ML022480080
| ML022480080 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/27/2002 |
| From: | Raghavan L NRC/NRR/DLPM/LPD3 |
| To: | Cooper D Nuclear Management Co |
| References | |
| TAC MB4216, TAC MB4218 | |
| Download: ML022480080 (58) | |
Text
September 27, 2002 Mr. Douglas E. Cooper Site Vice President Palisades Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530
SUBJECT:
PALISADES PLANT - EVALUATION OF CONTAINMENT INSERVICE INSPECTION RELIEF REQUESTS (TAC NOS. MB4216 AND MB4218)
Dear Mr. Cooper:
By letter dated February 21, 2002, as supplemented May 6, 2002, the Nuclear Management Company, LLC (the licensee), submitted Containment Relief Request (CRR)-08 and CRR-09 for the Palisades Plant. The licensee is seeking relief from the requirements of the 1992 edition with the 1992 addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (the Code),Section XI, Subsections IWE and IWL. As an alternative, the licensee proposes to use the provisions of Subsections IWE and IWL of the 1998 edition of the Code, which has not yet been incorporated by reference into 10 CFR 50.55a.
As stated in the February 21, 2002, letter, CRR-08 and CRR-09 supercede CRR-01, CRR-02, CRR-03, CRR-05, and CRR-07, which were previously approved by the Nuclear Regulatory Commission in a letter dated July 26, 1999.
The licensees proposed alternative to use the 1998 edition of Subsections IWE and IWL, as supplemented by commitments in the licensees February 21, 2002, letter, will provide an acceptable level of quality and safety for ensuring the integrity of the pressure boundary of the containment at Palisades. Therefore, the proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i). As requested, this relief is authorized for the balance of the current 10-year inspection interval.
Sincerely,
/RA/
L. Raghavan, Chief, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-255
Enclosure:
Safety Evaluation cc w/encl: See next page
ML022480080 *Provided SE input by memo OFFICE PDIII-1/PM PDIII-1/LA EMEB/SC* OGC/NLO** PDIII-1/SC NAME DHood for RBouling DTerao RHoefling LRaghavan JEads DATE 09/11/02 09/11/02 08/01/02 09/18/02 09/27/02 Palisades Plant cc:
Mr. Robert A. Fenech, Senior Vice President Michigan Department of Attorney General Nuclear, Fossil, and Hydro Operations Special Litigation Division Consumers Energy Company 630 Law Building 212 West Michigan Avenue P.O. Box 30212 Jackson, MI 49201 Lansing, MI 48909 Arunas T. Udrys, Esquire Mr. Roy A. Anderson Consumers Energy Company Executive Vice President and 212 West Michigan Avenue Chief Nuclear Officer Jackson, MI 49201 Nuclear Management Company, LLC 700 First Street Regional Administrator, Region III Hudson, WI 54016 U.S. Nuclear Regulatory Commission 801 Warrenville Road Laurie A. Lahti Lisle, IL 60532-4351 Manager - Licensing Nuclear Management Company, LLC Supervisor 27780 Blue Star Memorial Highway Covert Township Covert, MI 49043 P. O. Box 35 Covert, MI 49043 Steven T. Wawro Nuclear Asset Director Office of the Governor Consumers Energy Company P. O. Box 30013 Palisades Plant Lansing, MI 48909 27780 Blue Star Memorial Highway Covert, MI 49043 U.S. Nuclear Regulatory Commission Resident Inspectors Office Mr. John Paul Cowan Palisades Plant Senior Vice President 27782 Blue Star Memorial Highway Palisades Plant Covert, MI 49043 Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Drinking Water and Radiological Covert, MI 49043 Protection Division Michigan Department of Environmental Quality 3423 N. Martin Luther King Jr Blvd P. O. Box 30630 CPH Mailroom Lansing, MI 48909-8130 March 2002
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO RELIEF REQUEST FROM THE REQUIREMENTS OF 10 CFR 50.55a FOR CONTAINMENT INSERVICE INSPECTION NUCLEAR MANAGEMENT COMPANY, LLC PALISADES PLANT DOCKET NO. 50-255
1.0 INTRODUCTION
Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.55a(g)(6)(ii)(B) requires licensees of nuclear power plants to perform expedited examination of their primary containment structures in accordance with the requirements of Subsections IWE and IWL of the 1992 edition up to and including the 1992 addenda or the 1995 edition with the 1996 addenda of Section XI of the American Society of Mechanical Engineers (ASME)
Boiler and Pressure Vessel Code (the Code), as modified by the requirements of 10 CFR 50.55a(b)(2)(viii) and 10 CFR 50.55a(b)(2)(ix). Licensees of all operating nuclear power plants were required to complete their first period inspections by September 9, 2001.
