ML021420364
| ML021420364 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/06/2002 |
| From: | Harden P Nuclear Management Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC MB4216, TAC MB4218 | |
| Download: ML021420364 (36) | |
Text
Committed to Nuclear Excellence Palisades Nuclear Plant Operated by Nuclear Management Company, LLC May 6, 2002 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 DOCKET 50-255 - LICENSE DPR PALISADES NUCLEAR PLANT REQUEST FOR RELIEF FROM ASME CODE REQUIREMENTS FOR CONTAINMENT INSERVICE INSPECTION - CONTAINMENT RELIEF REQUESTS CRR-08 AND CRR-09 ADDITIONAL INFORMATION (TAC Nos. MB4216, MB4218)
Nuclear Management Company, LLC (NMC), requested approval for the subject containment relief requests by letter dated February 21, 2002. Nuclear Regulatory Commission (NRC) staff has requested NMC provide additional information concerning the ASME Boiler and Pressure Vessel (B&PV) Code, Section Xl, Subsections IWE and IWL. The NRC staff has requested that NMC provide detailed comparisons of the 1992 edition including the 1992 addendum, for subsections IWE and IWL, with the 1998 edition. The attached information, presented in tabular form, provides comparisons of each paragraph within both subsections for the 1992 and 1998 editions; the significance of each change on a generic basis; and how NMC proposes to address each change for the Palisades Plant.
SUMMARY
OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.
Paul A. Harden Director, Engineering CC Regional Administrator, USNRC, Region III Project Manager, USNRC, NRR NRC Resident Inspector - Palisades Attachments 27780 Blue Star Memorial Highway 9 Covert, MI 49043 Telephone: 616.764.2000
ATTACHMENT 1 NUCLEAR MANAGEMENT COMPANY PALISADES NUCLEAR PLANT DOCKET 50-255 May 6, 2002 CONTAINMENT RELIEF REQUEST CRR-08 ASME B&PV Code,Section XI Subsection IWE Comparison 20 pages follow
Attachment I Page I of 20 CONTAINMENT RELIEF REQUEST CRR-08 Subsection IWE Comparison IWE Changes Between IWE 1992 Edition with Significance of Change and/or Basis for Paragraph Addenda and IWE 1998 Edition Use as an Alternative Examination NMC Position for Palisades Plant 1100 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
1200 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
1210 No change N/A NMC will meet the requirement specified in ASME Section X1, 1998 Edition.
1220 Changed "containment" to "containment Nonsignificant NMC will meet the requirement system" specified in ASME Section Xl, 1998 Edition.
1230 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
1231 Remove item 3) - "single welded butt joints These single welded butt joints were Examination of welds is optional in from the weld side" - as a specific item removed as a separately listed examination 10 CFR 50.55a required to remain accessible for the life of the item and are now included within the item for plant.
the pressure retaining boundary as discussed in the changes to Table IWE-2500-1 below.
Changed wording from "80% of the surface The exclusions from 80% incorporated an NMC will meet the requirement area" to "80% of the pressure retaining existing Table IWE 2500-1 note and clarify specified in ASME Section X1, 1998 boundary" and stated exclusions from that that areas made inaccessible during Edition.
80%.
construction are also excluded.
Reworded paragraph b).
Change to b) is for clarity and is NMC will meet the requirement nonsignificant.
specified in ASME Section Xl, 1998 Edition.
Attachment I Page 2 of 20 CONTAINMENT RELIEF REQUEST CRR-08 Subsection IWE Comparison IWE Changes Between IWE 1992 Edition with Significance of Change and/or Basis for Paragraph Addenda and IWE 1998 Edition Use as an Alternative Examination NMC Position for Palisades Plant 1232 ASME Xl generic change from repair and/or Nonsignificant NMC will meet the requirement replacement to repair/replacement activities, specified in ASME Section Xl, 1998 Edition.
Deleted paragraph (a)(3) addressing Welded joints were removed as a separately Examination of welds is optional in inaccessible welded joints, listed examination items and are now 10CFR50.55a.
included within the item for the pressure retaining boundary as discussed in the changes to Table IWE-2500-1 below.
1240 No change N/A NMC will meet the requirement specified in ASME Section XI, 1998 Edition.
1241 Added stiffeners and, by reference to Clarifies the intent of the Code that areas NMC will meet the requirement IWE-2420, flaws accepted by evaluation as identified in IWE-2420(b) require an specified in ASME Section Xl, 1998 areas requiring augmented examination, augmented exam in the next period.
Edition.
1242 Changed IWE-2500(c) to IWE-2500(b)
Nonsignificant NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
2000 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
2100 Added new Subarticle 2100, "General" to The containment examinations are The NMC Containment Inspection provide reference to IWA-2000 with exceptions completely defined within the jurisdiction of Program will specify the requirements from IWA-2210, 2300, 2500 and 2600.
IWE, and thus reference to IWA-2210, and for personnel certification in IWA-2300 are not applicable, accordance with CP-1 89 and SNT-TC-1A.
The exceptions to IWA-2500, and IWA-2600 NMC will meet the requirement are to weld base exams that do not apply to specified in ASME Section XI, 1998 IWE. The examinations in the 1998 Edition Edition.
provide acceptable level of quality and safety as defined in IWE of the 1992 Edition.
Page 3 of 20 CONTAINMENT RELIEF REQUEST CRR-08 Subsection IWE Comparison IWE Changes Between IWE 1992 Edition with Significance of Change andlor Basis for Paragraph Addenda and IWE 1998 Edition Use as an Alternative Examination NMC Position for Palisades Plant 2200 Deleted paragraph c) which provided The deletion of an allowance for an NMC will meet the requirement allowances for the use of shop or field alternative examination ensures that proper specified in ASME Section Xl, 1998 examinations in lieu of on site preservice preservice examinations are performed and Edition.
examinations.
documented Deleted paragraph g) which required the The deletion of the requirement to document The NMC work order process requires condition of new coating to be documented in the condition of "new" non-pressure retaining notification of Responsible the preservice examination record.
coatings in the preservice examination Engineer (RE) who will ensure record provides for more efficient program thorough ISI and PSI examinations of implementation without affecting component containment surface including integrity, condition of base metal.
ASME Xl generic change from repair and/or Nonsignificant.
NMC will meet the requirement replacement to repair/replacement activities.
specified in ASME Section Xl, 1998 Edition.
2300 Added new Subarticle 2300, Visual Examination, Personnel Qualification and NMC has submitted (in letter dated Examination, Personnel Qualification and Responsible Individual" The philosophy of February 21, 2002) specific details Responsible Individual.
IWE to be an engineering inspection under regarding Visual Examination, the direction of the Responsible Individual is Personnel Qualification and contained in this new sub-article. The most Responsible Individual.
significant change is the definition of the roles and responsibilities of the Responsible Individual. This individual will be accountable for the entire inspection program which will meet or exceed the level of quality and safety defined in the 1992 Edition.
