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Welcome to the ASME Section XI Users Group Bulletin Board for the United States Nuclear Power Federal Regulations, Codes, & Standards Users Group. This bulletin board is for the use and benefit of all individuals and organizations that wish to post specific questions and replies that are relevant to the implementation and use of ASME Section XI. Questions and replies are posted below as they are received, and only identify the subject, date, and signature as provided, if any, to maintain individual privacy. Advertising and irrelevant material will not be posted. Please limit your postings to 100 words or less and do not include attachments. Send your questions and replies to bulletinboard@tech-tel.com.

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Bulletin Board Postings:

Date:  Monday, 2 May 2011

 

Subject:  Class 2 and 3 Pressure Testing Using IWx-2420(a)

 

Dear Group:  WF3 has several Category C-H and D-B pressure test examinations that are located within an area that is inaccessible for examination without the removal of a concrete block wall.  In the first and second ISI intervals, this block wall was partially removed and rebuilt each period to facilitate the examinations.  In this third interval, those same examinations are being labeled as “impractical” due to accessibility and will not be examined unless the block wall is breached for maintenance of other non pressure test activity.  The question is; “Can the rules of IWx-2420(a) be applied to categorize these examinations as “impractical” thereby removing them from period pressure test requirements for this third ISI interval”?

 

Mike Bratton

 

(Summary of Responses)

 

 

Date:  Tuesday, 16 November 2010

 

Subject:  Class 1 IWB-1220 Exemptions

 

Dear Group:  Please see my Class 1 IWB-1220 Questions regarding exemptions below.

 

Mike

 

(IWB-1220 Questions)

 

(IWB-1220 Responses)

 

 

Date:  Monday, 17 May 2010

 

Subject:  External Corrosion on ASME Class 1, 2, and 3 Piping

 

Dear Group:  What rules can be used to build up an area on piping found during a walk-down?  Code Case N-661-1 can be used to build up the OD when internal erosion/corrosion is found.

 

Generic letter 90-05 was put out for temp repairs, is that still current?

 

Mike

 

 

(Summary of Responses)

 

 

Date:  Tuesday, 16 February 2010

 

Subject:  Category B-P Leakage Test

 

Dear Group:  For PWR plants, at what pressure and temperature (psig/F) is the reactor coolant system when you perform your Category B-P Leakage Test?

 

Thanks, Jim Boughman

 

(Summary of Responses)

 

 

Date:  Wednesday, 22 April 2009

 

Subject:  Repair Replacement Items Under IWA-4120(e)

 

Dear Group:  We have some flow instrumentation that is tack welded to the inside pressure boundary of Class 3 piping.  Under IWA-4120(e) of ASME Section XI 1995 thru 1996 Addenda would these tack welds require an NIS-2 and notification of the ANII?

 

(Summary of Responses)

 

 

Date:  Tuesday, 21 April 2009

 

Subject:  Use of One ASME Section XI Edition/Addenda for Multiple Units

 

Dear Group:  I wish you could inform me if it is possible to use a single code edition in a nuclear power plant with two units which have different commercial operation dates.

 

I'm working in Laguna Verde Nuclear Power Plant, Veracruz, Mexico.  Thanks in advance, Jose

 

(See Response Below)

 

 

Date:  Wednesday, 22 April 2009

 

Subject:  Use of One ASME Section XI Edition/Addenda for Multiple Units

 

Dear Jose:  Code Case N-765 is awaiting publication in Supplement 8 to the 2007 Edition.  This will permit an owner to align inspection intervals for multiple units.  U.S. plants currently can only use this with an approved relief request from the Nuclear Regulatory Commission (NRC) until the NRC endorses N-765 in the NRC Regulatory Guide 1.147.

 

 

Date:  Wednesday, 7 January 2009

 

Subject:  Repair/Replacement Activities Utilizing IWA-4340

 

Dear Group:  I would like to post the following for industry feedback:

 

Background: 10CFR50.55a(b)(2)(xxv) prohibits licensees from using IWA-4340, "Mitigation of Defects by Modification," for those programs using the ASME Code, Section XI, 2001 Edition through the 2004 Edition.  The following questions are for those licensees using the 2001 Edition through the 2004 Edition.

 

Question #1:  What repair methods are your plants using to address defects caused by general or pitting corrosion in buried piping?

 

Question #2:  If the defective area is physically removed from the buried piping, do you consider the installation of a branch connection (encapsulating the affected area) to be a repair method that utilizes IWA-4340?

 

Thank you.  Mark

 

(Summary of Responses)

 

 

Date:  Monday, 2 June 2008

 

Subject:  Implementing IWA-5244 For The Underground Diesel Fuel Oil Tanks

 

Dear Group:  I would like to post the following for industry feedback:

 

A lot of discussion has circulated around the industry regarding buried portions of the Nuclear Service Water system containing butterfly valves and the IWA-5244 requirements.  I would like to know how those in the industry are meeting the IWA-5244 requirements for the underground Diesel Fuel Oil Storage tanks.  If included in the ISI program, these systems are generally classified as ISI Class 3.  I would appreciate any information regarding utility experience such as:

 

1.  ISI classification or omission from ISI based on Regulatory Guide 1.26.

 

2.  Does anyone use American Petroleum Institute (API) standards for testing?

 

3.  Does the candy cane vent, which is open to the atmosphere, constitute a nonisolable configuration?

 

4.  Does anyone use a customized test configuration such as a low pressure hose connected to the candy cane vent?

 

Thanks in advance for any information on this issue,

 

Jim

 

(Summary of Responses)

 

 

Date:  Wednesday, 20 February 2008

 

Subject:  Activities That May Impact Inservice Inspection Plans

 

Question #1:  Do you perform any of the following activities to identify changes to Class 1, 2, 3, MC/CC components that could impact your current and future Inservice Inspection Plans (including pressure testing plans)?

 

1.    Review Repair/Replacement Plans for Code Repair/Replacement Activities

 

2.    Review repair/replacement work packages associated with planned modifications prior to work being performed

 

3.    Review completed NIS-2 Forms for Repair/Replacement Activities

 

4.    Perform periodic reviews of work packages associated with plant maintenance activities

 

5.    Perform periodic reviews of as-built drawings releases for P&ID drawings to identify system classification and system boundary changes

 

Question #2:  What methods other than those described in Question #1 do you use to identify changes to Class 1, 2, 3, MC/CC components so that personnel responsible for your Inservice Inspection Program can evaluate what effect these changes have on your Inservice Inspection Plans?

 

Thanks, Mark

 

(Summary of Responses)

 

 

Date:  Friday, 11 January 2008

 

Subject:  Mid-Cycle Outage For Fuel Leak

 

Dear Group:  We’ve developed a fuel leak and have performed suppression to minimize further degradation.  Our site may still elect to perform a mid-cycle outage to remove the leaking bundle to minimize future source term.

 

After reviewing Section XI (current code of record is 1995 Edition with 1996 Addenda) and also Interpretation XI-1-01-19 (attached), we’ve concluded that Section XI doesn’t require a Category B-P pressure test for a mid-cycle outage even if the RPV head is removed and reinstalled.

 

For those plants that have performed a mid-cycle outage and removed/reinstalled the RPV head, what sort of inspection activity, if any, was performed to verify no leakage after reassembly?  What edition/addenda of Section XI was in effect as their code of record at the time of the mid-cycle outage?  Thanks, Ric

 

 

Date:  Tuesday, 22 January 2008

 

Subject:  Mid-Cycle Outage For Fuel Leak

 

Dear Ric:  Please see the responses below.

 

Mike Blew:  In this day and age, regardless what the ASME Code identifies (which are minimum requirements) I think to perform the exam would be prudent, based on the problems with boric acid.

 

Roy Blyde:  I fully agree with your Code interpretation, no Code examination is required for a mid cycle outage as it is not a refueling outage.

 

We have been in this situation during forced outage (FO28), head off but no fuel removed.  However, as a matter of good engineering practice we performed a VT-2 examination of the disturbed pressure boundary components.  This is a practice we use for all activities involving disassembly of pressure boundary components as we believe it is prudent to check for leaks following such disturbance.  However, these are not Code required examinations as they are maintenance activities, e.g. disassembly and reassembly of a valve bonnet or flanged joint.

 

I would therefore recommend that a non Code VT-2 examination is undertaken for the pressure boundary components that have been disassembled.

 

Jim Boughman:  I do not recall any mid-cycle outages at Duke Energy plants where the RPV head was removed and reinstalled.  In addition to Interpretation XI-1-01-19 that was referenced in the Monticello question, there have been other Interpretations issued on this subject as well.  XI-1-89-15 (Vol 25), XI-1-89-33 (Vol 27), and XI-1-86-13R (Vol 29).  Since ASME does not consider this scenario as a Category B-P activity, my opinion would be to consider this a maintenance activity and follow your site procedures that govern those activities.

 

Hien Do:  We do not require a Section XI pressure test after disassembly and reassembly of RPV Head mid-cycle when there are no Section XI repair/replacement activities.  However, it is my understanding that Ops would perform a walkdown at various pressure levels to check for leaks.  No VT-2 qualification is required for this Ops walkdown.

 

George Fechter:  The first thing I was going to mention was the inquiry that Monticello cited, and that definitely clarifies what Section XI feels is required.  I believe you could draw the logic that if there’s no R&R performed a VT-2 would not be required even for a Class 1 breach, and the removal of the RPV head to remove/replace a leaking fuel bundle is clearly not a Section XI R&R applicable activity.  But, I would perform a VT-2 of the RPV head flange and other RPV head vent piping flanges which are breached, not due to being a Code requirement, but as somewhat of a good engineering judgment since an improperly assembled connection in this area would assuredly result in another shutdown.  This would be similar to the logic of only performing a VT-2 of the portion of a system which had R&R performed.

 

Roy Hall:  Monticello is correct.  No ASME Category B-P exam is required provided there is no repair/replacement activity on the RPV or Class 1 systems and the mid-cycle outage doesn’t blossom into a refueling outage.

 

Dan Lamond:  I don't have much specific experience with this one other than the interpretation you have already mentioned as clarifying that Section XI pressure testing does not apply to this situation.  Beyond that, I would think it would fall under the plants maintenance program and that program would have requirements for assuring structural/joint integrity after disassembly/reassembly activities.

 

Alex McNeill:  The 95 Edition with the 96 Addenda of ASME Section XI, Category B-P requires the system leakage test after each refueling outage.  Refueling outage does not appear to be defined in the code.  This does not meet the classic refueling, but in literal sense you are refueling (exchanging fuel bundles).  Inquiry XI-1-01-19 appears in my mind to clarify that the refueling outage usage is to identify a test surveillance frequency (18 months to 24 months), and your proposed mid-cycle would not require a Class 1 system leakage test per Category B-P.  Clearly this is not a normal refueling and the fact fuel bundles are exchanged would have no bearing on what a system leakage test verifies.  I would support Monticello’s position.  Other items to consider however, is if any repair/replacement is planned on the Class 1 systems and the unit's technical specifications.  Both could drive the requirement for a system leakage test.

 

Gary Park:  I have not yet experienced a mid-cycle outage when the reactor head was required to be removed and reinstalled.  You would think at my age, I would have been through many of them (I guess I am just lucky).  However, I have read the interpretation that was referenced and it is pretty clear as to what the requirement is.  As you look at what we did many years ago in revisiting the many pressure testing inquiries and the ones that were revised stating that IWA-5211 was a definition and not a requirement; subsequently revising many interpretations.  Some ended up being changed to not requiring a pressure test under the repair/replacement rules.

 

Frank Schaaf:  This is a BS question.  Somebody does not want to do a test to save outage time.  The original requirement stems from the annual refueling cycle.  This requirement was to ensure that all the Class 1 holes made during the outage are closed.  So any hole in the pressure boundary made during the mini-outage (head removal) needs to be tested.  The Owner would be taking a great risk not doing the test, both in money and safety if a problem developed.  The Owner will spend more time and money trying to get out of the test than just doing it.  An option would be to control the holes opened and only inspect those holes.  Hope this helps.

 

Rick Swayne:  Section XI doesn't have any applicable requirements.  The leak testing is a maintenance activity.  It doesn't matter what Section XI Edition or Addenda they are using.

 

Ken Thomas:  When we had this condition, we performed the normal start-up walkdowns for evidence of leakage.  It was not a VT-2 examination since there were no ASME XI repair/ replacements performed during the mid-cycle outage.  At that time we were using the 1989 Edition of the Code.  I have attached a white paper we prepared for management.  This should help Monticello.

 

Russell Turner:  I would agree that a category B-P VT-2 is not required, as Section XI states it is for refueling outages.  I would consider that a maintenance outage.  However, there is probably some tech spec or maintenance requirement to look at the head during restart to ensure no flange leakage, and it’s a good idea to take a look.

 

Rick Wehry:  At Susquehanna, we came to the same conclusion (i.e., that Section XI doesn't require a B-P pressure test for a mid-cycle outage).  We performed mid-cycle fuel bundle re-channeling outages in 2006 (Unit 2) and 2007 (Unit 1)).  We did perform a non-VT-2 confidence leak check following re-assembly (performed by Maintenance) in each instance.  Our code of record is 1998 Edition through 2000 Addenda.