By letter dated February 21, 2002, as supplemented May 6, 2002, the Nuclear Management Company, LLC (the licensee) submitted Containment Relief Request (CRR)-08 and CRR-09 seeking relief from the requirements of the 1992 edition with the 1992 addenda of the ASME Code,Section XI, Subsections IWE and IWL. As an alternative, the licensee proposes to use the provisions of Subsections IWE and IWL of the 1998 edition of the Code, which has not yet been incorporated by reference into 10 CFR 50.55a. In the February 21, 2002, letter, the licensee provided a table comparing the requirements of the 1998 edition with the 1992 edition and addenda. This safety evaluation addresses the acceptability of the licensees proposed alternative.
2.0 EVALUATION OF CRR-08 In CRR-08, the licensee proposes to use the 1998 edition of Subsection IWE as an alternative to the requirements of the 1992 edition with the 1992 addenda for inspection of Class MC components and the metallic shell and penetration liners of Class CC pressure-retaining components. The May 6, 2002, supplemental letter contained a comparison of the changes in requirements between the 1992 edition up to including the 1992 addenda and the 1998 edition of Subsection IWE. The table in Attachment 1 to this safety evaluation (SE) contains comparisons of these requirements and the NRC staffs assessment of these changes.
Specifically, the four columns of the table provide the following information:
Column 1 The paragraph (sometimes includes articles and subarticles) corresponding to the 1992 edition with the 1992 addenda of Subsection IWE.
Column 2 Changes between the 1992 edition with the 1992 addenda and the 1998 edition.
Column 3 The licensees statement of significance and/or basis for use as an alternative inspection.
Column 4 The NRC staffs assessment of the acceptability of the requirements of the 1998 edition of the Code in terms of quality and safety.
Based on its review of the comparative requirements, the NRC staff identified several significant issues that required additional commitments from the licensee. These issues are evaluated in Sections 2.1 through 2.5 of this SE.
2.1 Visual Examination Methods and Personnel Qualification, IWE-2300 The 1992 edition and addenda invoke the use of IWA-2200 for visual, surface, and volumetric examination methods, and IWA-2300 for qualification of personnel. For qualification of personnel, the 1992 addenda of IWA-2300 requires personnel to be qualified and certified using a written practice prepared in accordance with ANSI/ASNT CP-189. The 1998 edition of IWE-2300 requires licensees to define requirements for visual examination of containment surfaces, and for qualifying the personnel performing visual examinations. In general, use of consensus standards for performance of containment examinations is preferable to licensee-defined requirements. Additionally, IWE-2320 requires that a responsible individual (RI) be responsible for activities related to the containment surface visual examinations and personnel qualification. Allowing individual licensees to develop guidance for conducting these activities creates a potential for substantial inconsistencies and may not provide an adequate level of quality and safety. In its February 21, 2002, submittal, the licensee committed to supplement the requirements of the 1998 edition of IWE-2300 with the following provisions:
- a. The qualification program for personnel performing the general and detailed visual examinations will meet the applicable requirements of IWA-2210 of the 1992 Edition and Addendum of Section XI.
- b. Palisades procedures will include the general and detailed visual examinations in the functional task descriptions for the VT-3 and VT-1 methods, respectively. Personnel performing the general and detailed visual examinations will be certified to VT-3 and VT-1, respectively.
- c. Performance requirements for general and detailed visual examinations will be included in the visual examination procedure. A performance demonstration will be developed and documented to establish the distances and illuminations for which the general and detailed visual examinations are sufficient to detect evidence of degradation that may affect the containment structure integrity or leak tightness. The Palisades visual examination procedure will be prepared by non-destructive examination (NDE) Level III personnel
and the RI, and demonstrated to the ANII [Authorized Nuclear Inservice Inspector].
- d. The general visual examination acceptance criteria will be included in the PalisadesSection XI visual examination procedure. The general visual examination of containment liner surfaces examines for indications of degradation that may affect the containment structural integrity or leak tightness. Indications of flaking, blistering or peeling coating; excessive corrosion; and general deformation, bulges, surface irregularities, or other signs of distress, will be recorded. The general visual examination of pressure retaining bolts connections examines for missing or loose bolting materials corrosion, bolting deformation, or other indications that may affect the integrity of bolted connection. Indications will be recorded. The general visual examination of moisture barriers examines for wear, damage, erosion, tears, surface cracks and other defects that would permit intrusion of moisture into inaccessible areas. Indications will be recorded. Recorded indications will be evaluated in accordance with IWE-3000, 1998 Edition.
