WASHINGTON, D.C. 20665-4001

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NUCLEAR REGULATORY COMMISSION,* 7

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I SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONL

! RELATED TO THE IMPLEMENTATION OF SUBSECTIONS IWE AND IWL ||'

OF ASME SECTION XI FOR CONTAINMENT INSPECTION - !L ;

REQUESTS FOR RELIEF!

FLORIDA POWER CORPORATION '

CRYSTAL RIVER UNIT 3

DOCKET NO. 50-302

1.0 INTRODUCTION|

Pursuant to 10 CFR 50.55a(b) and (g), inservice inspection (ISI) of containment must meet therequirements of the 1992 Edition,1992 Addenda of American Society of Mechanical Engineers !(ASME) Code, Section XI, Subsections IWE and IWL. Subsections IWE and IWL provide therequirements for ISI of Class CC (concrete containments), and Class MC (metalliccontainments) of light-water cooled power plants. Pursuant to Title 10, Code of Federal 1

Reaulations (10 CFR) Section 50.55a(g)(6)(ii)(B), the first period containment examinations j

must be completed by September 9,2001. Altematives to the requirements of 10 CFR I

| 50.55a(g) may be authorized pursuant to 10 CFR 50.55a(a)(3), if (i) the proposed altemative.

provides an acceptable level of quality and safety, or (ii) compliance with the specific irequirement'of the Code would result in hardship or unusual difficulty without a compensatingincrease in the level of quality and safety.

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By letter dated November 30,1998, the licensee, Florida Power Corporation (FPC), submittedRelief Request Nos. 98-012 to 98-018, seeking relief from some of the ASME Code Section XI,

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Subsection IWE requirements for Crystal River L'oi; 3 (CR-3).

2.0 EVALUATION OF RELIEF REQUESTS

2.1 Relief Reauest No. 98-012-11

2.1.1 Code Reauirement !

Table IWE-2500-1, Examination Category E-D (Item Nos. E5.10 and E5.20) requires a VT-3visual examination of seals and gaskets during the inspection interval. Seals and gaskets areto be examined for wear, damage, erosion, tears, surface cracks, or other defects that mayviolate the leak-tight integrity. Defective items are to be repaired or replaced.

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ENCLOSURE

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! 9910070153 991004 FPDR ADOCK 05000302P PDR

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!2.1.2 Code Reauirement From Which Relief is Reauested (as stated)

|iRelief is requested from performing the Code-required visual examination, VT-3, on the aboveidentifient metal containment seals and geskets.

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2.1.3 Basis for Relief (as stated).

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Seals and gaskets, subject to examination per the ASME Section XI Code, are those used on !penetrations (e.g. airlocks, hatches, etc.) which are required to assure containment leak tight jintegrity. As required by 10 CFR Part 50, Appendix J, these same seals and gaskets are i

required to be leak-rate tested (e.g., Type B test). The purposa of the Type B test is to detectlocal leaks at containment design pressure and to measure leakage across the leakage limiting I

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. boundary of containment penetrations whose design incorporates resilient seals, gaskets,sealing compounds, and electrical penetrations fitted with flexible metal seal assemblies.When compared to a visual examination, a leak rate test is considered a superior and provenmethod for detecting degradation that may cause containment leakage. If excessive leakageis detected during the test, then corrective actions would be taken and the connection re-

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tested. The performance of a visual examination will not provide any additional increase in jquality and safety.

For those penetrations (e.g., equipment hatch, etc.) that are routinely disassembled during arefueling outage, a Type B test is required upon final re-assembly and prior to start-up. Themechanical connection associated with these penetrations employ a tongue and groove or ringjoint configuration. Thus, the seals or gaskets are not accessible for examination when theconnection is assembled. For this reason, a VT-3 examination of the seal or gasket wouldhave to be' performed prior to final assembly. Since the potential damage to the seal or gasketwould most likely occur during the final assembly of the connection, the visual examinationprovides no compensating increase in quality or safety. Any damage to the seal or gasket thatmay have occurred which affected the leak-tightness of the containment would be identifiedduring the Type B test. !