 

Ron Yonekawa:  We haven’t really done a mid-cycle head removal (to my knowledge) so have no actual experience here.  We had revised the code for requirements for pressure testing to address when items are mechanically disassembled and reassembled to only require a leak test, so that is what I would think is required here.  There are tons of interps on IWA-5214.  I think the consensus of these is that a leakage test is required.

 

 

Date:  Friday, 4 January 2008

Subject:  Definition of Section XI Outage

Dear Group:  We are performing a repair on-line of one of our three class 2 RHR pumps by taking a short RHR outage. We are planning to perform the Code Category C-G pump casing welds during this time.  They are only accessible from the ID.  It will be the first pump in this group that is being disassembled during this inspection interval.  There are no definite plans to disassemble another pump in this group before the end of the interval.  If we find flaws that require additional examinations (IWC-2420) does the code require the additional examinations be performed during this repair evolution or can they be done at the next refuel outage?

 

IWC-2420 uses the term "current outage" as to when the additional exams are to be performed.  A search of Section XI for the word outage reveals that this term is only used with the time period that the plant is shut down.  It is not associated with a system outage when the plant is on-line.  A search of the interpretations did not reveal any applicable to this situation.  I could interpret IWC-2420 that since we are not in an outage I don't have to do additional examinations at this time.  However nothing in the Code would require me to do the additional exams at the next refuel outage.  Thanks, Doug

 

 

Date:  Tuesday, 15 January 2008

Subject:  Definition of Section XI Outage

Dear Doug:  Please see the responses below.

 

Ed Anderson:  This is a good question and I feel there is no easy answer but there are options that they can consider.

 

Normally, in-service examinations conducted during a scheduled refueling outage that reveal flaws exceeding the acceptance criteria would require as a minimum the following actions/steps, as applicable:

 

1. Supplemental examinations (IWC-3200), comparison to preservice/previous in-service examination to aid in characterization of flaw.

2. Repair/Replacement activity (IWC-3122.2).  Preparation of Repair/Replacement Plan (IWA-4150) or

3. Analytical evaluation (IWC-3122.3).  Submittal to NRC.

4. Expanded sample (IWC-2430).  Completed during outage.

5. Re-examinations (IWC-2420(b) and (c)

 

I am assuming that because they can only perform these pump examinations from the ID surface, that they must have a Relief Request that states they will perform these examinations only when the pump is disassembled.  In such a case, expanded samples would be required during the current outage (scheduled or not).  In addition, regardless of Code, their corrective action program should also require an extent of condition evaluation, which normally would require some sort of expansion.

 

As expansion would require the disassembly of another pump and/or all pumps, they should have a contingency plan in place.  As a minimum they should be prepared to perform an analytical evaluation based on the flaw, that would justify conditional acceptance till the next scheduled refueling outage.  This evaluation should also justify the need for not performing the expansion at this outage, considering bringing the unit down.  Provided the analytical evaluation and extent of condition evaluation would justify this action, and NRC acceptance is received prior to returning the pump to service.

 

Other considerations could include Requests for Relief or Alternatives from Code requirements.

 

Glenn Perkins:  I agree with Ed’s input.  Also consider the guidance provided by NRC RIS 2005-20.

 

Remember the on-line exam requirements that some were trying to add into the code, they ran into roadblocks with exactly this scenario.  What do we do when unacceptable flaws are identified?

 

Mike Blew:  If you are in an outage and your examination reveals indications that exceed the Code allowable, you are required to expand the sample.  I do not see how you could avoid disassembly of another pump without specific relief from the NRC to allow you to postpone the examination (expanded sample) untill the next refueling outage.  It may be prudent to present the relief to the NRC prior to the examination/repair.

 

James Boughman:  I am sorry, but I do not have enough experience with this scenario to provide meaningful feedback, but I would like to offer a comment.  The code does not currently have provisions for online examinations.  WG ISI Optimization has an action to address online exams (reference WGISIO #01-01).  This item was assigned to WG ISIO by Section XI Executive Committee during the February 2001 meeting.  Establishing the appropriate scope and applicability of the ASME Section XI Code for online exams has been circulating through the code body since Tony Lentz was chairman of Water Cooled Systems (a long time ago).  Those of us in the ISI Optimization working group have not been able to reach a consensus on the action.  Coincidentally, the biggest issue for the working group is how to address successive exams when performing online examinations.

 

I am afraid that a formal inquiry to ASME would not be useful unless it was worded in such a way the committee could not say the code does not address online exams.

 

Additionally, Warren Bamford, Frank Schaaf, and Roy Hall have made presentations to ISI Optimization on this issue.  Those guys may provide something of more value relative to their experience.

 

Ric Deopere:  I don’t have any experience with this particular situation and would have the same question about the definition of “current outage” for IWC-2430.

 

It might be best to submit an Interpretation from the Section XI Code.  That way, it may lead to clarification of the code requirements in subsequent editions/addenda.

 

Hien Do:  The code is totally silent about on-line exams.  If we had to perform sample exams during on-line ISI, we would consider the risk on completing the required additional exams during the work week window(s) of the affected system/subsystem.  If the risk is high, we would do the ISI as close to an outage as possible.

 

Another point I would like to add is that in absence of Code requirements, the plants also need to follow their CAP.  If degraded conditions are identified, the extended conditions needed to be addressed in a timely manner.

 

George Fechter:  First, I believe the reference should be to IWC-2430, Additional Examinations, versus IWC-2420, Successive Examinations.  My opinion would be that the additional examinations would have to be performed right away with the understanding that you have to schedule for exam personnel and any other planning implications (scaffolding, insulation, etc.).  This is the potential risk of performing on line ISI.  While the Section XI term “outage” refers to refueling outage, I do not think it would be the intent of Section XI to exempt performance of an additional exam due to the loophole of “system outage” not being defined.  I follow the logic noted in the final sentence of the 2ND paragraph, but this final sentence also provides me the background of taking the stance that Section XI wouldn’t permit a follow on exam to be exempted simply due to it not being discovered in the next refueling outage.  I would view this as a very risky basis in a regulatory sense to take to justify not performing this additional exam.

 

The Category C-G exams may be performed from the internal or external surface of a component.  I don’t see anything that would prohibit performing the exam from the internal surface of one pump and from the external surface of another pump.  I believe this is supported by the final sentence of IWC-2430(a), which provides for selection of welds outside of the system that the one containing the initially discovered flaws.

 

I haven’t run into this situation myself at Hatch since we only perform ISI during a refueling outage with the exception of ISI pressure tests, which are primarily performed online and which don’t have the scope expansion criteria of other categories.  I’m not sure where WG-ISI Optimization is with the on line ISI issue, or if it’s still an active issue being considered within Section XI.

 

Mark Ferlisi:  I’ll do a little digging to find out if we’ve ever run into this situation.  However, what the individual is running into is a typical risk that we all run into when we choose to perform any Code examinations during plant operation.

 

If I were to provide an opinion, I’d say that this plant is not in an outage and that the examination is being performed “on-line”, even though the component or system in question is not in service at the time.  This issue poses a dilemma for me in that, unless an adequate solution is found to the licensee’s concern, a licensee in this position might choose not to perform the Code examination simply to eliminate the risk that they might have to perform additional examinations.  If they choose not to perform the code required examination at this time, but find something of concern anyway, it is the plant’s Tech. Specs that would govern how they would respond.

 

I’ll think about this a bit more, but I believe that the licensee would have no choice but to perform the required additional examinations immediately if they find something in their C-G exams, unless they file a Relief Request.

 

Larry C. Keith:  Mark, I think you are right, I think once you find a reportable indication is found, the additional exams must be performed before the unit is operational or don’t examine it unless you are willing to take the risk of bringing the unit down.

 

Dan Lamond:  I don't think you are going to find a clear answer on this one.  I believe the real question here goes to the long standing item SCXI has been trying to address through WGISIOPT and SGWCS regarding the scoping of the Code.  Mainly, does the Code apply to online or non-refueling examinations, and if so, what are the requirements.  Since the Code does not specifically address this and has been unsuccessful coming to consensus on rewrites addressing this specific topic, the owners are left to perform these exams at risk and then interpret what is required if a flaw is found.  Conservative, do the expansion in the same outage.  Unconservative, do an evaluation to justify some time out in the future.  Perhaps reasonable, do an evaluation that justifies getting to the next system outage one of the other pumps in the group, assuming that next outage is not too far out in the future.

 

Scott Kulat:  I have not experienced this situation in practice, but the underlying concept of on-line examinations is a topic that the Code has been wrestling with for years.  I'm pretty sure that the Task Group on ISI Optimization is currently looking into developing criteria for this situation.  As it currently stands, I would think that if the utility performs the evaluation, they do so "at risk" because if they find something they will need to perform additional examinations right away.  If they do perform the examination and find a flaw, one potential option to address the issue is see if the flaw meets the criteria of Code Case N-586-1 which would eliminate the additional examinations.  Of course, that would require a root cause evaluation and favorable results.

 

Ed Maloney:  Good questions. No good answers yet.  I believe that the working group on Optimization is still struggling with the online exams issue, including what the 'Additional Examination' requirements need to be when performing exams online.

 

From a WGGR perspective, we have tabled any work on these issues pending results from the Optimization working group.

 

My thoughts tend toward performing the 'Additional Examinations' within some short time period after discovery of the flaws.  This would mean during the same operating cycle.  I realize that this might be more conservative than what the author proposes (next refueling outage), but it would satisfy the Code intent to perform the additional scope within a month or so of discovery (i.e.: during the current outage).

 

Alex McNeill:  The code is not to user friendly with regard to on-line examination.  We perform on-line examination in a few cases on components that can be expanded to easily, if necessary (e.g., supports outside containment), and usually close to a scheduled outage in case it goes sour.  In your example it would be my opinion that we would be driven to the code expansion requirements which we would interpret as being required during the mentioned RHR outage.  The code double sample plan is written to insure identification of a larger problem after the first failure.  Given the operational or access constraints for the expansion, we might plead a case to the NRC to allow expansion at a more optimal time in your example.  We would need to know what the root cause of the failure was before that was attempted, however.  There has been talk of providing on-line code requirements that would better define what needs to be done.  I have not heard anything recently.

 

Dajun Song:  In my opinion, once you conscientiously make a decision to perform an ASME XI inspection the rest of the Code requirements come into play.  Therefore, if you find a component that exceeds the acceptance standard, you have to expand the scope during that "RHR outage.  The Code does not allow the scope expansion to be performed during the next refueling outage.  That's why when we schedule on-line ISI, we make sure that either we are within 2-3 weeks prior to a refueling outage or that scope expansion will not affect the operability of a given system.  I would even go further to state that if the flaw exceeded the acceptance criteria and was evaluated as acceptable, you still have to expand the scope.  Again this is my opinion on what the Code says.  I did have a discussion with Russell T, and he and I concur.

 

Rick Swayne:  This is a common-sense question.  It is not specifically addressed by Subsection IWC.  However, the Foreword states, "The Code is not a handbook and cannot replace education, experience, and the use of engineering judgment.  The phrase engineering judgment refers to technical judgments made by knowledgeable engineers experienced in the application of the Code."  I will make those decisions only if I am paid to do so.

 

But first, I would answer a few questions.  Why are you trying to avoid sample expansion?  Are you afraid of the results?  Are you just trying to save money?  If you find flaws that require additional examinations, are you prepared to explain to the NRC and a skeptical public why the plant is in service without those examinations having been performed?  If you can take one RHR Pump off line, why can't you do the same with the other two?  If any other pump later causes a plant outage, are you prepared to explain why you didn't do the examinations when you had an opportunity to do so?  Worse yet, if you haven't performed those examinations before the end of the next refueling outage, can you explain why you should still have an operating license?

 

Ken Thomas:  Interesting.  We have not identified any C-G welds in RHR pump casings.

 

Currently, the code does not address scope expansion for on-line exams.  We have an action at SGWCS to provide those rules (see attached).

 

I would say you would have to discuss deferring any additional exams with the regulator.

 

Russell Turner:  Very tough question.  As you know, the committee's are working on making the Code a bit easier to use by redefining what an outage is, but they have a long way to go on that issue.  Looked at the 1989 and 2004 Codes, and they read essentially the same, so my answer should cover the Code of that utility.

 

One of the things ISI Optimization was looking at was how to get the additional exams to be deferred until the next outage.  The NRC was having difficulty accepting this idea, as they wanted us to look at other items as soon as possible, even if it meant shutting down the plant.  Another case of punishing us for doing the right thing sooner than required.  Here are the latest minutes from that action.  Most of the issues seem to have been resolved.  The title for this action is, "Applicability of Section XI and On-Line Examinations".