Page 4 of 20 CONTAINMENT RELIEF REQUEST CRR-08 Subsection IWE Comparison IWE Changes Between IWE 1992 Edition with Significance of Change andlor Basis for NMC Position for Palisades Plant Paragraph Addenda and IWE 1998 Edition Use as an Alternative Examination Added new paragraph 2310-Visual Examinations, which states:
a) the owner shall define requirements for visual examination of containment surfaces.
b) defines general examinations.
a) The VT-3 and VT-1 inspections of IWA have been replaced by Responsible Individual defined general and detailed visual exams, respectively. The definition of critical examination items and acceptable conditions has not changed, such that any conditions adversely affecting quality or safety are not impacted by this change.
b) The general visual examination is equivalent to the VT-3 exam in terms of assessing the general condition and potential for deterioration within the containment system. The use of owner defined inspection types allows for the involvement of qualified engineering personnel with backgrounds in programs such as the Maintenance Rule, containment coatings, and Appendix J. This provides for a containment inspection program that is performed by individuals with knowledge in containment degradation mechanisms.
.1.
1 NMC has submitted (in letter dated February 21, 2002) specific details regarding Visual Examination, Personnel Qualification and Responsible Individual.
NMC has submitted(in letter dated February 21, 2002) specific details regarding Visual Examination, Personnel Qualification and Responsible Individual.
2310
Attachment I Page 5 of 20 CONTAINMENT RELIEF REQUEST CRR-08 Subsection IWE Comparison IWE Changes Between IWE 1992 Edition with Significance of Change andlor Basis for NMC Position for Palisades Plant Paragraph Addenda and IWE 1998 Edition Use as an Alternative Examination T
--
c) defines detailed visual examinations.
d) and e) provide the requirements for the conditions of areas affected by repair/replacement activities, painted or coated areas, non coated areas.
c) The detailed visual examination is equivalent to the VT-1 exam in terms of assessing the general condition and potential for deterioration within the containment system. The use of owner defined inspection types allows for the involvement of qualified engineering personnel with backgrounds in programs such as the Maintenance Rule, containment coatings, and Appendix J. This provides for a containment inspection program that is performed by individuals with knowledge in containment degradation mechanisms.
-. 4.--
4 d) and e) Previously these examination requirements did not exist within the Article IWE-2000 but were contained in the acceptance criteria of Article IWE-3000.
Adding these specific attributes here ensures proper containment examinations.
There are no acceptance criteria specified since the proposal maintains owner defined examination requirements.
NMC has submitted(in letter dated February 21, 2002) specific details regarding Visual Examination, Personnel Qualification and Responsible Individual.
NMC has provided(in letter dated February 21, 2002) specific details regarding acceptance criteria for general and detailed visual examinations.
I I
2Z310 (.cont.)
Page 6 of 20 CONTAINMENT RELIEF REQUEST CRR-08 Subsection IWE Comparison IWE Changes Between IWE 1992 Edition with Significance of Change and/or Basis for Paragraph Addenda and IWE 1998 Edition Use as an Alternative Examination NMC Position for Palisades Plant 2320 Added new paragraph 2320 - "Responsible The qualifications along with the roles and Individual" - which a) states the qualification responsibilities of the Responsible Individual NMC will meet the requirement requirements of the Responsible Individual are clearly delineated within this sub-article, specified in ASME Section Xl, 1998 and This section clearly states the expectations Edition as interpreted by XI-1-98-31.
for the Responsible Individual, and brings accountability for the entire program to an individual knowledgeable in containments b) defines the responsibilities of the and their degradation mechanisms. This NMC will meet the requirement Responsible Individual for the development of individual will develop the inspection plans, specified in ASME Section Xl, 1998 plans and procedures; instruction, training and train personnel, direct or perform Edition as interpreted by XI-1-98-31.
approval of visual examination personnel; inspections, and finally evaluate the results.
performance or direction of visual The cohesiveness of the inspection program examinations; evaluation of results and has been improved by the addition of this documenting results.
sub-article, resulting in an increase of the level of quality and thus no adverse impact on safety.
2330 Added new paragraph 2330 - "Personnel Adding requirements for the owner to define NMC has submitted(in letter dated Qualification" -which a) states that the owner is personnel qualification requirements is February 21, 2002) specific details responsible for defining the qualification consistent with the philosophy that the regarding Visual Examination, requirements for personnel performing visual Responsible Individual must qualify the Personnel Qualification and examinations and inspection personnel. The code recognizes Responsible Individual.
that the qualifications may differ depending on the containment type and even the inspection period in question. This change is b) provides minimum qualification consistent with the other changes discussed 10 CFR 50.55a(b)(x)(B) requires the requirements that were previously contained in above and serves to improve the level of qualification of remote visual the acceptance criteria of IWE-3510.1.
quality and thus has no adverse impact on examinations.
safety.
NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
2400 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
Attachment I Page 7 of 20 CONTAINMENT RELIEF REQUEST CRR-08 Subsection IWE Comparison IWE Changes Between IWE 1992 Edition with Significance of Change andlor Basis for Paragraph Addenda and IWE 1998 Edition Use as an Alternative Examination NMC Position for Palisades Plant 2410 No change N/A NMC will meet the requirement specified in ASME Section X1, 1998 Edition.
2411 Deleted a subparagraph (b) discussing The deleted paragraph eliminates NMC will meet the requirement decreasing and extending inspection periods, duplication with IWA-2400.
specified in ASME Section X1, 1998 Edition.
2412 Deleted a subparagraph discussing The deleted subparagraph eliminates NMC will meet the requirement decreasing and extending inspection periods, duplication with I WA-2400. The added specified in ASME Section Xl, 1998 Added a subparagraph detailing requirements requirements for the scheduling of added Edition.
for the scheduling of added welds or welds or components was added prior to the components.
1998 Edition rewrite of Subsection IWE and is of marginal value with the 1998 revisions to Table IWE-2500-1.
2420 Revised (b) to remove repaired areas as areas Repaired areas that are likely to experience requiring reexaminations during the next accelerated degradation and aging are NMC will meet the requirement successive inspection period, already subject to augmented examinations specified in ASME Section Xl, 1998 per IWE-1241. Some repairs may be Edition.
located in non-augmented areas and may be necessary to correct physical damage caused by construction or craft activities.
Changing duration of reexamination of areas that remain essentially unchanged from "three consecutive inspection periods" to "the next successive inspection period" is consistent with the requirements for Class 2 components.
2420 Changed (c) to require that areas that remain The evaluation that determines that flaws or essentially unchanged for the next inspection areas of degradation remain unchanged is period no longer require augmented sufficient to conclude that there are no active examinations. The 1992 Addenda required corrosion mechanisms present.
three consecutive examinations to reach this conclusion.
Page 8 of 20 CONTAINMENT RELIEF REQUEST CRR-08 Subsection IWE Comparison IWE Changes Between IWE 1992 Edition with Significance of Change and/or Basis for Paragraph Addenda and IWE 1998 Edition Use as an Alternative Examination NMC Position for Palisades Plant 2430 Deleted the paragraph - Additional The changes to Table IWE-2500-1 eliminate NMC will meet the requirement Examinations - that discussed adding several examination categories. The specified in ASME Section XI, 1998 examinations items of the same category if categories that remain all require 100%
Edition.
flaws or areas of degradation are identified examination. Therefore no items are during an examination, available for additional examination.
