ML20212C292
| ML20212C292 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/16/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20212C291 | List: |
| References | |
| NUDOCS 9909210208 | |
| Download: ML20212C292 (13) | |
Text
r f*%ey$
l UNITED STATES p
[
j NUCLEAR REGULATORY COMMISSION i
4 WASHINGTON, D.C. 20666-0001
'+9.....,o SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR RELIEF REQUESTS FROM ASME CODE SECTION XI REQUIREMENTS AS ENDORSED BY 10 CFR 50.55a FOR CONTAINMENT INSPECTION ENTERGY NUCLEAR GENERATION COMPANY PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293
1.0 INTRODUCTION
Title 10 of the Code of Federal Regulations (CFR) Part 50.55a(g) requires nuclear power facility piping and components to meet the applicable requirements of Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (hereafter referred to as the Code).Section XI of the Code specifies Code acceptable repair. methods for flaws that exceed Code acceptance limits in piping that is in-service. A Code repair is required to restore the structuralintegrity of flawed Code piping, independent of the operational mode of the plant when the flaw is detected. Those repairs not in compliance with Section XI of the Code are non Code repairs. However, the implementation of required Code (weld) repairs to ASME Code Class 1,2 or 3 systems is often impractical for nuclear licensees since the repairs normally require an isolation of the system requiring the repair, and often a shutdown of the nuclear power plant.
Alternatives to Code requirements may be used by nuclear licensees when authorized by the Director of the Office of Nuclear Reactor Regulation if the proposed alternatives to the requirements are such that they are shown to provide an acceptable level of quality and safety in lieu of the Code requirements (10 CFR 50.55a(a)(3)(i)), or if compliance with the Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety (10 CFR 50.55a(a)(3)(ii)).
A licensee may also submit requests for relief from certain Code requirements when a licensee has determined that conformance with certain Code requirements is impractical for its facility (10 CFR 50.55a(g)(5)(iii)). Pursuant to 10 CFR 50.55a(g)(6)(i), the Commission will evaluate l
determinatic s of impracticality and may grant relief and may impose attemative requirements 1
as it deterrr, les is authorized by law.
l
2.0 BACKGROUND
in Federal Register Notice 61 FR 154, dated August 8,1996, the Nuclear Regulatory Commission (NRC) announced the amendment to its regulation,10 CFR 50.55a (rule). The rule incorporated by reference the 1992 Edition with 1992 Addenda of Subsections IWE and 9909210208 990916 PDR ADOCK 05000293 P
{
n t
2 lWL of Section XI of the ASME Code. Subsections IWE and IWL provide the requirements for inservice inspection (ISI) of Class CC (concrete containments), and Class MC (metallic containments) of light-water cooled power plants. The effective date for the amended rule was Lt.ptember 9,1996, and it requires the licensees to incorporate the new requirements into their ISI plans and to complete the first containment inspection by September 9,2001. However, a licensee can subrr.it a request for relief from one or more requircrrants of the regulation (or the endorsed code requirements) with proper justification. The previsidn for granting relief is incorporated in the regulation.
This evaluation addresses the merits of the requests for relief (Ref.1) proposed by Boston Edison Company (BECo) for the Pilgrim Nuclear Power Station (Pilgrim).
3.0' EVALUATION OF RELIEF REQUESTS
' 3.1 RELIEF REQUEST RR E1 Component identifications Seals and gasket of Class MC pressure retaining component, Examination Category E-D, item Numbers E5.10 and E5.20 of IWE 2500," Examination and Pressure Test Requirements,"
Table IWE-2500-1 ASME Section XI,1992 Edition,1992 Addenda.
Code Reauirements and Relief Reauest IWE-2500, Table IWE-2500-1, Examination Category E-D, requires seals and gaskets on
- airlocks, hatches, and other devices to be visually examined, VT-3, once each interval to ensure containment leak-tight integrity. Relief is requested from performing the Code-required visual examination, VT-3, on the above identified MC seals and gaskets in accordance with 10 CFR 50.55a(a)(3)(ii).
