Federal Regulations, Codes, & Standards
Users Group ©
ASME Section XI Meeting Notes – February 2007
Prepared By: Russell Turner
Company: Progress Energy
Meeting Dates: January 28 – February 1, 2007
For those of you who have not attended an ASME meeting, this meeting is open to anyone who has a desire to attend. Participation by all attendees is encouraged during the meetings, but is not required. This meeting was for all the ASME sections, I through XII. Just a note, for Section XI, there were more meetings and attendee’s than all the other sections combined. This report has only those items that were discussed when I was present.
The next meeting will be from May 14, 2007 through May 18,2007 in Grapevine, TX at the Gaylord Texan Resort and Convention Center; $169/night.
A general item all committee’s are working on is revising imprecise language. There are statements such as, “to the extent practical”. These words are located in every part of Section XI and are being revised to clarify their meaning.
There has been another change in how ASME will annul Code Cases. They will now be annulled 11 years after the Code edition/addenda in which they are incorporated are approved for use by the NRC. There will still be some Code Cases that will not be incorporated, and these may never be annulled.
Where an action was discussed in more than one committee, it was discussed below only once.
Attended the Workshop on the
Global Relevance of the ASME Boiler and Pressure Vessel Code. This was a meeting with several industry
leaders who have experience with ASME and other internationally recognized
pressure vessel standards. The most
familiar one to those of us in the
Special Working Group on Plant Life Extension
This group’s primary function is to look at how ASME can be improved with regard to the License Renewal process. It is an advisory committee to Sections II, III, V, IX, and XI. It does not write Code, but rather passes on Code suggestions to other committees. The regular NRC representative, Ken Chang, was not able to attend due to the governments Continuing Resolution and no travel budget, but was on a conference call with the group. Perhaps the biggest item he discussed was the NRC’s changing of their position on volumetric examination of socket welds. The NRC is apparently giving up on pressing the industry to develop a methodology for this technique, and will mandate the use of Code Case N‑712 instead. This Code Case says to perform a surface examination on those welds susceptible to external attack, and perform a VT-2 on those welds subject to thermal stresses. All but one plant had taken exception to this GALL requirement, and the other plant attempting to do these examinations has not had great success. Along with this, the NRC has changed their position on the use of Code Cases in general. They will allow them to be used during the period of extended operation. Previously, we would need to justify their use even though they may already be approved for use in RG 1.147 or in an approved relief request.
The Chairman of Section XI,
Currently, Section XI does not address “one-time” examinations. The view being proposed is to have a 20-year interval for areas that would be covered by this AMR. This would fit the ASME philosophy, and is in line with the slow collapse of the ten-year interval concept.
The committee chairman asked the members to solicit ideas from their company’s to further the process of getting the various Sections of the Code more in line with the idea of License Renewal.
There were representatives
Talked with ISI personnel who come from other utilities after the meeting. There is a significant amount of interest in taking ISI to the next level. What that level is differs between the utilities, so no consensus is forming at this time. Discussed some common problems everyone faces, with the most pronounced being emergent work not associated with ISI.
Inspection of Systems and Components
Had two items to present.
The first was incorporation of Code Case N-613-1. During a breakfast meeting with Mike
Gothard of EPRI (he paid), found that this Code Case is undergoing revision
and the best course of action at this time is to do nothing. The other action item was to research
whether repair welds on the RPV during construction were covered by Item No.
The Toshiba representative gave a handout on a problem found at the Genkai 2 plant. A three inch elbow on the letdown system developed a large crack at its center along the outer radius. Fortunately it was found before it went thru-wall, with only 1.5mm left of 9mm wall thickness. An action was opened to see if an examination requirement is something that should be incorporated into Section XI.
Other items of interest were:
A change to the Code to perform examinations on CRD bolting was passed. This was removed several years ago, but the NRC has been requiring utilities to perform examinations in accordance with earlier Codes. The new Code wording will limit the examinations to only when the connection is disassembled.