2500 Reworded the existing subparagraphs The reworded subparagraphs add clarity and NMC will meet the requirement consistent with the previous paragraph provide consistency.
specified in ASME Section XI, 1998 changes and with Table IWE-2500- I changes.
Edition.
Page 9 of 20 CONTAINMENT RELIEF REQUEST CRR-08 Subsection IWE Comparison IWE Changes Between IWE 1992 Edition with Significance of Change and/or Basis for Paragraph Addenda and IWE 1998 Edition Use as an Alternative Examination NMC Position for Palisades Plant 2500 (cont.)
Deleted the requirement to examine paint or The Codes jurisdiction is the pressure NMC has provided(in letter dated coatings prior to removal, retaining boundary, and not the non-February 21, 2002) details regarding pressure retaining coatings. Eliminating this base metal examinations.
requirement does not adversely impact the level of quality or the safety of the containment inspection program. The 1998 Edition increases the frequency of examination when compared to the 1992 Addenda. During examinations, the general and detailed visual examinations of coated areas will identify flaws and degradation in the containment base metal and result in appropriate corrective actions per the Code requirements. Should a coating be removed between inservice inspections, the Responsible Individual shall 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. This deletion provides for a more efficient program implementation without affecting component integrity.
Replaced the requirement for one foot square The new Table IWE-2500-2 provides more NMC will meet the requirement grids in thickness measurements with a detailed requirements for thickness specified in ASME Section XI, 1998 reference to Table IWE-2500-2.
measurement grids.
Edition.
Added a reference to IWE-5000 for pressure The added reference to IWE-5000 provides NMC will meet the requirement tests.
direction for the performance of pressure specified in ASME Section Xl, 1998 test.
Edition.
2600 Deleted a sentence discussing compatibility of The jurisdiction of the code does not include NMC will meet the requirement paint and coating systems and a requirement the quality and compatibility of containment specified in ASME Section Xl, 1998 to examine the new paint, coating systems. This change has no impact Edition.
on the scope of IWE inspections.
Attachment I Page 10 of 20 CONTAINMENT RELIEF REQUEST CRR-08 Subsection IWE Comparison IWE Changes Between IWE 1992 Edition with Significance of Change and/or Basis for Paragraph Addenda and IWE 1998 Edition Use as an Alternative Examination NMC Position for Palisades Plant 3100 Remove the word nondestructive from the Non-significant Consistent with IWB and NMC will meet the requirement heading.
IWC wording.
specified in ASME Section Xl, 1998 Edition.
3110 No change N/A NMC will meet the requirement specified in ASME Section XI, 1998 Edition.
3111 Replaced the reference to Table IWE-341 0-1 Table IWE-3410-1 and paragraph IWE-3115 NMC will meet the requirement with a reference to subarticle IWE-3500.
have been deleted and are discussed below, specified in ASME Section Xl, 1998 Removed reference to paragraph IWE-3115.
IWE-3500 adequately captures all of the Edition.
information previously contained in the deleted table and paragraph.
3112 Replaced the reference to Table IWE-3410-1 Nonsignificant NMC will meet the requirement with a reference to subarticle IWE-3500.
specified in ASME Section X1, 1998 ASME Xl generic change from repair and or Edition.
replacement to repair/replacement activities.
3114 Replaced the reference to Table IWE-3410-1 Nonsignificant NMC will meet the requirement with a reference to subarticle IWE-3500.
specified in ASME Section X1, 1998 ASME XI generic change from repair and/or Edition.
replacement to repair/replacement activities.
3115 Deleted subparagraph that addressed repair Nonsignificant - there were no submittal or NMC will meet the requirement programs and evaluations being subject to retention requirements changed by the specified in ASME Section Xl, 1998 review by authorities, deletion of the subparagraph.
Edition.
3120 Removed the word nondestructive from the Non-significant. Consistent with IWB and NMC will meet the requirement heading.
IWC.
specified in ASME Section XI, 1998 Edition.
3121 Removed the word nondestructive and deleted The removal of nondestructive is NMC will meet the requirement references to IWE-3124 and IWE-3125 for the nonsignificant. The referenced specified in ASME Section X1, 1998 acceptance of flaws for continued service.
subparagraphs did not actually apply to the Edition.
acceptance of flaws for continued service.
Attachment I Page 11 of 20 CONTAINMENT RELIEF REQUEST CRR-08 Subsection IWE Comparison IWE Changes Between IWE 1992 Edition with Significance of Change and/or Basis for Paragraph Addenda and IWE 1998 Edition Use as an Alternative Examination NMC Position for Palisades Plant 3122 Replaced the references to Table IWE-2500-1 Nonsignificant - the changes are for clarity NMC will meet the requirement and to IWE-3000 with a reference to subarticle and to reconcile paragraph numbering, specified in ASME Section Xl, 1998 IWE-3500. ASME Xl generic change from There were no submittal or retention Edition.
repair and/or replacement to requirements changed by the deletion of the repair/replacement activities. Reworded sentence addressing evaluation reviews.
several sentences. Deleted sentence that addressed evaluations being subject to review Consistent with IWB and IWC.
by authorities.
3124 Replaced the reference to Table IWE-3410-1 Nonsignificant NMC will meet the requirement with a reference to subarticle IWE-3500.
specified in ASME Section Xl, 1998 ASME Xl generic change from repair and/or Edition.
replacement to repair/replacement activities.
3125 Deleted subparagraph which addressed repair Nonsignificant - there were no submittal or NMC will meet the requirement programs and reexamination results being retention requirements changed by the specified in ASME Section Xl, 1998 subject to review by authorities, deletion of the subparagraph.
Edition.
3130 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
3200 Added a statement to the end of the paragraph The added statement clarifies requirements NMC will meet the requirement that states supplemental surface or volumetric and eliminates potential duplication or specified in ASME Section Xl, 1998 examinations are required when specified by contradiction of requirements in stating that Edition.
the engineering evaluation, the engineering evaluation requirements of IWE-3122 determine what and when supplemental examinations are required.
3410 Replace the reference to Nonsignificant NMC will meet the requirement Table IWL-3410-1 with a reference to specified in ASME Section Xl, 1998 subarticle IWE-3500-1.
Edition.
3430 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
3500 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
Attachment I Page 12 of 20 CONTAINMENT RELIEF REQUEST CRR-08 Subsection IWE Comparison IWE Changes Between IWE 1992 Edition with Significance of Change and/or Basis for NMC Position for Palisades Plant Paragraph Addenda and IWE 1998 Edition Use as an Alternative Examination 3510 Reconciled acceptance standards with the Previously examination requirements were NMC has provided(in letter dated IWE-2300 changes discussed above and the contained in the acceptance standards of February 21, 2002) specific details Table IWE-2500- 1 changes discussed below IWE-3500. This has been corrected by the regarding visual examination by:
addition of IWE-2300 as discussed above.
acceptance standards.
