NG-99-0491, Requests Relief from Noted Requirements,For Relief Requests MC-R002 Through MC-R006,MC-P001 & NDE-R015,rev 1.Approval Is Requested Prior to Refueling Outage 16,scheduled to Begin on 991008
| ML20205L296 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 04/02/1999 |
| From: | Peveler K IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT |
| To: | NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NG-99-0491, NG-99-491, NUDOCS 9904140220 | |
| Download: ML20205L296 (27) | |
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- s FM 'A' L L i A N T Esb3 UTIUTIES, its vuw inc.
IES' Utilities a2ErN[fcN Palo, I A 52324 -9785 a 1 .85
-- ..m.oum ,gyom NG-99-0491 Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station 0-PI-17 Washington, DC 20555-0001
Subject:
Duane Arnold Energy Center Docket No: 50-331 Op. License No: DPR-49 Relief Requests MC-R002, MC-R003, MC-R004, MC-R005, MC-R006, MC-R007, MC-P001 and NDE-015, Revision 1
Reference:
Letter dated March 23,1998, from NRC to L. Liu (lES),
Safety Evaluation of the Third 10-Year Inservice Inspection Interval Program Plan Requests for Relief for the Duane Arnold Energy Center.
File: A-100, A-286 By Federal Register Notice dated August 8,1996 (61 Federal Register 41303), the NRC amended 10CFR50.55a to incorporate by reference the 1992 Edition with 1992 Addenda of Subsection IWE of Section XI of the ASME Boiler and Pressure Vessel Code. Subsection IWE provides requirements for inservice inspection (ISI) of Class MC (metallic containments).- The purpose of this letter is to request relief from certain of these requirements. Similar relief was granted for the Davis-Besse Nuclear Power Station (Docket Number 50-346), pursuant to 10 CFR 50.55a(a)(3), by an NRC Safety Evaluation dated June 30,1998. Davis-Besse had submitted those reliefrequests on behalf of an Electric Power
- Research Institute (EPRI) project for the preparation of a Generic IWE/IWL Program and Guide.
The Duane Arnold Energy Center (DAEC) relief requests and the corresponding approved lf i Davis-Besse reliefs are as follows: i e DAEC relief request MC-R002 (corresponding to Davis-Besse RR-El), -
e - DAEC relief request MC-R003 (corresponding to Davis-Besse RR-E7),
- DAEC relief request MC-R004 (corresponding to Davis-Besse RR-E3),
4 e DAEC relief request MC-R005 (corresponding to Davis-Besse RR-E4), and
- DAEC relief request MC-R006 (corresponding to Davis-Besse RR-E6).
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April 2,1999 NG-99-0491 Page 2 IES Utilities also requests approval of DAEC relief request MC-P001, which is a modification of EPRI standard relief request number 6.
In addition, IES Utilities requests approval of Revision 1 to relief request NDE-R015. This relief was approved by the referenced letter and allows the use oithe 1989 Edition with 1989 Addenda to govern repair and replacement procedures for Class 1,2 and 3 components and their supports. Since the DAEC containment repair / replacement program is in accordance with the 1992 Edition with 1992 Addenda of Subsection IWE, this results in the maintenance of two separate repair / replacement programs to two different Codes. NDE-R015, Revision 1 modifies the relief to allow the use of the 1992 Edition with 1992 Addenda for repair and replacement procedures for Class 1,2,3 and MC pressure retaining components and their supports. As discussed in the attached revised relief request, the maintenance of two separate repair / replacement programs results in unnecessary burden while providing no increase in quality or safety.
Authorization to use the alternative requirements described in Code Case N-601 is requested in relief request MC-R007. As stated in footnote 6 to 10CFR50.55a, the use of Code Cases may be authorized by the Director of the Office of Nuclear Reactor Regulation, pursuant to 10CFR50.55a(a)(3). According to 10CFR50.55a(a)(3), the proposed alternatives must provide an " acceptable level of quality and safety." Use of the aforementioned Code Case does so, as discussed in the attached relief request MC-R007.
Pursuant to the provisions of 10CFR50.55a, IES Utilities hereby requests approval of these relief requests prior to Refueling Outage (RFO) 16, currently scheduled to begin on October 8,1999.
Sin r ly, Ov
'enneth E. Peveler Manager, Regulatory Performance Attachment cc: C. Rushworth (w/a)
E. Protsch (w/o)
- 3. Franz (w/o)
D. Wilson (w/o)
B. Mozafari (NRC-NRR)(w/a)
J. Dyer (Region Ill)(w/a)
NRC Resident Office (w/a)
Docu (w/a) l
i Attachment to NG-99-0491 Page1of25 RELIEF REQUEST NUMBER: MC-R002 COMPONENT IDENTIFICATION Code Class: MC
References:
IWE-2500 Table IWE-2500-1 Examination Category: E-D ltem Numbers: E5.10 and E5.20
Description:
Seals and Gaskets :
Component Numbers: N/A CODE REOUIREMENT ;
l IWE-2500, Table IWE-2500-1 requires seals and gaskets on airlocks, hatches, and other devices to be visually examined (VT-3) once each interval to assure containment leak-tight integrity.
The Acceptance Standard, (IWE-3513) states " Seals and gaskets shall be examined for wear, i damage, erosion, tear, surface cracks, or other defects that may violate the leak-tight integrity.
l Defective items shall be repaired or replaced".
BASIS FOR ALTERNATIVE 10 CFR 50.55a was amended in the Federal Register (61FR41303) to require the use of the 1992 Edition,1992 Addenda, of Section XI when performing containment examinations. The penetrations discussed below contain seals and gaskets.