- e. The detailed visual examinations will also be included in the PalisadesSection XI visual examination procedure. The detailed visual examination assesses the initial condition of surfaces requiring augmented examinations, in accordance with the IWE-1241, and determines the magnitude and extent of indications of degradation and distress of these containment surfaces. The detailed visual examination also determines the magnitude and extent of indications of degradation and distress of suspect containment surfaces. The detailed visual examination criteria of IWE-2310(e) of the 1998 edition are used, supplemented by additional criteria for bolted connections and moisture barriers as defined in the general visual examination criteria above.
- f. Results of a general visual examination are acceptable for continued service without further evaluation only when there is no evidence of damage or degradation of the inspected component or surface area.
- g. For IWE examinations, the Palisades Containment Inspection Program will continue to meet the requirements specified in the 1992 Edition of Section XI (ASNT-SNT-TC-1A, 1984 Edition or ANSI/ASNT CP-189, 1991 Edition) for the qualification of personnel performing examinations. In addition, the inspection and evaluation procedures that are used to perform inspections are reviewed and approved by a certified NDE Level III examiner and the ANII.
The NRC staff finds that complying with the 1998 edition of the Code, as supplemented by proposed provisions in the licensees containment inservice inspection procedures, provides a technically adequate approach for performing visual examination and personnel qualification, and, thus, will provide an acceptable level of quality and safety.
2.2 Examination of Paint and Coatings, IWE-2500(b)
The requirement to examine paint or coating prior to removal was deleted in the 1998 edition of the Code. The NRC staff has no objection to this deletion. However, in the absence of any examination for detecting flaws or degradation in the containment base metal, the recoating may be applied to a degraded containment surface. The licensees actions will assure that coatings will not be applied inappropriately to a degraded surface.
The licensee states that at Palisades, liner plate protective coating is maintained in accordance with administrative work requests and the work order program. As part of this program, the RI is required to perform a maintenance pre-review of any work order authorizing liner plate work.
During this review, the RI enters inspection requirements to ensure the liner plate will continue to meet design-basis requirements. These inspection requirements will include detailed inspections, general visual examinations, and detailed visual examinations. Items not meeting the acceptance criteria of examination procedures will be evaluated in accordance with the Palisades Corrective Action Program and accepted by analysis or repaired or replaced in accordance with Palisades programs.
The NRC staff finds that implementation of the licensees proposed process provides reasonable confidence that base metal degradation will be identified, and appropriate action taken, prior to recoating the containment liner.
2.3 Visual Examination Acceptance Standards for Categories E-A and E-C IWE-3510.1 and IWE-3511.1 of the 1998 edition of the Code state that the licensee is required to define the acceptance criteria for visual examination of containment surfaces when performing Category E-A and Category E-C examinations. The basic requirements for these examinations are provided in IWE-2310 and will be augmented by Palisades as described in Section 2.1 above.
The NRC staff finds that complying with the 1998 edition of the Code, augmented by the specific requirements in the licensees containment inspection program, will provide reasonable assurance that significant flaws and degradation of the containment are adequately identified during Category E-A and Category E-C examinations.
2.4 Ultrasonic Examinations, IWE-3511.3 In Paragraph IWE-3511.3 of the 1998 edition of the Code, examination of metallic liners of Class CC components has been excluded from the acceptance criterion which requires disposition of areas where material loss exceeds 10 percent of the nominal wall thickness.
Therefore, the 1998 Code is not acceptable for the metallic liners of Class CC components without augmentation by the licensee. The licensee states in its February 21, 2002, letter that NMC shall apply acceptance standards determined by an engineering analysis completed in accordance with Palisades administrative procedures. This engineering analysis will document
the minimum required thickness for specific areas on the containment liner plate. The 1998 edition applies the criteria in IWE-3511.3 to Class MC pressure-retaining components, and not to metallic liners of Class CC components. The licensee states that the ultrasonic examinations criteria in IWE-3511.3 will apply to Class CC components as well as to Class MC components. This is equivalent to the requirements of the 1992 addenda.
Therefore, the NRC staff concludes that the proposed acceptance criterion for material loss will ensure that the integrity of the liner plate is maintained and, thus, will provide an acceptable level of quality and safety.
2.5 Examination of Pressure Retaining Bolting, Table IWE-2500-1 The 1992 edition through the 1996 addenda requires licensees to perform a VT-1 visual examination on 100 percent of the pressure-retaining bolting. It also requires torque testing of each bolted connection. In the 1998 edition of IWE, the requirements for bolted connections have been moved to Examination Category E-A, Item E1.10, Containment Vessel Pressure Retaining Boundary and Item E1.11, Accessible Surface Areas. The 1998 edition requires that 100 percent of the accessible surface areas of the containment vessel pressure-retaining boundary be visually examined (general visual) during each inspection period. This corresponds to an examination of all bolted connections three times per inspection interval.