 

10/30/06 Action. Significant discussion took place pertaining to the revised information provided in the agenda.  Upon conclusion of all the comments, it was determined that the following items need to be considered for inclusion into the action:

 

1) addressing of supports (IWF),

2) risk informed implications with scope expansions,

3) can a Code Case modify a Code Case (Risk Informed),

4) time limit to performing analytical evaluation (tech spec LCO?),

5) clarify intent of postulated flaw analysis.

 

In addition, in the last paragraph of the inquiry reply, it was suggested to revise the last sentence to read “beyond the next scheduled refueling outage”, to be consistent with the response in (1).  It was the general consensus of the members and visitors present that the action needs to continue.  Although some support may have dwindled slightly since the initiation of the action and implementation of risk informed programs, the need to possibly address supports (IWF) may enhance the benefits.  The removal of Class 1 components from the action significantly reduced the potential scope, but was felt that may have increased the success possibility as the action continues through the approval process.  Possible vote in Jan 08.

 

01-29-07 Proposed Code Case revised to address comments.  This case should not address Risk Informed because you can not use one code case to modify another or to modify a relief request.  At present, not considered necessary to address component supports because the provisions of IWF-2430 and IWF-3122 are less stringent than the IWC/IWD requirements.  A separate action will be brought forward in May for supports.  With minor editorial changes, the Code Case passed 9-0-1. Item will be passed to WG ISC.

 

At WG-ISC at this time.

I noticed there were no negatives on the last vote, and I assume the NRC was the abstention.

My take on reading the existing Code is the additional exams need to be performed during the existing outage.  If performed on-line, then the definition of outage become vague.  Many utilities have "system outages" and used that as their "outage", but that link is weak.  There would be difficulty in convincing the NRC that the additional exams should not be performed as soon as possible as they tend to be very conservative.

Not sure I can really answer this.  My advice is to be prepared for the worst and hope for the best.  Understand what types of flaws are expected (casting flaws) or could be found (cracks) and be ready to evaluate them.  I think it may take a relief to not go into another pump almost immediately.  As always, when you run into a difficult situation such as this, be prepared to talk with the NRC and see if they will agree in writing to defer the exams until the next refuel outage.  Have your evaluation ready.

 

I have performed exams on-line in the past, and will continue doing them in the future.  Only one train at a time, usually only one component at a time.  That gives us some breathing room if something is found.  Not always ALARA, and the NDE folks can get mad when they are requested to do an exam next to the one they did yesterday.  It is a risk we evaluate up front and we thoroughly understand the potential consequences of our actions.

 

Ray West:  Here is my input, but I don't think it is the complete answer that the utility wants to hear.

 

As far as I am aware Section XI does not address ISI examination requirements for NDE or visual examinations other than at plant outages such as refueling shutdowns or maintenance shutdowns.  If you think the intent was there with the current requirements, I would consider that to be crafting the requirements ( i.e., the terminology that Gill Millman used for many years) and that would be unacceptable.  So, I believe that the situation that you have described below fits into the on-line ISI examination arena.  Since I believe this to be the case the rules of Section XI do not apply in regards to additional examinations.  However, there is no prohibition in performing the examination to meet Section XI ISI requirements and taking credit for the examination.  Owners do on-line ISI examinations for credit under their Section XI ISI programs all the time, but at their own risk.

 

What I mean by "at their own risk" I know from my own experience.  I found out many years ago that the additional examination requirements of Section XI are not applicable because doing this examination outside of a plant outage is the choice of the Owner.  The Owner has to accept the risk in doing this examination.  Depending on the severity of any indications or flaws identified by the Owner, the Owner must handle those indications or flaws under their own corrective action program.  Section XI acceptance criteria listed in Category C-G for your example pump welds can be used to evaluate any indications or flaws that are identified, but the Owner will also be required to perform an operability determination outside of Section XI space under the plant's license requirements (i.e., Technical Specifications or Technical Requirements Manual) and this operability determination has to include an extent of condition evaluation.  If it cannot be established by the Owner that the extent of condition evaluation shows that the indications or flaws are isolated to this particular pump, then the plant will have to disassemble another pump or make it in-operable.  Time frames for meeting this criteria are all outside of Code requirements.  This could result in entering an action statement and limited condition for operation, or in a worst case situation lead to shutting down the plant, thus as an Owner you have to be able to accept the risk when you perform on-line ISI examinations.

 

Now just so you are aware the Code has been working on an action item at the Working Group on ISI Optimization (WGISIO) to develop a Code case to provide rules for on-line ISI examinations.  The Code case passed the WGISIO and then went to the Working Group on Inspection of Systems and Components (WGISC).  The WGISC also passed the Code case during the November 2007 Code meetings.  The Code case should be on the SGWCS agenda for February and I have included a copy for your information.  The Code case provides rules for additional examinations to be performed when performing on-line ISI examinations. I support this Code case and I have attached a copy for your information.

 

I hope what I have given you here helps.

 

Ron Yonekawa:  First, I have to say that I am not the expert in this area, so anything I say will probably be a little suspect (Ray West, Chuck Wirtz and Rick Swayne are probably the best persons to ask).  Having said that, I believe your situation falls through the code crack somehow.  I believe the code assumes that all of these inspections are being done during a plant outage, so doing an inspection with the plant still on line is not specifically addressed.  I do not believe the code would intentionally require that the plant be shut down to do an additional inspection, if that were to be required, to expand the examination to “additional welds, areas or parts” of other components.  I do not read it to say that you must inspect other components, rather it seems to say that you are required to inspect within the component.  The footnote to item says within the “inspection item”.  So, if there are other welds “of similar material or service”, it sounds like you can do the expansion within the same pump that you have disassembled.  But, I guess you probably only have one weld of that category.

 

I believe that it would be good to pursue an inquiry on what “current outage” means relative to system outage not associated with a plant outage.  A second part or separate inquiry should address if it is the intent of the code to cause a plant outage (if necessary) to perform the additional exams if the examination causes an additional examination to be performed.  And the response could include a revision to these paragraphs to clarify that the additional examination can be performed during the next regularly scheduled plant outage.  I’m thinking that this is when the C-G examination would have been performed to begin with.

 

 

Date:  Thursday, 13 December 2007

Subject:  Examination Category B-G-1 Bolting

Dear Group:  Do most licensees interpret Table IWB-2500-1, Examination Category B-G-1, footnote (2) [1989 Edition through the 2004 Edition] to require that bushings and threads in base material of flanges be examined when the connection is disassembled, even if the bolting has already been examined during the interval with the bolting in place under tension, as permitted by footnote (1)?  Thank you, Gary

 

 

Date:  Thursday, 20 December 2007

Subject:  Examination Category B-G-1 Bolting

Dear Gary:  Please see the responses below.

 

James Agold:  We only have one plant with RPV bushings (Hatch-1 BWR-4).  The RPV studs typically remain in place during the entire 10-year ISI interval with the exception of four studs removed every refueling outage.

 

Southern Nuclear is performing these examinations:

 

(1) UT examination of the RPV studs once per ISI Interval;

(2) UT examination of the RPV flange threads once per ISI Interval;

(3) VT examination of the RPV bushings once per ISI Interval.

 

We believe the ASME Code only requires a one-time examination per the ISI interval but a utility could certainly look at the bushings to ensure that no damage has occurred.

 

Steve Brown:  The IWB experts I work with do not require another code exam to be done on IWB B-G-1 items if they are disassembled once the initial examination has been completed.

 

Dan Burgess:  It is our opinion that these are separate examinations, and that the Code requires them to be performed when the opportunity arises.  So, if a connection is disassembled and the bushings and threads in base material of flanges are able to be examined, they should be.

 

We do not recall having been asked this directly by any utilities, but our answer would be to examine.

 

Ric Deopere:  I know this is quite lengthy, but I hope it helps the end user understand the Code requirements a little better, and that they are also able to take advantage of alternatives provided by the Code Cases accepted by the NRC.

 

Based on my experience and understanding of the Code requirements, the answer to the question in your email below is YES, bushings and threads in base material of flanges require examinations stated in IWB-2500-1 B-G-1, even if the bolting has been previously examined “in-place under tension” during the Interval.  The code Item Numbers for bushings and threads in flange would not have been satisfied with an “in-place under tension” exam due to these items being inaccessible when a bolted connection remains assembled.  This same requirement would also be applicable to the item number for flange surface, when disassembled.

 

Footnote 1 that you mentioned in your email below applies to bolting;  the term bolting is a generic term which includes bolts, studs, nuts, bushings, washers, and threads in base material and flange ligaments between threaded stud holes. (Reference Interpretation XI-78-20).

 

Footnote 2 goes on further to state that bushings and threads in base material of flanges are required to be examined only when the connections are disassembled.  Bushings may be inspected in place.

 

As shown in the IWB-2500-1 Table for B-G-1, the bushings and threads in flange are permitted to be deferred to the end of the Interval.  Therefore, if the bolted connection is not disassembled for the duration of the Interval, no examination would be required for the applicable bolted connection.

 

For the other “bolting” components that were already examined “in-place under tension”, the examination would not need to be re-performed, i.e. bolt/stud, nut, washer, even if the connection is subsequently disassembled at a later time.

 

Although they don’t change the wording of the footnote requirements for bushings or threads in flanges, Code Cases N-652 and N-652-1 provide for alternatives to the B-G-1, B-G-2 requirements for IWB-2500-1, and the C-D requirements of IWC-2500-1 that are advantageous and more easily understood than those provided in IWX-2500-1 Tables.  I would highly, recommend an ISI Program Owner consider use of one of them as allowed (or soon to be allowed) by 10CFR50.55a.

 

·         CC N-652 is acceptable for use per Reg. Guide 1.147, Rev. 14.  RG 1.147, Rev.14 is acceptable for use per incorporation by reference in the current 10CFR50.55a.

 

o        Bushings and threads in flange are discussed in footnote 3 of the B-G-1 Table of the Code Case

o        N-652 was incorporated into the 2002 Addenda.

 

·         CC N-652-1 is listed as acceptable for use per Reg. Guide 1.147 Rev. 15 that was issued in Oct. 2007.  However, it should be noted that licensees cannot begin to use Rev.15 until incorporated by reference in the upcoming revision to 10CFR50.55a which is supposedly due for publication early in 2008.

 

o        Bushings and threads in flange are discussed in footnote 3 of the B-G-1 Table of the Code Case

o        N-652-1 was incorporated into the 2004 Addenda.

 

Hien Do:  My answer is Yes.

 

George Fechter:  I would understand the requirement to be that you would examine the bushings/threads in base materials of flanges when the connection is disassembled even if the bolting had previously been examined in place under tension.  In my opinion, the “in place under tension” option is only applicable for the final outage in an interval, and this is partially based upon the permissive to defer an examination to the end of an interval.  I would not think it would be acceptable to examine in place at the beginning of an interval without disassembly and then disassemble and not examine at a later date in the same interval.

 

Roy Hall:  Footnote 2 of the 2007 edition clarifies that the examination of the bushing is only required when the bolting is removed (not when the connection is disassembled).  You are then allowed to examine the bushing in place with the bolt/stud removed.  I do not see an allowance for crediting an examination of a bushing in place under tension.  According to my read, if you don’t remove the bolting for maintenance or other reasons, then no examination would be required for that interval.

 

For argument sake, let’s assume you could credit examination of bushings in place with the bolting still installed.  You may then wish to consider crediting the examination that allows the most access of the area.  This is similar to the requirements of Footnote 2 of B-L-2 and B-M-2 which requires an examination at a later time if subsequent disassembly for maintenance allows for a more extensive examination.

 

This is not an official interpretation.  It could certainly be argued either for or against additional examinations.  Based on this an Intent Inquiry would be prudent.  However, I think the argument I outlined above would keep someone out of trouble with auditors and regulators until the interpretation is addressed by the ASME Committees.

 

Scott Kulat:  My view of the Code philosophy is once an item is disassembled and accessible; the component must be examined (once during the interval).  For general precedence, I would cite Examination Category B-L-2 and B-M-2, Footnote (2).  I realize that these are different components (i.e., pumps and valves vs. flange threading), but it conveys the message that when something is made accessible, it should be examined.

 

Dan Lamond:  For this one, I think Note 4 clarifies it some for heat exchangers, pumps, and valves in that you don't even do bolting inspections unless the connection is disassembled.  Note 2 says bushings may be inspected in place so that should be done with the bolting in this case.  As for threads, the only specific requirement is for the RPV flange threads and that is for a volumetric once per ten years.  (Some of these notes have been cleared up in the later Code editions).

 

Gary Park:  I found 3 interpretations that may help. I remember that we just passed this a couple of meetings ago.

 

Code Interpretations
Interpretation: XI-1-04-18
Subject: Table IWB-2500-1, Examination Category B-G-1, Item No. B6.50
Date Issued: March 8, 2005
File: IN04-009

Question: Is it the intent of Examination Category B-G-1, Item No. B6.50 that reactor vessel bushings be examined when the head-to-flange connection is disassembled, and the studs remain in place?

 

Reply: No.