Electrical Penetrations:
Electrical penetrations use a header plate attached to e containment penetration nozzle flange with redundant 0-rings between the header p a and flange face. Modules through which electrical conductors pass are installe I in the header plate. One type, manufactured by Amphenol uses seals and gaskets to assure leak tight integrity. A second type, manufactured by Conax uses a set of compression fittings. Replacement modules for the Amphenol penetrations uso combination of 0-rings and compression fittings. Each penetration is pressurized with dry nitrogen to maintain and monitor integrity and to prevent the intrusion of mois ure into the penetration. These seals and gaskets cannot be inspected without disassembly of the penetration to gain access to the seals and gaskets.
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Attachment to NG 99-0491 Page 2 of 25 4
. l Containment Personnel. Eauipment. and Emernency Escape llatches:
1 The Personnel, Equipment, and Emergency Escape flatches 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 l the gaskets and seals. I Seals and gaskets receive a 10 CFR 50 Appendix J test. As noted in 10 CFR 50 Appendix J, the purpose is to measure leakage of containment or penetrations whose design incorporates resilient l seals, gaskets, sealant compounds, and electrical penetrations fitted with flexible metal seal l assemblies. Although not required by the Code, practical examination considerations of seals and gaskets require the joints, which are proven adequate through Appendix J testing, to be l disassembled. For electrical penetrations, this would involve a pre-maintenance Appendix J test, determination 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 cable, and a post maintenance Appendix J test of the penetration. The work required for the containment hatches would be similar except for the determination, re-termination, and testing of cables. This imposes the risk that equipment could be damaged. The 1992 Edition,1993 Addenda, of Section XI, IWE-2500-1, Category E-D (note 1) states that sealed or gasket connections need not be disassembled solely for performance of examinations. Category E-D was modified in the 1995 Edition of 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.
For those penetrations that are routinely disassembled, the gaskets are considered safety-related, and inspected during receiving inspection looking for cuts or tears and maintenance personnel perform a final examination prior to installation. In addition, a Type B test is required upon final assembly and prior to start-up. Since the Type B test will assure the leak tight integrity of primary containment, the perfonnance of the visual examination would not increase the level of safety or quality.
Seals and gaskets are not part of the containment pressure boundary under current Code rules (NE-1220(b)). When airlocks and hatches containing these materials are tested in accordance with 10 CFR 50, Appendix J, degradation of the seal or gasket material would be revealed by an increase in the leakage rate. Corrective measures would be applied and the component retested.
Repair or replacement of seals and gaskets is not subject to Code (1992 Edition,1992 Addenda) rules in accordance with Paragraph IWA-4111(b)(5) of ASME Section XI. 1 l !
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'. Attachment to NG-99-0491 l
- - Page 3 of 25 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. Specific reliefis requested in accordance with 10CFR 50.55a(a)(3)(i) on the basis that the proposed alternative would provide an acceptable level of quality and safety. Testing the seals and gaskets in accordance with 10CFR50, Appendix J will provide assurance of the leak-tight integrity of the seals and gaskets.
The requirement to examine seals and gaskets has been removed in the 1997 Addenda of ASME Section XI. This addenda has been approved by the ASME Main Committee and was published in the 1998 Edition.
ALTERNATE EXAMINATION The 1 .k-tightness of seals and gaskets will be tested in accordance with 10 CFR 50, Appendix J.
No additional alternatives to the visual examination, VT-3, of the seals and gaskets will be performed.
APPLICABLE TIME PERIOD Reliefis requested for the first ten year interval of the Containment Inspection Program for the DAEC.
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NG-99-0491 Page 4 of 25 RELIEF REQUEST NUMBER: MC-R003 COMPONENT IDENTIFICATION Code Class: MC
References:
IWE-2000 Table IWE-2500-1 Examination Category: E-G ltem Number: E8.20
Description:
Torque Testing of Bolting Component Numbers: All Class MC Pressure Retaining Bolting CODE REOUIREMENT IWE-2500, Table IWE-2500-1 requires a bolt torque or tension test for those bolted connections that have not been disassembled and reassembled during the interval.
BASIS FOR RELIEF 10CFR50.55a was amended in the Federal Register (61FR41303) to require the use of the 1992 Addenda, of Section XI when performing containment examinations. Bolt torque or tension testing is required on bolted connections that have not been disassembled and reassembled during the inspection interval. Determination of the torque or tension value would require that the boltitig be untorqued and then re-torqued or re tensioned.
Each penetration receives a 10CFR 50 Appendix J Type B test in accordance with the testing frequencies specified in Appendix J. As noted in 10CFR 50 Appendix J, the purpose of Type B tests is to measure leakage of containment penetrations whose design incorporates resilient seals, gaskets, sealant compounds, and electrical penetrations fitted with flexible metal seal assemblies.
The performance of the Type B test itself proves that the bolt torque or tension remains adequate to provide a leak rate that is within acceptable limits. The torque or tension value of bolting only becomes an issue if the leak rate is excessive. Once a bolt is torqued or tensioned, it is not subject to dynamic loading that could cause it to experience significant change. Appendix J testing and visual inspection is adequate to demonstrate that design function is met. Torque or tension testing is not required on any other ASME Section XI, Class 1,2, or 3 bolted connections or their supports as part of the inservice inspection program.
The requirements to perform bolt torque or tension tests has been removed in the 1997 Addenda of ASME Section XI. This addenda has been approved by the Main Committee and was issued in the 1998 Edition.
Reliefis requested in accordance with 10CFR50.55a(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.
'. Attachment to NG-99-0491 Page 5 of 25 ALTERNATE EXAMINATION The following examinations and tests required by Subsection IWE ensure the structural integrity and the leak-tightness of Class MC pressure retaining bolting, and, therefore, no additional alternative examinations are proposed. The following examination will be conducted however:
(1) Exposed surfaces of bolted connections shall be visually examined in accordance with requirements of Table IWE-2500-1, Examination Category E-G, Pressure Retaining Bolting, item No. E8.10, and (2) Bolted connections shall meet the pressure test requirements of Table IWE-2500-1, Examination Category E-P, All Pressure Retaining Components, Item E9.40, and (3) A General Visual Examination of the entire containment once each inspection period shall be conducted in accordance with 10CFR50.55a(b)(2)(x)(E).
