A tests.
CFR requires a general visual once l cach period.
i Item El.12: Redesignated item Replacing the accessible surface Changing " accessible surface areas" l from " accessible surface areas" to area designation (which is included . to " wetted surfaces of submerged "weited surfaces of submerged in El.ll) with wetted surface areas areas" essentially eliminates any l areas". Replaced examination (which were previously included in detailed visual examination method VT-3 with general visual. El.12 footnote 4) does not requirements for structures that are climinate or reduce any required part of reinforcing structure (i.e.,
examination areas. Requiring a stiffeninF nngs, manhole frames, general VT in lieu of a VT-3 and remforcement around openings, eliminates the more detailed VT of areas with satisfactory general VT The change to general visual results. The performance of the VT removes the emphasis on general willidentify any areas of containment welds.
deterioration or distress. Any areas identified will then be subject to a VT detailed examination to determine the magnitude and extent of those conditions. The VT general therefore, allows for more item El.20: Added BWR to item efficient containment 151 program description. Replaced implementation without adversely examination method VT-3 with affecting containment inteFrity. Relaxation of visual examination Feneral visual. requirements.
1998 Code is unacceptable.
This item is not applicabic to CPSES containments.
A-11 l
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I Ch:nges between IWE Lie:nsee's stat: ment of P r:gr:p 1992 Editiord 1992 Addend:n significence end/or basis for use h and the 1998 Edition as an alternative examination Disposition / Comments Table item El.30; Added item for Moisture barriers were previously Acceptable I W E- . moisture barriers with a general included in Examination Category 2500-1 l VT required each period. E D with a VT-3 required each (continue interval. Examining moisture d) barriers more frequently will assure rel;able detection of conditions adverse to containment quality.
Acceptable All items no.'s - Replaced reference to IWE-3510 for Non significant - Previously some examination requirements with examination requirements were IWE-2310. contained in IWE 3500. They now exist in IWE 2300 as discussed Previous visual examination abose. requirements included VT.I and Notes - Revised to specifically VT-3.1998 Edition specifies include welds and bolting as part general visual. 'Ihis is a significant of the pressure retaining Welds and bolting were previously relaxation in Code requirements.
boundary requiring examination. included in Examination Categories 1998 Code is unacceptable.
E-B. E-F and E-G. Includmg these items in the examination cateFory for the containment pressure retaining boundary prosides for more efficient program implementation without adversely affecting component ia:egrity.
Table Deleted examination category Pressure retaining welds are now Acceptable. VT-1 visual IWE- which addressed pressure included in Examination Category examination has been replaced with 2500-1 retaining welds. E-A as addressed above. a general visual examination. May not be sufficient to detect weld- ,
Examinat related discontinuities. However, ion 10 CFR 50.55a makes containment Category weld inspections optional. 4 E-B i
l A-12
r Ch:nges between IWE Lic:nsee's st:.tement of P;r:grep 1992 Edition /1992 Addinda significance and/or basis for use h and the 1998 Edition as an alternatise examination Disposition / Comments Table item E4.ll: Replaced Referring to the visual examination Replaced VT-1 with detailed visual.
IWE. examination method VT-1 with by the VT detailed term does not 2500-1 detailed visual. adversely affect the integrity of the 1998 Code is unacceptable. {
containment components examined.
Examinat j ion !
Category The added wording clarifies E-C ltem E4.12: Added grid line inspection requirements and ensures Acceptable. The recommended intersections to description of repeatabihty in the location of ultrasonic gridline sample parts examined. Changed subsequent thickness measurement requirements provide a more examination method from points, practical approach to augmented l volumetric to ultrasonic container examinations.
l thickness. )
Previously no references existed for examination requirements. These Allitem no.'s Added requirements have been added to Acceptable examination requiremes IWE-2300 and .2500 as discussed j paragraph number referenc6. above. Adding new references and I Updated acceptance standard updating paragraph numbers ensure references. proper requirements are applied to examinations.
l Three inspection periods cover a ten Acceptable. Areas equiring year interval. Performing augmented examination after an Notes - Changed note 2 from augmented examinations for at lea <.t engineering evaluation of Haws or requiring augmented examination two periods while continuing areas of degradation should be until an area remains unchanged general visual examinations each monitored sufficiently to assure that l for three consecutive inspection period provides for more efficient they are no longer suspect. lWB l periods to the next inspection program implementation without monitors for 3 periods. Consistent penod. Deleted note 3 which adversely affecting component with Class 2 requirements.
discusseu inspection deferrals. integnty. Deletion of note 3 is non significant.