 

Code Interpretations
Interpretation: XI-1-04-14
Subject: Table IWB-2500-1, Examination Category B-G-1, Pressure Retaining Bolting Greater Than 2 in. Diameter (1989 Edition Through the 2003 Addenda)
Date Issued: October 15, 2004
File: IN04-013

Question: Is it a requirement of Examination Category B-G-1, Item No. B6.40, and Footnote 2, that reactor vessel flange threads be examined when the head to flange connection is disassembled, and the studs remain in place?

Reply: Yes.

 

Code Interpretations
Interpretation: XI-1-98-75
Subject: Table IWB-2500-1, Examination Category B-G-1, Item Number B6.30 (1989 Edition Through 1998 Edition With 1999 Addenda)
Date Issued: March 27, 2000
File: IN00-003

Question (1): Are the RPV closure studs required to be removed sometime during the inspection interval to perform the examinations of Category B-G-, Item Number B6.30?

Reply (1): No.

 

Question (2): Does Examination Category B-G-1, Item Number B6.30 require that a volumetric and surface examination be performed on each RPV closure stud once per inspection interval?

 

Reply (2): No. The examinations of Item Number B6.30 are required only when the RPV closure stud is removed and then only once per inspection interval.

 

Doug Ramey:  That is how we interpret and have implemented it.

 

Charles Ross:  At Sizewell under Examination Category B-G-1 we would require that the threads in the base material be inspected (although not ASME requirement) when the connection is disassembled irrespective of any other previous examinations.

 

Your question raises an interesting and currently topical point.  On the steam generator hand holes we have the requirement to examine the base flange and studs which again is not an ASME requirement.  It is our policy to inspect the threads in a connection when it is disassembled, irrespective of any previous examinations.

 

Rick Swayne:  Section XI has generally been interpreted to require additional examinations when further disassembly makes the item available for examination.  Note (1) allows the bolting to be examined in any of three different conditions, but this does not apply to the bushings.  The bushings are required to be examined only when the bolting is removed.  This examination is independent of any prior examination of the bolting.  I don't think that you can assume that you are examining the bushings when you examine the bolting in place, or when you examine the threads in the flange.

 

XI-1-A05 (BC04-1733) Table IWB-2500-1, Examination Category B-G-1, Note 2 Bushing Examination Requirements

 

This revision clarifies that examination of bushings is required only when the associated bolting is removed.  The revision removes the reference to threads in base material of flanges from Footnote 2, because the note is applicable only to threads in the reactor vessel closure flange, which are disassembled at every refueling outage.  This revision incorporates Intent Interpretation IN04-009.

 

Interpretation: XI-1-04-18
Subject: Table IWB-2500-1, Examination Category B-G-1, Item No. B6.50
Date Issued: March 8, 2005
File: IN04-009

Question: Is it the intent of Examination Category B-G-1, Item No. B6.50 that reactor vessel bushings be examined when the head-to-flange connection is disassembled, and the studs remain in place?

 

Reply: No.

 

Ken Thomas:  No.  We only do the examination once per interval.

 

Russell Turner:  The bushings would have to be examined when the connection is disassembled even if the bolting was examined in place under tension.  Footnote 2 is separate from footnote 1, and the meaning is pretty clear to examine the bushing and/or threads when the opportunity arises, but only once per interval.  Same thought process as internal exams of pumps and valves.

 

Rick Wehry:  At Susquehanna, the only Item of Category B-G-1 that applies to your question is B6.40 for the threads in the flange of the RPV.  We typically remove 4 studs each outage in the cattle chute area, so we do examine (UT) the threads in the flange material for those four stud areas (but only once per Interval).  We've consistently examined those threads in the flange base material on Unit 1 and Unit 2 for each of the 3 inspection Intervals for SSES.

 

Ray West:  Do most licensees interpret Table IWB-2500-1, Examination Category B-G-1, footnote (2) [1989 Edition through the 2004 Edition] to require that bushings and threads in base material of flanges be examined when the connection is disassembled, even if the bolting has already been examined during the interval with the bolting in place under tension, as permitted by footnote (1)?

 

I think the answer is "yes" when you disassemble the bolting and make the bushings accessible then you are required to examine them.  I think the answer to the inquiry below reinforces my position here.  Examining the bushing on the flange surface with a VT-1 does not do much to identify the condition of the bushing while the bolting is in place.

 

Interpretation: XI-1-04-18

Subject: Table IWB-2500-1, Examination Category B-G-1, Item No. B6.50 (1989 Edition Through the 2001 Edition With the 2003 Addenda)

Date Issued: March 8, 2005

File: IN04-009

 

Question: Is it the intent of Examination Category B-G-1, Item No. B6.50 that reactor vessel bushings be examined when the head-to-flange connection is disassembled, and the studs remain in place?

 

Reply: No.

 

Kevin Whitney:  I do not have much experience with this.  Being a later vintage Section III plant, with the exception of the RPV and RCP studs , all other connections were designed to be less than 2".  We examine the flange threads on the RPV as they are routinely removed.  The code does not require pumps to be specifically disassembled for examination and we have not taken any of them apart this interval.

 

It is a good question.  In lieu of a code interpretation, I would probably be conservative and examine the flange threads/bushings if they were made available even though the bolting was examined under tension.

 

 

Date:  Monday, 17 September 2007

Subject:  ASME Section XI Class 2 and 3 Visual Acceptance Criteria

Dear Group:  The Section XI Class 2 and Class 3 visual examination acceptance criteria for Categories C-H (VT-2), D-A (VT-1), and D-B (VT-2) have been in the course of preparation for many years.  What acceptance criteria have licensees been using for these visual examinations?  Jim

 

 

Date:  Thursday, 27 September 2007

Subject:  ASME Section XI Class 2 and 3 Visual Acceptance Criteria

Dear Jim:  Please see the responses below.

 

Mike Blew:  We follow the direction of the Code for C-H, Acceptance Standard is IWC-3516, which of course is in course of preparation and redirects you to IWB-3522.  Similar situation with D-B, redirected to use IWB-3000.  Same with the VT-1 of integral attachments, redirected to use IWB-3000.

 

For VT-2, our in-house NDE procedure identifies "structural distress or leakage be evaluated by the group responsible to determine if corrective action is required" which we (ISI) would not accept any through wall leakage.  Leakage through bolted connections is identified and work requests are generated to correct the leak.  If bolting is affected, we have a process/relief request for addressing boron in contact with the bolting, VT-1 of the affected bolt, evaluation, etc.

 

The VT-1 NDE procedure identifies "Evaluation of identified relevant indications or flaws shall be performed by Engineering on a case by case basis" so essentially a VT-1 exam on an integral attachment, we (ISI) would not accept any linear indications and would require a weld repair.  This conclusion would be in conjunction with a civil engineering evaluation.

 

Jerry Crider:  We are currently using owner defined acceptance criteria.  I have included the section in our administrative procedure below.

 

For ISI Class 2 and 3 items, the acceptance standard of the ASME Section XI Code, IWC-3516 and Article IWD-3500 are in the course of preparation.  For this reason, the criteria listed below will be used for identifying relevant conditions as applicable.

1. Through-wall or through-weld leakage;

 

2. Leakage or flow test results from buried components in excess of established limits;

 

3. Material wastage resulting from leakage (including boric acid) that has reduced the component wall thickness;

 

4. Leakage or active boron residue that occurs at a pressure retaining bolted connection in a system borated for the purpose of controlling reactivity.

 

Ric Deopere:  MNGP uses the applicable acceptance requirements for VT-2 and VT-1 in IWB-3000.

 

George Fechter:  The acceptance criteria of IWB-3522 could be used.  I’ve never understood the division between Class 1, 2, and 3 leakage, other than Tech Spec issues/limits which Class 1 has versus the other classes.  Leakage thru wall, thru weld isn’t acceptable, leakage at a mechanical joint would be acceptable if component structural integrity isn’t impacted, and leakage at a mechanical joint is only required to be evaluated if the system is borated to control reactivity (thank goodness I’m at a BWR, makes things easier!), as well as the other VT-2 related requirements.

 

I’m only speaking above about the discovery of leakage versus issues which may be permitted via Code Case N-513, GL 90-05, and other applicable guidance.

 

Roy Hall:  Constellation Energy uses the acceptance criteria for similar Class 1 categories or components; unless we perform a specific analytical evaluation.

 

Scott Kulat:  My experience is that utilities like to keep their number of procedures to a minimum.  As such, they would have one procedure that addresses Code VT-2 examinations, which would be written to the IWB criteria.  The same holds true for procedures to examine attachment welds.

 

Dan Lamond:  the majority of what I have come across regarding Class 2 and 3 acceptance standards for the Categories in question simply utilize the Class 1 standards as referenced in IWC-3516 and IWD-3400.  I don't recall many specific procedures written by the owner using something different than the Class 1 standard.  I believe it is typically one program procedure which covers all three classes.  Of course the couple known exceptions commonly being used are Code Cases N-513-x, N-523-x, and N-566-x.

 

We do have an action at WGPT to assist WGISC and SGES draft these standards in the near future as part of our ongoing effort to revise IWA-5250 and IWx-3000 as it applies to pressure testing.

 

Alex McNeill:  Class 1 criteria that corresponds.

 

Ben Montgomery:  Callaway uses IWB acceptance criteria.

 

Gary Park:  We would have used the suggested acceptance standard in the code.  For example, under IWC-3000, it may have suggested using the IWB acceptance standards.  That is what we would have gone to.  We would not have made up our own.  I can remember long ago, once going to the material specification for acceptance of a component, but don't remember to many of the details.

 

Doug Ramey:  For VT-2 we use IWB-3522 and for VT-1 for attachment welds we use IWC-3120

 

Ken Thomas:

 

VT-1 Standard (Used for all classes):

 

The following relevant conditions are unacceptable for continued service (Reference IWB-3517.1 B-G-1 and B-G-2):

 

  • Crack-like flaws that exceed the allowable flaw standards of IWB-3515.
  • More than one deformed or sheared thread in the zone of thread engagement of bolts, studs, or nuts.
  • Localized general corrosion that reduces the bolt or stud cross-sectional area by more than 5%.
  • Bending, twisting, or deformation of bolts or studs to the extent that assembly or disassembly is impaired.
  • Missing or loose bolts, studs, nuts, or washers.
  • Fractured bolts, studs, or nuts.
  • Degradation of protective coatings on bolting surfaces.
  • Evidence of coolant leakage near bolting.

 

Relevant conditions for Class 3 Category D-A components shall be evaluated against the acceptance standards of IWC-3512.1.

 

Structural degradation of attachment welds such that the original cross-section area is reduced by more than 10%.

 

Visual examinations that detect surface flaws may be supplemented by either surface or volumetric examinations, as necessary, to characterize the flaw, at the discretion of the ISI Engineer.

 

Non-relevant conditions include fabrication marks, scratches, surface abrasion, material roughness, casting irregularities, and any other conditions acceptable by the material, design, or manufacturing specifications for the component.

 

VT-2 Standard (Used for all systems):

 

No leakage categorized as "Code Leakage" on Attachment 1 within the Core Spray Loop A Pump A and discharge piping boundaries and any non-code leakage has been dispositioned as acceptable.

 

"Code Leakage" is through wall leakage.  Non-code leakage is leakage through a mechanical joint.

 

Russell Turner:  No through wall leakage.  Leakage at mechanical connections is noted, WO's written, and boric acid issues resolved.

 

Rick Wehry:  At Susquehanna, our VT-1 Acceptance Criteria for Category D-A is IWD-3000, which in the 1998 Edition and 2000 Addenda defaults to IWB-3000, so we use the criteria of IWB-3000.  For Categories C-H and D-B, our Station Pressure Test Program Station Engineering procedure states: "During performance of system pressure testing, the acceptance criteria is, "no pressure boundary leakage from component body, pipe wall, or vessel wall."

 

Kevin Whitney:  We apply Class 1 IWB-3000 visual acceptance criteria across the board.

 

 

Date:  Monday, 9 July 2007

Subject:  When do Most Licensees Submit Relief Requests to the NRC?

Dear Group:  When submitting Relief Requests pursuant to 10 CFR 50.55a(g)(5)(iv), do most licensees submit these requests to the NRC at or near the end of each 120-month inspection interval, or at some other frequency (e.g., after each refueling outage, at the end of an inspection period, or at some other frequency)?  Mark

 

 

Date:  Thursday, 12 July 2007

Subject:  When do Most Licensees Submit Relief Requests to the NRC?

Dear Mark:  Please see the responses below.

 

James Agold:  Southern Nuclear hasn't been consistent about submittal of limitations to the NRC in the past.  We have recently instituted a procedural requirement that limitations should be submitted to the NRC at the conclusion of each ISI period.  Our thoughts were that this would keep us up-to-date on this issue.

 

Mike Blew:  We at RNP formulate the applicable Relief Requests when we develop the 10 Year Program.  If there is a need to submit during the interval, we submit them.  The only one that we submit at the end is the limited exam Relief Request.  There have been issues with the NRC in submitting limited exams early (prior to the end of interval), therefore we wait and roll it up at the end of the interval.