APPLICABLE TIME PERIOD Reliefis requested for the first ten-year interval c f the Containment Inspection Program for i DAEC.
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Attachment to NG-99-0491 Page 6 of 25 RELIEF REQUEST NUMBER: MC-R004 CON"PONENT IDENTIFICATION Code Class: MC
Reference:
IWE-2200(g)
Examination Category: N/A Item Number: N/A
Description:
Preservice Examination of Reapplied Paint or Coatings Component Numbers: All Class MC Painted or Coated Surfaces CODE REOUIREMENT <
IWE-2200(g) requires that when paint or coatings are reapplied, the condition of the new paint or coating shall be documented in the preservice examination records.
HASIS FOR Al TERNATIVE Paint and coatings are not part of the containment pressure boundary under current Code rules (Paragraph NE-2110 (b) of ASME Section III). Neither paint nor coatings contribute to the structural integrity or leak tightness of the containment. Funhermore the paint and coatings on the containment pressure boundary were not subject to Code rules when they were originally applied and are not subject to ASME XI rules for repair or replacement in accordance with IWA-4111(b)(5). The adequacy of applied coatings is verified through the DAEC's design controls.'
Recording the condition of reapplied coating in the preservice record does not substantiate the containment structural integrity. Should deterioration of the coating in the reapplied area occur, the area will require additional evaluation regardless of the preservice record. Recording the condition of new paint or coating in the preservice records does not increase the level of quality and safety of the containment.
SECY 96-080, response to Comment 3.2 about IWE-2200(g) states, "In the NRC's opinion, this 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 DAEC's design controls.
Reliefis requested in accordance witn 10CFR50.55a(a)(3)(i). The DAEC's design controls currently provide an adequate level of quality and safety.
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- IES Utilities' response to Generic Letter 98-04 summarizes the design controls for coatings / paint as they apply to the DAEC (NG-98-1901, dated 11/11/98).
Attachment to NG-99-0491 Page 7 of 25 The requirement to perform a preservice examination when paint or coatings are reapplied has been removed in the 1997 Addenda of ASME Section XI. This addenda has been approved by the ASME Main Com.mittee and was issued in the 1998 Edition.
l AI, TERNATE EXAMINATION l
The paint and coatings in the containment will be examined in accordance with the DAEC's '
design controls. Although repairs to paint or coatings are not subject to the repair / replacement rules of ASME XI (Inquiry 97-22), repairs to the primary containment boundary, if required, would be conducted in accordance with ASME Section XI Code rules.
APPLICAllLE TIME PERIOD Reliefis requested for the first ten-year interval of the Containment inspection Program for DAEC.
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, Attachment to NG-99-0491 Page 8 of 25 RELIEF REQUEST NUMBER: MC-R005 COMPONENT IDENTIFICATION C : Class: MC
References:
IWE-2500(b)
Examination Category: N/A Item Number: N/A
Description:
Visual Examination of Painted or Coated Containment Components Prior to Removal of Paint or Coatings Component Numbers: All Class MC Painted or Coated Surfaces CODE REOUIREMENT 1
IWE-2500(b) requires that when paint or coatings are to be removed, the paint or coatings shall be visually examined in accordance with Table IWE-2500-1 prior to removal, i
HASIS FOR ALTERNATIVE 10CFR50.55a was amended in the Federal Register (61FR41303) to require the use of the 1992 Edition,1992 Addenda, of Section XI when performing containment examinations. Paint and coatings are not part of the containment pressure boundary under current Code rules (Paragraph NE-2110 (b) of ASME Section III). The interiors of containments are painted to prevent rusting.
Neither pai"* nor coatings contribute to the structural integrity or leak tightness of the containment. Furthermore the paint and coatings on the containment pressure boundary were not subject to Code rules when they were originally applied and are not subject to ASME 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 XI rules for removal of paint or coatings when unrelated to a Section XI repair or replacement activity is a burden without a compensating increase in quality or safety.
Reliefis requested in accordance with 10CFR50.55a(a)(3)(i). DAEC's design controls
- currently provide an adequate level of quality and safety. l l
- IES Utilities' response to Generic Letter 98-04 summarizes the design controls for I coatings / paint as they apply to the DAEC (NG-98-1901, dated 11/11/98).
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l ALTERNATE EXAMINATION .
l The paint and coatings in the containment will be examined in accordance with the DAEC's design controls and the requirements of Examination Category E-A. If degradation of the
- coating is identified, additional measures will be applied to determine if the containment pressure boundary is affected. Although repairs to paint or coatings are not subject to the repair / replacement rules of ASME XI (Inquiry 97-22), repairs to the primary containment boundary, if required, would be conducted in accordance with ASME Section XI Code rules. )
l APPLICABLE TIME PERIOD Reliefis requested for the first ten-year interval ef the Containment Inspection Program for DAEC.
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. Attachment to NG-99-0491 Page 10 of 25 RELIEF REQUEST NUMBER: MC-R006 COMPONENT IDENTIFICATION Code Class: MC
References:
IWE-2420 (b) and (c)
Examination Category: All Category Numbers item Number: AllItem Numbers ;
Description:
Successive Examinations of Repaired Areas j Component Numbers: All components CODE REOUIREMENT ASME Section XI,1992 Edition,1992 Addenda, IWE-2420(b) and IWE-2420(c) requires that l when component examination results require evaluation of flaws, areas of degradation, or repairs in accordance with IWE-3000, and the component is found to be acceptable for continued service, the areas containing such flaws, degradation, or repairs shall be reexamined during the next inspection period listed in the schedule of the inspection program ofIWE-2411 or IWE-2412, in accordance with Table IWE-2500-1, Examination Category E-C.
Reliefis requested from the requirement ofIWE-2420(b) and (c) to perform successive examination of repairs.