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Performance of the visual examination of the seals or gaskets would require disassembly andre-assembly of the mechanical connection for those penetrations (e.g., personnel airlock, etc.)that are not routinely disassembled during a refueling outage. The seals or gaskets,

. associated with these penetrations are not accessible for examination when the connection isassembled For this reason, the connection would require disassembly for the sole purpose ofperforming the visual examination. Since these connections are periodically Type B tested to

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. verify their leak-tight integrity, the hardships of performing an additional as-found Type B test,performing disassembly and re-assembly activities, and the increase of the component

| damage probability has been dete; mined to be unwarrantec' ar.*>e%d e cur,ponsating| increase in quality and safety.

Seals and gr.skets are not part of the containment pressure boundary under current Coderules (NE-1220(b)). When the airlocks and hatches containing these materials are tested in

- accordance with 10 CFR Part 50, Appendix J, degradation of the seal or gasket material wouldbe revealed by an increase in the leakage rate.' Corrective measures would be applied and thecomponent re-tested.' Repair or replacement of seats and gaskets is not subject to Code

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(1992, Edition,1992 Addenda) rules in accordance with Paragraph IWA-4111(b)(5) of ASMEi

Section XI. '

The visual examination of seals and gaskets in accordance with IWE-2500, Table IWE-2500-1is an increased burden without a compensating increase in quality or safety.

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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 acompensating increase in the level of quality and safety. Testing the seats and gaskets inaccordance with 10 CFR Part 50, Appendix J will provide adequate assurance of the leak-tightintegrity of the seals and gaskets.

The requirement to examine seals and gsskets has been removed in the re-write of the ASME,

Code, Section XI, Subsection IWE, which has been approved by ASME and published in the ;

' 1998 Edition.

2.1.4 Altemative Examination (as stated)

The leak-tightness of seals and gaskets will be tested in accordance with 10 CFR Part 50,Appendix J. The 10 CFR Part 50, Appendix J, Type B testing is performed at least once eachinspection interval.

2.1.5 Staff Evaluation

The licensee proposes to use the existing 10 CFR Part 50, Appendix J, Type B testing as averification of seal and gasket integrity, rather than disassembling the subject components forthe sole purpose of examination.

Performing the VT-3 examinations on the subject gaskets and seals would require disassemblyand re-assembly of the mechanical connection for those penetrations that are not routinelydisassembled during a refueling outage. The ASME Main Committee and the Board ofNuclear Codes and Standards have also determined that a VT-3 examination of the seals andgaskets is no longer warranted. Both organizations have approved the re-write of SubsectionIWE to delete the requirement for performing a VT-3 examination of the seals and gaskets.This re-write of Subsection IWE was published in the 1998 Edition of the ASME Code, SectionXI. Requiring the licensee to disassemble components for the sole purpose of inspecting sealsand gaskets would place a significant hardship on the licensee without a compensatingincrease in quality and safety.

The licensee will verify the leak-tight integrity of seals and gaskets, utilized on penetrations,that are required to assure containment leak-tight integrity, in accordance with the applicablerequirements of 10 CFR Part 50, Appendix J. Therefore, the proposed attemative isauthorized pursuant to 10 CFR 50.55a(a)(3)(ii) on the basis that compliance with the specifiedrequirements would result in hardship or unusual difficulty without a compensating increase inthe level of quality and safety. The proposed testing provides reasonable assurance ofcontainment leak-tight integrity.

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|2.2 Relief Reauest No. 98-013-Il|,

|. 2.2.1 Code Reauirement

Subarticle IWA-2300, " Qualification of Nondestructive Examination Personnel," requires.

' qualification of nondestructive examination (NDE) personnel to CP-189 - 1991, " Standard for a'

Qualification and Certification of Nondestructive Testing Personnel," as amended by the ASMESection XI.-,

2.2.2 Code Reauirements From Which Relief is Reauested (as stated)|

Relief is requested from the provisions of Paragraph IWA-2300, " Qualification ofnondestructive Examination Personnel,"in accordance with CP-189, as amended by ASMESection XI.