 

Jerry Crider:  For normal coverage issues (exams completed with less than 90%), we plan to hold and submit the requests for relief in one package near the end of the interval.

 

If something (e.g., hardship or impractical) should come up during the interval, we would submit the request for relief at that time.

 

Russ Day:  I have two answers for you....we submit at both times.  For relief requests related to coverage or percentages, they will MOST likely be submitted at the end of the interval as part of the interval closeout.  If something should come up during the interval, we will most likely submit the request at that time!  We do not have a set frequency for submitting relief requests to the NRC.

 

Ric Deopere:  It depends on the situation.

 

If an exam is performed with the currently approved methodology and is limited, where essentially 100% code coverage cannot be achieved, the request is typically submitted at some period of time following a refueling outage, e.g. 90 – 180 days; it varies.  A licensee actually has 12 months following completion of an interval to submit these per 10CFR50.55a, however not too many sites are exercising that option anymore – more often than not, they want to know if their relief is approved before it’s too late to recover if their request happens to be denied.  With the ‘encouragement’ of a Region III NRC Inspector, Monticello and Prairie Island committed to submit our limited exam relief requests following each refueling outage.

 

If it is known ahead of time that a required exam cannot be performed at all, i.e. inaccessible, extreme radiation exposure, etc., Relief should be proposed ahead of time, however once again, it is not required for up to 12 months from the end of the interval.

 

George Fechter:  Plant Hatch submitted end of the interval relief requests for the 3rd ISI Interval following the final outage for each unit during the interval.  While the ISI Interval effectively ended on 12/31/05 for each unit, the interval was extended until 3/27/06 (approximately) for Unit 1 per the permissive within Section XI to do so in order to coincide with a refueling outage to allow completion of ISI required examinations.  For Unit 2, the end of the interval relief requests were submitted prior to the end of 2005, and for Unit 1, the end of the interval relief requests were submitted shortly after the end of the interval extension.

 

Richard Gimple:  The way I read and interpret 50.55a(g)(5)(iv), it is saying that if your new ISI program update is not going to include, or did not include (if already issued), a Code requirement that is impractical as permitted per (g)(4), the basis for the impracticality must be demonstrated to the satisfaction of the NRC within 12 months of the end of the interval in which the impracticality was found.  I don't know how other plants handle impractical exams, but if it is a Code requirement, we would identify the requirement in the new ISI program plan and put in a relief request with the submittal of the new ISI program update if we were sure we couldn't meet the requirement, or we would include the requirement in the new ISI program update and perform the requirement and determine the extent of impracticality and then submit the relief request.  We don't just not include something in the program plan.  So in my opinion, (g)(5)(iv) doesn't apply to your particular question of when do we submit relief requests.

 

However, I will tell you that we got criticized by the NRC a number of years ago for submitting some relief requests on the RPV end of interval exams later than 12 months after the end of the interval in which we identified the impracticality and the NRC's basis for the criticism was (g)(5)(iv).  I wasn't aware of that criticism until later or I would have pursued discussion on the subject since it isn't the way I read (g)(5)(iv).

 

I think the proper paragraph is (g)(5)(iii) for impracticality relief requests, which doesn't have any time period identified.

 

With the above in mind, we judge the timing of a relief request submittal according to need for when we need to credit the exam and try to submit the relief before the end of the period or interval in which we need to credit the exam.  We also don't like to wait and submit a bunch of relief requests at the end of the interval, particularly if we have known about the need for quite awhile.  We also evaluate the potential for the NRC to impose additional requirements as part of the approval, and if we think that is possible, we will try to submit the relief request in time to allow performance of additional requirements before the end of the current interval.  In general, we probably group and submit relief requests 3 or 4 times an interval (with submittal of the ISI program and after each period, if important to crediting the exam for the period).  Due to work overload, we have submitted several relief requests at the end of the interval just because we hadn't got them submitted earlier, but that isn't the desired approach.

 

I am sure you are quite aware of the NRC's LIC-2 Rev. 1 and NEI's white paper on Standard Format for Requests from Commercial Reactor Licensees Pursuant to 10 CFR 50.55a, Rev. 1.  These don't provide much info but LIC-2 section 4.2 C and the NEI document sections 2.8 and 3.0 do touch briefly on this subject.

 

Robin Graybeal:  My opinion would be that if you are requesting relief from a particular requirement, you should have that relief prior to when the requirement must be satisfied.  As such, I guess my answer is "It depends on the request".

 

Scott Kulat:  I've seen quite a number of ways that plants have submitted their Relief Requests.  Most are either in conjunction with outages and the corresponding 90 Day Summery Reports, or at the end of their interval.  However, some submit at the end of each period, and a few even require submittal prior to the end of the outage that identifies the coverage issue.  I don't really monitor this type of thing so I can't really identify a trend, but then again there may not be a trend.

 

Dan Lamond:  For normal coverage issues (exams completed with less than 90%), most plants hold and submit these in one package near the end of the interval, some time after the last outage.  If the last outage falls right at the end of the interval, they may use the 10CFR paragraph and submit up to 12 months into the next interval or submit what they have from prior outages first and then address any issue from the last outage in that extension time frame.

 

A couple exceptions I have seen include the vessel welds where many plants have received permanent relief request approval, and another example might be complete physical obstructions (like pump casing welds which are within a concrete pedestal) where the obstruction is known and relief is then typically submitted up front with the initial program.

 

Ron Lippy:  I would like to clarify my "position" regarding relief requests, and the "requirement" (in my opinion) of when you need to submit them.  I guess that I was thinking more from an aspect of interval updates but now that I have read some of the responses, I believe that I have an opinion (if you can believe that).  Anyway, in my opinion ALL relief requests submitted to the NRC under "alternative" and "hardship" conditions must be approved by the NRC (again in my opinion) PRIOR to the implementation of the "alternative".  IN other words an SER accepting the request for relief MUST be received (this could be a verbal or written) before implementation of the "alternative" can be performed.  The ONLY exception to this (again in my opinion) is if the requirement is CLEARLY IMPRACTICAL.  This is discussed in fairly significant detail in NUREG 1482 Rev 0 and Rev 1 for IST but, is equally applicable to ISI.

 

I believe that the 10 CFR 50.55a permits you to "wait" for up to 12 months AFTER the start of the successive 10 year interval for requesting and receiving approval for a relief PROVIDED that a NEW requirement for an exam or a test is endorsed (by the later edition of the Code) which may NOT be able to be tested/examined prior to the start of the interval and upon “implementation” of this NEW test or exam requirement, it is determined that the facility is UNABLE to meet the NEW requirement.

 

This actually happened to me a few years back during an NRC Inspection and the logic as I have described above was used and APPROVED by the NRC.  Granted this was in the IST arena but, I believe that it would be equally applicable and acceptable in the ISI arena as well.

 

In my opinion, UNLESS the test or exam being incorporated is NEW or is Clearly Impractical, I believe that approval of the relief request (i.e. SER) would be required PRIOR to implementation of the "alternative".

 

Of course there is always "exigent relief" but, that is another story.

 

Gary Park:  I do have some input.  With coming back to the DAEC, I discovered that we had not submitted some relief request on items that were impractical during our 3rd 10 Year Interval (ended on 11/01/06) and we submitted those a few months ago.  My goal is to submit those after each outage in the future (based on discovery) rather than try to keep track of them for some future submittal.

 

Glenn Perkins:  Usually at the end of the interval when all exams have been completed.

 

Doug Ramey:  We have been submitting them at the end of the 120 month period.  I am reconsidering this for our current interval and submit them at the end of every outage.

 

Dajun Song:  We just completed our 2nd Interval, and for this particular interval we will be submitting at the end of the interval.  However, going forward, I believe we are going to submit once per period.

 

Rick Swayne:  I don't think that anyone waits until the end of the interval on purpose.  I think the NRC allows that delay, just in case someone gets to the end of the interval and discovers that they missed an exam.  I think most owners make these filings before the interval, whenever possible, or before they intend to deviate from the Code requirements.  No one wants to deviate from the Code requirements at the risk of not having their deviation accepted by the NRC.

 

Ken Thomas:  We submit them when we identify the need for them.  That may be at the start of the interval or after an outage.  We do not wait until the end of the interval.  I think that is consistent with the NRC's expectation.

 

Ernie Throckmorton:  It was my experience that 1) all relief requests that were known were submitted at the time of the program submittal prior to the beginning of the interval; 2) relief requests that were identified as part of an examination, such as coverage or access, were submitted at the end of the outage, usually within 90-days; and 3) relief requests dealing with programmatic issues identified during the interval were submitted as they arose.  The objective was to have no programmatic issues open at the end of each period.

 

Russell Turner:  I have seen it both ways.  My preference is to do it at least once every period because memories fade and personnel change.  But what has generally happened is most places I have been keep them until the end of the interval.  Harris plant elected to do it at the end of the interval.

 

Kevin Whitney:  My end of interval submittals are typically related to generic limitations such as single sided stainless exams or reactor vessel weld coverage because 10CFR removed previously approved relief requests, etc.

 

If I want a relief request to use a more recent edition of the Code for a particular Item No., I will submit a relief request about a year prior to its use.  I try not to "cherry pick" newer editions of the Code too often because I know the NRC is not real keen on this practice.  I will also submit these to paragraph 55a(a)(3)(i) or (ii).

 

 

Date:  Tuesday, 6 March 2007

Subject:  NRC Enforcement Positions for ASME Codes

Dear Group:  I understand that the ASME has been working with the NRC to help clarify the NRC’s endorsement positions for Nonmandatory Appendices, references in Codes to other Codes, certain Subsections in Section III and Code Cases related to certain Codes.  Can you tell me what the status is?  Thanks, George

 

 

Date:  Sunday, 11 March 2007

Subject:  NRC Enforcement Positions for ASME Codes

Dear George:  On January 11.2007, the NRC presented their draft positions as follows:

 

1.  All Nonmandatory Appendices are considered approved for use for the currently endorsed ASME Code Editions and Addenda of Section III (Division I), Section XI (Division I) and the OM Code as listed in 10 CFR 55a.

 

2.  All references in these Codes to supporting Codes such as Section II, Section V and Section IX are implicitly approved for use, up to the latest published versions available.

 

3.  The current endorsement of ASME Section III (Division I) Subsections NE for containments, NF for supports and NG for core support structures are implicitly approved for use, but are not mandatory.

 

4.  Code Cases published for Sections II, V and IX are also implicitly approved.

 

The NRC is expected to publish their final positions soon, but the publication media is unknown at this time.

 

 

Date: Tue, 11 July 2006

Subject:  Authorized Nuclear Inspectors, Forms, etc.

Dear Group:  I’m looking for information regarding Authorized Nuclear Inspectors, forms, etc., can you help?  Don

 

 

Date: Sun, 30 July 2006

Subject:  Authorized Nuclear Inspectors, Forms, etc.

Dear Don:  Take a look at http://www.authorizedinspector.com.

 

 

Date: Tue, 3 January 2006

Subject:  Summary of ASME Code Changes

Dear Group:  Does anyone provide a summary of ASME Code changes?  Thanks, Pete

 

 

Date:  Sun, 8 January 2006

Subject:  Summary of ASME Code Changes

Dear Pete:  Take a look at: http://cstools.asme.org/csconnect/public/index.cfm?SummaryOfChanges=yes for the Boiler and Pressure Vessel Code 2005 Addenda.  This is the beginning of a new service by ASME.

 

 

Date: Thur, 20 October 2005

Subject: IWA-4221(c)

Dear Group: IWA-4221(c) states that the item may meet all or portions of the requirements of Section III when the Construction Code was not Section III.  The Construction Code of (our) original item was RCC of France.  Can I use Section III as an alternative?  Thanks, Song

 

 

Date: Mon, 21 November 2005

Subject: IWA-4221(c)

Dear Song: IWA-4221(c) states that an item may meet all or portions of later requirements of different editions and addenda of the Construction Code if the item is reconciled as stated in IWA-4221(c).  This means that an item such as piping that was constructed to an older United States standard, e.g. B31.1, may be repaired or replaced by piping constructed to a later United States standard such as B31.7 or Section III.

 

IWA-4221(c) does not address the use of Section III as an alternative for Construction Codes from other countries.

 

Contrary Opinion (Fri, 2 June 2006)

 

I would like to offer a contrary opinion.  Section XI was originally intended only for Section III plants.  It was backfitted onto ASME B31.1, B31.7, Section VIII, etc.  There is nothing in Section XI that prevents use of Section III as an alternative for Construction Codes from other countries.  In fact, the RCCM Code was adapted from Section III.  Section III makes a completely suitable alternative to the RCCM Code, as well as to many other Construction Codes of other countries.

 

Rick Swayne

 

 

Date: Mon, 11 April 2005

Subject: ASME Code Case N-532-1

Dear Group: Is anyone currently implementing Code Case N-532-1, and if so, what have been the positive and negative attributes versus the requirements of IWA-4000 and IWA-6000?  Bill

 

 

Date: Tue, 19 April 2005

Subject: ASME Code Case N-532-1

Dear Bill: The following is the best we have received.

