ASN Guide 19
ASN Guide 19
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Application of the
French Order dated
12/12/2005 on Nuclear
Pressure Equipment
GUIDE No. 19
1. INTRODUCTION ..............................................................................................................................4
2.4. ASN RECOMMENDATIONS FOR THE APPLICATION OF APPENDIX 5 OF THE FRENCH ORDER
ON NUCLEAR PRESSURE EQUIPMENT ............................................................................... 12
2.5. ASN RECOMMENDATIONS FOR THE APPLICATION OF APPENDIX 6 OF THE FRENCH ORDER
ON NUCLEAR PRESSURE EQUIPMENT ................................................................................14
The interpretations of Directive 97/23/EC and the French Decree dated 13 December 1999 provided
by the guidelines on the application of the directive are applicable to nuclear pressure equipment,
except where the Order specifies or supplements the provisions arising from these texts. In the latter
case, the provisions of the Order shall prevail. In similar fashion, the application of a harmonised
European standard gives the presumption of conformity with the essential safety requirements (EES)
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that it covers.
Art. 2 – I –
The pressure equipment referred to in points a) to r) of paragraph II of Article 2 of the French
Decree dated 13 December 1999 is not subject to the provisions of the Order. Nevertheless, the
primary motor-driven pumps of pressurised water nuclear steam supply systems are conventionally
considered as nuclear pressure equipment, without the need to ensure that pressure is a significant
factor in their design and manufacture.
Pressure equipment shall be said to be equipment that directly ensures the containment of
radioactive substances under the conditions defined for its operation if its failure, in at least one of
the normal operating situations to which the equipment is subject, involves the release of radioactive
substances outside the equipment, irrespective of any other means of containing said radioactive
substances that could be implemented over and above the pressure equipment, especially in keeping
with the safety and radiation protection rules.
Pressure equipment, whose failure could give rise to radioactive emissions, may not be regarded as
nuclear pressure equipment on this criterion alone if it does not in itself directly ensure the
containment of radioactive substances under the conditions defined for its operation. Thus, for
example, equipment that does not ensure the containment of radioactive substances but whose
failure could, as a result of external hazard, compromise the integrity of other equipment and
thereby result in radioactive emissions, shall not be considered as nuclear pressure equipment.
A permanent assembly, within the meaning of m) of Article 1 of the Decree in reference [1], carried
out under the responsibility of the manufacturer on a pressure part of an item of nuclear pressure
equipment, is an integral part of this equipment. Such an assembly shall, therefore, be subject to the
provisions of the Order, even if the item thus assembled is not intended to remain permanently
attached to the equipment (for example, the welding of a temporary handling device).
Art. 2 – II –
The activity taken into account for the classification levels of nuclear pressure equipment
corresponds only to the activity of the fluid contained; the possible activation of the equipment itself
is not to be considered. An acceptable procedure is to take into account the activity of the fluid
contained in normal operating situations within the meaning of EN 13445.
Release of activity as assessed according to the provisions of the Order is conventional and must not
be compared to an actual or hypothetical release whatever it may be. The volume to be taken into
account is that defined by the Decree. The activity concentration of the fluid contained to be taken
into account is specified in the safety report of the basic nuclear installation or in a technical report
at the disposal of the ASN. The justifications for the activity are not necessarily based on samples
and measurements.
An item of equipment may only have a single level. Where equipment includes several
compartments, the release from each compartment may be assessed individually, taking into account
the maximum leakage acceptable in operation between the compartments. The level of the
equipment is then determined by the total release of activity obtained after adding together the
release from each compartment. However, the risk analysis performed by the manufacturer shall
take into account the fluid actually contained, including the maximum leakage between the
compartments, in the situation studied.
The piping , pressure fittings or safety accessories connected to a compartment may be classified
into levels by considering the release of activity from said single compartment if the design of said
compartment integrates the following points:
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- the pressure design, in normal operating situations, is carried out by considering the
maximum pressure for each compartment without taking into account the backpressure in the
neighbouring compartment except if the latter is under negative pressure;
- measures for in-service monitoring to ensure that there is no leakage between compartments.