Adding the requirement that the owner shall This change directly corresponds to the define acceptance criteria for visual addition of IWE-231 0 (a).
examination of containment surfaces; Removing the wording for Responsible This change directly corresponds to the NMC will meet the requirement individual and for personnel qualifications; addition of IWE-2320.
specified in ASME Section XI, 1998 Combining 3510.2 and 3510.3 and removing Edition.
specific VT-1 and VT-3 examination attribute wording; and Incorporating IWE-3511, 3513, 3514 and 3515 These changes correspond to the changes NMC will meet the requirement with changes into IWE-3510.
in the examination categories of Table specified in ASME Section Xl, 1998 IWE-2500-1 and to the removal of Edition.
examination standards paragraphs per the addition of IWE-2310 (e)(3) and (4).
By the incorporation of IWE-3515 the The resulting acceptance standards for NMC will meet the requirement acceptance standards for bolting were bolting provide for more practical specified in ASME Section Xl, 1998 changes from referencing material specs and containment ISI program implementation Edition.
torque or tension limits to conditions affecting without adversely affecting containment leak leak tight or structural integrity, tight or structural integrity.
The Appendix J testing is considered sufficient for determining the leak-tight integrity of the penetration.
3511 Deleted subparagraph that addressed Examination category E-B has been NMC will apply the Class MC examination category E-B.
incorporated into examination category E-A acceptance criteria to Class CC liners.
per the changes to Table IWE-2500-1.
Page 13 of 20 CONTAINMENT RELIEF REQUEST CRR-08 Subsection IWE Comparison IWE Changes Between IWE 1992 Edition with Significance of Change and/or Basis for NMC Position for Palisades Plant Paragraph Addenda and IWE 1998 Edition Use as an Alternative Examination 3512 Renumbered subparagraph to IWE-351 1.
The subparagraph was renumbered based NMC will meet the requirement Reconciled acceptance standards with the on the deletion of previous IWE-351 1 as specified in ASME Section Xl, 1998 IWE-2300 changes discussed above and the discussed above. Previously examination Edition.
Table IWE-2500-1 changes discussed below requirements were contained in the acceptance standards of IWE-3500. This has been corrected by the addition of IWE-2300. This change is based on Regulatory requirements excluding containment welds, and the elimination of any direct references to containment weld examinations in the Code.
Added the requirement that the owner shall This change directly corresponds to the NMC will meet the requirement define acceptance criteria for visual addition of IWE-2310 (a).
specified in ASME Section Xl, 1998 examination of containment surfaces; Edition.
Combined 3512.2 and 3512.3 with changes These changes directly correspond to the NMC will meet the requirement into 3511.2 and removed specific VT-1 addition of IWE-2310 (e)(1) and (2) and specified in ASME Section XI, 1998 examination attribute wording; and eliminate potential duplication or Edition.
contradiction of requirements.
Reworded ultrasonic examination This change eliminates the need to perform NMC will apply the provisions of subparagraph and limited the UT to Class MC the UT examination on metallic liners of IWE-3511.3 to both Class MC components.
Class CC components.
components and metallic liners of Class CC components.
Attachment I Page 14 of 20 CONTAINMENT RELIEF REQUEST CRR-08 Subsection IWE Comparison IWE Changes Between IWE 1992 Edition with Significance of Change and/or Basis for P
Paragraph Addenda and IWE 1998 Edition Use as an Alternative Examination NMC Position for Palisades Plant 3513 Deleted subparagraph IWE-3513 that Examination category E-D has been NMC will meet the requirement addressed examination category E-D.
incorporated into examination category E-A specified in ASME Section Xl, 1998 per the changes to Table IWE-2500-1.
Edition.
3514 Deleted subparagraph IWE-3514 that Examination category E-F has been NMC will meet the requirement addressed examination category E-F.
incorporated into examination category E-A specified in ASME Section Xl, 1998 per the changes to Table IWE-2500-1.
Edition.
3515 Deleted subparagraph IWE-3515 that Examination category E-G has been NMC will meet the requirement addressed examination category E-G.
incorporated into examination category E-A specified in ASME Section Xl, 1998 per the changes to Table IWE-2500-1.
Edition.
4100 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
5200 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
5210 No change N/A NMC will meet the requirement specified in ASME Section X1, 1998 Edition.
Attachment I Page 15 of 20 CONTAINMENT RELIEF REQUEST CRR-08 Subsection IWE Comparison IWE Changes Between IWE 1992 Edition with Significance of Change and/or Basis for NMC Position for Palisades Plant Paragraph Addenda and IWE 1998 Edition Use as an Alternative Examination 5220 ASME XI generic change from repair and/or Nonsignificant NMC will meet the requirement replacement to repair/replacement activities.
specified in ASME Section XI, 1998 Edition.
5221 Removed the quote from 10 CFR 50, Nonsignificant - the requirement to meet the NMC will meet the requirement Appendix J.
requirements of the Appendix J paragraph specified in ASME Section XI, 1998 referenced is not affected by removing the Edition.
quoted Appendix J paragraph.
5222 ASME XI generic change from repair and/or Nonsignificant NMC will meet the requirement replacement to repair/replacement activities.
specified in ASME Section X1, 1998 Edition.
Changed word "repair" to "weld."
Added (DN25)
DN25 is a standard measurement identification.
5240 Replaced a reference to IWA-5240 with The types of examinations performed in the NMC will meet the requirement requirements to perform detailed visual containment program are all contained in specified in ASME Section XI, 1998 examination of repair/replacement areas IWE-2300. The requirements of IWA-5240 to Edition.
during pressure tests.
detect evidence of leakage will be satisfied through the use of the detailed visual examination of IWE-2300.
5250 Changed Corrective Measures to Corrective Nonsignificant NMC will meet the requirement Action in the heading. ASME XI generic specified in ASME Section XI, 1998 change from repair and/or replacement to Edition.
repair/replacement activities.
7100 No change N/A NMC will meet the requirement specified in ASME Section X1, 1998 Edition.
Table 2411-1 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
Attachment I Page 16 of 20 CONTAINMENT RELIEF REQUEST CRR-08 Subsection IWE Comparison IWE Changes Between IWE 1992 Edition with Significance of Change and/or Basis for Paragraph Addenda and IWE 1998 Edition Use as an Alternative Examination NMC Position for Palisades Plant Table 2412-1 Replaced the separate entries for 1s and Nonsignificant - The previous requirements NMC will meet the requirement successive intervals with one entry for all for the Ist and successive intervals ere specified in ASM E Section Xl, 1998 intervals, identical. Therefore, combining the entries Edition.
does not affect any requirements.
Added Note (1) that states that if the first Ensures allocations of examinations are NMC will meet the requirement period completion percentage for any done throughout the 10-year interval. The specified in ASME Section Xl, 1998 examination category exceeds 34%, at least IWE change is consistent with changes Edition.
16% of required examination shall be made in IWB, IWC, IWD and IWF.
performed in the second period.
Table 2500-1, El. 11 Revised frequency of examination from Removing the requirement to coordinate NMC will meet the requirement Cat. E-A "prior to each type A test" to "100% during examinations with type A tests, and requiring specified in ASME Section Xl, 1998 each period."
a general visual every inspection period is Edition.
more restrictive. This change corresponds with the rule as stated in 10 CFR 50.55a.