Included in the examination are bolts, studs, nuts, bushings, washers, and threads in base material and flange ligaments between fastener holes. The Code does not require that the bolted connection be disassembled for performance of the examination.
A general visual examination alone will not allow identification of flaws or degradation in inaccessible areas. In addition, the acceptance criteria for general visual examinations do not provide sufficient guidance for acceptance of flaws. Therefore, the NRC staff finds that the requirements for visual examination of bolted connections in the 1998 edition are not fully satisfactory. The NRC staff recommends the following guidelines:
A detailed visual examination should be performed for areas where flaws or degradation are indicated.
Damaged bolted connections should be disassembled and a detailed visual examination of the bolted connection components should be performed.
A general visual examination (or detailed visual examination if applicable) should be performed when a bolted connection is disassembled at the time of a scheduled general visual examination. All accessible surface areas of the connection (bushings, threads, ligaments in the base material of flanges) should be included in the examination.
A general visual examination (or detailed visual examination if applicable) should be performed when a bolted connection is disassembled at times other than a scheduled visual examination. Procedures should be used to ensure that the integrity of the reassembled bolted connections are maintained. The procedures should include acceptance criteria for the continued use of all parts of the connections including bolts, studs, nuts, bushings, washers, and threads in base material and flange ligaments between fastener holes.
The licensees proposed alternative provisions for the examination of containment pressure boundary bolted connections as described in Item 5 of Attachment 1 of its letter dated February 21, 2002, is consistent with the NRC staffs guidelines and provides a reasonable and practical approach to ensure that degraded and damaged bolting is adequately identified.
Therefore, the NRC staff finds that the licensees proposed alternative provides an acceptable level of quality and safety.
3.0 EVALUATION OF CRR-09 In CRR-09, the licensee proposes to use the 1998 edition of Subsection IWL as an alternative to the requirements of the 1992 edition and addenda for inspection of Class CC components.
The May 6, 2002, supplemental letter contained a comparison of the changes in requirements between the 1992 edition and addenda and the 1998 edition of Subsection IWL. The table in to this SE shows this comparison and the NRC staffs associated assessment.
Specifically, the four columns of the table provide the following information:
Column 1 The paragraph (sometimes includes articles and subarticles) corresponding to the 1992 edition and Addends of Subsection IWL.
Column 2 Changes between the 1992 edition and addenda and the 1998 edition.
Column 3 The licensees statement of significance and/or basis for use as an alternative inspection.
Column 4 The NRC staffs assessment of the acceptability of the requirements of the 1998 edition of the Code in terms of quality and safety.
Based on its review of the comparative requirements, the NRC staff identified several significant issues that required additional commitments from the licensee. These issues are evaluated in Sections 3.1 through 3.3 of this SE.
3.1 Qualification of Visual Examination Personnel for Concrete Inspection, IWL-2300 The 1998 edition of IWL-2310(d) requires the licensee to define the qualification requirements to qualify personnel to perform visual examinations of concrete and tendon anchorage hardware, wires, or strands. Prior to the 1997 addenda, IWL-2310(c) required that visual examination personnel be qualified in accordance with IWA-2300 or IWA-2350, as applicable.
In general, use of consensus standards for qualification of examination personnel is preferable to licensee-defined requirements. Allowing individual licensees to develop guidance for conducting these activities creates a potential for substantial inconsistencies and may not provide an adequate level of quality and safety.
In its February 21, 2002, letter, the licensee provided the following information on its personnel qualification requirements:
- a. The qualification program for personnel performing the general and detailed visual examinations will meet the applicable requirements of IWA-2300 of the 1992 Addendum.
- b. Palisades procedure will include the general and detailed visual examinations in the functional task descriptions for the VT-3 and VT-1 methods, respectively. Personal performing the general and detailed visual examinations will be certified to VT-3 and VT-1, respectively.
- c. Performance requirements for general and detailed visual examinations will be included in the Palisades visual examination procedure. The detailed visual examination will meet the resolution requirements for VT-1 contained in Table IWA-2210-1 in the 1992 Edition and Addenda. A performance demonstration will be developed and documented to established the distances and illumination for which the general and detailed visual examinations are sufficient to detect evidence of degradation that may affect the containment structural integrity. The Palisades visual examination procedure will be prepared by nondestructive examination (NDE)
Level III personnel and the Responsible Engineer and demonstrated to the ANII.
- d. The visual examinations will be performed in accordance with 1998 edition, Subsection IWL-2310, IWL-2510, and IWL-2524.1.
