ML021050463
| ML021050463 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 05/01/2002 |
| From: | Vissing G Office of Nuclear Reactor Regulation |
| To: | |
| Vissing G | |
| References | |
| TAC MB2946 | |
| Download: ML021050463 (32) | |
Text
APPENDIX A JAMES A. FITZPATRICK NUCLEAR POWER PLANT SUBSECTION IWE COMPARISON TABLE
APPENDIX A -- JAMES A. FITZPATRICK NUCLEAR POWER PLANT -- IWE COMPARISON IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination 1100 No change N/A 1200 No change N/A 1210 No change N/A 1220 Changed containment to Nonsignificant Editorial change has no safety or containment system quality significance. Acceptable.
1230 No change N/A 1231 Removed item 3) - single welded These single welded butt joints were Examination of welds is optional in butt joints from the weld side - as a removed as a separately listed 10 CFR 50.55a. Acceptable.
specific item required to remain examination item and are now accessible for the life of the plant. included within the item for the pressure retaining boundary as discussed in the changes to Table IWE-2500-1, Item E1.10 below.
Changed wording from 80% of the The exclusions from 80% Wording of IWE-1231 changed to surface area to 80% of the incorporate an existing Table IWE be consistent with the existing pressure retaining boundary and 2500-1 note and clarify that areas Table IWE 2500-1 and its note.
stated exclusions from that 80%. made inaccessible during Acceptable.
construction are also excluded.
Reworded paragraph b). Change to b) is for clarity and is Editorial change has no safety or nonsignificant. quality significance. Acceptable.
IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination 1232 ASME XI generic change from Nonsignificant Editorial change has no safety or repair and/or replacement to quality significance. Acceptable.
repair/replacement activities.
Welded joints were removed as a Examination of welds is optional in Deleted paragraph (a)(3) separately listed examination items 10 CFR 50.55a. Acceptable.
addressing inaccessible welded and are now included within the item joints. for the pressure retaining boundary as discussed in the changes to Table IWE-2500-1 below.
1241 Added stiffeners in IWE-1241(a) The additional areas subject to Adding stiffeners in IWE-1241(a) and, by added reference to IWE- augmented examination further requiring examination and adding 2420(b), flaws accepted by assure containment integrity. reference to IWE-2420(b) further evaluation as areas requiring assure containment integrity.
augmented examination. Acceptable.
1240 No Change N/A 1242 Changed IWE-2500(b) to IWE- Nonsignificant Acceptable.
2500(c) 2000 No change N/A 2100 Added new Subarticle 2100 - The additional general requirements By adding additional general General - to provide reference to invoked by reference to IWA-2000 requirements of IWA-2100, further IWA-2000 with exceptions from where none were referenced assure containment integrity.
IWA-2210, 2300, 2500 and 2600. previously further assure Also, IWE-2310, 1998 covers the containment integrity. The visual examinations as identified in exceptions provided are significant IWA-2210. Acceptable IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination in that related requirements have Per the 1998 Code, personnel will been incorporated into IWE-2310, not have to be certified to CP-189 2320 and 2330. These changes are (IWA-2300) - Licensee committed discussed below. JAFNPP's visual to certify inspection personnel in examination requirements are accordance with CP-189 in defined in Relief Request RR-27, accordance with the 1992 Proposed Alternatives, item 1). Addenda, IWA-2300 requirements since July 1, 2001. Acceptable.
2200 Deleted paragraph c) which The deletion of an allowance for an The deletion of paragraph (c) provided allowances for the use of alternative examination ensures that ensures that proper preservice shop or field examinations in lieu of proper preservice examinations are examination is performed per on site preservice examinations. performed and documented. Table IWE-2500-1. Acceptable.
Deleted paragraph g) which The deletion of the requirement to See discussion under Paragraph required the condition of new document the condition of new 2500 for additional discussion on coating to be documented in the non-pressure retaining coatings in JAFNPP's coatings program.
preservice examination record. the preservice examination record Acceptable.
provides for more efficient program implementation without affecting component integrity. JAFNPPs coating procedure covers containment coating applications without the need for an additional Code examination.
ASME XI generic change from Nonsignificant. Editorial change has no safety or repair and/or replacement to quality significance. Acceptable.
IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination repair/replacement activities.