Examinat Deleted examination category Moisture barriers have been Visual examination acceptance ion which addressed seals, gaskets included in Examination Category criteria no longer exist for moisture l Category and moisture barriers. E- A as addressed above. Seals and barriers.
! ED gaskets previously required examination once per an interval with effectively an acceptance criteria of leak tightness. Leak tight integrity is verified during each
- 10CFR50 App. J leak test.
l Rcmoving these inspection items provides for more efficient program implementation without adversely affecting component integrity.
Examinat Deleted examination category Dissimilu metal welds are now Acceptable. 507r of the total i' ion which addressed dissimilar metal included in Examination Category number of dissimilar metal welds Category welds. E-A as addressed above. were to receive a surface
, E-F examination. The 1998 Examination Category E A does not specifically address dissimilar metal welds and all surfaces receive a general visual. CFR does not require examination of containment welds.
A-13 i-
Chinges between IWE Licensee's stitement of Par:gr:p 1992 Edition /1992 Add:ndi signific:nce and/or bisis for use h and the 1998 Edition as an alternative examination Disposition / Comments Examinat Deleted examination category Pressure retaining bolting is now Acceptable.1992 required VT-1 ion which addressed pressure included in Examination Category visual of boltinF when a connection Category retaining bolting. E-A as addressed above, was disassembled. The 1998 E-G Edition requires general visual, in place, with no requirement when the joint is disassembled. Appendix J test verifies the bolted connection integrity.
Examinat Deleted examination category Appendix J testing is mandated by Acceptable ion which addressed 10CFR50 plant technical specifications.
Category Appendix J testing for all Removing this duplicate EP pressure retaining components. requirement from IWE does not adversely affect component integnty.
Table Added new Table IWE-2500 The new requirements provide for Acceptable IWE- Ultrasonic Thickness consistency and repeatability in ,
2500-2 Measurements For Augme .ed obtaining thickness measurements 1 Examinations - w hich detaih and thus assure 'he reliable griddmg and thickness detection of cond:tions adscrse to measurement requirements. containment integrity.
1 Table Deleted table. Non significant - the contents of the Acceptable IWE- previous table are adequately 3410-1 addressed in IWE-3500 l
A-14 t
l t
F r
I I
l l
Appendix B IWL Comparison Table l
l 1
l l
l App:ndix B I
IWL Comparison Table )
1 l
Changes between IWL Licensee's statement of I Paragrap 1992 Edition /1992 Addenda significance and/or basis for use h and the 1998 Edition as an alternative examination Disposition / Comments IWL- ASME Section XI generic Non significant None 1100 wording change from repair, l replacement and or modification }
terms to repair / replacement activities.
IWL- no change n/a 1200 IWie no change n/a 1210 IWL- no change n/a 1220 I W L- Changed " Inspection" to Non sigmficant )
2l00 " General"in heading.
(a) Provided reference to IWA- (a)The additional Feneral IWL examinations will not require 2000 with exceptions from IWA- requirements imoked by reference the visual examinations identified in 2210 and -2300 for visual to IWA-2000 where none were IWA-2100. Personnel will not have examinations and for referenced previously further assure to be certified to CP-189 (IWA-qualification of visual containment integnty. The 2300). The 1998 Code examination personnel. exceptions from IWA 2210 and unacceptable.
IWA-2300 are significant in that the related previous requirements have been changed and incorporated into IWL-2310. The IWL-2310 changes are addressed below.
(b) Provided requirements for This paragraph has not been Authorized Nuclear Inservice included in the 1998 Edition but lapectors. (b) The addition of Authorized was in the licensee's "rew rite" Nuclear Inservice Inspector I requirements ensures proper !
Inspector qualification.