An action to remove the requirement to perform transverse examinations on vessels two inch and less in thickness was discussed. It has committee support, but the NRC stated that the issue has not been evaluated. The leak before break on piping does not apply to vessels, and until the evaluation is performed, the NRC will vote negative.
The elimination of the examination of valve and pump body welds has been approved and is at Sub-Group Water Cooled Systems. This eliminates two examination categories and the associated acceptance criteria and figures.
There is some movement to address new types of weld configurations. One new weld is the steam generator nozzle to pump casing welds in the new Westinghouse plants. Another is the new style of steam generator nozzles that have been put in service with steam generator replacements.
It was learned that Code Case N-702, “Alternative Requirements for Boiling Water Reactor (BWR) Nozzle Inner Radius and Nozzle to Sell Welds”, is being reviewed by the NRC for one plant, and a RAI is about to be sent to that plant shortly. The utility will report at that time.
WG Design and Programs.
This group is essentially the beginning for any Repair/Replacement Activity changes. My action was to present a Code change eliminating the requirement to have ANII involvement, an NIS-2, and a Repair/Replacement Activity plan when replacing bolting that is being replaced as a maintenance activity, not due to in-service degradation. In an unofficial poll performed about two years ago, it was discovered that somewhere between 40-50% of the R/R Activities fell into this area. It was felt that since RRA was for when degradation occurred due to in-service conditions, having to invoke the rules of Section XI to get new bolting was unnecessary. At that time, the group felt this was a worthwhile action, but there are problems with ensuring the proper rules are followed. After much discussion, it was felt that this needed to be its own separate paragraph instead of modifying the existing wording. This is a reversal of what was decided when the action first came up for consideration. If the next rewrite is not successful, it will probably be dropped.
Other items on the agenda:
Change IWA-4520 to permit the use of Section XI personnel qualifications, methods, and criteria for repair/replacement activities.
Establishing Section XI NDE Methods and acceptance standards for acceptance of R/R activities.
Add rotation of CRD’s to alternative requirements (BWR only at this time).
ISI Program Owners Group
This group is comprised mainly of utility members, but in keeping with the ASME open door policy, anyone can attend. This meeting had Larry Dugger of INPO attending. He wanted to bring the group up to speed on INPO related activities as they deal with ISI, and to get some ideas as to how INPO can be of assistance. For almost two hours, Mr. Dugger listened to the ISI issues of the industry. My opinion as to what everyone was discussing:
ISI is below the radar screen of most plants, and does not get much attention. Plants add additional responsibilities to ISI personnel as no problems are occurring at most plants. This makes it difficult to keep their programs in the green and spend sufficient time to make improvements.
The Program Health Annuciator panels everyone uses need to be improved. Many are too easy to show the ISI Program as green, don’t reflect what is actually going on, or just not right. Some plants have three colors, others four. For those that do have four, it appears that getting to green is very difficult. It was suggested INPO set up some guidelines to get consistency around the industry.
There is no actual training on how to build or implement an ISI Program. ASME and Reedy Associates have their training, but that is geared towards familiarizing personnel with what Section XI says and the history behind some of the Code wording, not how to implement it. Everyone in the room learned how to implement through OJT with little or no guidance. Even if training is mandated, there is no training available at this time. INPO has thought about this in ISI and other areas, but no action so far.
January 31, 2007
Subgroup on Water Cooled Systems
This group looks at all actions from pressure testing and Inspection of Systems and Components. Some of the items from other subgroups also come on the agenda due to some cross jurisdictional areas within Section XI.