HASIS FOR RELIEF 10 CFR 50.55a was amended in the Federal Register (61FR41303) to require the use of the 1992 Edition,1992 Addenda, of Section XI when performing containment examinations. The purpose of a repair is to restore the component to an acceptable condition for continued service in accordance with the acceptance standards ofIWE-3000. Paragraph IWA-4150 requires the owner to conduct an evaluation of the suitability of the repair including c4 nsideration of the cause of failure.
If the repair has restored the component to an acceptable condition, successive examinations are l
not warranted. If the repair was not suitable, then the repair does not meet Code requirements i 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 l 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 lWE-2420(c) constitutes a burden without a compensating increase I in quality or safety.
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Attachment to NG-99-0491 Page11of25 SECY 96-080, in the resolution to Comment 3.3, states, "The purpose ofIWE-2420(b) is to manage components found to be acceptable for continued service (meaning no repair or replacement at this time) as an Examination Category E-C component... If the component had been repaired or replaced, then the more frequent examination would not be needed."
Pursuant to 10CFR50.55a(a)(3)(ii), reliefis requested on the basis that compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
The requirement to perform successive examinations following repairs has been removed in the 1997 Addenda of ASME Section XI. This addenda has been approved by the ASME Main Committee and was issued in the 1998 Edition.
APPLICABLE TIME PERIOD Reliefis requested for the first ten year interval of the Containment Inspection Program for the l DAEC.
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. Attachment to NG-99-0491 Page 12 of 25 RELIEF REQUEST NUMBER: MC-R007 COMPONENT IDENTIFICATION Code Class: MC
References:
Table IWE-2500-1 Examination Category: E-A Item Number: El.12, El .20
Description:
Extent and Frequency of VT-3 Component Numbers: All Components CODE REOUIREMENT.
ASME Section XI,1992 Edition,1992 Addenda,IWE-2500-1 requires the VT-3 visual examinations be performed 100% at the end of the interval for Items El.12 and El.20.
BASIS FOR ALTERNATIVE Code Case 'N-601 " Extent and Frequency of VT-3 Visual Examination for Inservice Inspection of Metal Containments,Section XI, Division 1" provides an alternative to the Code Requirements of performing 100% ofItems El.12 and El.20 at the end of the interval. The l
Duane Arnold Energy Center (DAEC) feels it is more important to perform visual examinations i
of the Accessible Surface Areas of the Containment and Vent System during the interval rather than at the end of the interval. This way the integrity of the Containment and Vent System at the l DAEC can be better monitored between the Integrated Leak Rate Tests (Appendix J) and the
! Visual Examination VT-3 required by IWE-2500-1. The successive inspection requirements of IWE-2420 will be maintair.ed.
Pursuant to 10CFR50.55a(a)(3)(i), reliefis requested on the basis that the attemative examination would result in an acceptable level of quality and safety.
l l ALTERNATIVE EXAMINATION (S):
The DAEC will perform the VT-3 visual examinations of the Accessible Surface Areas of the
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containment structure and Vent Systems in accordance with Code Case N-601. This code case ;
provides an alternative to perform the visual examinations at any time during the interval, provided the requirements for successive inspections in IWE-2420 are met.
APPLICAHL.E TIME PERIOD l
Reliefis requested for the first ten year interval of the Containment Inspection Program for the DAEC.
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, Attachment to NG-99-0491 Page 13 of 25 RELIEF REQUEST NUMBER: MC-P001 COMPONENT IDENTIFICATION Code Class: MC
Reference:
IWE-5240 Examination Categories: All Category Numbers Item Numbers: All item Numbers
Description:
VT-2 Examinations following Repairs / Replacements /
Modifications Component Numbers: All Components 1
CODE REOUIREMENT Paragraph IWE-5240 of the 1992 Edition,1992 Addenda of ASME Section XI requires a VT-2 visual examination be performed in conjunction with the pressure testing following all repairs, replacements, or modifications.
Minor repairs as defined in IWE-5222 can be deferred until the next scheduled leakage test, i provided nondestructive examination is performed in accordance with the approved repair progr$n. Minor repairs consist of the following:
- 1) welds of attachments to the surface of the pressure retaining boundary
- 2) repair cavities, the depth of which does not penetrate the required design wall more than 10%; and
- 3) welds attaching penetrations that are NPS 1 or smaller HASIS FOR RELIEF Pursuant to 10CFR50.55a(a)(3)(ii), reliefis requested on performing VT-2 examinations for ;
minor repairs on the basis that compliance with the specified requirements would result in l hardship or unusual difficulty without a compensating increase in the level of quality and safety.
10 CER 50.55a was amended in the Federal Register (61FR41303) to require the ur of the 1992 j Edition,1992 Addenda, of Section XI when performing containment examinations. Paragraph i IWE-5210 states that except as noted within Paragraph IWE-5240, the requirements of Article IWA-5000 are not applicable to Class MC components. Paragraph IWE-5240 states that the requirements (corrected from IWA-5246 to IWA-5240 in the 1993 Addenda) fbr visual examinations are applicable. Paragraph IWA-5240 identifies a "VT-2" Visual Examination.
VT-2 examinations are conducted to detect evidence ofleakage from pressure retaining components, with or without leakage collection systems, as required during the conduct of a system pressure test. In addition, personnel performing VT-2 examinations are required to be l
qualified in accordance with Subarticle IWA-2300 of ASME Section XI.
, Attachment to NG-99-0491 Page 14 of 25 Table IWE-2500-1, Examination Category E-P, identifies the examination method of 10CFR50, Appendix J and does not specifically identify a VT-2 Visual Examination.10CFR50, Appendix J provides requirements for testing as well as acceptable leakage criteria. These tests are performed by Appendix J " test" personnel and utilize calibrated equipment to determine acceptability. Additionally,10 CFR 50.55a(b)(2)(x)(E) requires a general visual examination of the containment each period that would identify any structural degradation that may contribute to leakage.