IWL- no change n/a i i
2200 IWL- no change n/a l 2210 l l
IWL- no change n/a 2220 IWL- ASME Section XI generic change Non significant Acceptable 2230 from repair and or replacement to repair / replacement activities.
IWL- no change n/a 2300 B-2
~
r l App:ndix B s .
! Changes between IWL Licensee's statement of i Paragrap 1992 Edition /1992 Addenda significance and/or basis for use j h and the 1995 Edition as an alternative examination Disposition / Comments IWL- These changes are elated to the 2310 IWl 2100 changes addressed above and are considered significant.
l (a) Replaced VT-lc and VT-3C (a) Containment examinations are The 92 Edition Exam Cat. L A, visual examination terminology intended to identify indications of specifies a VT-3C visual for l with new VT general and VT significant conditions over large concrete and a VT-lC visual for detailed examination terms. areas. The VT Feneral examination suspect areas. IWL-2310 identifies is performed to indicate the general VT-lC visual as the detailed structural condition for determining examination perfonaed after the concrete deterioration and distress. VT-3C visual identifies suspect l The VT detailed examination is areas.
performed to determine the The 1998 Code is unacceptable, magnitude and extent of the deterioration.
(b) Replaced reference to IWA.
2210 for illumination levels, examination distances and (b) Direct visual examination is not Specific illumination and resolution
! resolution requirements with practical on all areas of details from the licensee's program specific examination attributes. containment surfaces. The previous should be provided.
VT requirements precluded the The 1998 Code is unacceptable.
ability to demonstrate that remote visual examination was equivalent to direct visual examination.
Providing specific examination attributes in IWL as opposed to referencing the generic requirements ofIWA focuses the l
visual examination on areas important to the verification of containment integnty.
1 IWL- (c) Repiaeed reference to IWA- (c) Invoking requirements Consistency with existing ISI visual f l 2310 2300 for concrete examination comparable to CP-189 would examination requirements could personnel quali0 cation complicate containment ISI provide for an efficient internal requirements with provisions for program development without a program. However,open-ended, the owner to define the compensating increase in plant ow ner-defined visual examination examination personnel quality or safety. Requiring an requirements do not provide qualification requirements. owner defined program provides for uniformity and consistency more efficient program industry-wide. The 1998 Code is l implementation by permitting unacceptable.
i' personncI performing containment examinations to be qualified to written practices that are more consistent to those used for other NDE personnel.
B-3
l App:ndix B Changes between IWL Licensee's statement of Paragrap 1992 Edklon/1992 Addenda significance and/or basis for use i h and the 1998 Edition as an alternative examination Disposition / Comments l
IWL- Changed wording slightly. Non significant - clanfies wording. Acceptable 2320 Made the ASME Section XI Non significant generic change from repair and or replacement to repair / replacement activities.
The added pressure test Added a responsibility for the responsibilities for the Responsible Responsible Engineer to review Engineer ensures proper certain pressure test procedures. performance of pressure testing activities.
IWL- no change n/a 2400 IWL- no change n/a 2410 IWL- no change n/a 2420 IWL- Changed wording for sites with Non significant - clarifies wording Acceptable 2421 more than one plant. Changed and accommodates plant life frequencies by adding "and every extensions.
10 years thereafter".
lWL- no change n/a 2500 IWL- Changed heading. Non significant. Acceptable 2510 Changed wording consistent with Non significant the changes to IWL-2310 addressed abose.
The added details ensure proper Added two subparagraphs tendon anchcrage area providing more detailed examinations. However,these examination requirements for changes do not apply to CPSES tendon anchorage areas. containments.
IWL- no change n/a 2520 IWL- no change n/a 2521 IWL- Changed the heading and added a The added details ensure proper Acceptable 2522 subparagraph to address tendon tendon examinations. Ilowever, elongation. those changes do not apply to CPSES.
B-4 l
App:ndix B Changes between IWL Licensee's statement of Paragrap 1992 Edition /1992 Addenda significance and/or basis for use h and the 1998 Edition as an etternative examination Disposition / Comments IWL- no change n/a 2523 IWL- Changed wording consistent with Non significant. Acceptable 2524 the changes to IWL-2310 addressed above.