2.2.3 Basis for Relief (as stated)

A written practice based on the requirements of CP-189, to implement Subsection IWE,duplicates efforts already in place for the CR-3 Third Ten Year Inservice inspection Program,which meets the requirements established in ASME Section XI,1989 Edition, no Addenda.Personnel qualifications are currently based on SNT-TC-1 A, " Personnel Qualification andCertification in Nondestructive Testing," as amended by the requirements of ASME Section XI.Additionally Subarticle IWA-2300 of ASME Section XI,1992 Edition,1992 Addenda, states," Certifications based on SNT-TC-1 A are valid until re-certification is required." j

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i' Visual examination is the primary NDE method required by Subsection IWE. The requirementestablished in SNT-TC-1 A for personnel certifications are similar to the requirements described i

in'CP-189. Therefore, use of CP-189 in place of SNT-TC-1 A will not improve the capability ofexamination personnel to perform the visual and ultrasonic thickness examinations required by

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|Development and administration of a second program would not enhance safety or quality andwould serve as a burden, particular1y in developing a second written practice, tracking of

' certifications, and duplication of paperwork . The current personnel certification program meetsthe requirements of ASME Code, Section XI,1989 edition. . Updating the personnelcertification program to meet the requirements of ASME Code Section XI,1992 Edition andCP-189 would require a similar request for relief.

Relief is requested in accordance with 10 CFR 50.55a(a)(3)(ii). Compliance with the specifiedrequirements of this section would result in hardship or unusual difficulty without a

- compensating increase in the level of quality and safety.

L 2.2.4 Alternative Examination (as stated)

Personnel qualified and certified to a written practice based on SNT-TC-1A and ASMEg

| Section XI,1989 Edition, No Addenda, shall conduct examinations required by SubsectionIWE. Visual examination personnel will receive specific training in conducting containmentexaminations.

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The current FPC program for qualifying and certifying NDE personnel is based on the 1989Edition of the ASME Section XI requirements for Class 1,2, and 3 components. The 1989Edition of the Code requires the use of SNT-TC-1 A for the qualification and certification ofNDE personnel. Thus, the staff recognizes that the licensee would have to develop a secondprogram for qualifying and certifying its NDE personnel for containment inspection inaccordance with Subarticle IWA-2300 of the 1992 Edition of the Code.

As noted by the licensee, visual examination is the primary NDE method required bySubsection IWE. The requirement established in SNT-TC-1A for personnel certifications aresimilar to the requirements described in CP-189. Therefore, use of CP-189 in place of SNT-TC-1 A will not improve the capability of examination personnel to perform the visual andultrasonic thickness examinations required by IWE.

Thus, the staff concludes that the imposition of the requirement of Subarticle IWA-2300 (1992Edition) for containment inspection will subject the licensee to hardship without acompensating increase in the level of quality anti safety. The staff concludes that thelicensee's proposed attemative is authorized pursuant to 10 CFR 50.55a(a)(3)(ii) on the basisthat compliance with the specified requirements would result in hardship or unusual difficultywithout a comperuating increase in the level of quality and safety.


2.3.1 Code Reauirement

IWE-2200(g) requires that when paint or coatings are re-applied, the condition of the new paintor coating will be documented in the preservice examination records.


The quality of property applied coatings is important to assure degradation of the liner does notoccur, but neither paint nor coatings contribute to the structural integrity or leak tightness of thecontainment. The paint and coatings on the containment pressure boundary were not subjectto Code rules when they were originally applied and are not subject to ASME Section XI rulesfor repair or replacement in accordance with IWA-4111(b)(5). The adequacy of appliedcoatings is verified through the inspections performed by the CR-3 Painting Program.

The Painting Program at CR-3 ansures that all protective coatings used for Service Level 1coatings are proper coatings, applied by qualified personnel and in accordance withmanufacturers' instructions, and are inspected and properly documented. The CR-3 PaintingProgram meets the intent of Regulatory Guide 1.54, Revision O.

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Recording the condition of re-applied coating in the preservice record does not substantiatethe containment structuralintegrity. Deterioration of the coating in the reapplied ana wouldrequire additional evaluation regardless of the preservice record. Recording the condition ofnew paint or coating in the preservice records does not increase the level of quality and safetyof the containment.