Basis for Relief
. Title 10'of the Code of Federal Regulations part 50.55a was amended, as cited in the Federal
. Register (61 FR 41303), to require the use of the 1992 Edition,1992 Addenda, of Section XI when performing containment examinations. The penetrations discussed below contain seals and gaskets:
A' Electrical Penetrations Electrical penetrations include electrical power, signal, and instrument leads with the penetrating sleeves welded to the primary containmer:t vessel. Medium-voltage power
. penetrations at Pilgrim have primary seals made of aluininum-ceramic material. The low voltage power, control and instrumentation cable, and coaxial cable penetrations uee a bonding resin to maintain the leaktight integrity of the containment penetrating sleeves. Each penetration is pressurized to 45 psig with dry nitrogen to maintain and monite integrity and to prevent the intrusion of moisture into the penetration.
- These seals and gaskets cenmi b2 inspected without disassembly of the penetration to Cdn access to the seals and pskets.
)
, B.
Drywell Head, Drywell Head Manway, Drywell Personnel and Equipment Hatches, CRD Service, Torus Access and Drywell Stabilizer Access Hatches The personnel hatches utilize an inner and outer door with gasket surfaces to ensure a leak tight integrity. These hatches also contain other gaskets and seals such as the handwheel shaft seals, electrical penetrations, blank flanges, and equalizing pressure connections which require disassembly to gain access to the gaskets and seals.
The other hatches listed above utilize seals and/or gaskets in Appendix J testable joints to maintain leak-tight integrity. Seals and gaskets receive a 10 CFR 50 Appendix J, Type B test. As noted in 10 CFR 50 Appendix J, the purpose of Type B tests is to measure leakage of containment penetrations whose design incorporates resilient seals, gaskets, sealant compounds, and electrical penetrations fitted with flexible metal seal assemblies. Examination of seals and gaskets requires the joints, which are proven J
adequate through Appendix J testing, to be disassembled. For electrical penetrations, this would involve a pre-maintenance Appendix J test, de-termination of cables at electrical penetrations if enough cable slack is not available, disassembly of the joint, removal and examination of the seals and gaskets, reassembly of the joint, re-termination of the cables if necessary, post-maintenance testing of the cables, and a post maintenance Appendix J test of the penetration. The work required for the containment hatches would be similar except for the de-termination, re-termination, and testing of cables. This imposes the risk that equipment could be damaged. The 1992 Edition,1992 Addenda, of the ASME Code Section XI recognizes that disassembly of joints to perform these examinations is not warranted. Note 1 in Examination Category
' E-D was modified in the 1995 Edition of ASME Code Section XI to state that sealed or gasket connections need not be disassembled solely for performance of examinations.
{
However, without disassembly, most of the surface of the seals and gaskets would be inaccessible.
1 For those penotrations that are rout:nely disassembled, a Type B test is required upon final assembly and prior to start-up. Since the Type B test will ensure the leak-tight integrity of primary containment, the performance of the visual examination would not heresse the level of safety or quality.
i Set!s and gaskets are not part of the containment pressure boundary under current Code rules (NE-1220 (b)). When the airlocks and hatches containing these materials are tested in accordance with 10 CFR 50, Appendix J, degradation of the seal or gasket material would be revealed by an increase in the leakage rate. Corrective rr,casures would be applied, and the component retested. Repair or replacement oi seals and gaskets is not subject to Code (1992 Edition,1992 Addenda) rules in accordance with Paragraph IWA-4111(b)(5) of ASME Section XI.
The visual examination of seals and gaskets in accordance with IWE-2500, Table IWE-2500-1 is a burden without any compensating increase in the level of safety or quality.
Relief is requested from performing thu Oode required visual examination, VT-3, on the
. above identified MC seals and gaskett L Pecordance with 10 CFR 50.55a(a)(3)(ii).
s-
. Compliance with the specifi% 94uirements of this section would result in hardship or un'.'sual difficulty without a composating ;ncrease in the level of quality and safety.
