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Federal Regulations, Codes, & Standards Users Group © |
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ASME Section XI Users Group Bulletin Board |
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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. To search this bulletin board for key words and phrases, click on "Edit" on your web browser tool bar and then click "Find ... ". In the resulting dialog box, insert the desired key word or phrase and then click "Find ... ", repeatedly as necessary to locate multiple entries as you proceed through the page. |
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Note: All information provided on this bulletin board is provided "as is", without warranty of any kind, as stipulated in the Disclaimer and Conditions of Use for this web site. |
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Bulletin Board Postings: |
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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 |
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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 |
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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 |
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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, |
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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? |
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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, (See Response Below) |
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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.
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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 |
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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 |
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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 |
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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 |
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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 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 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. 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. |
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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 |
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Date: Tuesday, 15 January 2008 Subject: Definition of Section XI Outage Dear Doug: Please
see the responses below. 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? 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, 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. 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.
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. 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. 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). 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? 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. 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. 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. 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. |
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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, |
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Date: Thursday, 20 December 2007 Subject: Examination Category B-G-1 Bolting Dear
Gary: Please
see the responses below. 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. We do not recall having been asked
this directly by any utilities, but our answer would be to examine. 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. 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. 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. 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). Code Interpretations 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 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 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. 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 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. 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. |
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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 |
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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. 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. 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. 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. 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):
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. |
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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 |
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Date: Thursday, 12 July 2007 Subject: When do Most Licensees Submit Relief
Requests to the NRC? Dear
Mark: Please
see the responses below. 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. 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. 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, 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. 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. 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. 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. 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. 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). |
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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 |
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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. |
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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 |
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Date: Sun, 30
July 2006 Subject: Authorized Nuclear Inspectors, Forms, etc. Dear
Don: Take a look at http://www.authorizedinspector.com. |
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Date: Tue, 3
January 2006 Subject: Summary of ASME Code Changes Dear
Group: Does anyone provide a summary
of ASME Code changes? Thanks, Pete |
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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. |
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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 |
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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 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. |
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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 |
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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 Michael |
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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 |
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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 |
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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 |
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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 |
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Date: Tue, 25 May
2004 Subject: NRC
Approval of Latest ASME Section III, Section XI, and 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 |
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Date: Thur, 27
May 2004 Subject: NRC
Approval of Latest ASME Section III, Section XI, and 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. |
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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
|
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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.
|
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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, This response
represents the collective input received from
|
|||
|
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.
|
|||
|
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,
|
|||
|
Date: Sat, 18
March 2000 Subject: ASME
Section XI Subcommittee Web Site Dear
|
|||
|
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
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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
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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
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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
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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
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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
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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
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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
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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.
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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,
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