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In SECY'96-080, " Issuance of Final Amendment to 10 CFR Section 50.65a to incorporate byReference the ASME Boiler and Pressure Vessel Code (ASME Code), Section XI, Division 1,Subsection IWE and IWL," 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 performedwith 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 currentlyaccomplished through the inspections performed by the CR-3 Painting Program.

- Relief is requested in accordance with 10 CFR 50.55a(a)(3)(i). The CR-3 Painting Program~ currently provides an adequate level of quality and safety.

The requirement to perform a preservice examination when paint or coatings are re-appliedhas been removed in the re-write of the ASME Code, Section XI, Subsection IWE, which hasbeen approved by ASME and published in the 1998 Edition.


Reapplied paint and coatings on the containment vessel will be examined in accorciance withthe CR-3 Painting Program. Although repairs to paint or coatings are not subject to the

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repair / replacement rules of ASME XI (Inquiry 97-22), repairs to the primary containmentboundary, if required, would be conducted in accordance with ASME Section XI Code rules.

2.3.4 Staff Evaluation !

In the basis for the relief request, the licensee states that the Painting Program at CR-3 !

ensures that all protective coatings used for Service Level 1 coatings are (1) proper coatings, '

. (2) applied by qualified personnel in accordance with the manufacturers' instructions,(3) inspected, and (4) properly' documented. In addition, the Painting Program at CR-3 is

' written to comply with the applicable requirements of Regulatory Guide 1.54. The licensee's |

Painting Program provides a conservative approach to the inspection and documentation of ;

new coatings and as such, the staff concludes that the proposed attemative provides an jacceptable level of quality and safety. Therefore, the licensee's proposed altemative isauthorized pursuant to 10 CFR 50.55a(a)(3)(i).


2.4.1. Code Reauirementi

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. ||

2.4.2 Basis for Relief (as stated):

; The interiors of containments are painted to prevent rusting. Neither paint nor coatingscontribute to the structuralintegrity or leak tightness of the containment. The paint and

. coatings on the containment pressure boundary were not subject to Code rules when theywere originally applied and are not subject to ASME Section XI rules for repair or replacementin accordance with IWA-4111(b)(5). Degradation or discoloration of the paint or coating

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materials on containment would be an indicator of potential degradation of the containmentliner. Additional measures would have to be employed to determine the nature and extent ofany degradat!on, if present. The application of ASME Section XI rules for removal of paint orcoatings, when unrelated to an ASME Section XI repair or replacement activity, is a burdenwithout a compensating increase in quality or safety.

The Painting Program at CR-3 ansures that all protective coatings used for Service Level 1coatings are proper coatings, applied by qualified personnel and in accordance withmanufacturers' instructions, and are inspected and properly documented. The CR-3 PaintingProgram meets the intent of Regulatory Guide 1.54, Revision O.

Relief is requested in accordance with 10 CFR 50.55a(3)(i). The inspections performed by theCR-3 Painting Program provide an adequate level of quality and safety.

The requirement to inspect coatings prior to removal has been removed in the re-write of theASME Code, Section XI, Subsection IWE which has been approved by ASME and published inthe 1998 Edition.


The condition of the containment vessel bad .r aterial will be verified prior to the application ofnew paint or coating as required by the CR-3 Painting Program. Additional measures will beinvoked to determine the condition of the containment pressure boundary, in the eventdegradation of the coating is identified. Repairs to the primary containment boundary, if

( necessary, will be conducted in accordance with ASME Section XI Code rules.


The staff finds that performing an additional examination prior to the removal of the old paintand documenting its condition (in addition to the licensees' program that is subject to thequality assurance requirements of 10 CFR Part 50 Appendix B) would be a burden without acompensating increase in quality or safety. The Crystal River Painting Program is adequate tomonitor the proper remumi vi old paint and the application of new coatings. Therefore, thelicensee's proposed attemative to the requirement of Subarticle IWE-2500(b) of the Code isauthorized pursuant to 10 CFR 50.55a(s)(3)(ii).