2300 Added new Subarticle 2300 - The paragraphs within this IWE 2300 - Visual Examination, Visual Examination, Personnel Subarticle are considered significant Personnel Qualification and Qualification and Responsible and contain requirements that either Responsible Individual, is newly Individual. did not previously exist or that were added Subartical. See comments contained in other areas. Placing regrading IWE-2310, IWE-2320, these requirements within Article and IWE-2330.
IWE-2000 further ensures proper Examination and Inspection of areas important to containment integrity and provides consistency with Subsections IWB, IWC and IWD. The specific paragraphs added are discussed below. JAFNPP has submitted additional commitments, as detailed in Relief Request RR-
- 27. Reference to the applicable additional commitments are identified in the discussion below.
2310 Added new paragraph 2310 - Visual a) Adding requirements for the Consistency with existing ISI visual Examinations - which a) states that owner to define visual examination examination requirements provide the owner shall define requirements requirements provides for more for an efficient internal program; for visual examination of efficient containment ISI program that coupled with the program containment surfaces; implementation by allowing established for JAFNPP should examinations that may be more provide uniformity and consistency IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination consistent with existing ISI, industry wide. The 1998 Code containment coating, maintenance with the specific commitments in rule and Appendix J programs. the September 7, 2001, submittal are acceptable.
JAFNPPs visual examination requirements are defined in Relief Request RR-27, Proposed Alternatives, item 1).
b) and c) define general and detailed visual examinations; and b) and c): The general visual The 1998 Edition does not specify examination is performed to indicate acceptance criteria since the the general condition of the examination requirements are containment. The detailed visual defined by the owner. The staff examination is performed to does not find this to be acceptable.
determine the magnitude and extent The licensee provided specific of any deterioration or distress. acceptance criteria for the general Referring to visual examinations by and detailed visual examinations in new general visual and detailed its September 7, 2001, submittal.
visual terms does not adversely This is acceptable.
affect the integrity of the containment components examined.
The provisions of JAFNPPs general visual and detailed visual examinations are defined in Relief Request RR-27, Proposed Alternatives, item 1).
IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination d) and e) provides the requirements d) and e): Previously these Adding these specific attributes for the conditions of areas affected examination requirements did not ensure proper containment by repair/replacement activities, exist within Article IWE-2000 but examinations. Also, the licensee painted or coated areas, and non- rather only in the acceptance criteria provided specific acceptance coated areas. of Article IWE-3000. Adding these criteria for the general and detailed specific attributes here ensure visual examinations in its proper containment examinations. September 7, 2001, submittal.
JAFNPPs acceptance criteria for Acceptable.
general and detailed visual examination further define the examination criteria to be used. The JAFNPP acceptance criteria are defined in Relief Request RR-27, Proposed Alternatives, item 3).
2320 Added new paragraph 2320 - a) The details for the Responsible This is editorial change.
Responsible Individual - in which Individual qualification requirements Acceptable.
a) states the qualification were previously contained in the requirements of the Responsible acceptance standards of IWE-Individual and 3510.1.
b) defines the responsibilities of the b) The added detailed The duties identified must be Responsible Individual for the responsibilities for the Responsible performed regardless of who is development of plans and Individual ensure proper assigned to do them. However, procedures; instruction, training and performance of those related the philosophy of the 1998 Edition approval of visual examination activities. Having an individual give the responsible individual personnel; performance or direction possessing the qualifications complete control over the program.
IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination of visual examinations; evaluation described in paragraph 2320 a) This provides consistency in all the of results and documenting results. performing the responsibilities plan and procedure; performance defined in paragraph 2320 b) and direction of examination; ensures the reliable detection of evaluation of results and conditions adverse to containment documentation. Acceptable.
integrity.
2330 Added new paragraph 2330 - a) Adding requirements for the The staff finds owner-defined Personnel Qualification - which a) owner to define personnel personnel qualification states that the owner is responsible qualification requirements provides requirements to be unacceptable.
for defining the qualification for more efficient containment ISI Personnel should be qualified in requirements for personnel program implementation by accordance with Subsection IWA performing visual examinations and permitting personnel performing requirements. The licensee states containment examinations to be that personnel will be qualified in qualified to written practices that are accordance with CP-189 since more consistent to those used for July 1, 2001. This is acceptable.
other NDE personnel. JAFNPP's personnel qualification requirements are defined in Relief Request RR-27, Proposed Alternatives, item 1).
b) provides minimum qualification b) Providing these details in the Use of the 1998 Edition is requirements that were previously qualification requirement paragraph unacceptable without additional contained in the acceptance criteria focuses the containment visual commitments from the licensee.
of IWE-3510.1. qualification on areas important to The licensee provided the containment integrity. JAFNPP's qualification requirements for personnel qualification and direct and remote visual examination provisions that examinations in its September 7, IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination supplement the Code requirements 2001, submittal. This is are defined in Relief Request RR-27, acceptable.