 

We have not implemented this Case. With the additional restriction imposed by the NRC in the Reg. Guide 1.147, we do not see any real advantage.

 

Ken

 

We see no distinct advantage to utilizing the Code Case since the approval in Reg Guide 1.147 requires completion each refueling outage. We still have to complete the NIS-2 for each R/R and have the form available so it isn't any trouble to submit them as an attachment to the NIS-1. We are also utilizing IDDEAL Software Suite and we carry our NIS-1 from the previous outage, modify it for the current outage and paste the ISI scope from IDDEAL. I usually have the NIS form done within 2 days of the completion of the last exam performed and wait for the last NIS-2 to be signed. Some of our sister plants use the CC but we don't and do not have any plans to utilize it.

 

Michael

 

 

Date: Tue, 9 November 2004

Subject: Helicoil Inserts/IWA-4451.1(b)

Dear Group: Is anyone aware of a supplier of helicoil inserts that has been evaluated for compliance with NCA-3800 or 10CFR50, Appendix B?

Thanks,

Bill

 

 

Date: Sun, 14 November 2004

Subject: Helicoil Inserts/IWA-4451.1(b)

Dear Bill: I don’t have any specific names. Because of this issue, we added IWA-4451.1 in the 1999 Addenda to eliminate the requirement for qualifying them to NCA-3800. This provision was also in Code Case N-496.

Rick

 

 

Date: Fri, 5 November 2004

Subject: ASME Code Requirements for Snubber Examinations

Dear Group: I understand that there are Code requirements for snubber examinations in Section XI (2003 Addenda) that are not in the OM Code. Can you describe what the requirements are and where they can be found? Thank you, Bill

 

 

Date: Fri, 5 November 2004

Subject: ASME Code Requirements for Snubber Examinations

Dear Bill: The requirements for snubber examinations in Section XI (2003 Addenda) that are not in the OM Code are as follows:

1. IWA-2110(a)(3), (e), (g), and (i) for ANII Inspection and Verification

2. IWA-2210 (b), (e), (f), and Table IWA-2210-1 for Lighting, Distance, Character Resolution with Section V, Article 9

3. IWA-2213 for VT-3 Examination Requirements

4. IWA-2310 and IWA-2312(d) for Examination Personnel Qualifications per ANSI/ASNT CP-189

5. IWA-2314 for Examination Personnel Certification and 5 Year Recertificaton per ANSI/ASNT CP-189

6. IWA-2321 for Annual Personnel Vision Tests

7. IWA-6210(c) for Class 1 and 2 Owners Summary Report

8. IWA-6210(d) for Class 1 and 2 Owners Report Form NIS-1

9. IWF-5200(a) for VT-3 Preservice Examinations

10. IWF-5300(a) for VT-3 Inservice Examinations

 

 

Date: Tue, 25 May 2004

Subject: NRC Approval of Latest ASME Section III, Section XI, and OM Code

Dear Group: What are the latest versions of the ASME Boiler and Pressure Vessel Codes to be approved by the NRC for Sections III, XI, and OM, and when will they be indicated as approved in 10 CFR 50.55a? Thank you, Alice

 

 

Date: Thur, 27 May 2004

Subject: NRC Approval of Latest ASME Section III, Section XI, and OM Code

Dear Alice: The latest versions of the ASME Boiler and Pressure Vessel Codes to be approved by the NRC for Sections III, XI, and OM will be the 2001 Edition through the 2003 Addenda, and per the May 2004 NRC Section XI Report, http://www.sectionxi.com/Meeting-Notes-and-Reports/NRC-Section-XI-Report(May-2004)W-Norris.html on the Meeting Notes and Reports Page http://www.sectionxi.com/Meeting-Notes-and-Reports/Meeting-Notes-and-Reports.html, they are to be indicated as approved in 10 CFR 50.55a in September 2004.

 

 

Date: Mon, 2 February 2004

Subject: Documentation For Repair/Replacements

Dear Group: Sizewell B is performing a Class 2 repair/replacement on the Reactor Building Spray System piping and supports. The original construction code is the 1983 Edition with the Winter 1985 Addenda of Section III and the current Section XI Code is the 1989 Edition with the Winter 1990 Addenda.

What are the requirements regarding the Section III A-Forms, N-Forms, design specification, revision of original forms, Section XI NIS-2 Form, etc.? Ron

 

 

Date: Thur, 5 February 2004

Subject: Documentation For Repair/Replacements

Dear Ron: The short answer is that any components, parts, or appurtenances to be N or NPT stamped must be furnished in accordance with a Certified Design Specification and supplied with the applicable Section III Code Data Reports.  N-stamped components must be furnished with a Certified Design Report, when that is required by Section III.  The A-Forms are nonmandatory sample statements.  The N-Forms are mandatory.  Revision of original Forms is not required.  See IWA-4300 in the 2003 Addenda for requirements for updating design documentation.  An NIS-2 must be completed for all Repair/Replacement Activities.

Rick Swayne

 

 

Date: Wed, 7 January 2004

Subject: Pressure Testing Open Ended Tanks

Dear Group: When using the 1998 Edition of Section XI, is it a requirement to perform a pressure test and VT-2 examination on Class 2 and Class 3 tanks that are vented open to the atmosphere?

Jim Boughman

 

 

Date: Fri, 9 January 2004

Subject: Pressure Testing Open Ended Tanks

Dear Jim: Unfortunately, this is a thorny subject due to the inadequacy of the Code. However, consider this:

In the 1998 Edition of Section XI for Class 2 and 3 Components, the titles of both Examination Categories C-H and D-B are "All Pressure Retraining Components". It can be argued that tanks vented open to the atmosphere are not pressure retaining.

That being said, IWC-5230(c) and (d) for Class 2 and IWD-5222(c) and (d) for Class 3 do impose hydrostatic test requirements for storage tanks. However, no such requirements exist for the system leakage test.

Therefore, if a plant was invoking only the system leakage test for Class 2 and 3 to satisfy the system pressure test each period and the end of interval test for Class 3 using Code Case N-498-1, it would appear that there are no pressure test requirements for tanks.

Note: This discussion does not address the system pressure test requirements following a repair/replacement activity.

 

 

Date: Wed, 5 November 2003

Subject: Class MC Component Supports

Dear Group: Is it your interpretation that 10 CFR 50.55a mandates the use of Section XI, Subsection IWF, for Class MC Component Supports? Thanks for your help. Dustin

 

 

Date: Sun, 9 November 2003

Subject: Class MC Component Supports

Dear Dustin: Yes, it is our understanding that 10 CFR 50.55a mandates the use of Section XI, Subsection IWF, for Class MC Component Supports. Although 10 CFR 50.55a is not as clear as it should be, there are several observations that support this position.

1. Class MC supports are clearly within the scope of IWF and no exceptions have been taken in 10 CFR 50 regarding the IWF requirements for Class MC supports.

2. 10 CFR 50.55a(f) states in part "Requirements for inservice inspection of ... Class MC ... supports ... are located in §50.55a(g)". However, requirements for Class MC supports are not specifically addressed in 10 CFR 50.55a(g), which we think was an editorial oversight.

3. NEI's April 11, 1997 Question No. 15 asked, "Is it the intent that all Class MC supports be examined by the end of the utility's current interval? The NRC responded to the question on May 30, 1997 and stated in part " ... support welds are to be examined in accordance with the requirements of the rule." and further stated in part " ... examine the rest of the supports ... utilizing the applicable provisions of Subsection IWF."

4. It seems that the structural monitoring of Class MC supports should be of equal or greater significance than for Class 2 or Class 3 supports.

5. We have reviewed the Federal Registers during this time frame and have found nothing to indicate that the NRC has taken an exception to the IWF requirements for Class MC supports.

6. If it was known that the NRC took an exception to the IWF requirements for Class MC supports, We think there would be an action at Section XI to resolve it. But, there is no such action that we are aware of.

7. Upon reviewing the NRC Generic Aging Lessons Learned (GALL) Report, it is very clear that Class MC Component Supports are within the scope for license renewal.

 

 

Date: Tue, 5 August 2003

Subject: IWA-2216

Dear Group: IWA-2216 states " ... the remote visual examination system shall have the capability of distinguishing and differentiating between the colors applicable to the requirements of VT-1 and VT-3 for the component examination being conducted."

Question: If the remote visual examination system consists of the camera and recorder, would it be a color system?

Song

 

 

Date: Fri, 8 August 2003

Subject: IWA-2216

Dear Song: The key here is the phrase "applicable to the examination." The need for color should be evaluated. It is not generally needed for RPV internal exams, where we are primarily concerned with cracking and mechanical damage. Were corrosion is the primary concern and characterizing the corrosion product is important, then color would be useful. The need for color can also be determined after the initial examination, where, if unexpected areas of corrosion are detected, it is determined that characterization of the corrosion products is necessary (i.e., it then becomes "applicable to the examination"). Doug Henry

 

 

Date: Tue, 20 May 2003

Subject: IWB-3131(c) - 1995 Edition with 1996 Addenda

Dear Group:

IWB-3131(c): states "Volumetric and surface examination results shall be compared with recorded results of the preservice examination and prior inservice examinations. Acceptance of the components for continued service shall be in accordance with IWB-3132, IWB-3133, and IWB-3134."

(1) Is it the intent of this paragraph to provide previous examinations (preservice and/or inservice) for comparison with current examination results, regardless whether there were indications recorded on the previous examinations.

(2) If a previous examination (surface) had linear indications (regardless whether they exceed Code acceptance criteria), and the indications were removed and the results satisfactory, would the comparison be required?

(3) If the current examination is satisfactory, and the previous examinations were satisfactory, would the comparison be required?

Mike

 

 

Date: Fri, 23 May 2003

Subject: IWB-3131(c) - 1995 Edition with 1996 Addenda

Dear Mike: As an unofficial response, we offer the following:

(1) Some way or another the current Class 1 volumetric and surface examinations need to be compared with the previous examinations to ensure that previous indications (if any) are not growing in size, and new indications have not appeared that maybe should be monitored over a period of time.

(2) The Code does not seem to allow for an exception here. So, we guess it would be required. It's possible under the right circumstances that removed indications could reappear as new indications in the same area.

(3) We don't think it's a matter of an examination being satisfactory, we think it is a matter of trying to identify indications that may be growing in size over time, and trying to identify new indications.

Hope this helps.

 

 

Date: Sat, 1 March 2003

Subject: ISI Interval Synchronization

Dear Group: Do you know whether any licensee has petitioned the NRC to allow adjustment of their plant's ISI Interval dates so that a common ISI Interval could be used for multiple units and/or multiple plants? Mark

 

 

Date: Thur, 6 March 2003

Subject: ISI Interval Synchronization

Dear Mark: Apparently, several licensees have petitioned the NRC to allow adjustment of their plant's ISI Interval dates so that a common ISI Interval could be used for multiple units and/or multiple plants. A few of the plants include North Anna, Calvert Cliffs, San Onofre, Palo Verde, Point Beach, and Prairie Island.

This response represents the collective input received from Ernie Throckmorton, Dajun Song, Bill Lazear, Bob Browning, Gary Park, and Russell Turner.

 

 

Date: Wed, 2 October 2002

Subject: ASME Code Case Applicability

Dear Group: I have copies of many ASME Code Cases but it is not clear how you determine which code editions and addenda they are applicable to. Are code cases applicable to all editions and addenda of the code? Kurt

 

 

Date: Sat, 5 October 2002

Subject: ASME Code Case Applicability

Dear Kurt: No, code cases are only applicable to those editions and addenda of the code as either indicated in the code case or as indicated in the "Applicability Index" located in the front of the official volume of ASME Code Cases.

 

 

Date: Wed, 7 August 2002

Subject: Size Exemptions

Dear Group: What is the ASME Code position when you have a Class 2 Residual Heat Removal (RHR) line that is in the Program (8" Sch 80), based on size and thickness, and it drops (via a reducer) in size to an exempt size (3" Sch 10), travels some distance and then enlarges to a larger size (via a expander) to (6" Sch 80) and then connects to a tank/vessel? Do ASME Code rules for surface/volumetric examination apply to the pipe once it expands to the 6" Sch 80 (from the 3" Sch 10 exempt) and the tank/vessel? Michael

 

 

Date: Sat, 10 August 2002

Subject: Size Exemptions

Dear Michael: Although this Bulletin Board cannot provide an "ASME Code position", apparently the ASME Code rules for surface/volumetric examination do apply to the pipe once it expands to the 6" Sch 80 (from the 3" Sch 10 exempt), and the rules may also apply to the vessel. Section XI does not address tanks.

Upon reviewing the Section XI Interpretation Index up through Volume 50, you will find XI-1-86-43R (File No. IN86-012*) in Volume No. 20 on Page 125. Question and Reply No. 2 indicates that if components are larger than the size exemption they are required to be examined, even if they are connected to piping that is exempt based on size.