Testing the seals and gaskeb i..;. aordance with 10 CFR 50, Appendix J will provide adequate assurance of the leak-tight integrity of the seal and gaskets.
Alternative Examinations J
The leak-tightness of seals and gaskets will be tested in accordance with 10 CFR 50, Appendix J. TM 10 CFR 50, Appendix J, Type B testing is performed at least once each inspection interval.
Staff Evaluation of RR E1:
The staff does not fully agree with the licensee's statement that the penetration seals and gaskets are not part of the containment pressure boundary. However, the staff concludes that the licensee's proposed alternative examination (Type B testing required by 10 CFR Part 50, Appendix J) of the containment penetration seals and gaskets (including those of electrical penetrations) will verify the leak-tight integrity of the seals and gaskets and provides ree=onable assurance of structuralintegrity. Therefore, the staff concludes that the alternative is authorized pursuant to 10 CFR 50.55a(3)(i) on the basis that the proposed alternative provided an acceptable level of quality and safety.
3.2 RELIEF REQUEST RR E2 Component identification All components subjected to examination in accordance with Subsection IWE of the 1992 Edition,1992 Addenda ASME Section XI.
Code Requirements Subarticle IWA-2300," Qualification of Nondestructive Examination Personnel,"(NDE Personnel) requires qualification of nondestructive examination personnel to CP-189 - 1991,
" Standard for Qualification and Certification of Nondestructive Testing Personnel," as amended
' by the ASME Code. Relief is requested from the provisions of this Subarticle.
Basis for Relief As cited in the Federal Register (61 FR 41303),10 CFR 50.55a was amended to require the use of the 1992 Edition,1992 Addenda, of Section XI, when performing containment examinations. In addition to the requirements of Subsection lWE, this also imposes the requirements of Subsection IWA, General Requirements,1992 Edition,1992 Addenda of Section XI. Subarticle IWA-2300, requires qualification of nondestructive examination
. personnel to CP-189, as amended by Subarticle IWA 2300.
-l
' A written practice based on the requirements of CP-189, as amended by the requirements of the Subarticle IWA 2300, to implement Subsection IWE duplicates efforts already in place for all other subsections. The Pilgrim third 10-year ISI program is written to meet the 1989 Edition of Section XI. Subarticle IWA 2300 of this edition requires a written practice based on
5-SNT-TC-1 A, " Personnel Qualification and Certification in Nondestructive Testing,' as amended by the requirements of Subarticle IWA 2300. Further, Subarticle IWA 2300 of the 1992 Edition, 1992 Addenda, states, " Certifications based on SNT-TC-1 A are valid until recertification is required."
Visual examination is the primary nondestructive examination method required by Subsection IWE. Neither CP-189 nor SNT-TC-1 A specifically includes visual examination.
Therefore, the Code requires qualification and certification to comparable levels as defined in CP 189 or SNT-TC-1 A, as applicable, and the licensee's written practice. Ultrasonic thickness examinations may also be required by Table IWE 2500-1. These examinations are relatively simple and do not require an extensive training and qualification program. Therefore, use of CP-189 in place of SNT-TC-1 A will not improve the capability of examination personnel to perform the visual and ultrasonic thickness examinations required by Subsection IWE.
Development and administration of a second program would not enhance safety or quality and would serve as a burden, particularly in developing a second written practice, tracking of certifications, and duplication of paperwork. This duplication would also apply to Nondestructive
)
Examination (NDE) vendor programs. Updating the 1992 Edition,1992 Addenda, fo.
Subsections IWB, lWC, etc., would require a rimilar request for relief.
j Relief is requested in accordance with 10 CFR 50.55a(a)(3)(ii). Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Alternative Examinations Examinations required by Subsection IWE shall be conducted by personnel qualified and certified to a written practice based on SNT-TC 1 A and the 1986 Edition, of ASME Section XI.
Visual examination personnel will receive specific training in conducting containment examinations.