2.5.1 Code Reauirement ;

Paragraph IWE-5240, " Visual Examination," of the 1992 Edition,1992 Addenda, of AGMESection XI, requires that the requirements of Paragraph IWA-5240, " Visual Examination," for

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VT-2 visual examination is applicable following repair, replacement, or modification.

2.5.2 Code Reauirement From Which Relief is Reauested (as stated)Relief is requested from performing the VT-2 visual examination in connection with systempressure testing following repair, replacement or modification under Article IWE-5000, " SystemPressure Tests."

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Repair / replacements see performed in accordance with the CR-3 repair / replacement program,- which specifies the repair methods and NDE necessary to ensure the original quality, andconstruchon requirements of the containment vessel are met. A VT-1 examination isconducted to detect discontinuities and imperfections on the surface of components.

Paragraph IWA-4422.2, " Defect Removal Without Welding or Brazing," states that afterremoval of defects detected by visual or surface examination, surface examination of thedefect removal area shall be performed

Paragraph lWE-5210 states that, except as noted within Paragraph IWE-5240, '' VisualExamination," the requirements of Article IWA-5000 are not applicable to Class MC or ClassCC components. Paragraph IWE-5240 states that, the requirements of Paragraph IWA-5240

. corrected from IWA-5246 to IWA-5240 in the 1993 Addenda) for visual examinations are(|-apphcable. Paragraph IWA-5240 describes a VT-2 visual examination. VT-2 examinations are -conductcd to detect evidence of leakage from pressure retaining components, with or withoutleakage collection systems, as required during the conduct of a system pressure test.

Table IWE-2500-1, Examination Category E-P, specifies the examination method of 10 CFRPart 50, Appendix J following each repair, modification, or replaccment and does notspecifically identify a VT-2 examination. Appendix J of 10 CFR 50 provides requirements for i

- testing as well as acceptable leakage criteria. These tests are performed by qualified !

personnel and utilize calibrated' equipment to determine acceptability.. Additionally,10 CFR50.55a(b)(2)(x)(E) requires a general visual examination of the containment each period thatwould identify any structural degradt. tion that may contribute to leakage. A VT-2 visual

i examination will not provide additioreal assurance of safety beyond that of current'

repair / replacement and 10 CFR Part 50, Appendix J practices.

' Relief is requested in accordanct; with 10 CFR 50.55a(a)(3)(i). Pressure testing in accordancewith 10 CFR Part 50, Appendix J, provides an adequate level of quality.


Testing and examination shall be conducted in accordance with 10 CFR, Appendix J. A| preservice visual examination (VT-1) will be performed on the repair / replacement.


ASME Sechon XI,1992 Edition with the 1947 Aodenda, %regraph IWE-5240, requires ai visual examination (IWA-5240) on areas affected by repair / replacement activities. Paragraph

IWA-5240, " Visual Examination," requires a VT-2 examination of pressure retainingcomponents for evidence of leakage. The licensee proposes to perform repair / replacements|

in accordance with its own (CR-3) repair / replacement program, "which specifies the repair !

methods and nondestructive examinations necessary to ensure the original quality, and |construction requirements of the containment vessel are met." As part of the CR-3,

l repair / replacement program, a VT-1 examination is conducted to detect discontinuities andimperfections on the surfaces of components.

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. Table IWE-2500-1, Examination Category E-P, specifies pressure testing via 10 CFR Part 50,- Appendix J, followmg each repair, modification, or replacement and does not specify a VT-2

, . examination. Therefore,' the staff agrees with the licensee that a VT-2 examination will notprovide additional assurance of safety beyond the licensee's repair / replacement program,which includes a VT-1 examination to detect surface discontinuities and imperfections, and thepressure test required by 10 CFR Past 50,' Appendix J following each repair, modification, or

~ replacement. On this basis, the staff concludes that the altomative proposed by the licensee isauthorized pursuant to 10 CFR 50.55a(s)(3)(ii).