A "VT-2" Visual Examination for minor repairs will not provide additional assurance of safety beyond that of current Appendix J practices. The presence of a VT-2 examiner in addition to Appendix J test personnel for minor repairs could result in unnecessary exposure duplication and violation of"ALARA" good practice without any substantial increase in safety. It is important to note that all minor repairs will be examined (surface or visual) per the applicable construction code requirements.
ALTERNATE EXAMINATION The requirements ofIWE-5240 shall be performed on major repairs on the containment pressure boundary. However for minor repairs, testing shall be conducted in accordance with 10CFR50, Appendix J, in lieu ofIWE-5240.
APPLICAHIJ TJB1E PERIOD ;
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Reliefis requested for the first ten year interval of the Containment Inspection Progre io, &
DAEC.
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, Attachment to NG-99-0491 l Page 15 of 25 RELIEF REQUEST NUMBER: NDE-R015, Revision 1 COMPONENT IDENTIFICATION Code Classes: 1,2, and 3
References:
IWA, IWB, IWC, IWD, and IWF-4000 (IWX-4000)
IWA, IWB, IWC, IWD, and IWF-7000 (IWX-7000)
Examination Category: Not Applicable item Number: Not Applicable
Description:
Use of the 1992 Addenda of SecGon XI to Govem Repair Procedures (IWX-4000) and Replacementr. (lWX-7000)
Component Numbers: All Class 1,2,3, and MC pressure retaining components and their supports.
CODE REOUIREMENT IWX-4000 provides the rules and requirements for repair of pressure retaining components and their supports, and for the attachment of replacements to the system by welding or brazing.
IWX ~7000 provides the rules and requirements for the specification and construction ofitems to be used for replacement.
10CFR 50.55a dated September 6,1996 requires the implementation of Subsections IWE and IWL of the 1992 Edition with the 1992 Addenda.
9AjSIS FOR ALTERNATIVE TL i992 Addenda to Section XI made several changes to Articles lWX-4000 and IWX-7000.
Very few of these changes were technical in nature. Instead, the changes restructured some of the reymaments, (ie. combined IWX-4000 and IWX-7000 into one section) clarified others that were difficult to interpret, and eliminated redundant requirements. Of the actual technical changes made, these changes either add enhancements to the program or add requirements not applicable to DAEC.
Meeting both the 1989 with the 1989 Addenda and the 1992 with the 1992 Addenda of ASME Section XI requires the maintenance of two separate repair and replacement programs (one for the IWB,IWC, and IWD components per the 1989 Addenda of ASME Section XI and one for the 1992 Addenda for the containment vessel). Duplicate records to demonstrate compliance with the 1989 Addenda and the 1992 Addenda will also be required. This duplication of programs and records increases the man-hours necessary to maintain the DAEC Repair / Replacement Program without providing any increase in quality or safety.
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Attachment to NG-99-0491 Page 16 of 25 Attached is a' detailed reconciliation of each of the changes made and a comparison of the 1992 Addenda to the 1989 Addenda of Section XI. Each change classified as Technical Significant is addressed in the attachment as to how it will be implemented at the DAEC.
ALTERNATE EXAMINATION This alternative is requested in accordance with 10CFR 50.55a(a)(3)(ii). DAEC will use the 1992 Edition of ASME Section XI, as amended by the 1992 Addenda, to govern Repair Procedures (IWX-4000) and Replacements (IWX-7000) for Class 1,2,3, and MC pressure retaining components and their supports.
APPL lCAllLE TIME PERIOD Reliefis requested for the third ten-year interval of the Inservice Inspection Program for DAEC.
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. Attachment to NG-99-0491 Page 17 of 25 Certificate of Reconciliation This Certificate of Reconciliation provides the basis for revisions to the IES Utilities ASME Section XI " Repair, Replacement and Modification Administration Document" in order to mee t the 1992 Edition with the 1992 Addenda of ASME Section XI for Subsection IWE. On September 9,1996, the Nuclear Regulatory Commission (NRC) issued a revision to 10 CFR 50.55a, implementing subsections IWE and IWL' of the 1992 edition, including the 1992 addenda of Section XI of the ASME Code. This required utilities to develop and implemen' a program for the examination of containments by September 9,2001. Additionally, it required implementation of an IWE/IWL repair / replacement program efTective September 9,1996. I Revision 0 of Relief Request NDE-R015 was approved on 03/23/98 to allow the use of the 1989 Edition of ASME 5ection XI as amended by the 1989 Addenda. Because of the hardship to maintain two separate Repair / Replacement Programs, Revision I is made to allow the use of the 1992 Edition of ASME Section XI as amended by the 1992 Addenda. This recocciliation is completed to providejustification for allowing the use of the 1992 Addenda for Class 1,2,3, and MC pressure retaining components and their supports.
The current revision of the " Repair, Replacement and Modification Administration Document" is based on the 1989 Addenda of ASME Section XI. There are some general issues to discuss prior to delineating the specific chane,s that have been made to the ASME Section XI Code (1989 ,
Addenda to 1992 Addenda). I
- 1) The 1990 Addenda updated the temperbead welding requirements and replaced half bead welding with temperbead welding. This included Code Case N-432.
- 2) The 1991 Addenda consisted of a complete rewrite ofIWA-4000 and IWA-7000 into one article, IWA-4000. The requirements ofIWB-4000, IWE-4000 and IWF-4000 were also moved into the new IWA-4000.
- 3) The 1991 Addenda incorporated the requirements of Code Case N-432," Repair Welding Using Automatic or Machine Gas Tungsten-Arc Welding (GTAW) Temper Bead Technique."
- 4) The 1992 Addenda deleted the exemption from IWA-4000 for NPS 1 and smaller items.
This was replaced with alternative, less restrictive requirements which provide assurance that j the item will function as designed. The new requirements are applicable to the smaller of the !
following, (a) NPS 1; or (b) the size and design such that in the event of postulated failure l
during normal plant otM ig conditions, the reactor can be shut down and cooled in an "
orderly manner, assei gi i akeup is provided by normal reactor coolant makeup systems operable from onsite .. argtney power. This means that the new requirements cannot be applied to the DAEC normal makeup sized piping (1.12" water,2.24" steam).