Staff Evaluation of RR E2 The current Pilgrim program plan for qualifying and certifying NDE personnel is based on the 1989 Edition of the ASME Section XI requirements for Class 1,2, and 3 components. The 1989 Edition of the Code requires the use of SNT-TC 1 A for the qualification and certification of NDE personnel. Thus, the staff recognizes that the licensee will have to develop a second program for qualifying and certifying its NDE personnel for containment inspection in accordance with Subarticle IWA-2300 of the 1992 Edition of the Code. Moreover, as pointed out by the licensee, most of the containment examinations required by Subsection IWE are VT-3, general visual. Volumetric examination is required during the containment surface augmented inspection. As the licensee's current procedure for qualifying and certifying NDE l
personnel, based on the provisions of SNT-TC-1 A, is acceptable for Class 1,2, and 3 i
components, the use of NDE personnel qualified by the procedure for containment augmented examination will not compromise the quality of the examination.
1 As the VT-3 visual examination is the basic examination technique for containment inspection, i
the licensee has developed procedures (1) for qualification of the visual examination personnel
E
., for vision tests; and (2) illumination requirements in accordance with IWA 2320 of the 1992 Edition and Addenda, as modified by the Rule.
Considering these factors, the staff concluden, that the it.'oosition of the requirement of Subar1icle IWA-2300 (1992 Edition) for containmem b- :etion will subject the licensee to hardship without a compensating increase in the level of quality and safety. The staff concludes that the licensee's proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(ii).
3.3 RELIEF REQUEST RR E3 Component Identification All Class MC, Paragraphs IWE 2420(b) and IWE 2420(c) successive examination requirements for components found acceptable for continued service.
Code Requirement (s) and Relief Request Paragraphs IWE 2420(b)'and IWE-2420(c) of the 1992 Edition,1992 Addenda of ASME Section XI, require that when component examination results require evaluation of flaws, evaluation of areas of degradation, or repairs in accordance with Article IWE-3000, "Acceptance Standards," and the component is found to be acceptable for continued service, the areas containing such flaws, degradation, or repairs shall be reexamined during the next
- inspection period listed in the schedule of the inspection program of Paragraph IWE-2411,
" Inspection Program A," or Paragraph IWE-2412, " Inspection Program B,"in accordance w."h Table IWE-2500-1, Examination Category E-C. Relief is requested from the requirements of Paragraphs IWE-2420(b) and IWE 2420(c) to perform successive examination of repairs.
. Basis for Relief As cited in the Federal Register (61 FR 41303),10 CFR 50.55a was amended to require the use of the 1992 Edition,1992 Addenda of Section XI, when performing containment examinations. The purpose of a repair is to restore the component to an acceptable condition fo continued service in accordance with the acceptance standards of Article IWE 3000.
Pe ragraph IWA-4150, " Verification of Acceptability," requires the licensee to conduct an av aluation of the suitability of the repair including consideration of the cause of failure, if the repair has restored the component to an acceptable condition, successive examinations are not warranted. If the repair was not suitable, then the repair does not meet the Code requirements and the component is not acceptable for continued service. Neither Paragraph IWB 2420(b), Paragraph IWC-2420(b), nor Paragraph IWD 2420(b) requires a repair to be subject to successive examination requirements. Furthermore, if the repair area is subject to accelerated degradation, it would still require augmented examination in accordance with Table IWE 2500-1, Examination Category E-C.
The successive examination of repairs in accordance with Paragraphs IWE-2420(b) and IWE-2420(c) constitutes a burden without a compensating increase in the levsl of quality or safety..
q 7-Relief is requested in accordance with 10 CFR 50.55a(a)(3)(ii). Compliance with tne specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality arEl safety.
The requirement to perform successive examinations following repairs has been removed in the rewrite of Subsection IWE of ASME Section XI.
Alternate Examinations Successive examinations in accordance with Paragraphs IWE-2420(b) and IWE-2420(c) are not required for repairs made in accordance with Article IWA-4000. Therefore, the alternative to conduct an evaluation of the suitability of the repair in accordance with Paragraph 1WA 4150 is proposed.