IWL- Changed wording for sample Non signincant. Acceptable 2525 analysis.
IWL- Added a subparagraph addressing The added details ensure tendon Acceptable 2526 replacement of corrosion integrity. However, these changes protection medium. da not apply to CPSES.
IWL- no change n/a 3100 IWL- no change n/a 3110 IWL- ASME Section XI generic change Non significant. Acceptable 311I from repair and or replacement to replace / replacement activities.
lW L- no change n/a l
3112 I W L- ASME Section XI generic change Non significant. Acceptable 3113 from repair and or replacement to replace / replacement activities.
lWL- no change n/a 3220 IWL- Added acceptance criteria The added details ensure proper Acceptable 3221 attnbutes for tendon elongation. tendon examinations. However.
free water content and corrosion these changes do not apply to protection medium reduction. CPSES containments.
IWL- no change n/a 3222 IWL- ASME Section XI generic change Non significant.
3223 from repair and or replacement to replace / replacement activities.
IWL- no change n/a 3300 l
4 l IWL- Added applicabihty for other Non signincant. Acceptable i 3310 plants at the same site.
l l
ASME Section XI generic change Non significant.
from repair and or replacement to replace / replacement activities.
l B-5 I
l
r l App:ndix B I
Changes between IWL Licensee's statement of Paragrap 1992 Edition /1992 Addenda significance and/or basis for use h and the 1998 Edition as an alternative examination Disposition / Comments IWL- Deleted paragraph which Non significant - there were no Acceptable. The Regulations do not l 3320 addressed engineerinF submittal or retention requirements require the licensees to submit their l evaluations being subject to changed by the deletion of the containment inspection programs.
review by authorities. subparagraph.
I W L- ASME Section XI generic change Non significant - all related repair Acceptable 4000 from repair and or replacement to and replacement requirements have replace / replacement activities. been consolidated into IWL-4000.
IWL- no change n/a 4100 l IWL- Exempted grease cups and Non significant - the exempted Acceptable 4110 installation screws from the items are non structural items and score. do not apply to CPSES containments.
ASME Section XI generic chanFe Non significant.
from repair and or replacement to replace / replacement activities.
IWL- ASME Section XI generic change Non significant. Acceptable 4200 from repair and or replacement to replace / replacement activities.
Added a new paragraph -4210 to The added requirements ensure Acceptable require Repair / Replacement proper repair / replacement plan Plans to be developed under the development. l direction of a Responsible l EnF ineer. !
IWL- Changed paragraph number to - Non sigmficant Acceptable 4210 4220 remosed the word repair from headmg and changed referenced paragraph numbers consistent with the addition of a new paragraph -4210 above.
Non significant Changed wording consistent with the changes to IWL-2310 ;
addressed above.
Non siFnificant ASME Section XI generic change from repair and or replacement to replace / replacement activities.
Non significant i
Changed repair material to new matenal in several places.
l W L- Changed paragraph number to - Non significant Acceptable 4220 4230.
l B-6
E App:ndix B l
Changes between IWL Licensee's statement of Paragrap 1992 Edition /1992 Addenda significance and/or basis for use h and the 1998 Edition as an alternative examination Disposition / Comments IWL. Changed paragraph number to - Non significant. Acceptable 4230 4240 and clarified by removing the word repair.
Ncn tignificant.
ASME Section XI generic change '
from repair and or replacement to replace / replacement activities.
The added detailed requirements Added detailed requirements for ensure proper repair / replacement the contents of a plan development for post.
repaidreplacement plan. tensioning systems. However, these changes do not apply to CPSES containments.
IWL- ASME Section XI generic change Non significant. Acceptable 4300 from repair and or replacement to replace / replacement activities.
I W L- ASME Section XI generic change Non siFnificant. Acceptable 1- 5100 from repair and or replacement to i replace / replacement activities.
l IWL- no change n/a 5200 l IWL. ASME Section XI Feneric change Non significant. Acceptable 5210 from repair and or replacement to replace / replacement activities.