 

 

Date: Sun, 16 June 2002

Subject: Incomplete or Partial Examination Coverage

Dear Group: If a plant is using ASME Code Case N-460 entitled "Alternative Examination Coverage for Class 1 and 2 Welds", where does it say the licensee must seek relief from the NRC if the examination coverage for any weld is 90% or less? Thank you, Barbara

 

 

Date: Wed, 19 June 2002

Subject: Incomplete or Partial Examination Coverage

Dear Barbara: When using ASME Code Case N-460, it is clearly stated in the NRC Information Notice 98-42 that "The NRC has adopted and further refined the definition of "essentially 100 percent" to mean "greater than 90 percent" ... for required examination coverage of reactor pressure vessel welds ... or other areas required by ASME Section XI." This Information Notice further states "When a licensee is unable to examine "essentially 100 percent" of each weld, it must seek relief from the NRC in accordance with 10 CFR 50.55a(g)(5)(iii)."

NRC Information Notice 98-42 entitled "Implementation of 10 CFR 50.55a(g) Inservice Inspection Requirements" is available from the Libraries and Reference Sources page under Reference Links via the "NRC Generic Communications" link.

 

 

Date: Tue, 23 April 2002

Subject: Form NIS-2 Required Information

Dear Group: Where is it clarified that the information to be included in the Form NIS-2 for a repair/replacement activity to the 1989 Edition of Section XI must include information for both the item being replaced and the item being installed? Mark

 

 

Date: Sat, 27 April 2002

Subject: Form NIS-2 Required Information

Dear Mark: It has been clarified in Section XI Interpretations Vol. 49, Interpretation XI-1-01-13, that the information to be included in the Form NIS-2 for a repair/replacement activity to the 1989 Edition of Section XI must include information for both the item being replaced and the item being installed.

 

 

Date: Wed, 6 March 2002

Subject: NRC Approval and Disapproval of ASME Section XI Code Cases

Dear Group: I understand the NRC has issued new draft regulatory guides proposing the approval and disapproval of ASME Section XI code cases. Can you please direct me to where I may find them? Thank you, Cindy

 

 

Date: Fri, 8 March 2002

Subject: NRC Approval and Disapproval of ASME Section XI Code Cases

Dear Cindy: The new NRC draft regulatory guides proposing the approval and disapproval of ASME Section XI code cases can be found as follows. Go to the Libraries and Reference Sources page and then scroll down under "Reference Links" and click on NRC Draft NUREGS and Draft Regulatory Guides. Click on "Rulemaking Text and Other Documents" and then scroll down to the bottom of the list to file 123-0144.pdf entitled "Draft Regulatory Guide DG-1091 - Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1". Also see file 123-0145.pdf entitled "Draft Regulatory Guide DG-1112 - ASME Code Cases Not Approved for Use".

 

 

Date: Wed, 16 January 2002

Subject: Plant License Renewal

Dear Group: Where can I find some current information on plant license renewal? Thanks, Charles

 

 

Date: Fri, 18 January 2002

Subject: Plant License Renewal

Dear Charles: You can find information on plant license renewal on the Nuclear Regulatory Commission (NRC) web site at http://www.nrc.gov/reactors/operating/licensing/renewal.html and on the Nuclear Energy Institute (NEI) web site at http://www.nei.org/doc.asp?catnum=3&catid=14.

 

 

Date: Sat, 1 December 2001

Subject: When a Refueling Outage Overlaps Two Inspection Periods

Dear Group: When a refueling outage overlaps two inspection periods, where can I find guidance for the 1989 Edition of Section XI on performing examinations and applying the proper credit to each inspection period? Thank you, Judy

 

 

Date: Sun, 2 December 2001

Subject: When a Refueling Outage Overlaps Two Inspection Periods

Dear Judy: The subject of performing examinations and applying proper credit for two inspection periods (Winter 1981 Addenda through 1989 Edition) is discussed by Interpretation XI-1-95-55 as published in ASME Section XI Interpretation Volume No. 41 on Page 346.

 

 

Date: Tue, 16 October 2001

Subject: ASME Section III and XI Inquiries

Dear Group: Where can I find guidance on the web for submitting inquiries to ASME Section III and Section XI? Thank you, Fred

 

 

Date: Sun, 21 October 2001

Subject: ASME Section III and XI Inquiries

Dear Fred: Take a look at the ASME Guide entitled "Guide to Submittal of Technical Inquiries to an ASME Committee" located at http://www.asme.org/cns/departments/PTCS/Public/InquirySubmittal.html.

 

 

Date: Wed, 10 October 2001

Subject: Inservice Inspection Program Records and Reports

Dear Group: I was recently told that certain Inservice Inspection Records and Reports are to be retained for the service lifetime of the component or system. Our plant is using the 1989 Edition of ASME Section XI. Can you please tell me where I can find this requirement? Thanks for your help, Tim

 

 

Date: Fri, 12 October 2001

Subject: Inservice Inspection Program Records and Reports

Dear Tim: The requirement to retain Inservice Inspection Program Records and Reports for the service lifetime of the component or system can be found in IWA-6310 of the 1989 Edition of ASME Section XI.

 

 

Date: Fri, 17 August 2001

Subject: Inservice Inspection Program Conflict With Technical Specification Requirements

Dear Group: What guidance can you offer if our newly revised Inservice Inspection Program now conflicts with an existing Technical Specification requirement? George

 

 

Date: Tue, 21 August 2001

Subject: Inservice Inspection Program Conflict With Technical Specification Requirements

Dear George: The Code of Federal Regulations in 10 CFR 50.55a Paragraph (g)(5)(i)(ii) states, "If a revised inservice inspection program for a facility conflicts with the technical specification for the facility, the licensee shall apply to the Commission for amendment of the technical specifications to conform the technical specification to the revised program. The licensee shall submit this application, as specified in §50.4, at least six months before the start of the period during which the provisions become applicable, as determined by paragraph (g)(4) of this section."

 

 

Date: Wed, 25 July 2001

Subject: Class 1 Integrally Welded Attachments

Dear Group: The 1989 Edition of ASME Section XI does not seem to require any examinations for Class 1 Integrally Welded Attachments for the 3rd and 4th interval in either Category B-H or B-K-1. Is that correct? Julie

 

 

Date: Sat, 28 July 2001

Subject: Class 1 Integrally Welded Attachments

Dear Julie: The omission of examinations for Class 1 Integrally Welded Attachments for the 3rd and 4th interval for both Categories B-H and B-K-1 was an oversight that was corrected in ASME Section XI in the 1995 Addenda.

 

 

Date: Tue, 12 June 2001

Subject: Examination Category Quantities Less Than Three

Dear Group: What guidance can you offer if a plant is using the 1989 Edition of ASME Section XI and has only one or two items in an Examination Category thereby prohibiting equal distribution of the examinations among the three examination periods? Thank you, William

 

 

Date: Fri, 15 June 2001

Subject: Examination Category Quantities Less Than Three

Dear William: Consideration could be given to adopting Paragraphs IWB-2412(a), IWC-2412(a), and IWD-2412(a) of the 1994 Addenda of ASME Section XI. If there are only two items (Class 1, 2, 3) or welds (Class 1, 2) to be examined in an examination category, these paragraphs permit the items or welds to be examined in any two periods, or in any one period if there is only one item or weld to be examined.

 

 

Date: Wed, 21 March 2001

Subject: Examination Requirements for Dynamic Restraints (Snubbers)

Dear Group: Do the examination requirements of the 1989 Edition of ASME Section XI, Article IWF-2000, apply to snubbers? Jim

 

 

Date: Sun, 25 March 2001

Subject: Examination Requirements for Dynamic Restraints (Snubbers)

Dear Jim: No, per IWF-1220, entitled "Snubber Inspection Requirements", snubbers are to be examined and tested in accordance with the requirements of Article IWF-5000.

 

 

Date: Thur, 14 December 2000

Subject: NRC Regulatory Guide 1.35 vs. ASME Section XI IWL-3000

Dear Group: Regulatory Guide 1.35 revision 3 "Inservice Inspection of Ungrouted Tendons in Prestressed Concrete Containments" uses the term "prescribed lower limit" when referring to the acceptance criteria for a tendon. The prescribed lower limit is the predicted lower limit of the calculated tolerance band.

IWL-3000 uses the term predicted force. Is IWL referring to the predicted force as the predicted lower limit in the tolerance bands as referenced in Regulatory Guide 1.35.1 "Determining Prestressing Forces for Inspection of Prestressed Concrete Containments" or are they referring to the predicted force without the tolerance bands? Mike

 

 

Date: Mon, 18 December 2000

Subject: NRC Regulatory Guide 1.35 vs. ASME Section XI IWL-3000

Dear Mike: The Regulatory Guide does something that is not really good practice. It applies an uncertainty factor to the computed (predicted) tendon force and then applies a second factor to the acceptance criterion. The two factors should be replaced by one and this is done in IWL. However, one could argue that IWL's predicted force is the Reg. Guide's predicted lower limit. The bottom line is that there is no clear answer to the question you posed. Still, good engineering practice dictates that the predicted force be a specific value and not a range if the tolerance is applied to the acceptance criterion, as it is in IWL. Hope the above is of some use. The question has surfaced before and the answer, then as now, is a bit nebulous. Howard Hill

 

 

Date: Fri, 3 November 2000

Subject: Inservice Inspection (ISI) Software

Dear Group: What type of software do you use to track and analyze ISI Inspections? Russ

 

 

Date: Thur, 16 November 2000

Subject: Inservice Inspection (ISI) Software

Dear Russ: The responses indicate that the software currently being used in the industry to track and analyze ISI inspections includes Microsoft Access, WinISI, DataCheck, Paradox/PAL, IDDEAL, and Raytheon. Dennis

 

 

Date: Fri, 8 September 2000

Subject: High Pressure Safety Injection System Piping

Dear Group: Somebody recently said that the NRC does not require examination of High Pressure Safety Injection System Piping less that NPS 4 for circumferential and branch piping welds. Can you tell me where that is stated? Thank you very much for your help. Ronald

 

 

Date: Tue, 12 September 2000

Subject: High Pressure Safety Injection System Piping

Dear Ronald: You will find that discussed in the Federal Register dated 9-22-99 on Page 51400 and in 10 CFR 50.55a(g)(4)(iii).

 

 

Date: Thur, 22 June 2000

Subject: Availability of NRC Regulatory Guides

Dear Group: Are NRC Regulatory Guides available to the public for free or are they only available through a paid subscription service? Heather

 

 

Date: Wed, 28 June 2000

Subject: Availability of NRC Regulatory Guides

Dear Heather: With the exception of NRC Draft Regulatory Guides, published Regulatory Guides are generally only available through a paid subscription service. However, the NRC does provide a few of the Regulatory Guides free, including Regulatory Guide 1.147, and they are available from the "NRC Regulatory Guides" link provided at this site on the Libraries and Reference Sources page under "References Links".

 

 

Date: Wed, 10 May 2000

Subject: Proposed Elimination of the Mandatory ISI and IST Program Updates

Dear Group: It is my understanding that the NRC has now decided to maintain the mandatory 10 year Inservice Inspection (ISI) and Inservice Testing (IST) program updates. Where can I find this discussed? Again, I appreciate your help. Barbara

 

 

Date: Tue, 23 May 2000

Subject: Proposed Elimination of the Mandatory ISI and IST Program Updates

Dear Barbara: The NRC decision to maintain the mandatory 10 year Inservice Inspection (ISI) and Inservice Testing (IST) program updates is discussed on the NRC Web Site on "The Commissions Activities" page under "Staff Requirements Memoranda" as File SECY-00-0011 dated 04-13-2000. Wally

 

 

Date: Sat, 15 April 2000

Subject: ASME Section XI Reference of ACI 201.1 R-68

Dear Group: ACI 201.1 R-68 is referenced as the source document for VT-3C examinations for determining the condition and extent of degradation of concrete structures, as it applies to Section XI IWL Inservice Inspection, but this guideline has been superceded by ACI 201.1 R-92. My question is, does the Code recognize this change and accept the current revision (92), or does R-68 still apply? Eric

 

 

Date: Tue, 18 April 2000

Subject: ASME Section XI Reference of ACI 201.1 R-68

Dear Eric: As indicated in Section XI, Table IWA-1600-1 of the NRC approved 1992 Addenda and the 1996 Addenda, only ACI 201.1 R-68 (1984) is approved for usage. Use of any other revision would require an approved relief request from the NRC.

 

 

Date: Tue, 14 March 2000

Subject: ASME Section XI Subcommittee Web Site

Dear Group: Does the ASME Section XI Subcommittee have a web site and if so where my I find it? Thank you, Arnold

 

 

Date: Sat, 18 March 2000

Subject: ASME Section XI Subcommittee Web Site

Dear Arnold: You will find a link to the ASME Section XI Subcommittee web site on the Institutions and Organizations page.