Indication will be recorded, and subsequently evaluated, by the Responsible Engineer in accordance with IWL-2320, IWL-3200 and IWL-3300.
The NRC staff finds that complying with the 1998 edition of the Code, as supplemented by proposed provisions in the licensees containment inservice inspection procedures, provides a technically adequate approach for performing visual examination and personnel qualification, and, thus, will provide an acceptable level of quality and safety.
3.2 Examination of Concrete, IWL-2510 The 1992 edition and addenda requires the use of visual examination procedures VT-3C and VT-1C for the examination of concrete. In the 1998 edition and addenda, IWL-2310, these procedures have been changed to general visual and detailed visual examinations. The 1998 Code requires the licensee to define the requirements for visual examination of tendon anchorage hardware, wire, and strands. Use of consensus standards for visual examination methods is preferable to licensee-defined requirements. Allowing individual licensees to develop guidance for conducting these activities creates a potential for substantial inconsistencies and may not provide an adequate level of quality and safety.
In its February 21, 2002, submittal, the licensee provided the performance requirements for general and detailed visual examinations:
The general visual examinations provide a screening mechanism to locate conditions that may be indicative of damage or distress. Containment surfaces are accepted on the basis of a general visual examination only when there are no indications of damage or distress that are a code concern.
IWL-detailed visual examinations are conducted when the criteria for acceptance by general visual examinations are not met, or when the surface or component is initially classified as suspect or otherwise requires augmented examination. Suspect areas are defined in Table IWL-2500-1, Categories L1.12 and L2.30. For IWL-detailed visual examinations, the surface may be accepted for continued service without further evaluation provided one of the following is demonstrated:
- a. The Responsible Engineer determines that the flaw or area of degradation is nonstructural in nature or has no unacceptable effect on the structural integrity of the containment, as determined by an evaluation of the magnitude and extent of the relevant indication from ACI 201.1R. Although not required by IWL-2310(a),
ACI 349.3R may be used, as appropriate.
- b. The Responsible Engineer determines that the flaw or area of degradation is limited to the outermost concrete layer with no rebar exposure, or, if rebar is exposed, the rebar does not exhibit evidence of corrosion.
- c. The Responsible Engineer is able to accept the indication based on a review of a previous evaluation from historical record.
The NRC staff finds that complying with the 1998 edition of the Code, augmented by the specific requirements in the licensees Containment Inspection Program, will provide reasonable assurance that significant flaws and degradation of the containment are adequately identified during IWL-2510 examinations and, thus, will provide an acceptable level of quality and safety.
3.3 Examination of Suspect Areas, Table IWL-2500-1 Table IWL-2500-1 of the 1998 edition of the Code requires a general visual examination for Item L1.12 (suspect areas). The 1992 addenda of the Code requires a VT-1 examination. The licensee states in February 21, 2002, letter that it will perform detailed visual examinations of suspect areas addressed in Category L-A, Item L1.12. The licensees proposal meets the intent of the 1992 Code requirements and, therefore, is acceptable.
4.0 CONCLUSION
The licensees proposed alternative to use the requirements of the 1998 edition of Subsections IWE and IWL, as supplemented by commitments in the licensees submittal of February 21, 2002, as supplemented May 6, 2002, provides an acceptable level of quality and safety for ensuring the integrity of the pressure boundary of the containment at Palisades.
The licensees proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i) for the balance of the 10-year inspection interval.
Attachments: 1. Palisades Plant -- IWE Comparison
- 2. Palisades Plant -- IWL Comparison Principal Contributor: G. Bedi Date: September 27, 2002
PALISADES PLANT -- IWE COMPARISON IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (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 Editorial change has no safety or 1220 Changed containment to Nonsignificant quality significance. Acceptable.
containment system 1230 No change N/A Examination of welds is optional in 1231 Removed item 3) - single welded These single welded butt joints were 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 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.
stated exclusions from that 80%. made inaccessible during Acceptable.
construction are also excluded.
Reworded paragraph b). Change to b) is for clarity and is nonsignificant. Editorial change has no safety or quality significance. Acceptable.
ATTACHMENT 1
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination Editorial change has no safety or 1232 ASME XI generic change from Nonsignificant quality significance. Acceptable.
repair and/or replacement to repair/replacement activities.
Deleted paragraph (a)(3) Welded joints were removed as a Examination of welds is optional in addressing inaccessible welded separately listed examination items 10 CFR 50.55a. Acceptable.
joints. and are now 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 Adding stiffeners in IWE-1241(a) 1241 Added stiffeners and, by reference Clarifies the intent of the Code that requiring examination and adding to IWE-2420, flaws accepted by areas identified in IWE-2420(b) reference to IWE-2420(b). The evaluation as areas requiring require an augmented exam in the additional areas subject to augmented examination. next period.
augmented examination further assure containment integrity.