The specific changes will be addressed by comparing the 92A requirements with the 89A requirements. Each change will be categorized as Editorial (E), Technical, Significant (T.' l Technical, Non-significant (TN), or No Change (NC). The Technical, Significant categos changes will be addressed in more detail as to the applicability to the DAEC. "
IWL " Requirements for Class CC Concrete Components of Light-Water Cooled Plants" is not applicable to the Duane Arnold Energy Center. !
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,' Attachment to l
NG-99-0491 Page 18 of 25 IWA-4110 Scope (a) Added metal containment and metallie TS (See Note 1) portions of Class CC along with integral attachments.
(b) This is a combination ofIWA-4110(b) NC i
! and IWA-7110.
(c) This is a new paragraph which TS (See Note 2) provides requirements for concrete containments.
IWA-4111 (a) This paragraph simplified the NC Applicability applicability.
l 1WA-4111 (b) Added new sub-sub-paragraph (1) E which incorporated IWA-7400(b)(1) and (b)(2) " Nonstructural internals."
(2) Added exemptions of" permanently- TN sealed, fluid filled tubing systems furnished with instruments.
Ilowever, added requirements for TS (See Note 3) instrument, control and sampling piping when classified as Code Class 1,2, or 3.
(3), (4), & (5) TN Expanded on the items that are exempt from the requirements of ASME Section XI. This was taken from ASME Section III NB-2120.
IWA-4111 (c) NC (d) Added requirements for the Owner to review replacement ofitems exempt TS (See Note 3) under 4111(b) to determine effect on the IST Program.
(e) Added requirement to follow IWA-4000 if the items under IWA-4111(b) TS (See Note 3) are welded to the pressure retaining portion of a component or to a component support or installed in a component support path.
(f) Incorporation ofIWA-7400(b)(1) and IWA-7320(b) NC (g) Added reference that Appendix J provides guidance to determine 'IN applicability.
IWA-4120 Removal of exemption for < 1" on TS (See Note 4) l 4121,4122 replacements I l
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l Attachment a NG-99-049 '
Pageisor25 IWA-4130 Same as IWA-7120 except added the word E
" repair."
IWA-4140 Same as IWA-4130 and IWA-7131 except E added the word " replacement."
IWA-4150 Same as IWA-7220 except added word 1
" repair."
IWA-4160 Combined IWA-4140 and IWA-7140 exce'[I -
deleted "...when making a repair by welding, brazing or metal removal (mechanical or thermal)."
IWA-4170 Added words "either in their entirety or TN portions thereof." Otherwise it is a combination of IWA-7210(a), IWA-4120(b)
& (c) IWA-4120, IWA-7210(b), and IWA-7210(c).
IWA-4180 Same as 1WA-4200 and IWF-4300(b). NC IWA-4210 Same as IWA-4210 except added the word E
" replacement."
IWA-4220 Same as IWA-4400 except added the word li
" Replacement Plan."
IWA-4310 Same as IWA-4300 except added option to TN use Flaw Evaluation Rules in accordance with ASME Section XI for the acceptance of the defect removal area and any remaining portion of the flaw.
lWA-4321 Same as IWA-4321 NC IWA-4322 Same as IWA-4322 NC IWA-4330 Same as IWA-4330 NC IWA-4331 Same as IWA-4340 except added clarification TS (See Note 5) i when an examination is required j IWA-4411 Same as IWB-4220 except specifying TN applicability to Class 1 and may be used for Class 2 & 3 heat exchangers.
lWA-4411.1 Same as IWB-4221 E IWA-4411.2 Same as IWB-4222.1 E 1WA-4411.2.2 Same as IWB-4222.2 NC l IWA-4411.3 Same as 1WB-4223 NC j IWA-4411.4 Same as IWB-4224 NC IWA-4412 Same as lWB-4230, changed to add the use of TN automatic welding and clarification of the use and application to Class I heat exchanger tubes of P. Nos. 8 and 4x materials.
IWA-4412.1 Same as 1WB-4231 NC
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NG-99-0491 Page 20 of 25 IWA-4412.2 Same as IWB-4232 except clarified the use of E Section IX.
lWA-4412.2(a) Same as IWB-4232.l(a) e cept added use of TN (1) shielded metal are welding.
IWA-4412.2(a) Same as IWB-4232.l(d) except added E (2) reference of an F-number which was taken from IWB-4232.4.
lWA-4412.2(a) Similar to IWB-4232.l(b) E (3)
IWA-4412.2(a) Same as IWB-4232.2 NC (3)(a)-(2)
IWA-4412.2(a) Same as IWB-4232.3 except reduced the TS (See Note 6)
(4) required thickness of the test assembly to 1 1/2 max. I IWA-4412.2(a) New paragraph providing qualification TS (See Note 7) f (5) requirements. j IWA-4412.2(a) Same as IWB-4232.3 except specified the E (6) requirements are in lieu of Section IX.
lWA-4412.2(b) Same as IWB-4232.4 except climinated the TN list of essential variables.
lWA-4412.2(b) Extended the time period for renewal of TN (4) qualification to six (6) months IWA-4412.3 Same as IWB-4233 except provides a better TN ,
description of what is required IWA-4412.4 Same as IWB-4234 NC IWA-4412.5 Same as IWB-4235 except eliminated IWB- TN 4235(b) which detailed what a PQR and welder / welder operator records include IWA-4420 Same as IWB-4311 and IWB-4312 E IWA-4421.3 Same as 1WB-4313.1 E IWA-4421.3.2 Same as IWB-4313.2 E IWA-4421.4 Same as IWB-4314 E IWA-4421.5 Same as IWB-4315 E IWA-4422 Same as IWB-4321 E l IWA-4422.2 Same as IWB-4322.1 E IWA-4422.2.2 Same as 1WB-4322.2 E IWA-4422.3 Same as IWB-4323 NC IWA-4422.4 Same as IWB-4323 NC IWA-4423.1 Same as IWB-4331 E IWA-4423.2 Same as IWB-4332.1 except specified the E
< % ament thickness applies between the holes.