Proposed Alternatives, item 1).
2400 No change N/A 2410 No change N/A 2411 Deleted a subparagraph discussing The deleted subparagraph The deleted subparagraph decreasing and extending eliminates duplication with IWA- requirements are similar to as of inspection periods. 2400. IWA-2400. The Code 1998 Edition invokes the requirements of IWA-2400 under newly added paragraph IWE-2100. This is acceptable.
2412 Deleted a subparagraph discussing The deleted subparagraph The deleted subparagraph decreasing and extending eliminates duplication with IWA- requirements are similar to as of inspection periods. Added a 2400. The added requirements for IWA-2400. The Code 1998 Edition subparagraph detailing the scheduling of added welds or invokes the requirements of IWA-requirements for the scheduling of components was added prior to the 2400 under newly added added welds or components. 1998 Edition rewrite of Subsection paragraph IWE-2100. This is IWE and is of marginal value with acceptable.
the 1998 revisions to Table IWE-2500-1 (refer to the evaluation in this table).
2420 Revised (b) to remove repaired Repaired areas that are likely to Changing duration of areas as areas requiring experience accelerated degradation reexamination of areas that remain IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination reexaminations during the next and aging are already subject to essentially unchanged from three successive inspection period. augmented examinations per IWE- consecutive inspection periods to 1241. Some repairs may be located the next successive inspection in non- augmented areas and may period is consistent with the be necessary to correct physical requirements for Class 2 damage caused by construction or components. Acceptable.
craft activities. Not having to repeat examinations of these non augmented repaired areas provides for more efficient program implementation without adversely affecting component integrity.
Changed (c) to require that areas This is now consistent with Class 2 Changing duration of which remain essentially successive inspections. The reexamination of areas that remain unchanged for the next inspection engineering evaluation of IWE- essentially unchanged is period no longer require augmented 3122.3, along with the reexamination consistent with the requirements examinations. The 1992 Addenda in the next inspection, is sufficient to for Class 2 components.
required three consecutive assure that augmented Acceptable examinations to reach this examinations need not be continued.
conclusion.
2430 Deleted the paragraph - Additional The changes to Table IWE 2500-1 The 1998 Code does not rely on Examinations - which discussed eliminate several examination sampling as 100% of the adding examination items of the categories. The categories that containment surface is already same category if flaws or areas of remain all require 100% examined. Therefore, elimination degradation are identified during an examination. Therefore no items are of this requirement is appropriate.
examination. available for additional examinations. Acceptable.
IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination 2500 Reworded the existing The reworded subparagraphs add The rewording of the subparagraphs consistent with the clarity and provide consistency subparagraph provides previous paragraph changes and within IWE. consistency between the with Table IWE-2500-1 changes. paragraph IWE-2500 and Table IWE-2500-1. Acceptable.
Deleted the requirement to examine The 1998 Edition increases the Elimination of the paint or coatings paint or coatings prior to removal. frequency of examination when examination prior to removal has compared to the 1992 Addenda.
been found acceptable provided During examinations, the general adequate provisions exist in the and detailed visual examinations of licensees program to examine the coated areas will identify flaws and base metal prior to reapplication of degradation in the containment base the coating. The licensee metal and result in appropriate adequately addressed base metal corrective actions per the Code examination in its September 7, requirements. Should a coating be 2001, submittal.
removed between required inservice inspections, the JAFNPP nuclear coatings pre-application inspections, and nonconformance and corrective action programs, would identify and resolve any base metal conditions that could challenge the structural integrity of the containment. As a result, there is no anticipated benefit from a separate Code requirement to inspect coatings prior to removal.
IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination This deletion provides for a more efficient program implementation without affecting component integrity.
The ultrasonic gridline approach is Replaced the requirement for one- The new Table IWE 2500-2 provides a sampling methodology similar to foot square grids in thickness more detailed requirements for that of other portions of the Code measurements with a reference to thickness measurements and is and other erosion/corrosion Table IWE 2500-2. discussed below. monitoring programs. Acceptable.