Acceptable.
Editorial change has no safety or 1242 Changed IWE-2500(b) to IWE- Nonsignificant quality significance. Acceptable.
2500(c) 2000 No change N/A By adding additional general 2100 Added new Subarticle IWE-2100 - The containment examinations are requirements of IWA-2100, further General - to provide reference to completely defined within the assures containment integrity.
IWA-2000 with exceptions from jurisdiction of IWE, thus reference to Also, IWE-2310, 1998 covers the IWA-2210, 2300, 2500 and 2600. IWA-2210, and IWA-2300 are not visual examinations as identified in applicable.
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination 2100 (cont) The exceptions to IWA-2500, and IWA-2210. Acceptable.
IWA-2600 are to weld base exams that do not apply to IWE. The NMC Per the 1998 Code, personnel will Containment Inspection Program will not have to be certified to CP-189 specify the requirements for (IWA-2300) - Licensee committed personnel certification in accordance to certify inspection personnel in with CP-189 and SNT-TC-1A.
accordance with CP-189 and SNT-Therefore, the examinations in the TC-1A.
1998 Edition provide acceptable level of quality and safety as defined Acceptable.
in IWE of the 1992 Edition.
The deletion of paragraph (c) 2200 Deleted paragraph c) which The deletion of an allowance for an ensures that proper preservice provided allowances for the use of alternative examination ensures that examination is performed per shop or field examinations in lieu of proper preservice examinations are Table IWE-2500-1. Acceptable.
on site preservice examinations. performed and documented.
The deletion of the requirement to The licensees work order process Deleted paragraph g) which document the condition of new requires notification of Responsible required the condition of new non-pressure retaining coatings in Engineer (RE) who will ensure coating to be documented in the the preservice examination record thorough ISI and preservice preservice examination record. provides for more efficient program inspection (PSI) examinations of implementation without affecting containment surface including component integrity. condition of base metal without the The NMC work order process need for an additional Code requires notification of Responsible examination. Acceptable.
Engineer (RE) who will ensure thorough ISI and PSI examinations of containment surface including condition of base metal.
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination 2200 (cont) Nonsignificant. This is editorial change.
Acceptable.
ASME XI generic change from repair and/or replacement to repair/replacement activities.
2300 Added new Subarticle 2300 - Visual Examination, Personnel Visual Examination, Personnel Qualification and Responsible IWE 2300 -Visual Examination, Qualification and Responsible Individual - The philosophy of IWE Personnel Qualification and Individual. to be an engineering inspection Responsible Individual is newly under the direction of the added subarticle. The specific Responsible Individual is contained paragraphs IWE-2310, IWE-2320, in this new sub-article. The most and IWE-2330 added are significant change is the definition of discussed below. The NMC has the roles and responsibilities of the submitted additional commitments, Responsible Individual. This as detailed in Containment Relief individual will be accountable for the Request CRR-08. Reference to entire inspection program which will the applicable additional meet or exceed the level of quality commitments are identified in the and safety defined in the 1992 discussion below.
Edition.
Consistency with existing ISI visual 2310 Added new paragraph 2310 - Visual a) The VT-3 and VT-1 inspections of examination requirements provide Examinations - which a) states that IWA have been replaced by for an efficient internal program; the owner shall define requirements Responsible Individual defined that coupled with the program for visual examination of general and detailed visual exams, established for NMC will provide containment surfaces; respectively. The definition of critical uniformity and consistency examination items and acceptable industry wide. NMCs visual conditions has not changed, such examination requirements are that any conditions adversely
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination affecting quality or safety are not defined in Containment Relief 2310 (cont) impacted by this change. Request CRR -08, Proposed Alternatives, item 1). The 1998 Code with the specific commitments are acceptable.
b) and c) defines general and detailed examinations. b) and c): The general visual and The 1998 Edition does not specify detailed examinations are equivalent acceptance criteria since the to the VT-3 and VT-1 exams in examination requirements are terms of assessing the general defined by the owner. The staff condition and potential for does not find this to be acceptable.
deterioration within the containment The licensee provided specific system. The use of owner defined acceptance criteria for the general inspection types allows for the visual and detailed examinations involvement of qualified engineering defined in Containment Relief personnel with background in Request CRR-08, Proposed programs such as Maintenance Alternatives, item 1), in its Rule, containment coating, and February 21, 2002, submittal. This Appendix J. This provides for a is acceptable.
containment inspection program that is performed by individuals with knowledge in containment degradation mechanisms.