 

 

Date: Wed, 10 November 1999

Subject: Snubber Testing and Examinations

Dear Group: I understand that the NRC has clarified that the testing of snubbers is governed by ASME Section XI and that the examination of snubbers is to be performed in accordance with the ASME Section XI, VT-3 examination method. Is this true, and if so where is this documented? Thank you, Shawn

 

 

Date: Mon, 15 November 1999

Subject: Snubber Testing and Examinations

Dear Shawn: The NRC has clarified that the testing of snubbers is currently governed by ASME Section XI and that the examination of snubbers is to be performed in accordance with the ASME Section XI, VT-3 examination method. You will find this documented in the September 22, 1999 Federal Register as referenced below in the response dated Wed, 29 September 1999. Specifically, you will find this stated in the Federal Register on Pages 51374, 51388, 51389, and 51399.

 

 

Date: Mon, 27 September 1999

Subject: NRC Approval of 1996 Addenda for ASME Section III, Section XI, and Operations and Maintenance Code

Dear Group: Where can I find a copy of the NRC final rule for their acceptance of the 1996 Addenda of the ASME Boiler and Pressure Vessel Code, for Section III, Section XI, and the Operations and Maintenance Code? Charlie

 

 

Date: Wed, 29 September 1999

Subject: NRC Approval of 1996 Addenda for ASME Section III, Section XI, and Operations and Maintenance Code

Dear Charlie: The approval was issued in the Federal Register on Wednesday, September 22, 1999. The document is available from the "Federal Register: 1999 Issues" link provided on this site on the Libraries and Reference Sources page, under "Reference Links". Scroll down the Federal Register page to Nuclear Regulatory Commission, RULES, [FR Doc.99-24256]. Dennis

 

 

Date: Thur, 6 August 1999

Subject: NRC Regulatory Guide 1.147

Dear Group: Would someone please confirm what the latest revision is for the NRC Regulatory Guide 1.147, entitled "Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1"? Thank you. Hong

 

 

Date: Tue, 10 August 1999

Subject: NRC Regulatory Guide 1.147

Dear Hong: The latest revision of the NRC Regulatory Guide 1.147 is Revision 12, dated May 1999. Dennis

 

 

Date: Tue, 4 May 1999

Subject: Proposed Elimination of the Mandatory ISI and IST Program Updates

Dear Group: It is my understanding that the NRC has now issued in the Federal Register for public comment their proposal to eliminate the mandatory 10 year Inservice Inspection (ISI) and Inservice Testing (IST) program updates. Where can I find this issue of the Federal Register? I appreciate you help. Barbara

 

 

Date: Fri, 7 May 1999

Subject: Proposed Elimination of the Mandatory ISI and IST Program Updates

Dear Barbara: The NRC proposal and request for public comment regarding the elimination of the mandatory 10 year Inservice Inspection (ISI) and Inservice Testing (IST) program updates was issued in the Federal Register on Tuesday, April 27, 1999. The document is accessible from the "Federal Register: 1999 Issues" link provided on the Libraries and Reference Sources page, under "Reference Links". Scroll down the Federal Register page to Nuclear Regulatory Commission, PROPOSED RULES, [FR Doc.99-10491]. Dennis

 

 

Date: Fri, 9 April 1999

Subject: Proposed Elimination of the Mandatory ISI and IST Program Updates

Dear Group: I understand that the NRC is proposing to eliminate the mandatory 10 year Inservice Inspection (ISI) and Inservice Testing (IST) program updates. Where can I find this subject discussed? Thank you, Ed

 

 

Date: Mon, 12 April 1999

Subject: Proposed Elimination of the Mandatory ISI and IST Program Updates

Dear Ed: You will find the proposed elimination of the mandatory 10 year Inservice Inspection (ISI) and Inservice Testing (IST) program updates discussed in the NRC Commission Paper SECY-99-017, entitled "Proposed Amendment to 10 CFR 50.55a" (Filed as SECY-99-078). Another paper of current and related interest is SECY-99-029, entitled "NRC Participation in the Development and Use of Consensus Standards". Both documents are accessible from the NRC SECY Paper link provided herein on the Libraries and Reference Sources page, under "Reference Links". Pete

 

 

Date: Thur, 14 Jan 1999

Subject: Classification of Containment Piping Penetration Flued Heads

Hello Group: I would appreciate a little help from anyone. What guidance is available for classifying the flued head with its integral attachment to piping at containment penetrations? Should the flued head be considered a component support, recognizing that the pipe stress analyst may have treated it as an anchor point in the analysis, or should it be considered an integral part of the piping that performs a containment boundary function? Any response will be helpful. Thank you. Jose

 

 

Date: Tue, 2 Feb 1999

Subject: Classification of Containment Piping Penetration Flued Heads

Dear Jose: The 1989 Edition of ASME Section III, Rules for Class 1 Components in Paragraph NB-1132.2(a), entitled "Jurisdictional Boundary" states "Attachments cast or forged with the component and weld buildup on the component surface shall be considered part of the component." Since piping systems are considered to be components, an argument can be made that the flued head is part of the piping system, and therefore is not a component support. Further classification guidance is provided in ASME Section III for containment penetrations in Figure NE-1120-1 entitled "Typical Containment Penetrations". Hope this helps. Dennis

 

 

Date: Wed, 18 Nov 1998

Subject: Piping Probability Risk Assessment

Dear Group: Would someone please suggest some recent NRC references that discuss probability risk assessment for inservice inspection of piping systems. Thanks in advance. Michael

 

 

Date: Tue, 1 Dec 1998

Subject: Piping Probability Risk Assessment

Dear Michael: The subject of Piping Probability Risk Assessment is discussed in the following NRC documents: Federal Register, Vol.60, Page 42622 (60 FR 42622), August 16,1995; Regulatory Guide 1.174, July 1998, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis"; Regulatory Guide 1.178, September 1998, "An Approach for Plant-Specific, Risk-Informed Decision making: Inservice Inspection of Piping"; Administrative Letter 98-09, October 30, 1998, "Priority for NRR Review of Risk-Informed Licensing Actions". Hope this helps. Ray

 

 

Date: Sat, 19 Dec 1998

Subject: Piping Probability Risk Assessment

Dear Michael: You might also be interested in taking a look at the ASME B&PV Code Cases N-560 "Alternative Examination Requirements for Class 1, Category B-J Piping Welds", N-577 "Risk Informed Requirements for Class 1, 2, and 3 Piping - Method A" (Westinghouse methodology),and N-578 "Risk Informed Requirements for Class 1, 2, and 3 Piping - Method B" (EPRI methodology). George

 

 

Date: Wed, 28 Oct 1998

Subject: Augmented Piping Examinations Between Containment Isolation Valves

Dear Group: I would greatly appreciate it if someone could please suggest a few references where the NRC augmented volumetric examination requirements are identified for piping located between containment isolation valves. Thanks to all for hosting the bulletin board service. Ginger Robinson

 

 

Date: Thur, 12 Nov 1998

Subject: Augmented Piping Examinations Between Containment Isolation Valves

Dear Ginger: You will find discussion on the subject in the following documents: NUREG-0800 Section 3.6.2, MEB 3-1, Paragraph B.1.b.(7); Section 6.6, Paragraph I.7 and II.7; Regulatory Guide 1.70, Section 6.6.8; NRC Generic Letter 84-04 (PWR's Only); NRC Generic Letter 87-11; and in the Federal Register, Vol. 62, No. 232, 12-3-97, on Page 63895 in Paragraph 2.3.1.2.3. Dennis

 

 

Date: Tue, 6 Oct 1998

Subject: Service Induced Defects or Conditions

Dear Group: Does anyone know if the rules of Section XI for reexaminations or additional examinations are limited only to "service induced" defects or conditions and where this subject may be discussed? Qaun

 

 

Date: Mon, 12 Oct 1998

Subject: Service Induced Defects or Conditions

Dear Quan: Apparently Section XI requires reexaminations and additional examinations whether the defects or conditions are "service induced" or not. Take a look at ASME Section XI Interpretation XI-1-83-04 (BC 82-427), dated August 6, 1982. The Section XI Committee has been addressing this further as Action Item ISI 94-25 which is still ongoing. Also take a peek at the NRC Generic Letter 91-18 regarding resolution of degraded and nonconforming conditions. Good Luck. Chris

 

 

Date: Wed, 23 Sep 1998

Subject: Addition and/or Deletion of Inspection Items

Dear Group: What guidance does Section XI provide for adding and/or deleting inspection items in the inservice inspection program plan during the inspection interval? Thank you. Rick

 

 

Date: Mon, 28 Sep 1998

Subject: Addition and/or Deletion of Inspection Items

Dear Rick: Section XI provides guidance for adding and/or deleting inspection items in Paragraphs IWB-2412(b), IWC-2412(b), IWD-2412(b), and IWF-2410(c) in the 1994 Addenda. Also see Section XI, Non-mandatory Appendix F, Paragraph F-2200(b). George

 

 

Date: Wed, 9 Sep 1998

Subject: Overlaping Periods due to Period Extension

Hello User Group: Does someone know where I may find some guidance on crediting examinations when examination periods overlap due to a period extension in accordance with IWB-2412? Thanks in advance.

 

 

Date: Mon, 14 Sep 1998

Subject: Overlaping Periods due to Period Extension

See Section XI Interpretation: XI-1-95-55 (IN96-019) dated January 23, 1997, found in Interpretations Publication No.41 (1997A) on Page 346 which states that examinations may be performed to satisfy the requirements of both periods as long as any single examination is not credited to both periods. Mark

 

 

Date: Fri, 28 Aug 1998

Subject: Use of Sealants

Hello: Can someone tell me if ASME Section XI permits the use of sealants to stop Class 1 or Class 2 Leakages? Thank you. Al

 

 

Date: Tue, 8 Sep 1998

Subject: Use of Sealants

Dear Al: See ASME Section XI Interpretation: XI-1-95-26 (IN95-002) found in the Interpretations Publication No. 37 (1995A) on Page 314 which states "The use of sealants is neither required nor prohibited by Section XI". Scott

 

 

Date: Mon, 17 Aug 1998

Subject: Containment Repair and Replacement Activities

Hello Group: Where does the NRC say that plants are required to perform containment repairs and replacements to ASME Section XI, Subsections IWE and IWL, prior to September 9, 2001? Richard

 

 

Date: Thur, 20 Aug 1998

Subject: Containment Repair and Replacement Activities

Dear Richard: One such citation can be found in the NRC Information Notice 97-29, "Containment Inspection Rule" dated May 30, 1997 which states "Any repair or replacement (R/R) activity to be performed on containments after the effective date of September 9, 1996, has to be carried out in accordance with the respective requirements of Subsections IWE and IWL". Fred Bloom

 

 

Date: Wed, 12 Aug 1998

Subject: NRC Inspection Manual

Dear Group: Can someone tell me if the NRC Inspection Manual includes a procedure for the inspection of nuclear power plant containment structures and where I would find it? Thank you. James

 

 

Date: Sat, 15 Aug 1998

Subject: NRC Inspection Manual

Dear James: Take a look at NRC Inspection Manual, Inspection Procedure 62003, entitled "Inspection of Steel and Concrete Containment Structures at Nuclear Power Plants". You can access it at this site in Libraries and Reference Sources under "Reference Links" entitled NRC Inspection and Enforcement Manual. Then click on the File IP60.ZIP which is a ZIP file that requires unzipping with either winzip, pkunzip, etc. Winzip shareware is also available at this site for downloading in the Supporting Software section. Sara Steward

 

 

Date: Wed, 5 Aug 1998

Subject: NRC Notification and Submittal of the IWE/IWL Containment Program

Dear Group: I understand that utilities do not have to submit their ASME Section XI IWE/IWL Containment Program to the NRC, but they do have to submit a notification of commitment. Can someone please clarify this subject and tell me where I may find reference to these requirements? Thanks in advance. Bill Waters

 

 

Date: Fri, 7 Aug 1998

Subject: NRC Notification and Submittal of the IWE/IWL Containment Program

Dear Bill: NRC SECY-96-080, Attachment 4, on Page 7, in reference to 50.55a(g)(6)(ii)(B)(5), states that "Licensees must submit in writing to the Director of the Office of Nuclear Reactor Regulation notification of commitment to the containment inservice inspection program as required by Subsection IWE and Subsection IWL with specified modifications."

Also, note that 10 CFR 50.55a(g)(5)(ii) states, "If a revised inservice inspection program for a facility conflicts with the technical specification for the facility, the licensee shall apply to the Commission for amendment of the technical specifications ... at least six months before the start of the period during which the provisions become applicable ... ." Dennis

 

 

Date: Fri, 17 Jul 1998

Subject: ASME Section XI Containment Inspection Program

Dear User Group: Can anyone tell me what date the ASME Section XI, Subsection IWE and IWL, examinations are to be completed to satisfy the first inspection period requirements and where I would find the reference? Thanks in advance. Jim Tucker

 

 

Date: Fri, 17 Jul 1998

Subject: ASME Section XI Containment Inspection Program

Dear Jim: The Subsection IWE and IWL examinations for the first inspection period are to be completed by September 9, 2001 as required by 10 CFR 50.55a(g)(6)(ii)(B)(1). Good Luck, Gary