Paragraph IWE-2500 is for Added a reference to IWE-5000 for The added reference to IWE-5000 Examination and Pressure Test pressure tests. provides direction for the Requirements and IWE-5000 is performance of pressure tests. for System Pressure Tests.
Therefore, referencing IWE-5000 in IWE-2500 is streamlining the IWE. Acceptable.
2600 Deleted a sentence discussing The removal of this sentence The deleted sentence regarding compatibility of paint and coating addressing new non-pressure reapplied paint and coating refers systems and a requirement to retaining paint and coatings provides to non-pressure retaining paint and examine the new paint. for more efficient containment ISI coating. To be consistent, the program implementation without compatibility of paint and coating adversely affecting component systems with the existing system, integrity. The compatibility of paint and the examination of newly and coating systems with the applied coatings, is addressed in existing system, and the the JAFNPP containment coating IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination examination of newly applied specification and procedures.
coatings, is addressed in the Acceptable.
JAFNPP containment coating specification and procedures.
3100 Removed the word nondestructive Nonsignificant This is an editorial change.
from the heading. Acceptable.
3110 No Change N/A 3111 Replaced the reference to Table Table IWE-3410-1 and paragraph This is an editorial change.
IWE-3410-1 with a reference to IWE-3115 has been deleted and is Acceptable.
Subarticle IWE-3500. Removed discussed below. IWE-3500 reference to paragraph IWE-3115. adequately captures all of the information previously contained in the deleted table and paragraph.
3112 Replaced the reference to Table Nonsignificant This is an editorial change.
IWE-3410-1 with a reference to Acceptable.
subarticle IWE-3500. Replace the reference to IWA-6630 instead of IWA-6620. ASME XI generic change from repair and/or replacement to repair/replacement activities.
3114 Replaced the reference to Table Nonsignificant This is an editorial change.
IWE-3410-1 with a reference to Acceptable.
IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination subarticle IWE-3500. ASME XI generic change from repair and/or replacement to repair/replacement activities.
3115 Deleted subparagraph which Nonsignificant - there were no The regulations do not require the addressed repair programs and submittal or retention requirements licensee to submit the containment evaluations being subject to review changed by the deletion of the inspection program. Acceptable.
by authorities. subparagraph.
3120 Removed the word nondestructive Nonsignificant This is an editorial change.
from the heading. Acceptable.
3121 Removed the word nondestructive The removal of nondestructive is This is an editorial change.
and deleted references to IWE- nonsignificant. The referenced Acceptable.
3124 and IWE-3125 for the subparagraphs did not actually apply acceptance of flaws for continued to the acceptance of flaws for service. continued service.
3122 Replaced the references to Table Nonsignificant - the changes are for This is an editorial change.
IWE-2500-1 and to IWE-3000 with clarity and to reconcile paragraph Acceptable.
a reference to subarticle IWE-3500. numbering. There was no submittal Combining IWE 3122.2 and 3122.3, or retention requirements changed and IWE 3122.4 is renumbered as by the deletion of the sentence IWE 3122.3. ASME XI generic addressing evaluation reviews.
change from repair and/or replacement to repair/replacement activities. Reworded several sentences. Deleted sentence IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination which addressed evaluations being subject to review by authorities.
3124 Replaced the reference to Table Nonsignificant This is an editorial change.
IWE-3410-1 with a reference to Acceptable.
subarticle IWE-3500. ASME XI generic change from repair and/or replacement to repair/replacement activities.
3125 Deleted subparagraph which Nonsignificant - there were no This is an editorial change.
addressed repair programs and submittal or retention requirements Acceptable.
reexamination results being subject changed by the deletion of the to review by authorities. subparagraph.
3130 No change N/A 3200 Added a statement to the end of the The added statement clarifies This is an editorial change.
paragraph that states supplemental requirements and eliminates Acceptable.
surface or volumetric examinations potential duplication or contradiction are required when specified by the of requirements in stating that the engineering evaluation. engineering evaluation requirements of IWE-3122 determine what and when supplemental examinations are required.
3410 Replaced the reference to Table Nonsignificant This is an editorial change.
IWE-3410-1 with a reference to Acceptable.
IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination subarticle IWE-3500.