IWL- no change n/a l 5220 IWL- Changed wording by removing Non significant - the removed Acceptable 5230 some specific IWE related wording was IWE specific and is requirements while maintaining contained in IWE-5000.
the reference to IWE-5000.
IWL- Deleted paragraph which Non significant - the schedule of Acceptable 5240 addressed the scheduling of pressure tests are contained in IWE-pressure tests. 5000 as referenced in IWL-5230.
IWL- Changed wording regarding the The clanfied role of the Acceptable 5250 role of the Responsible Engineer Responsible Engineer ensures in pressure test activities. proper pr.:ssure test procedures and examinations.
ASME Section XI generic change from repair and or replacement to Non significant.
replace / replacement activities.
Changed VT terminology consistent with the changes to The VT terminology changes are IWL-2310 addressed above, discussed in IWL-2310 above.
B-7 L
c I
App 2ndix B
\
Changes between IWL Licensee's statement of Paragrap 1992 Edition /1992 Addenda significance and/or basis for use h and the 1998 Edition as an alternative examination Disposition / Comments IWL- Changed heading from Corrective Non significant Acceptable l 5260 Measures to Correction Action.
l ASME Section XI generic change Non significant from repair and or replacement to replacc/ replacement activities.
lWL- ASME Section XI generic change Non significant Acceptable 53(0 from repair and or replacement to replace / replacement activities.
IWL- Deleted Article including IWL- Non significant - all related repair Acceptable 7000 7000, -7110. -7120 consistent and replacement requirements have l with the IWL-4000 changes been incorporated into IWL-4000. l above.
Table Changed item Ll.ll from all Changing item Ll.Il provides for Acceptable IWL- areas to all accessible areas. more practical examination 2500-) implementation than previous requirements.
Changed VT exam method terminology consistent with the The VT terminology changes are paragraph IWL-2310 changes discussed in IWL-2310 above. j above. ;
1 Table Changed inspection periods to Non significant - accommodates Acceptable IWL- state every 5* year in lieu of plant life extensions for tendon 2521-1 listing out each year and changed examinations. However,these note 2 for having to meet requirements do not apply to acceptance criteria from "each of CPSES containments.
the earlier inspections" to "for the last 3 inspections'.
Table Added optional test methods for Non significant - additional test Acceptable IWL- corrosion protection medium method options provides for more 2525-1 analysis. practical test implementation.
However, these requirements do not apply to CPSES containments.
B-8
r l
1 i
l I
Appendix C Comanche Peak Supplements to 1998 Code l
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, . . Appendix C Comanche Peak Supplemental Information to the 1998 Code Edition Initial 1998 Code Proposed supplemented Proposed Alternative Alternative (March 26,1999 RAI response) Recommendations / Comments
)1 IWE-2310 " Visual Examinations"- a) General Visual criteria the owner shall define requirements for visual examination of containment developed from VT-3
" face 5-procedures that are used to examine ASME Class 1,2, and 3 components. i Pressure retaining I bolting recording criteria developed from ;
the VT-1 procedure used for Class 1 bolting.
Moisture barriers examined for tears, cracks or damage that permits moisture to intrude.
Detailed Visual exam 1
criteria developed from VT-1 and VT-3 procedures IWE-2330 " Personnel Qualification"- The Containment Visual Examination Authorize per 10 CFR 50.55a(a)(3)(i).
a) the owner shall define the Program is developed from the qualification requirements for personnel Fuidelines of SNT-TC-1 A and ANSI performing visual examinations. N45.2.6. Certified personnel will hase
" demonstrated skill, demonstrated knowledge, documented training, and documented experience required to properly perform the duties of a specificjob."
IWE-2500 - Deleted the requirement to None.
examine paint or coatings prior to removal.
IWE-3510.1 and IWE 3511.1 -The See IWE-2310 abose. Authonze per 10 CFR 50.55a(a)(3)(i).
owner shall define acceptance criteria for sisual examination of containment surfaces.
Table IWE-2500-1 Notes - Revised to See criteria defined in IWE-2310 Authorize per 10 CFR 50.55a(a)(3)(i).
include welds and bolting as part of the abose.
I pressure retaining boundary requiring examination.
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