d) and e) provides the requirements for the conditions of areas affected d) and e): Previously these NMC has provided acceptance by repair/replacement activities, examination requirements did not criteria for general and detailed painted or coated areas, and non- exist within Article IWE-2000 but visual examinations are defined in the Containment Relief Request
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination coated areas. were contained in the acceptance CRR-08, Proposed Alternatives, criteria of Article IWE-3000. Adding items 1) and 3), in submittal dated these specific attributes here ensure February 21, 2002. The 1998 2310 (cont) proper containment examinations. Code with the specified There are no acceptance criteria commitments and acceptance specified since the proposal criteria are acceptable.
maintains owner defined examination requirements.
a) The details for the Responsible Added new paragraph 2320 - The qualification along with the roles 2320 Individual qualification Responsible Individual - which and responsibilities of the requirements were previously a) states the qualification Responsible Individual are clearly contained in the acceptance requirements of the Responsible delineated within this sub-article.
standards of IWE-3510.1. This is Individual and This section clearly states the editorial change. Acceptable.
expectations for the Responsible Individual, and brings accountability for the entire program to an b) The added detailed b) defines the responsibilities of the individual knowledgeable in responsibilities for the Responsible Responsible Individual for the containment and their degradation Individual ensure proper development of plans and mechanisms. This individual will performance of those related procedures; instruction, training and develop the inspection plans, train activities. Having an individual approval of visual examination personnel, direct to perform possessing the qualifications personnel; performance or direction inspections, and finally evaluate the described in paragraph 2320 a) of visual examinations; evaluation results. The cohesiveness of the performing the responsibilities of results and documenting results. inspection program has been defined in paragraph 2320 b) improved by addition of this sub-ensures the reliable detection of article, resulting in an increase in conditions.
level of quality and thus no adverse impact on safety.
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination The philosophy of the 1998 Edition give the responsible individual complete control over the program.
This provides consistency in all the plan and procedure; performance and direction of examination; evaluation of results and documentation. Acceptable.
The staff finds owner-defined 2330 Added new paragraph 2330 - a) Adding requirements for the personnel qualification Personnel Qualification - which a) owner to define personnel requirements to be unacceptable.
states that the owner is responsible qualification requirements is Personnel should be qualified in for defining the qualification consistent with the philosophy that accordance with Subsection IWA requirements for personnel the Responsible Individual must requirements. The licensee states performing visual examinations and qualify the inspection personnel.
that qualification program for The code recognizes that the personnel will be in accordance qualification may differ depending on with Subsection IWA, and will be the containment type and even the qualified in accordance with ASNT-b) provides minimum qualification inspection period in question. This SNT-TC-1A, 1984 Edition or requirements that were previously change is consistent with the other ANSI/ASNT CP-189, 1991 Edition contained in the acceptance criteria changes discussed above and This is acceptable.
of IWE-3510.1. serves to improve the level of quality and thus has no adverse impact on safety.
2400 No change N/A 2410 No change N/A
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination The deleted subparagraph 2411 Deleted a subparagraph discussing The deleted subparagraph requirements are similar to as of decreasing and extending eliminates duplication with IWA-IWA-2400. The Code 1998 Edition inspection periods. 2400.
invokes the requirements of IWA-2400 under newly added paragraph IWE-2100. This is Acceptable.
The deleted subparagraph 2412 Deleted a subparagraph discussing The deleted subparagraph requirements are similar to as of decreasing and extending eliminates duplication with IWA-IWA-2400. The Code 1998 Edition inspection periods. Added a 2400. The added requirements for invokes the requirements of IWA-subparagraph detailing the scheduling of added welds or 2400 under newly added requirements for the scheduling of components was added prior to the paragraph IWE-2100. This is added welds or components. 1998 Edition rewrite of Subsection Acceptable.
IWE and is of marginal value with the 1998 revisions to Table IWE-2500-1 (refer to the evaluation later in this table).
Changing duration of 2420 Revised (b) to remove repaired Repaired areas that are likely to reexamination of areas that remain areas as areas requiring experience accelerated degradation essentially unchanged from three reexaminations during the next and aging are already subject to consecutive inspection periods to successive inspection period. augmented examinations per IWE-the next successive inspection 1241. Some repairs may be located period is consistent with the in non- augmented areas and may requirements for Class 2 be necessary to correct physical components. Acceptable.
damage caused by construction or craft activities. Changing duration of reexamination of areas that remain essentially unchanged from three
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination consecutive inspection periods to the next successive inspection period is consistent with the requirements for Class 2 components.