Stsit Evaluation of RR-E3 x 64 Code requires licensees to verify the.ndequacy of repairs, the staff agrees with the licensee inet successive examinations after 'epairs d6 not provide an additional safety benefit.
This position is consistent with Code requirements for ASME Code Class 1,2, and 3 components.
The staff concludes that the alternative to the Code requiremenis in lWE 2420(b) and 9420(c) related to successke examination of repairs provides reasonable assurance of structural integrity and is authorized pursuant to 10 CFR 50.55a(a)(3)(ii) on the basis that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety, i
3.4 RELIEF REQUEST RR E4 Components identification Class MC pressure retaining bolting.
Code Requirements and Relief Request ASME Section XI,1992 Edition with the 1992 Addenda, Table IWE-2500-1, Examination Category E-G, Pressure Retaining Botting, item 8.20 requires a bolt torque or tension test on bolted connections that have not been disassembled and reassembled during the inspection interval.' Relief is requested from ASME Section XI 1992 Edition,1992 Addenda, Table IWE-2500-1 Examination Category E-G, Pressure Retaining Bolting, item 8.20.
Basis for Re,ief As cited in the Federal Register (61 FR 41303),10 CFR 50.55a was amended to require the use of the 1992 Edition,1992 Addenda, of ASME Section XI when performing containmant examinations. Bolt torque or tension testing is required on bolted connections that have not been disassembled and reassembled during the inspection interval. Deterrnination of the
, I torque or tension value would rewire that the bolting be un-torqued and then re-torqued or
. re-tensioned.
Each containment penetration receives a 10 CFR 50 Appendix J, Type B test in accordance with the specified testing frequencies. As noted in 10 CFR 50 Appendix J, the purpose of Type B tests is to measure leakage of containment penetrations whose design incorporates resilient seals, gaskets, sealant compounds, and electrical penetrations fitted with flexible metal seal assemblies. The parformance of the Type B test itself proves that the bolt torque or tension remains adequate to provide a leak rate that is within acceptable limits. The torque or tension value of bolti% only becomes an issue if the leak rate is excessive. Once a bolt is torqued or tensior,t d, it is not subject to dynam'c loading that could cause it to experience significant change. Appendix J testing and visual inspection is adequate to demonstrate that
' the design function is met. Torque or tension testing is not required for any other ASME Section XI, Class 1,2, or 3 bolted connections or their supports as part of the ISI program.
Relief is requested in accordance with 10 CFR 50.55a(a)(3)(ii). Un-torquing and subsequent i
re-torquing of bolted connections which are verified not to experience unacceptable leakage through 10 CFR 50, Appendix J, Type B testing result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Alternate Examination (s)
The following examinations and tests required by Subsection IWE ensure the structural integrity and the leak tightness of Class MC pressure retaining bolting, and are proposed as the altemative to the required examinations.
0)
Exposed surfaces of bolted connections shall be visually examined in accordance with requirements of Table IWE-25001, Examination Category E G, Pressure Retaining Bolting, item No. E8.10; and b
(2)
Bolted emnections shall meet the pressure test requirements of Table IWE-2500-1, Examination Category E-P, All Pressure Retaining Components, item E9.40.
Staff Evaluation of RR E4 The staff concludes that Type B testing under 10 CFR Part 50, Appendix J demonstrates that i bolt torque or tension is adequate to provide a leak rate within acceptable limits. Un-torquing and subsequent re-torquing of bolted connections that are verified to experience acceptable leakage through Type B testing would result in unnecessary examinations that do not enhance safety. The staff finds that the alternative provides reasonable assurance of structuralintegrity
- and is authorized pursuant to 10 CFR 50.55a(a)(3)(ii) on the basis that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety.
l
.g.