Appendix J, Option A, requires periodic (one each period) Type A tests. Appendix J, Option B, is based on historical performance and requires periodic visual inspection for Type A tests.
Attachment I Page 17 of 20 CONTAINMENT RELIEF REQUEST CRR-08 Subsection IWE Comparison IWE Changes Between IWE 1992 Edition with Significance of Change and/or Basis for NMC Position for Palisades Plant Paragraph Addenda and IWE 1998 Edition Use as an Alternative Examination Table 2500-1, E1.12 Redesignated item from "accessible Replacing the accessible surface area NMC will meet the requirement Cat. E-A surface areas" to "wetted surfaces of designation (which is now included in E1.1 1) specified in ASME Section Xl, 1998 (cont.)
submerged areas." Replaced examination with wetted surface areas (which were Edition.
method VT-3 with general visual, previously included in El.12, footnote 4) does not eliminate or reduce any required examination areas. The condition of distress that would be detected by a VT-3 examination is 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 El.11 to perform general visual examinations every inspection period increases the total number of examination 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.
E1.20 Added BWR to item description.
This change has no impact on the level of This item is not applicable to the Replaced examination method VT-3 with quality or the safety of the containment Palisades' containment.
general visual.
inspection program.
Attachment I Page 18 of 20 CONTAINMENT RELIEF REQUEST CRR-08 Subsection IWE Comparison IWE Changes Between IWE 1992 Edition with Significance of Change and/or Basis for Paragraph Addenda and IWE 1998 Edition Use as an Alternative Examination NMC Position for Palisades Plant Table 2500-1, E1.30 Added item for moisture barriers with a Moisture barriers were previously included in NMC will meet the requirement Cat. E-A general VT required each period, examination category E-D with a VT-3 specified in ASME Section XI, 1998 (cont.)
required each interval. Examining moisture Edition.
barriers more frequently will assure reliable detection of conditions adverse to quality.
All item numbers - Replaced reference to Nonsignificant - Previously, some NMC will meet the requirement IWE-3510 for examination requirements with examination requirements were contained in specified in ASME Section XI, 1998 IWE-2310.
IWE-3500. They now exist in IWE-2300 as Edition.
discussed above.
Notes - Revised to specifically include welds Welds and bolting were previously included NMC has provided(in letter dated and bolting as part of the pressure-retaining in examination categories E-B, E-F and E-G.
February 21, 2002) additional boundary requiring examination.
Including these items in the examination information regarding general visual category for the containment pressure-examinations.
retaining boundary provides more efficient program implementation without adversely affecting component integrity.
Table 2500-1 Deleted examination category that addressed Pressure retaining welds are now included in NMC will meet the requirement Cat. E-B pressure-retaining welds.
examination category E-A. 10 CFR 50.55a specified in ASME Section XI, 1998 makes containment weld inspections Edition.
optional.
Attachment I Page 19 of 20 CONTAINMENT RELIEF REQUEST CRR-08 Subsection IWE Comparison IWE Changes Between IWE 1992 Edition with Significance of Change andlor Basis for P
Paragraph Addenda and IWE 1998 Edition Use as an Alternative Examination NMC Position for Palisades Plant Table 2500-1 E4.11 Replaced examination method VT-1 The conditions of distress or deterioration NMC has provided(in letter dated Cat. E-C with detailed visual, that would be detected by a VT-1 are the February 21, 2002) additional details same conditions that will be detected by the regarding detailed visual verses VT-1 detailed visual examination, as defined in examinations.
IWE-2300.
E4.12 Added grid line intersections to The added wording clarifies inspection NMC will meet the requirement description of parts examined. Changed requirements and ensures repeatability in specified in ASME Section Xl, 1998 examination method from volumetric to the location of subsequent thickness Edition.
ultrasonic thickness.
measurement points.
All item no.'s - Added examination requirement Previously, no references existed for NMC will meet the requirement paragraph number references. Updated examination requirements. These specified in ASME Section Xl, 1998 references in Acceptance Standard and Extent requirements have been added to IWE-2300 Edition.
and Frequency columns.
and 2500 as discussed above. Adding new references and updating paragraph numbers ensure proper requirements are applied to examinations.
Notes - Changed note 2 from requiring Three inspection periods cover a ten-year NMC will meet the requirement augmented examination until an area remains interval. Performing augmented specified in ASME Section Xl, 1998 unchanged for three consecutive inspection examinations for at least two periods while Edition.
periods to the next inspection period. Deleted continuing general visual examinations each note 3 which discussed inspection deferrals.
period provides for more efficient program implementation without adversely affecting component integrity. Deletion of note 3 is non-significant. Change from three consecutive periods to one period is consistent with the requirements for class 2 components.
Attachment I Page 20 of 20 CONTAINMENT RELIEF REQUEST CRR-08 Subsection IWE Comparison IWE Changes Between IWE 1992 Edition with Significance of Change andlor Basis for Paragraph Addenda and IWE 1998 Edition Use as an Alternative Examination NMC Position for Palisades Plant Table 2500-1 Deleted examination category that addressed Moisture barriers have been included in NMC will meet the requirement Cat. E-D seals, gaskets and moisture barriers, examination category E-A as addressed specified in ASME Section Xl, 1998 above. Seals and gaskets previously Edition.
required examination once per an interval with effectively an acceptance criterion of leak tightness. Leak tight integrity is verified during each 10 CFR 50, Appendix J leak test.
Table 2500-1 Deleted examination category that addressed Dissimilar metal welds are now included in NMC will meet the requirement Cat. E-F dissimilar metal welds.
examination category E-A.
specified in ASME Section Xl, 1998 Edition.
Table 2500-1 Deleted examination category that addressed Pressure retaining bolting is now included in NMC has provided(in letter dated Cat. E-G pressure-retaining bolting.
examination category E-A.
February 21, 2002) additional information regarding inspection of 1992 required VT-1 visual of bolting when a bolted connections when connection is connection was disassembled. The 1998 disassembled.
Edition requires general visual, in place, with no requirement when the joint is disassembled.
Table 2500-1 Deleted examination category that addressed Appendix J testing is mandated by plant NMC will meet the requirement Cat. E-P 10 CFR 50, Appendix J testing for all pressure technical specifications. Removing this specified in ASME Section Xl, 1998 retaining components.
duplicate requirement from IWE does not Edition.
adversely affect component integrity.
Table IWE-Added new Table IWE-2500 Ultrasonic The new requirements provide for NMC will meet the requirement 2500-2 Thickness Measurement For Augmented consistency and repeatability in obtaining specified in ASME Section Xl, 1998 Examinations - which details gridline spacing thickness measurements and assure the Edition.
and thickness measurement requirements.
reliable detection of conditions adverse to containment integrity.