IWA-4423.2.2 s as 1WB-4332.2 E j iWA-4423.3 l s ._. ; IWB-4333 NC l
. Attachment to NG-99-0491 Page 20 of 25 lWA-4412.2 Same as IWB-4232 except clarified the use of E Section IX.
IWA-4412.2(a) Same as IWB-4232.l(a) except added use of TN (1) shielded metal are welding.
IWA-4412.2(a) Same as IWB-4232.l(d) except added E (2) reference of an F-number which was taken from IWB-4232.4.
lWA-4412.2(a) Similar to IWL1-4232.l(b) E (3) 1WA-4412.2(a) Same as IWB-4232.2 NC (3)(a)-(2)
IWA-4412.2(a) Same as IWB-4232.3 except reduced the TS (See Note 6)
(4) required thickness of the test assembly to 1 1/2 max.
IWA-4412.2(a) New paragraph providing qualification TS (See Note 7)
(5) requirements.
IWA-4412.2(a) Same as IWB-4232.3 except specified the E (6) requirements are in lieu of Section IX.
lWA-4412.2(b) Same as IWB-4232.4 except climinated the TN list of essential variables.
IWA-4412.2(b) Extended the time period for renewal of TN (4) qualification to six (6) months IWA-4412.3 Same as IWB-4233 except provides a better TN description of what is required IWA-4412.4 Same as IWB-4234 ,
NC IWA-4412.5 Same as lWB-4235 except eliminated I'WB- TN 4235(b) which detailed what a PQR and welder / welder operator records include IWA-4420 Same as IWB-4311 and IWB-4312 E IWA-4421.3 Same as IWB-4313.1 E IWA-4421.3.2 Same as IWB-4313.2 E IWA-4421.4 Same as IWB-4314 E l IWA-4421.5 Same as IWB-4315 E l IWA-4422 Same as IWB-4321 E !
IWA-44'22.2 Same as 1WB-4322.1 E )
1WA-4422.2.2 Same as 1WH-4322.2 E l IWA-44'22.3 Same as l'. '323 NC IWA-4422.4 Same as l' ' '323 NC IWA-4423.1 Same as 1 41 E I IWA-4423.2 Same as lWB24332.1 except specified the E ligament thickness applies between the holes.
lWA-4423.2.2 Same as IWB-4332.2 E IWA-4423.3 Same as IWB-4333 NC l t- _
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l , Attachment to NG-99-0491 Page 21 of 25 IWA-4423.4 Same as IWB-4334 NC IWA-4424 Same as IWB-4341, IWB-4342, IWB-4343, E and IWB-4344 IWA-4425 Same as IWB-4351 E IWA.4425.2 Same as IWB 4352.1, IWB-4352.2, IWB- E 4353, and IWB-4354 IWA-4500 This revision incorporates the provisions of TS (See Note 8)
Code Case N-432 with the exception of a change in the Procedure Qualincation wherein the test assembly material shall be of the same P-Number and Group Number as opposed to the same speci6 cation type, grade, and class.
This change included addition of the GTAW f
technique (IWA-4522.2) and other technical changes like the limits on the permissible depth and area of temperbead repairs.
IV/A-4513.1 .(a) Same as IWA-4511(a) NC (b) Changed the requiren.:nts to bake and TS (See Note 8) maintain all covered electrodes in accordance with the manufacturer's recommendation.
(c) This paragraph is similar to IWA- TS (See Note 8) 4511(b)(2).110 wever, it deleted the I specine requirements for rebaking and referenced paragraph b above (manufacturer's recommendations). It also divided and specined the hours for E70XX (8 Ilts.) and E80XX (4 Hrs.) that an electrode can remain outside the holding oven.
IWA-4513.1 (d) Similar to IWA-4513(c) TN (e) Similar to IWA-4513(d). Also changed TS (See Note 8) from '3T' to " weld area" for specified area requiring 2-hr. hold time at i temperature after completion of weld !
repair in P-1 materials, for P-3 materials !
the hold time shall be 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> minimum.
IWA-4513.2 (c) Change from "450 - 550 F to a TS (See Note 8)
"300 F" for P-1 materials and added clari6 cation of P-3 materials to a four- I hour hold time.
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. Attachment to NG-99-0491
, Page 22 of 25 IWA-4514 (a) Similar to IWA-4514. Added TS (See Note 8) requirement that initial layer shall be examined by the magnetic particle method after grinding or machining.
Each subsequent layer shall be examined by the magnetic panicle method if a final volumetric exam is not performed.
IWA-4521.1 (a) Similar to lWA-4522.l(a) NC (b) Change from test assembly base material TN size from 18" x 18" x 5" thick to 12" x 12" x 2" thick.
(c) Removed the additional requirements of TN two side-bend specimens IWA-4522.1 (b) Allows larger bead width size (lWA- TN 4521(a)).
(c) Similar to IWA-4521(b); however, TN deleted the pre-heat treatment and added the requirement that all covered electrodes for qualification test and repair welding shall be from freshly opened, hermetically sealed packages and discarded if removed longer than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
lWA-4522.1 (d) Deleted the allowance of rebakiki. TN l Specifies discard.ing after 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
(e) Similar to IWA-4523(b); however, TN (See Note 8) changed the amount of the first layer that is removed. TN l (f) Similar to IWA-4523(c); however, separates the P No. I and P No. 3 materials for maintaining heat times: 2 i hours for P-1 and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for P-3 IWA-4522.2 Added requirements for Gas Tungsten Are TS (See Note 8)
Welding IWA-4523 Similar to IWA-4524 with clarification of the E area requiring examination IWA-4530 Added requirements if the defect penetrates TS (See Note 8) into the ferritie base metal.
lWA-4531 Same as NB-4522.11(f)(Section 111,1989, NC 89A).