3.5 REllEF REQUEST RR-E5
- Component identification
' All Class MC, Subarticle IWE-2500(b) visual examinations per Teble IWE-2500 of painted or
- coated containment component prior to removal of paint or coatings.-
Code Requirements:
- ASME Section XI,1992 Edition,1992 Addenda, Subarticle IWE-2500(b) requires that when paint or coatings are to be removed, the paint or coatings shall be visually examined in
. accordance with Table IWE-2500 prior to removal. Relief is requested from the requirements of
-lWE 2500(b).
Basis for Relief I
As cited in the Federal Register (61 FR 41303),10 CFR 50.55a was amended to require the use of the 1992 Edition,1992 Addenda, of ASME Section XI when performing containment
- examinations. Paint and coatings are not part of the containment pressure boundary under the current Code rules as they are not associated with the pressure retaining function of the component (Paragraph NE 2110 (b)(5) of ASME Section Ill). The containment interior surfaces are painted to prevent rusting and exposed to an inert atmosphere at all tima except during refueling or maintenance outages. The exterior surfaces of the torus, vent syn, tem, and drywell head are also painted and exist in a controlled atmosphere (secondary containment).
. Neither paint nor coatings contribute to the structural integrity or leak tightness of the containment. Furthermore the paint and coatings on the containment pressure boundary were not subject to the Code rules when they were originally applied and are not subject to ASME Section XI rules for repair or replacement in accordance with IWA-4111(b)(5). Degradation or discoloration of the paint or coating materials on containment would be an indicator of potential degradation of the containment pressure boundary. Additional measures would have to be
' employed to determine the nature and extent of any degradation,if present. The application of ASME Section XI rules for removal of paint or coatings when unrelated to an ASME Section XI repair or replacement activity, is a burden without a compensating increase in quahty or safety.
Relief is requested in accordance with 10 CFR 50.55a(a)(3)(i). Pilgrim Specifications C-98 A, M530, and M531 currently control containment coating activities at Pilgrim and provide an adequate level of quality and safety as they conform to Regulatory Guide 1.54, ANSI Standards N101.4 and N5.12.: All containment coating work at Pilgrim is performed by qualified vendors
- who are approved to provide coating services subject to 10 CFR 50 Appendix B controls on special processes. Additionally, the general visual walkdown required by subsection IWE of ASME Section XI to be performed once every inspection period will provide an adequate periodic assessment of the condition of containment coatings, i
i The requirement to inspect coatings prior to removal has been removed in the rewrite of Subsection lWE of ASME Section XI.
y
s. Alternate Examinations The condition of the containment vessel base material will be verified prior to the application of new paint or coating as required by the Pilgrim maintenance program. If degradation is identified, additional measures will be applied to determine if the containment pressure boundary is affected. Repairs to the primary containment boundary, if required, will be conducted in accordance with Code rules.
4 Staff Evaluation of RR-E5
. As indicated in the staff evaluation of RR E6, the staff finds that the Pilgrim coating program is adequate to monitor the proper removal of the old paint and application of the new coat;ngs.
Performing additional examinations prior to removal of the old paint and documenting its condition (in addition to the licensee's program being subjected to the quality assurance requirements of 10 CFR Part 50 Appendix B), would impose a burden on the licensee without a compensating increase in quality or safety. On this basis, the licensee's alternative coating program is authorized pursuant to 10 CFR 50.55a(a)(3)(i).
I 3.6 RELIEF REQUEST RR E6 Code Requirements and Relief Request ASME Section XI,1992 Edition,1992 Addenda, Subsection IWE-2200(g) requires that when paint or coatings are reapplied, the condition o' the new paint or coating shall be documented in the preservice examination records. Relief is requested from the requirement to perform a preservice inspection of new paint or coatings.
Basis for Relief Paint and coatings are not part of the containment pressure boundary under the current Code rules as they are not associated with the pressure retaining function of the component (Paragraph NE 2110(b)(5) of ASME Section lil). Neither paint nor coatings contribute to the structural integrity or leak tightness of the containment. Furthermore, the paint and coatings on the containment pressure boundary were not subject to the Code rules when they were originally applied and are not subject to ASME Section XI rules for repair or replacement in accordance with IWA-4111(b)(5).