3430 No change N/A 3500 No change N/A 3510 Reconciled acceptance standards Previously examination Owner-defined visual examination with the IWE-2300 changes requirements were contained in the requirements do not provide discussed above and the Table acceptance standards of IWE-3500. uniformity and consistency IWE-2500-1 changes discussed This has been corrected by the industry wide. This is below by: addition of IWE-2300 as discussed unacceptable unless the licensee above. provides specific acceptance standards. The licensee provided this information in its September 7, 2001, submittal. Acceptable.
Adding the requirement that the owner shall define acceptance This change directly corresponds to The licensees visual examination criteria for visual examination of the addition of IWE-2310(a) acceptance criteria are defined in containment surfaces; discussed above. JAFNPPs visual Relief Request RR-27, Proposed examination acceptance criteria are Alternatives, item 3). Acceptable.
defined in Relief Request RR-27, Proposed Alternatives, item 3).
Removing the wording for This is an editorial change to Responsible Individual and for This change directly corresponds to rearrange the paragraph.
personnel qualifications; the addition of IWE-2320 discussed Acceptable.
above.
Combining 3510.2 and 3510.3 and This is an editorial change to IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination removing specific VT-3 examination These changes directly correspond rearrange the paragraphs.
attribute wording; and to the addition of IWE-2310(e)(1) Acceptable.
and (2) discussed above.
This is an editorial change to Incorporating IWE-3511;3513,3514 rearrange the paragraph.
and 3515 with changes into IWE- These changes correspond to the Acceptable.
3510. changes in the examination categories of Table IWE-2500-1 as discussed below and to the removal of examination requirements from the acceptance standards paragraphs.
The examination of bolting, seals By the incorporation of 3515 the and gaskets to determine their acceptance standards for bolting The resulting acceptance standards ability to maintain containment leak were changed from referencing for bolting provide for more practical tight integrity as a separate material specs and torque or containment ISI program inspection is considered tension limits to conditions affecting implementation without adversely unnecessary. The Appendix J, leak tight or structural integrity. affecting containment leak tight or Type A test is considered sufficient structural integrity.
for determining the leak-tight integrity of the penetration.
Acceptable.
3511 Deleted subparagraph which Examination category E-B has been Examination category E-B has addressed examination category E- incorporated into examination been merged with E-A , which is B. category E-A per the changes to consistent with the changes to Table IWE-2500-1 discussed below. Table IWE-2500-1. The details of changes in Table IWE-2500-1 are discussed below. Acceptable.
IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination 3512 Renumbered subparagraph to IWE- The subparagraph was renumbered This is an editorial change as 3511. Reconciled acceptance based on the deletion of previous discussed in the comments standards with the IWE-2300 IWE-3511 as discussed above. column for IWE-3511.
changes discussed above and the Previously examination Acceptable.
Table IWE-2500-1 changes requirements were contained in the discussed below acceptance standards of IWE-3500.
This has been corrected by the addition of IWE-2300 as discussed above.
Added the requirement that the owner shall define acceptance This change directly corresponds to The licensees visual examination criteria for visual examination of the addition of IWE-2310(a) acceptance criteria are defined in containment surfaces; discussed above. JAFNPPs visual Relief Request RR-27, Proposed examination acceptance criteria are Alternatives, item 3).
defined in Relief Request RR-27, Proposed Alternatives, item 3). Acceptable.
Combined 3512.2 and 3512.3 with changes into 3511.2 and removed These changes directly correspond This is an editorial change to specific VT-1 examination attribute to the addition of IWE-2310(e)(1) rearrange the paragraphs.
wording; and and (2) discussed above and Acceptable.
eliminate potential duplication or contradiction of requirements.
Reworded ultrasonic examination subparagraph and limited the UT to This change eliminates the need to Class MC components. perform the UT examinations on IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination metallic liners of Class CC Licensee states it will apply components. JAFNPP will apply the provisions of IWE-3511.3 to both provisions of IWE-3511.3 to both Class MC and metallic liners of Class MC components and metallic Class CC components. This is liners of Class CC components, as acceptable.
stated in Relief Request RR-27, Proposed Alternatives, item 3).
3513 Deleted subparagraphs Examination categories E-D, E-F Acceptable. The regulations do not 3514 IWE-3513, 3514 and 3515 which and E-G have been incorporated require the examination of 3515 addressed examination into examination category E-A containment welds.
categories E-D, E-F, and E-G, per the changes to Table IWE-respectively. 2500-1 discussed below.