An item of particular interest to utilities would give guidance on how to handle on-line examinations. When ISI finds a defect, all rules for ISI are in force, including the requirement to perform additional examinations. If the additional examinations include areas that are normally inaccessible while the plant is on line, then the plant must shut down and make the areas accessible. This is a Catch-22 situation. The NRC is happy we find things earlier than normal, but acknowledge they punish us for doing something better. This proposed Code Case would give guidance on what to do (analytical evaluations) and would allow a plant to remain on line until the next outage. If the NRC accepts it, then the mechanism is in place to allow deferral of the examinations to the next refuel outage. This is still a tough Code Case to live with, but would allow a plant to continue operating.
The elimination of the examination of valve and pump body welds has been approved and is at Sub-Committee Section XI. This eliminates two examination categories and the associated acceptance criteria and figures.
An action to correct reference errors in IWB-3522 and a conflict associated with IWB-3522.1 passed unanimously.
An action to extend the scope of class 3 pressure testing to include open-ended discharge piping has received a 2nd negative at main Committee. The action will come back to Section XI for resolution.
An action to include a new item number for extended class 1 pressure boundaries has passed Main Committee.
Inspection Program A and all its associated parts has been approved for complete removal from Section XI. No plant in the world currently used Program A, which had a different examination schedule from the 10-year intervals used by all plants.
An action to clarify what to
do when new flaws or changes to existing flaws are observed during successive
examinations was passed. This was a
result of an incident at
There was a discussion on the use of Section V. What edition/addenda is required to be used with each edition/addenda of Section XI. The NRC said they do not specify which to use, so we may use any of them. This and other discussions with the NRC took place in January 2007, and the minutes of the meeting should be posted on the NRC’s web site soon.
This is where requested interpretations of Section XI rules are taken. It comprises of several individuals who form the committee and discuss the interpretations. Visitors may join in the conversation. When an interpretation is agreed upon, the chairman, vice-chairman, and three others sign off the interpretation. Visitors often make up one or more of the three other individuals.
One interp in particular had a great deal of discussion. Are the temperature and pressure notes at the bottom of the NIS-2 form required to be filled in with the actual temperature and pressure? The answer as this interp went through the various committee’s was no, only when they are not recorded elsewhere or there was a specific temperature and pressure required not covered by any other means was it required. But this did not satisfy everyone, and the question went on for 1-1/2 hours, until the chairman requested the answer would be the committee would look at a Code change. This interp took about one hour each at two other committees I attended.
Overall, there were seven interps presented, of which only one was answered. One was postponed to the next meeting, and the session broke up after going over the time limit by almost an hour.
Sub-Committee Section XI
This is the highest body within Section XI. If an action gets past this level, it goes to Main Committee, then on to BNCS. All actions within Section XI go through this committee. Was not able to attend the entire meeting.
One item being discussed was Code Case N-755 for use of polyethylene piping for buried systems. Duke has a significant amount of it installed in non-safety related Service Water systems, and it has performed well. The proposed Code Case sets up rules to replace the standard carbon steel piping on the safety-related side of the system. The NRC is for this code Case, but committee members and the NRC still have questions. Duke is planning on installing a significant amount of this piping in 2008, and needs the Code Case in place by that time. If not, then the piping replacement cost doubles, and the problem with the piping system is still not solved, only deferred to a later time.
This committee will be starting earlier in the future to allow more time for discussion and to reduce the amount of items being deferred to the next meeting.
Some of the agenda items were:
A change in Class 1, 2, and 3 piping acceptance standards (failed)
Code Case N-752, Risk Informed Safety Classification for R/R activities for moderate energy class 2 and 3 systems.
Question as to whether interior attachments to RPV head fall under B-N-2 (passed, but due to the number of negatives, will be sent back to committee. It was felt that advancing this to the next level with a larger than normal number of negatives would influence some of the Main Committee members to also vote negative.).
Use of ultrasonics in lieu of radiography for preservice examinations.
Add to IWA-9000 the definition of “part”.
Revise figures IWC-2500-3(b) and IWC-2500-4(a) to show a ½” examination area on the nozzles to make them consistent with other figures.
Allow periods to be extended or reduced by up to one year for any reason, not just for an outage.