Table Deleted Table Nonsignificant - the contents of the previous NMC will meet the requirement IWE-341 0-1 table are adequately included in IWE-3500.
specified in ASME Section Xl, 1998
___________________________EditiEdiion
ATTACHMENT 2 NUCLEAR MANAGEMENT COMPANY PALISADES NUCLEAR PLANT DOCKET 50-255 May 6, 2002 CONTAINMENT RELIEF REQUEST CRR-09 ASME B&PV Code,Section XI Subsection IWL Comparison 13 pages follow Page 1 of 13 CONTAINMENT RELIEF REQUEST CRR-09 Subsection IWL Comparison IWL Changes Between IWL 1992 Edition with Significance of Change and/or Basis for Paragraph Addenda and IWL 1998 Edition Use as an Alternative Examination NMC Position for Palisades Plant 1100 ASME Section Xl generic wording change from Nonsignificant NMC will meet the requirement repair, replacement and/or modification terms to specified in ASME Section Xl, 1998 repair/replacement activities.
Edition.
1200 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
1210 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
1220 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
2100 Changed "Inspection" to "General" in heading.
Nonsignificant NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
Provided reference to IWA-2000 with exceptions The additional general requirements invoked The NMC Containment Inspection from IWA-2210 and 2300 for visual examinations by reference to IWA-2000 where none were Program will specify the requirements and for qualification of visual examination referenced previously further assure for personnel certification in personnel.
containment integrity. The exceptions from accordance with CP-189 and IWA-2210 and IWA-2300 are significant in SNT-TC-1A.
that the related previous requirements have been changed and incorporated into IWL-2310.
(b) Provided requirements for Authorized Inspector responsibilities addressed Nuclear Inservice Inspectors.
I in IWA.
Page 2 of 13 CONTAINMENT RELIEF REQUEST CRR-09 Subsection IWL Comparison IWL Changes Between IWL 1992 Edition with Significance of Change and/or Basis for NMC Position for Palisades Plant Paragraph Addenda and IWL 1998 Edition Use as an Alternative Examination 2200 Deleted reference to IWL-2500.
The reference to IWL-2500 in the 1992 NMC will meet the requirement Addenda was incorrect. The preservice specified in ASME Section Xl, 1998 examination requirements were always to be Edition.
performed in accordance with IWL-2210, IWL-2220 and IWL-2230. This is a nonsignificant change associated with a subsequent inquiry.
2210 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
2220 No change N/A NMC will meet the requirement specified in ASME Section X1, 1998 Edition.
2230 ASME Section Xl generic change from repair Nonsignificant NMC will meet the requirement and/or replacement to repair/replacement specified in ASME Section XI, 1998 activities.
Edition.
2300 No change; content changes in IWL-231 0.
The philosophy of Subsection IWL to be an NMC will meet the requirement engineering inspection program under the specified in ASME Section XI, 1998 direction of the Responsible Individual is Edition.
contained in this revised subarticle. This individual will be accountable for the entire inspection program that will meet or exceed the level of quality and safety defined in the 1992 Edition.
Page 3 of 13 CONTAINMENT RELIEF REQUEST CRR-09 Subsection IWL Comparison IWL Changes Between IWL 1992 Edition with Significance of Change andlor Basis for Paragraph Addenda and IWL 1998 Edition Use as an Alternative Examination NMC Position for Palisades Plant (a) replaced VT-1 C and VT-3C visual examination terminology with new general visual and detailed visual examination terms.
a) The VT-3C and VT-1 C inspections of IWL have been replaced by Owner (Responsible Individual) defined general and detailed visual examinations, respectively. The definition of critical examination items and acceptable conditions has not changed Therefore; any conditions adversely affecting quality or safety are not impacted by this change.
The general and detailed visual examinations are equivalent to the VT-3C and VT-IC examinations in terms of assessing the general condition and potential for deterioration within the containment system.
(b) Eliminated reference to IWA-221 0 for b) Direct visual examination is not practical on NMC has submitted (in letter dated illumination levels, examination distances and all areas of containment surfaces. The February 21, 2002) specific details resolution requirements.
previous VT requirements precluded the regarding Visual Examination.
ability to demonstrate that remote visual examination was equivalent to direct visual examination. Providing examination attributes in IWL as opposed to referencing the generic requirements of IWA focuses the visual examination on areas important to the verification of containment integrity.
(c) Replaced reference to IWA-2300 for concrete (c) Requiring an owner defined program NMC has submitted(in letter dated examination personnel qualification provides for more efficient program February 21, 2002) specific details requirements with provisions for the Owner to implementation by permitting personnel regarding Qualifications.
define the examination personnel qualification performing containment examinations to be requirements.
qualified to written practices that are more consistent to those used for other NDE personnel.
(d) Added requirement for the Owner to define requirements for visual examination of tendon anchorage hardware, wires or strands.
d). Examination of wires or strands are performed by qualified subcontract quality control personnel as part of a tendon surveillance inspection contract. The examinations meet the requirements of IWL-2523.2.
NMC has submitted (in letter dated February 21, 2002) specific details regarding Visual Examinations.
2310 Page 4 of 13 CONTAINMENT RELIEF REQUEST CRR-09 Subsection IWL Comparison IWL Changes Between IWL 1992 Edition with Significance of Change and/or Basis for Paragraph Addenda and IWL 1998 Edition Use as an Alternative Examination NMC Position for Palisades Plant 2320 Changed wording slightly, Nonsignificant - clarifies wording.
NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
Made the ASME Section Xl generic change from Nonsignificant NMC will meet the requirement repair and/or replacement to repair/replacement specified in ASME Section Xl, 1998 activities.
Edition.
Added a responsibility for the Responsible The added pressure test responsibilities for NMC will meet the requirement Individual to review certain pressure test the Responsible Individual ensures proper specified in ASME Section Xl, 1998 procedures.
performance of pressure testing activities.
Edition.
2400 No change N/A NMC will meet the requirement specified in ASME Section XI, 1998 Edition.
2410 Added to (c) a condition that allows for deferral This change ensures that all surfaces that NMC will meet the requirement of concrete visual examinations to the next can be inspected are examined, but specified in ASME Section Xl, 1998 scheduled plant outage for inaccessible portions recognizes the personnel safety of the Edition.
of concrete surface.
inspectors.
2420 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
2421 Changed wording for sites with more than one NMC is a single unit site. Change clarifies NMC will meet the requirement plant. Changed frequencies by adding "and wording and accommodates plant life specified in ASME Section Xl, 1998 every 10 years thereafter."
extension.
Edition.
2500 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
Page 5 of 13 CONTAINMENT RELIEF REQUEST CRR-09 Subsection IWL Comparison IWL Changes Between IWL 1992 Edition with Significance of Change and/or Basis for NMC Position for Palisades Plant Paragraph Addenda and IWL 1998 Edition Use as an Alternative Examination 2510 Changed heading. Changed wording consistent Nonsignificant NMC will meet the requirement with the changes to IWL-2310 addressed above, specified in ASME Section Xl, 1998 Edition.
In (a), eliminated the reference to the specific This is an editorial change for consistency in NMC will meet the requirement revision (R-68) of ACI-201.1.
the Code. The revision of referenced specified in ASME Section Xl, 1998 documents are contained in Table Edition.
IWA-1600-1 which still requires the same revision as specified in the 1992 Addenda.