The category of equipment, established according to the provisions of guide sheet 2/27, is
determined by the fluid that generates the highest category taking into account the initial fluid, the
intermediate fluid and the final fluid that are likely to be obtained under all reasonably foreseeable
operating conditions.
Isolation, excluding the main primary and main secondary systems of nuclear steam supply systems
as defined by the Order dated 10 November 1999, is considered to be safe if it complies with the
three criteria below:
it is normally closed or fail-safe or its actuating device has an architecture for preventing the
common mode failures;
it closes quickly enough so that the activity released during the closure is low compared to the
activity contained by the equipment or systems that it isolates;
its reliability is defined by the requirements of the operator, demonstrated (for example, initially
by tests or a qualification, then, when operating, by periodic tests) and maintained.
Safe isolation may be achieved by a single isolation device subject to appropriate specific
justifications.
In normal circumstances, a safety accessory may not be considered as safe isolation.
Art. 3. – I –
A safe state is when an installation is in a stable and controlled state regarding, where appropriate,
control of the nuclear reaction, power or heat removal and the containment of radioactive
substances.
The choice of level N1 classification or the application of the assumption excluding the failure of
nuclear pressure equipment cannot justify the absence of the study of its failure in the safety report
or related records.
Art. 3. – II –
If subsection II of Article 3 is applied, the limits of the safety importance classes should be
considered as safe isolation, irrespective of whether they are attained or not.
Art. 6 – II –
A professional guide is drawn up by one or more operators, one or more manufacturers or any
organisation composed of all relevant professionals. It may include nuclear pressure equipment in
general or a clearly identified terms of equipment. It may only be used within the scope of
application for which it has been drawn up.
Art. 14 – I –
Certain items of nuclear pressure equipment are subject to one or more inspection operations
referred to in Article 18 of the French Decree dated 13 December 1999. Apart from the main
primary system and main secondary systems of water nuclear steam supply systems, for which the
Order dated 10/11/99 specifies said inspection operations, the specific rules for undertaking these
inspection operations are defined in Appendix 6 of the Order dated 12/12/2005.
Art. 16 – I –
Manufacturing is started when an operation such as forming, machining, assembly, heat treatment,
etc. is performed on a material under the responsibility of the equipment manufacturer.
By way of exception, the manufacture of a component that is subject to a technical qualification due
to the risks of heterogeneity related to the development of materials, begins with this creation.
- The situations corresponding to other reasonably foreseeable conditions, within the meaning of
1.1 of Appendix 1 of the French Decree dated 13 December 1999, which may be classified,
along the lines of the classification suggested by the French version of standard EN 134454-3:
o exceptional conditions corresponding to very low probability events that require the
shutdown and suitable equipment checks;
o test situations for the tests after manufacture.
Situations that involve short-term exceedances of the maximum allowable pressure under the
conditions laid down by 2.11.2 of the French Decree dated 13 December 1999 correspond to
exceptional situations. Insofar as these situations are taken into account in a suitable manner in
the design, shutdown and suitable equipment checks are not required. Suitable design involves
providing a system for collecting waste and limiting the general stresses of the membranes
caused by the pressure to 110% of the values resulting from the application of point 7 of
Appendix 1 of the French Decree dated 13 December 1999.
With regard to damage, other than excessive distortion, the criteria for damage prevention must
be respected with the safety margins for common operational incidents which are included in
normal operating situations. The pressure level to be taken into account is that which is likely to
be achieved in these situations with a maximum of 110 % of PS (maximum acceptable pressure
value).
It is essential not to confuse the operating conditions of the basic nuclear installation with the
situations of the nuclear pressure equipment. The case of equipment that comprises the backup
systems (a system that needs to be operational during an accident or post-accident operating
condition of the basic nuclear installation) is, in this respect, particularly explicit since the conditions
defined for its operation include those that appear during the accident operating conditions of the
basic nuclear installation.
The operator provides the manufacturer with the description of all the situations - normal operating
situations, exceptional situations, test situations and highly improbable situations - that must be
defined in line with the safety report, and all the loads to be taken into account for every situation.
Good practice is when the safety report supplemented by the related records explains, in sufficient
detail, the approach for drawing up the list of situations for all the nuclear pressure equipment from
all the operating conditions of the basic nuclear installation. It may also explain the types of loads to
be taken into account and their combinations for all equipment situations. The situations and loads
may be defined by the operator so that the equipment may be allocated several allocations.