- 2.6 Relief Reauest No. 98-017-11 '


' ASME, Section XI,1992 Edition,1992 Addenda, Paragraphs IWE-2420(b) and IWE-2420(c)requires that when component examination results require evaluation of flaws, evaluation ofareas 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 re-examined during the next inspection period listed in I

the schedule of the inspection program of Paragraph IWE-2411, " Inspection Program A," orParagraph IWE-2412, " Inspection Program B," in accordance with Table IWE-2400-1, ;

Examination Category E-C. ||

2.6.2 Code Reauirement From Which Relief is Reauested (as stated) !

Relief is requested from the requirement of Paragraphs IWE-2420(b) and IWE-2420(c) toperform successive examination of repairs. !

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The purpose of a repair is to restore the component to an acceptable condition for continuedservice in accordance with the acceptance standards of Article IWE-3000. Paragraph IWE-

- 4150, " Verification of Acceptability," requires the owner to conduct an evaluation of the,

suitability of the repair including consideration of the cause of failure. ]

If the repair has restored the component to an acceptable condition, successive examinationsare not warranted if the repair was not suitable, then the repair does not meet Coderequirements and the component is not acceptable for continued servics. Neither Paragraph ;

- |WB-2420(b), Paragraph IWC-2420(b), nor Paragraph IWD-2420(b) requires a repair to besubject to successive examination requirements. Furthermore, if the repair' area is subject to

- accelerated degradation, it would st!'l require augmented examination in accordance withTable IWE-25001, Examination Category E-C.

7 The successive examination of repairs in accordance with Parsgraphs IWE-2420(b) andIWE-2420(c) constitutes a burden without a compensating increase in quality or safety.

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in SECY 96-080, *lssuance of Final Amendment to 10 CFR Section 50.55a to incorporate by. Reference the ASME Boiler and Pressure Vessel Code (ASME Code), Section XI, Division 1,Subsection IWE and Subsection IWL," dated April 17,1996, response to comment #3.3 states,

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"The purpose of IWE-2420(b) is to manage components found to be acceptable for continued |service (meaning no repair or replacement at this time) as an Examination Category E-C |component, if the component had been repaired or replaced, then the more frequent

iexamination would not be needed "

|Relief is requested in accordance with 10 CFR 50.55a(a)(3)(ii). Compliance with the specifiedrequirements of this section would result in hardship or unusual difficulty without a jcompensating increase in the level of quality and safety. !

IThe requirement to perform successive examinations following repairs has been removed in . |the re-write of the ASME Code, Section XI, Subsection lWE, which has been approved byASME and published in the 1998 Edition.

2.6.4 Altemative Examination (as stated)1

Successive examinations in accordance with Paragraphs IWE-2420(b) and IWE-2420(c) are i4

not required for repairs made in accordance with Article IWA-4000. ;

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2.6.5 Staff Evaluatign

As the Code requires the licensees to verify the -%uacy of repairs, the staff has determined j

that successive examinutions after repair do I,. !s an additional safety benefit.'

Considering the hardship associated with these requirements without a compensating increase |in the level of quality and safety, the staff finds that the licensee's proposed attemative to theCode requirements of IWE-2420(b) and IWE-2420(c) is authorized pursuant to 10 CFR50.55a(a)(3)(ii). ,

2.7 Relief Reauest No. 98-018-11 :1


Table IWE-25001, Examination Category E-G (item no. E8.20) requires a torque or tension i4test of bolted connections that have not been disassembled and reassembled during the

inspection interval.

2.7.2 Code Reauirement From Which Relief is Reauested (ac stated) 1

Relief is requested from ASME, Section XI,1992 Edition,1992 Addenda, Table IWE-2500-1Examinatum Category E-G, Pressure Retaining Bolting, item E8.20. Table IWE-2500-1'

:requires a bolt torque or tension test on bolted connections that have not been disassembled 1

and reassemtned during the inspection interval.

2.7.3 Basis for Relief (as stated) .

Determination of the torque or tension value would require that the bolting be un-torqued andthen re-torquod or re-tensioned. Bolt torque or tension testing is currently required on bolted

. connections that have not been disassembled and re-assembled during the inspection interval.