4100 No change JAFNPPs relief request does not include using the 1998 Edition of IWA-4000. JAFNPP will continue to use IWA-4000 from the 1992 Addenda as required by NRC clarification of the 10 CFR 50 regulations that mandated implementation of IWE and IWL.
5200 No change N/A 5210 No change N/A 5220 ASME XI generic change from Nonsignificant Editorial change has no safety or repair and/or replacement to quality significance. Acceptable.
repair/replacement activities.
IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination 5221 ASME XI generic change from Nonsignificant - the requirement to Editorial change has no safety or repair and/or replacement to meet the requirements of the quality significance. Acceptable.
repair/replacement activities. Appendix J paragraph referenced is Removed the quotation of 10 CFR not affected by removing the quoted 50 Appendix J paragraph IV.A. Appendix J paragraph IV.A..
5222 ASME XI generic change from Nonsignificant Editorial change has no safety or repair and/or replacement to quality significance. Acceptable.
repair/replacement activities.
5240 Replaced a reference to IWA-5240 The addition of specific IWE Referencing IWE-2310, visual with requirements to perform examination requirements during examination in lieu of IWA-5240, detailed visual examination of pressure testing in lieu of visual examination provides more repair/replacement areas during referencing IWA general focuses on containment integrity pressure tests. requirements focuses requirements than the general requirement on issues specific to containment (IWA-5240). Acceptable.
integrity and therefore provides added assurance of the integrity of repaired/replaced areas.
5250 Changed Corrective Measures to Nonsignificant Editorial change has no safety or Corrective Action in the heading. quality significance. Acceptable.
ASME XI generic change from repair and/or replacement to repair/replacement activities.
7100 No change N/A IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination Table 2411-1 No change N/A Table 2412-1 Replaced the separate entries for Nonsignificant - The previous Editorial change has no safety or 1st and successive intervals with requirements for the 1st and quality significance. Acceptable.
one entry for All intervals. successive intervals were identical.
Therefore combining the entries does not affect any requirements.
Changed minimum and maximum Provides more flexibility in This change provides more examination completion scheduling examinations, but flexibility in scheduling percentages and added Note (1) ensures allocation of examinations is examination, but ensures full which states that if the first period done throughout the 10-year examination. Acceptable.
completion percentage for any interval. The IWE change is examination category exceeds consistent with changes made in 34%, at least 16% of required IWB, IWC, IWD, and IWF.
examinations shall be performed in the second period.
Table 2500-1 E1.11 Revised frequency of Removing the requirement to Removing the requirement to Cat. E-A examination from prior to each coordinate examinations with type A coordinate examinations with type type A test to 100% during each tests allows for more efficient A tests allows for more efficient period. containment ISI program containment ISI program implementation without adversely implementation without adversely affecting containment integrity. The affecting containment integrity.
requirement to perform general Also, the requirement to perform visual examinations every inspection general visual examinations every period increases the total number of inspection period increases the examinations on the containment total number of examinations on surface in the interval. the containment surface in the IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination interval. Acceptable.
E1.12 Re-designated item from Replacing the accessible surface accessible surface areas to area designation (which is now wetted surfaces of submerged included in E1.11) with wetted Acceptable with licensees areas. Replaced examination surface areas (which were commitments for general visual method VT-3 with general visual. previously included in E1.12 footnote examination requirements and
- 4) does not eliminate or reduce any acceptance criteria as stated in its required examination areas. The September 7, 2001, submittal.
conditions of distress which would be detected by a VT-3 examination are the same conditions that would be detected by a general visual examination (refer to the evaluation of IWE-2300 above). The requirement to perform a detailed examination on any suspect area has not changed. The new requirement in item E1.11 to perform general visual examinations every inspection period increases the total number of examinations on the containment surface in the interval.
The overall impact of this change is to increase the level of quality and does not adversely affect the safety of the containment inspection program.
IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination E1.20 Added BWR to item This item is not applicable to the N/A description. Replaced examination JAFNPP containment.
method VT-3 with general visual.
E1.30 Added item for moisture Moisture barriers were previously Acceptable with licensees barriers with a general visual included in examination category E- commitments for general visual required each period. D with a VT-3 required each interval. examination requirements and Examining moisture barriers more acceptance criteria as stated in its frequently will assure reliable September 7, 2001, submittal.
detection of conditions adverse to containment integrity.