The equipment conformity assessment focuses on all the requirements corresponding to all the
situations of the equipment question. In practice, these are:
for normal operating situations, exceptional situations and test situations, conformity with the
essential safety requirements defined in Appendix 1 of the French Decree No. 99-1046 dated 13
December 1999, specified and supplemented by the essential safety requirements defined in
Appendices 1 to 3, depending on the level of equipment, in the Order dated 12 December 2005,
consistent with the risk analysis;
for highly improbable situations, conformity with the requirements provided to the manufacturer
by the operator, consistent with the safety report supplemented by the related records and those
arising from the risk analysis. These requirements focus in particular on prevention regarding plastic
instability damage and abrupt fracture, deferred by creep.
Special case of nuclear pressure equipment constituting the main primary system and main
secondary systems of PWRs:
Exceedances of the maximum allowable pressure of equipment constituting the main primary and
secondary systems of pressurised water reactors are possible under the conditions laid down in
paragraph 2.11.2 of Appendix 1 of the French Decree of 1999 and Article 4-II-c of the Order dated
10/11/1999.
The classification of situations and all the regulatory requirements on the maximum acceptable
pressure and temperature limits for pressure equipment constituting the main primary and main
secondary systems are presented in Table 2.
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- 2. Design -
In order to take account of the effects of irradiation on the materials, the manufacturer shall ensure
that, during the intended service life of the equipment, its characteristics are adapted to the intended
use of the equipment.
- 3. Manufacture -
- 3.1. Forging and foundry operations -
Inclusion cleanliness is more particularly required for thin-walled equipment and when the direction
of the inclusions might cause a loss of resistance for the equipment.
- 4. Materials -
In specifying the requirements of points 4.1, 4.2 a) and 4.3 first paragraph of section 4 of Appendix
1 of the Decree, applicable to assembly materials, the requirements for the materials referred to in 4
of Appendix 1 of the Order are, in the same manner, applicable to assembly materials.
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Table. 1 – Classification of situations. Requirements and related criteria for maximum acceptable
pressure and temperature values (PS and TS) for nuclear pressure equipment excluding main
primary and main secondary systems.
PS / TS
Classification of situations
Normal
Normal
operating
operating - T TS.
situations
situations
Common - P PS.
(second
operational
category
incident
situations) situations.
Reasonably
- Art.4-II-c of the Order dated
foreseeable Exceptional situations 10/11/1999;
situations (third category situations)
- P 110 % PS with short-term
exceedance;
- adequate protection device when T
TS.
The above recommendations for the requirements in Appendix 1 remain valid for the same
requirements in Appendices 2 and 3.
In specifying the requirements of points 4.1, 4.2 a) and 4.3 first paragraph of section 4 of Appendix
1 of the Decree, applicable to assembly materials, the requirements for the materials referred to in 4
of Appendix 2 are, in the same manner, applicable to assembly materials.
The documentary material on the neutrality of products used for thermal insulation or for equipment
coatings is provided by the manufacturer where these products form part of the equipment.
Otherwise, a technical analysis report prepared by a notified body or, where appropriate, by a
recognised inspection service may replace them.
The operational incidents to be listed in the operating record include in particular the stresses on
safety accessories. This applies to significant and recognised stresses, without it being necessary to
systematically instrument the safety accessories.
All the required technical documentation includes the items relating to the manufacture and
operation of equipment, such as the records of non-destructive tests. The test results must be kept for
the entire service life of the equipment in question.
The internal check of newly-subject equipment which, as a result of its design, has no visible
part after all the exposure work has been carried out and all the removable items have been
dismantled, focuses on an array of bare parts. This specific point must then be taken into account by
the operator in the maintenance and inspection operations program.
The inspection report is signed by the operator, which enables the latter to become acquainted
with it and to take responsibility under the Order, whilst being aware of the condition of the pressure
equipment pool in its plant. If necessary, the operator then reviews the maintenance and inspection
operations programs on the basis of the remarks made by the people who carried out the periodic
inspections.