-The adequacy of applied coatings is verified through the inspections and tests performed by qualified vendors approved by BECO to provide coating services at Pilgrim subject to 10 CFR 50 Appendix B controls on spe:ial processes. Primay containment coating activities at Pilgrim are currently controlled by Pilgrim Specifications C-98a, M530, and M531 which conform to Regulatory Guide 1,54 and ANSI Standards N 101.4 and N5.12. Additionally, the general visual walkdown required by Subsection IWE to be performed once each inspection period w:ll provide
. an adequate periodic assessment of the condition of containment coatings. Recording the condition of reapplied coatings in the preservice record does not substantiate the containment structuralintegrity. Should deterioration of the coating in the reapplied area occur, the area will require additional evaluation regardless of the preservice record. Recording the condition of new paint or coatings in the preservice records does not increase the level of quality and safety of the containment.
, In SECY 96-080, " Issuance of Final Amendment to 10 CFR Section 50.55a to incorporate by Reference the ASME Boiler and Pressure Vessel Code (ASME Code),Section XI, Division 1, Subsection IWE and Subsection lWL," dated April 17,1996, response to Comment 3.2 about IWE-2200(g) states, "In the NRC's opinion, this does not mean that a visual examination must be performed with every application of paint or coating. A visual examination of the topcoat to determine the soundness and the condition of the topcoat should be sufficient." This is currently accomplished through the inspections required by Specifications C-98A, M530, and M531 and performed by qualified vendors who are approved to provide coating services at Pilgrirn subject to 10 CFR Part 50 Appendix B controls.
Relief is requested in accordance with 10 CFR 50.55a(a)(3)(i). The inspection and test performed in accordance with Pilgrim Specifications C-98A, M50, and M531 provide an adequate level of quahty and safety since the specifications conform to Regulatory Guide 1.54 and ANSI Standards N101.4 and N5.12. The requirement to perform a preservice examination when paint or coatings are reapplied has been removed in the rewrite of Subsection IWE of ASME Section XI.
Altemate Examinations Reapplied paint and coatings on the containment vessel will be examined in accordance with j
Pilgrim Specifications C 98A, M530, and M531. Although repairs to paint or coatings are not I
subject to the repair / replacement rules of ASME XI (Inquiry 97-22), repairs to the primary containment boundary, if required, would be conducted in accordance with Code rules.
Staff Evaluation of RR E6 The staff does not fully agree with the licensee's belief that the quality and integrity of the paint applied to containment surfaces are not relevant to the containment's functionalintegrity. In Table 3 of the Final Rule (SECY 96-080), there are numerous examples where the containment integrity was found to be questionable because of the degradation of the applied paint and coating, and corrosion of the metal. However, the staff considers the attemative program, as stated by the licensee, for application of paint or coating, its inspection, and its quality assurance provisions to be adequate for protecting the inside steel surfaces of the Pilgrim containment and provide reasonable assurance of structuralintegrity. The staff concludes that the attemative proposed by the licensee is authorized pursuant to 10 CFR 50.55a(a)(3)(i) on the basis that it provides an acceptable level of quality and safety.
4.0 CONCLUSION
Based on our review of the information provided in the licensee submittal, the staff finds that for RR-E1, RR-ES,' and RR E6, the altematives proposed by the licensee are authorized pursuant to 10 CFR 50.55a(a)(3)(i) on the basis that the altematives provide an acceptable level of quality and safety. For RR-E2, RR E3, and RR E4, the staff finds that the attematives
Tl
[
l proposed by the licensee are authorized pursuant to 10 CFR 50.55a(a)(3)(ii) on the basis that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety.
Principal Contributor: Sang Bo Kim Date: September 16,1999 l
)
)
k
. 5.0 REFERENCE 1.
Letter, L. F. Alexander, Boston Edison to NRC," Request for Relief from the 1992 Edition 1992 Addenda of ASME Section XI, Subsection IWE Related Containment inspection Program" dated November 23,1998
)
I i
i l
)