1WA-4530 references Section 111.
lWA-4532 Same changes as described above for IWA- TN 4522.1 l
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, Attachment to NG-99-0491 Page 23 of 25 IWA-4532.2 New requirements for Gas Tungsten-Arc TN Welding. These requirements were taken from Section Ill with some changes IWA-4533 Similar to IWA-4534(b) E IWA-4541(c) New requirement allowing the alternative for TN a temper bead repair IWA-4542 Same requirements as IWE-4210 - 4226 NC through IWA-4546 IWA-4600 Similar to IWA-7510 and IWB-7300 NC IWA-4700 Same as IWA-4700, except added the words TS (See Note 9)
"or the installation of a replacement by welding." Added new paragraph (c) which addresses the installation of mechanical joints.
lWA-4720 Added requirement for testing of Class MC TS (See Note 10) i and Class CC after repair and replacements IWA-4810 Same as IWA-4600 E 1WA-4820 Same as IWA-7530 E IWA-4900 Combination of IWA-4800, IWA-7520 and E IWA-7330.
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, Attachment to NG-99-0491 Page 24 of 25 Notes Note 1 Metal containment is applicable to the DAEC under the new rule. The Repair / Replacement procedure has been revised to address metal containment (Drywell and Torus).
Note 2 This paragraph does not apply to the DAEC.
Note 3 IWA-4111(b) was revised to clarify the exemptions from the scope of the repair and replacement rules. It also clarified that an owner may determine by evaluation that a replacement activity will not affect pump or valve performance parameters. The existing DAEC Repair / Replacement document already includes the provision to
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determine whether an activity could affect pump or valve performance under i Attachment II.
I Note 4 This revision deletes the exemption from the provisions of the repair / replacement requirements for NPS 1 and smaller items and replaces it with alternative, less restrictive provisions to provide assurance that the item will function as designed. The reduced provisions are no longer applicable to Class 1 items larger than the makeup capability limit for the DAEC (1.12" ID, water & 2.24" ID, steam), nor for heat exchanger tubing or sleeves or welded tube plugs for heat exchanger tubing. The
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revision provides alternative requirements for the smaller of(1) NPS 1, or (2) size determined by makeup capacity for Class 1 systems. The DAEC makeup capacity is larger than NPS 1 for both water and steam, so the alternative requirements will be applied to NPS I and smaller.
To summarize what IWA-4122 requires:
(a) Items shall meet the original construction code requirements except a Certificate of Authorization or the use of an ANil is neither required nor prohibited.
(b) Items to be used as replacements shall follow the DAEC QA Program and meet the technical requirements of the Construction Code. For Section 111 items, NCA-3800 need not be met, provided the QA Program provides measures to assure that the material to be used for replacement is furnished in accordance with the material specification and the applicable material requirements of Section 111. Pressure testing, ANil, and NIS-2 completion are not required.
(c) When the replacement is due to a failure, an evaluation of the suitability of the replacement is required.
(d) For replacements that could affect pump or valve performance, an inservice test i shall be performed prior to returning to service. i (e) The DAEC shall designate the size in which the alternative requirements apply.
The Repair / Replacement and Modification Program has been revised to include the above requirements.
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- Attachment to NG-99-0491 Page 25 0f 25 Note 5 This provides a clarification that the magnetic particle or liquid penetrant examination l is not required when the defect removal requires the removal of the full thickness of the weld and proper clean-up (inside surface is inaccessible) cannot be performed. The Repair / Replacement and Modification Program already contains this clarification in Paragraph 5.3.3.g.
Note 6 This requirement applies to tube or tubesheet hole plugging. A note was added to Paragraph 5.3.10.b clarifying the allowable reduction in test assembly thickness.
Note 7 The change specified that the procedure qualification test assembly shall simulate the welding position of the production tube sheet. A note was added to Paragraph 5.3.10.b to include this change if using the 1992 Edition with 1992 Addenda.
Note 8 This was the incorporation of Code Case N-432," Repair Welding Using Automatic or 1 Machine Gas Tungsten-Arc Welding (GTAW) Temperhead Technique." Code Case N- I 432 required material for the test assembly to be of the same specification, type, grade I
and class. The 1992 Addenda changed the material requirements for the test assembly to the same P Number and Group Number. This change is based on materials of the same chemistry and heat treatment responding the same during the welding process.
ASME Section 111 has also implemented this change for temper bead welding processes. The change also included the addition of the GTAW temperhead repair techniques with additional limits on the permissible depth and area of temperbead repairs. There was also a lowering of the postweld temperature maintenance for the GTAW temperbead weld repair process from a range of 450"F to 550 F to a minimum temperature of 300 F. Code Case N-432 has been approved by the NRC (Regulatory Guide 1.147, Rev. I1, dated October 1994). The DAEC currently has a welding procedure PI-A-TBR which was qualified for the SMAW temperbead process on P-1 material. Since this Paragraph IWA-4500 is specified as Alternative Repair Welding
. Methods, each welding repair that is outside the qualification parameters of Pl-A-TBR shall require a new welding procedure. For example, if a repair was to be made on dissimilar metal a new procedure meeting the requirements ofIWA-4530 would be required.
Note 9 Added requirements for pressure testing of mechanicaljoints. Provided exemption for connections, piping, tubing, valves and fittings (except heat exchanger tubing) from pressure testing. The ASME Section XI, System Pressure Testing Administrative Document, already addresses pressure testing of mechanical connections (Ref.
Paragraph 5.1.10.c). ;
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Note 10 Added requirements for pressure testing of Class MC and Class CC after repair and replacement activities. Class CC is not applicable to the DAEC. The ASME Section XI, System Pressure Testing Administrative Document, addresses pressure testing of Class MC and Class CC components under Paragraph 5.12.
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