The deadline for the periodic inspection is calculated from the date on which the last periodic
inspection operation was carried out under paragraph 3.4 of Appendix 5 and the interval between
two periodic inspections specified in paragraph 3.3 of said Appendix. All inspection operations must
be performed before the re-commissioning of the equipment.
A component intended for repairing or modifying nuclear pressure equipment may be subject to an
assessment of its conformity with the applicable regulatory requirements (French Decrees dated
02/04/1926, 18/01/1943, 3/12/1999, Order dated 12/12/2005 or requirements defined by the operator
based on the manufacturer’s data in the context of repaired or modified newly-subject nuclear
pressure equipment) and according to the procedures that would have been selected if said
component had been manufactured as part of the manufacture of a new item of equipment. The
notified body or inspection body may then draw up an attestation of conformity for the component
on the basis of which the supplier of the component may draw up a component certificate. These
two documents shall be taken into account during the conformity assessment of the repaired or
modified item of nuclear pressure equipment or, where appropriate, by the operator if it is an
operation that is not significant.
When repairing or modifying newly-subject nuclear pressure equipment, which, although not subject
to all the technical provisions of the French Decrees dated 02/04/1926, 18/01/1943 or 13/12/1999,
was manufactured according to these provisions, the test is performed with the load factor defined in
said Decrees. If not, the test is performed at a pressure defined according to the provisions specified
in paragraph 7.4 of the essential safety requirements of the French Decree dated 13 December 1999.
If it is found that this factor is not suitable, the operator shall undertake the test with the maximum
admissible and justified load, which it justifies and which may not be less than 120% x PS. If not,
the conformity of the repaired or modified nuclear pressure equipment cannot be attested to.
The Order specifies, according to the second and third items of § 2.1, that the level N2 and N3
equipment covered by the periodic requalification operations are:
- the II to IV category containers and the safety accessories and pressure fittings that are
connected to them or that are associated with them;
- category III piping and the safety accessories and pressure fittings that are connected to it or
that are associated with them.
Accordingly, nuclear pressure equipment that consists of containers and piping, and the safety
accessories and pressure fittings that are connected to it or that are associated with it, are subject to
the requalification operations.
Article 2.3 of Appendix 6 defines the operations included in the periodic requalification:
- a periodic requalification inspection;
- a hydrostatic test;
- a check of the safety accessories that protect the equipment.
The hydrostatic test applies to all level N1 and category I to IV nuclear pressure equipment,
irrespective of the type (container, piping, pressure fitting and safety accessory), as well as the
containers and piping with the pressure fittings or security accessories that are connected to it or
associated with it in levels N2 and N3 and category II to IV or III depending on whether it is a
container or piping.
Regarding safety accessories for which there is no pressure risk; subject to said justification, the
relevant safety accessories may be exempted from the hydrostatic test (e.g. rupture discs).
When a safety accessory protects several items of nuclear pressure equipment, the operations
required to ensure the points listed in 2.6 of Appendix 6 may only be undertaken during the periodic
requalification of the equipment that has the shortest periodic requalification periodicity. The date
on which these operations are first carried out must, however, correspond to the first deadline of the
periodic requalification of the protected nuclear pressure equipment. The reports for the periodic
requalification of each item of nuclear pressure equipment must attest to the completion of these
operations.
The internal check of newly-subject equipment which, as a result of its design, has no visible part
after all the exposure work has been carried out and all the removable items have been dismantled,
focuses on an array of bare parts. This specific point must then be taken into account by the notified
body and agreed during the periodic requalification of the equipment.
The intervals between the periodic requalification of equipment are calculated from the date of the
final check test or, where appropriate, from the date of the prior requalification test. When the
equipment is not subject to a periodic requalification test, the requalification intervals are calculated
from the dates on which the periodic requalification inspections are carried out.
Regarding newly-subject equipment: equipment commissioned before 22 January 2011 must be
subject to a periodic requalification before the deadline calculated from 22 January 2011 and
corresponding to the interval between two periodic requalifications as defined at point 2.2 of
Appendix 6. Equipment commissioned after 22 January 2011 is subject to periodic requalification
before the deadline calculated from the date of commissioning of the equipment and corresponding
to the interval between two periodic requalifications as defined at point 2.2 of Appendix 6.
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