Nonsignificant - Previously some All item no.s - Replaced reference examination requirements were to IWE-3510 for examination contained in IWE-3500. They now requirements with IWE-2310. exist in IWE-2300 as discussed This is an editorial change.
above. Acceptable.
Welds and bolting were previously Notes - Revised to specifically included in examination categories include welds and bolting as part of E-B, E-F and E-G. Including these the pressure retaining boundary items in the examination category for This is an editorial change.
requiring examination. the containment pressure retaining Acceptable.
boundary provides for more efficient program implementation without adversely affecting component integrity.
IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination Table 2500-1 Pressure retaining welds are now 10 CFR 50.55a makes Deleted examination category Cat. E-B included in examination category containment weld inspections which addressed pressure retaining E-A as addressed above. optional. Acceptable.
Table 2500-1 E4.11 Replaced examination The conditions of distress or Acceptable with licensees Cat. E-C method VT-1 with detailed visual. deterioration which would be commitments for detailed visual detected by a VT-1 are the same examination requirements and conditions that will be detected by acceptance criteria as stated in its the described detailed visual September 7, 2001, submittal.
examination, as discussed in IWE-2300 above.
The added wording clarifies The recommended ultrasonic E4.12 Added grid line intersections inspection requirements and gridline sample requirements to description of parts examined. ensures repeatability in the location provide a more practical approach Changed examination method from of subsequent thickness to augmented container volumetric to ultrasonic thickness. measurement points. examinations. Acceptable.
Previously no references existed for Acceptable.
All item no.s - Added examination examination requirements. These requirement paragraph number requirements have been added to references. Updated references in IWE-2300 and 2500 as discussed Acceptance Standard and Extent above. Adding new references and and Frequency columns. updating paragraph numbers ensure proper requirements are applied to examinations.
IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination Notes - Changed note 2 from Three inspection periods cover a ten Change from three consecutive requiring augmented examination year interval. Performing periods to one period is consistent until an area remains unchanged augmented examinations for at least with the requirements for Class 2 for three consecutive inspection two periods while continuing general components. Acceptable.
periods to the next inspection visual examinations each period period. Deleted note 3 which provides for more efficient program discussed inspection deferrals. implementation without adversely affecting component integrity.
Deletion of note 3 is nonsignificant.
Table 2550-1 Deleted examination category Moisture barriers have been Appendix J, Type A test is Cat. E-D which addressed seals, gaskets included in examination category E- considered sufficient for and moisture barriers. A as addressed above. Seals and determining the leak-tight integrity gaskets previously required of seals and gaskets. Acceptable.
examination once per an interval with effectively an acceptance criteria of leak tightness. Leak tight integrity is verified during each 10 CFR 50 Appendix J leak test.
Removing these inspection items provides for more efficient program implementation without adversely affecting component integrity.
Table 2550-1 Deleted examination category Dissimilar metal welds are now 10 CFR 50.55a makes Cat. E-F which addressed dissimilar metal included in examination category E- containment weld inspections welds. A as addressed above. optional. Acceptable.
IWE Changes between IWE Licensees statement of significance Comments Paragraph 1992 Edition/Addenda. and and/or basis for (1992 Ed.) the 1998 Edition use as an alternative examination Table 2550-1 Deleted examination category Pressure retaining bolting is now 1992 Edition required VT-1 of Cat. E-G which addressed pressure retaining included in examination category E- bolting when a connection is bolting. A as addressed above. disassembled. Licensee has committed to this. Licensees alternative is consistent with staffs guidelines. Acceptable.
Table 2550-1 Deleted examination category Appendix J testing is mandated by Deleting Examination Cat. E-P, Cat. E-P which addressed 10CFR50 plant technical specifications. provides relief to licensee without Appendix J testing for all pressure Removing this duplicate requirement affecting component integrity.
retaining components. from IWE does not adversely affect Appendix J test is already required component integrity. per Technical Specification.
Acceptable.
Added new Table IWE-2500 The new requirements provide for The new requirements provide Ultrasonic Thickness consistency and repeatability in consistency and repeatability in Measurements For Augmented obtaining thickness measurements obtaining thickness measurements Examinations - which details and thus assure the reliable and thus assure the reliable gridline spacing and thickness detection of conditions adverse to detection of conditions adverse to measurement requirements. containment integrity. containment integrity. Acceptable.
Table IWE- Deleted table. Nonsignificant - the contents of the This is an editorial change.
3410-1 previous table are adequately Acceptable.
addressed in IWE-3500.