Adds the requirement to (b) that the Responsible Increases the level of quality and safety of the NMC will meet the requirement Engineer will designate areas as suspect and examinations, specified in ASME Section Xl, 1998 requiring additional examinations.
Edition.
Adds the requirement (c) for a visual The added details ensure proper tendon NMC will meet the requirement examination of all tendon anchorage areas and anchorage area examinations. The addition specified in ASME Section Xl, 1998 tendon end caps shall be examined for specific of (c) is consistent with the rule in 10 CFR 50.
Edition.
conditions.
2520 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
2521 Changed random sample wording in (a).
Nonsignificant - the random sample was NMC will meet the requirement always by type of tendon as shown in Table specified in ASME Section Xl, 1998 IWL 2521-1.
Edition.
2522 Changed the heading and added a The added details ensure proper tendon NMC will meet the requirement subparagraph to address tendon elongation, examinations, specified in ASME Section Xl, 1998 Edition.
2523 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
Page 6 of 13 CONTAINMENT RELIEF REQUEST CRR-09 Subsection IWL Comparison IWL Changes Between IWL 1992 Edition with Significance of Change andlor Basis for NMC Position for Palisades Plant Paragraph Addenda and IWL 1998 Edition Use as an Alternative Examination 2524 Eliminated the VT-1 exam and replaced it with This change is consistent with the changes NMC will meet the requirement the detailed visual exam described in IWL-2310.
described in IWL-2310, and the change in specified in ASME Section X1, 1998 IWE-2310 which eliminated the VT-1 exam Edition.
and replaced with a detailed visual exam and is applicable to the anchorage exam.
2525 Changed wording for sample analysis.
Nonsignificant NMC will meet the requirement specified in ASME Section XI, 1998 Edition.
2526 Added a subparagraph addressing replacement The added details ensure tendon integrity and NMC will meet the requirement of corrosion protection medium.
provide the Responsible Engineer options specified in ASME Section X1, 1998 from which to specify corrosion medium Edition.
replacement.
3100 No change N/A NMC will meet the requirement specified in ASME Section X1, 1998 Edition.
3110 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
3111 ASME Section Xl generic change from repair Nonsignificant NMC will meet the requirement and/or replacement to repair/replacement specified in ASME Section XI, 1998 activities.
Edition.
3112 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
3113 ASME Section XI generic change from repair Nonsignificant NMC will meet the requirement and/or replacement to repair/replacement specified in ASME Section X1, 1998 activities.
Edition.
3120 No change N/A NMC will meet the requirement specified in ASME Section X1, 1998 Edition.
Page 7 of 13 CONTAINMENT RELIEF REQUEST CRR-09 Subsection IWL Comparison IWL Changes Between IWL 1992 Edition with Significance of Change andlor Basis for NMC Position for Palisades Plant Paragraph Addenda and IWL 1998 Edition Use as an Alternative Examination 3200 No change N/A NMC will meet the requirement specified in ASME Section XI, 1998 Edition.
3210 Removed the word concrete from the heading.
Nonsignificant NMC will meet the requirement specified in ASME Section XI, 1998 Edition.
3211 Added tendon end and anchorage areas to the The added details ensure proper tendon NMC will meet the requirement scope of the subparagraph and added corrosion examinations, specified in ASME Section XI, 1998 protection medium leakage and end cap Edition.
deformation as acceptance criteria attributes.
ASME Section XI generic change from repair Nonsignificant NMC will meet the requirement and/or replacement to repair/replacement specified in ASME Section XI, 1998 activities.
Edition.
3212 No change N/A NMC will meet the requirement specified in ASME Section XI, 1998 Edition.
3213 ASME Section XI generic change from repair Nonsignificant NMC will meet the requirement and/or replacement to repair/replacement specified in ASME Section XI, 1998 activities.
Edition.
3220 No change N/A NMC will meet the requirement specified in ASME Section XI, 1998 Edition.
Page 8 of 13 CONTAINMENT RELIEF REQUEST CRR-09 Subsection IWL Comparison IWL Changes Between IWL 1992 Edition with Significance of Change andlor Basis for NMC Position for Palisades Plant Paragraph Addenda and IWL 1998 Edition Use as an Alternative Examination 3221 Added acceptance criteria attributes for The additions to the acceptance criteria of NMC will meet the requirement unbonded post-tensioning systems in the IWL-3221 have provided further assurance specified in ASME Section Xl, 1998 following areas:
that the Responsible Engineer will evaluate Edition.
3221.1 (c) evaluates the predicted force for all potential conditions that could impact the the next scheduled exam meets the post-tensioning system integrity. These minimum design prestress force.
enhancements to the 1998 Edition increase 3221.1(d) compares the elongation with the the level of quality of the inspection program last measurement and specifies that it and have no adverse impact on the safety of cannot vary by more than 10%.
the inspection program described in the 1992 3221.3(e) added evidence of free water as Edition. These additions are consistent with an unacceptable condition. 3221.4 added the requirements of the rule as stated in criteria to compare the difference of the IOCFR 50.55a.
amount of corrosion protection medium removed with that replaced.
3222 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
3223 ASME Section Xl generic change from repair Nonsignificant NMC will meet the requirement and/or replacement to repair/replacement specified in ASME Section Xl, 1998 activities.
Edition.
3300 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
3310 Added applicability for other plants at the same NMC is a single unit site.
NMC will meet the requirement site.
specified in ASME Section Xl, 1998 Edition.
ASME Section Xl generic change from repair Nonsignificant NMC will meet the requirement and/or replacement to repair/replacement specified in ASME Section Xl, 1998 activities.
Edition.
Page 9 of 13 CONTAINMENT RELIEF REQUEST CRR-09 Subsection IWL Comparison IWL Changes Between IWL 1992 Edition with Significance of Change and/or Basis for Paragraph Addenda and IWL 1998 Edition Use as an Alternative Examination NMC Position for Palisades Plant 3320 Deleted paragraph that addressed engineering Nonignificant - there were no submittal or NMC will meet the requirement evaluations being subject to review by retention requirements changed by the specified in ASME Section Xl, 1998 authorities.
deletion of the subparagraph. The Edition.
Regulations do not require licensees to submit their containment inspection programs.
4000 ASME Section XI generic change from repair Nonsignificant - all related repair and NMC will meet the requirement and/or replacement to repair/replacement replacement requirements have been specified in ASME Section XI, 1998 activities, consolidated into IWL-4000.
Edition.
4100 No change N/A NMC will meet the requirement specified in ASME Section XI, 1998 Edition.
4110 Exempted grease cups and installation screws Nonsignificant - the exempted items are non-NMC will meet the requirement from the scope.
structural items.
specified in ASME Section Xl, 1998 Edition.
ASME Section X1 generic change from repair Nonsignificant NMC will meet the requirement and/or replacement to repair/replacement specified in ASME Section XI, 1998 activities.
Edition.
4120 Reworded to use the new repair/replacement Nonsignificant NMC will meet the requirement activity wording and combined paragraph (a),
specified in ASME Section X1, 1998 (b) and (c). Changed the paragraph reference Edition.
to the Repair/Replacement Program and Plan to address paragraph renumbering in IWA-4000.