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Each containment penetration receives a leak test in accordance with 10 CFR Part 50Appendix J, Type B test, in accordance with the specified testing frequencies. As noted in 1

:10 CFR Part 50 Appendix J, the purpose of Type B tests is to measure the leakage of '

containment penetrations whose design incorporates resilient seals, gaskets, sealantcompounds, and electrical penetrations fitted with flexible metal seal assemblies. Theperformance of the Type B test itself proves that the bolt torque or tension remains adequateto 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. 1

Appendix J testing and visual inspection is adequate to demonstrate that the design function ismet. Torque or tension testing is not required for any other ASME Section XI, Class 1,2, or 3bolted connections or their supports as part of the inservice inspection program CR-3 has two '1

, pressure unseating penetrations, the equipment hatch and a blind f ange for post-accidentsampling. The equipment hatch is normally removed during each outage, however the blindflange is not routinely disassembled during the outage.

' Relief is requested in accordance with 10 CFR 50.55a(s)(3)(ii). Un-torquing and subsequent !re-torquing of bo!ted connections, which are verified not to experience unacceptable leakagethrough 10 CFR, Appendix J, Type B testing, results in hardship or unusual difficulty without a ;

compensating increase in the level of quality and safety. |

The requirement to perform bolt torque or tension tests has been removed in the re-write of the jASME Code, Section XI, Subsection IWE, which has been approved by ASME and publishedin'the 1998 Edition. '


The following examinations and tests required by IWE ensure the structural integrity and theleak-tightness of Class MC pressure retaining bolting, and, therefore, no additional attemativeexaminations are proposed:

1. Exposed surfaces of bolted connections shall be visually examined in accordance withrequirements of Table IWE-2500-1, Examination Category E-G, Pressure RetainingBolting, 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.

2.7,5 Staff Evaluation !

)ASidE Sechon'XI,1992 Edition with the 1992 Addenda, Table IWE-2500-1, Examination 2

Category E-G, Pressure Retaining Bolting, item E8.20 requires bolt torque or tension testingon bolted connections that have not been disassembled and reassembled during theinspection interval. This examination is used to aid in the determination that leak-tight seals .

exist and that the structuralintegrity of the subject bolted connections is maintained. Thelicensee proposes to use the 10 CFR Part 50, Appendix J, Type B test as an alternative to theCode requirement to verify the integrity of penetrations with bolted connections.

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The staff agrees with the licensee that bolt torque or tension testing on bolted connections thathave not been disassembled or reassembled during the inspection interval would result in ahardship, whereas the leak testing via 10 CFR Part 50, Appendix J, testing (pressure testing)would adequately verify the leak-tight integrity of the containment. The staff finds thatcompliance with ASME Code requirements will cause a hardship or an unusual difficultybecause the un-torquing and subsequent re-torquing of bolted connections involvesunnecessary radiation exposure and costs to perform the work. The staff also finds that thealtamative approach proposed by the licensee (the pressure test required by 10 CFR Part 50,Appendix J, to verify the leak-tight integrity of bolted connections for containment vessel leak-tight integrity) will provide reasonable assurance of the containment leak-tight integrity, whichis the basic purpose of the ASME Code requirements. On this basis, the staff concludes thatthe altamative proposed by the licensee is authorized pursuant to 10 CFR 50.55a(a)(3)(ii).

3.0 CONCLUSION

Based on the information provided in the relief requests, the staff concludes that for Request|

for Relief No. 98-014, the licensee's proposed altemative will provide an acceptable level of. jquality and safety. Therefore, the proposed altamative may be authorized for the first 10-year '

containment inservice inspection interval pursuant to 10 CFR 50.55a(a)(3)(i). For Requests forRelief Nos. 98-012,98-013,98-015,98-016,98-017, and 98-018, the staff concludes that -compliance ~with the specified requirements would result in hardship or unusual difficultywithout a compensating increase in the level of quality or safety. These proposed attemativeswill provide reasonable assurance of containment pressure integrity and, therefore, may beauthorized pursuant to 10 CFR 50.55a(a)(3)(ii).

Principal Contributor: Clifford G. Munson, NRR

Date: October 4,1999

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WASHINGTON, D.C. 20665-4001

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Transcript of WASHINGTON, D.C. 20665-4001