Page 10 of 13 CONTAINMENT RELIEF REQUEST CRR-09 Subsection IWL Comparison IWL Changes Between IWL 1992 Edition with Significance of Change and/or Basis for NMC Position for Palisades Plant Paragraph Addenda and IWL 1998 Edition Use as an Alternative Examination 4200 ASME Section XI generic change from repair Nonsignificant NMC will meet the requirement and/or replacement to repair/replacement specified in ASME Section X1, 1998 activities.
Edition.
Added a paragraph number IWL-4210, to the Nonsignificant, this is a paragraph numbering NMC will meet the requirement information included under IWL-4200 and change from the 1992 Edition.
specified in ASME Section X1, 1998 changed terminology from repair and/or Edition.
replacement to repair/replacement activities.
4210 Changed paragraph number to 4220, removed Nonsignificant NMC will meet the requirement the word repair from heading and changed specified in ASME Section X1, 1998 referenced paragraph numbers consistent with Edition.
the addition of a new paragraph 4210.
Changed wording consistent with the changes Nonsignificant NMC will meet the requirement to IWL-2310 addressed above.
specified in ASME Section XI, 1998 Edition.
ASME Section XI generic change from repair Nonsignificant NMC will meet the requirement and/or replacement to repair/replacement specified in ASME Section XI, 1998 activities.
Edition.
Changed repair material to new material in Nonsignificant NMC will meet the requirement several places.
specified in ASME Section XI, 1998 Edition.
4220 Changed paragraph number to 4230.
Nonsignificant NMC will meet the requirement specified in ASME Section XI, 1998 Edition.
Page 11 of 13 CONTAINMENT RELIEF REQUEST CRR-09 Subsection IWL Comparison IWL Changes Between IWL 1992 Edition with Significance of Change and/or Basis for NMC Position for Palisades Plant Paragraph Addenda and IWL 1998 Edition Use as an Alternative Examination 4230 Changed paragraph number to 4240 and Nonsignificant NMC will meet the requirement clarified by removing the word repair.
specified in ASME Section X1, 1998 Edition.
ASME Section Xl generic change from repair Nonsignificant NMC will meet the requirement and/or replacement to repair/replacement specified in ASME Section Xl, 1998 activities.
Edition.
Added detailed requirements for the contents of The added detailed requirements ensure NMC will meet the requirement a repair/replacement plan.
proper repair/replacement plan development specified in ASME Section X1, 1998 for post-tensioning systems.
Edition.
4300 ASME Section Xl generic change from repair Nonsignificant NMC will meet the requirement and/or replacement to repair/replacement specified in ASME Section X1, 1998 activities.
Edition.
5100 ASME Section X1 generic change from repair Nonsignificant NMC will meet the requirement and/or replacement to repair/replacement specified in ASME Section Xl, 1998 activities.
Edition.
5200 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
5210 ASME Section X1 generic change from repair Nonsignificant NMC will meet the requirement and/or replacement to repair/replacement specified in ASME Section XI, 1998 activities.
Edition.
5220 No change N/A NMC will meet the requirement specified in ASME Section Xl, 1998 Edition.
5230 Changed wording by removing some specific Nonsignificant - the removed wording was NMC will meet the requirement IWE related requirements while maintaining the IWE specific and is contained in IWE-5000.
specified in ASME Section X1, 1998 reference to IWE-5000.
Edition.
Page 12 of 13 CONTAINMENT RELIEF REQUEST CRR-09 Subsection IWL Comparison IWL Changes Between IWL 1992 Edition with Significance of Change andlor Basis for NIIC Position for Palisades Plant Paragraph Addenda and IWL 1998 Edition Use as an Alternative Examination 5240 Deleted paragraph that addressed the Nonsignificant - the schedule of pressure NMC will meet the requirement scheduling of pressure tests.
tests are contained in IWE-5000 as specified in ASME Section Xl, 1998 referenced in IWL-5230.
Edition.
5250 Changed wording regarding the role of the The clarified role of the Responsible NMC will meet the requirement Responsible Individual in pressure test Individual ensures proper pressure test specified in ASME Section Xl, 1998 activities.
procedures and examinations.
Edition.
ASME Section XI generic change from repair Nonsignificant NMC will meet the requirement and/or replacement to repair/replacement specified in ASME Section XI, 1998 activities.
Edition.
Changed visual examination terminology The visual examination terminology changes NMC will meet the requirement consistent with the changes to IWL-2310.
are discussed in IWL-2310.
specified in ASME Section XI, 1998 Edition.
5260 Changed heading from Corrective Measures to Nonsignificant NMC will meet the requirement Corrective Action.
specified in ASME Section XI, 1998 Edition.
ASME Section Xl generic change from repair Nonsignificant NMC will meet the requirement and/or replacement to repair/replacement specified in ASME Section Xl, 1998 activities.
Edition.
5300 ASME Section XI generic change from repair Nonsignificant NMC will meet the requirement and/or replacement to repair/replacement specified in ASME Section Xl, 1998 activities.
Edition.
7000 Deleted Article including IWL-7100, 7110, 7120 Nonsignificant - all related repair and NMC will meet the requirement consistent with the IWL-4000 changes above, replacement requirements have been specified in ASME Section Xl, 1998 incorporated into IWL-4000.
Edition.
Page 13 of 13 CONTAINMENT RELIEF REQUEST CRR-09 Subsection IWL Comparison IWL Changes Between IWL 1992 Edition with Significance of Change and/or Basis for Paragraph Addenda and IWL 1998 Edition Use as an Alternative Examination NMC Position for Palisades Plant Table Changed item L1.11 from all areas to all The addition of accessible provides NMC will meet the requirement 2500-1 accessible areas.
consistency with the requirements of the specified in ASME Section XI, 1998 scope of IWL-1 000, and does not alter the Edition.
level of quality of the inspection plan described in the 1992 Edition.
Replaced the VT-3C, VT-1C, and the VT-1 The acceptability of the change to the general NMC has submitted (in letter dated exams with general visual and detailed visual, and detailed visual inspections is discussed in February 21, 2002) specific details respectively, as described in the paragraph IWL-2310.
regarding Visual Examinations.
IWL-231 0.
Note: the item L1.12 examination method in the 1998 Edition contains a publication error. The "general visual" should be "detailed visual."
Table Changed inspection periods to state every 5"'
Nonsignificant - accommodates plant life NMC will meet the requirement 2521-1 year in lieu of listing out each year and changed extensions for tendon examinations, specified in ASME Section X1, 1998 note 2 for having to meet acceptance criteria Edition.
from "each of the earlier inspections" to "for the last 3 inspections."
Added optional test methods for corrosion Nonsignificant - additional test method NMC will meet the requirement protection medium analysis.
options provides for more practical test specified in ASME Section XI, 1998 implementation.
Edition.
Added acceptance criteria for water content.
Previous acceptance criteria were noted as NMC will meet the requirement "in course of preparation." Providing the specified in ASME Section X1, 1998 acceptance criteria assures consistent Edition.
implementation.