The evaluation that determines that Changed (c) to require that areas flaws or areas of degradation remain This is now consistent with Class 2 which remain essentially unchanged is sufficient to conclude successive inspections. The unchanged for the next inspection that there are no active corrosion engineering evaluation of IWE-period no longer require augmented mechanisms present. 3122.3, along with the examinations. The 1992 Addenda reexamination in the next required three consecutive inspection, is sufficient to assure examinations to reach this that augmented examinations conclusion. need not be continued.
Acceptable.
The 1998 Code does not rely on 2430 Deleted the paragraph - Additional The changes to Table IWE 2500-1 sampling as 100% of the Examinations - which discussed eliminate several examination containment surface is already adding examination items of the categories. The categories that examined. Therefore, elimination same category if flaws or areas of remain all require 100%
of this requirements is appropriate.
degradation are identified during an examination. Therefore no items are Acceptable.
examination. available for additional examinations.
The rewording of the 2500 Reworded the existing The reworded subparagraphs add subparagraphs provides subparagraphs consistent with the clarity and provide consistency consistency between IWE-2500 previous paragraph changes and within IWE.
and Table IWE2500-1.
with Table IWE-2500-1 changes.
Acceptable.
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination Deleted the requirement to examine The Code jurisdiction is the pressure Elimination of the paint or coatings paint or coatings prior to removal. retaining boundary, not the non- examination prior to removal has pressure retaining coatings. been found acceptable provided Eliminating this requirement does adequate provisions exist in the not adversely impact the level of licensees program to examine the quality or the safety of the base metal prior to reapplication of containment inspection program. the coating. The licensee 2500 (cont) The 1998 Edition increases the addressed base metal examination frequency of examination when in its February 21, 2002 compared to the 1992 Addenda. submittals.
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 required 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
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination integrity. The ultrasonic gridline approach is a sampling methodology similar to Replaced the requirement for one- The new Table IWE 2500-2 provides that of other portions of the Code foot square grids in thickness more detailed requirements for and other erosion/corrosion measurements with a reference to thickness measurements and is monitoring programs. Acceptable.
Table IWE 2500-2. discussed below.
2500(cont.) This change provides direction for Added a reference to IWE-5000 for The added reference to IWE-5000 performance test. Acceptable.
pressure tests. provides direction for the performance of pressure tests.
Elimination of this sentence is 2600 Deleted a sentence discussing The jurisdiction of the Code does not considered acceptable when compatibility of paint and coating include the quality and compatibility covered by existing nuclear systems and a requirement to of the containment coating systems.
coatings program. Acceptable examine the new paint. This change has no impact on the scope of IWE inspections.
This is editorial change.
3100 Removed the word nondestructive Nonsignificant from the heading. Acceptable.
3110 No change N/A 3111 This is editorial change.
Replaced the reference to Table Table IWE-3410-1 and paragraph 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.
This is editorial change.
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination 3112 Replaced the reference to Table Nonsignificant Acceptable.
IWE-3410-1 with a reference to subarticle IWE-3500. ASME XI generic change from repair and/or replacement to repair/replacement activities.
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination This is editorial change.
3114 Replaced the reference to Table Nonsignificant IWE-3410-1 with a reference to Acceptable.
subarticle IWE-3500. ASME XI generic change from repair and/or replacement to repair/replacement activities.
The regulations do not require the 3115 Deleted subparagraph which Nonsignificant - there were no licensee to submit the containment addressed repair programs and submittal or retention requirements inspection program. Acceptable.
evaluations being subject to review changed by the deletion of the by authorities. subparagraph.
This is editorial change.
3120 Removed the word nondestructive Nonsignificant. Consistent with IWB from the heading. and IWC. Acceptable.
This is editorial change.
3121 Removed the word nondestructive The removal of word nondestructive and deleted references to IWE- is 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.
This is editorial change.
3122 Replaced the references to Table Nonsignificant - the changes are for 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 ASME XI generic change from or retention requirements changed repair and/or replacement to by the deletion of the sentence repair/replacement activities. addressing evaluation reviews.
Reworded several sentences. Consistent with IWB and IWC.
Deleted sentence which addressed
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination evaluations being subject to review by authorities.
This is editorial change.
3124 Replaced the reference to Table Nonsignificant IWE-3410-1 with a reference to Acceptable.
subarticle IWE-3500. ASME XI generic change from repair and/or replacement to repair/replacement activities.
This is editorial change.
3125 Deleted subparagraph which Nonsignificant - there were no 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 This is editorial change.
3200 Added a statement to the end of the The added statement clarifies 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.
This is editorial change.
3410 Replaced the reference to Table Nonsignificant IWE-3410-1 with a reference to Acceptable.
subarticle IWE-3500.
3430 No change N/A
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination 3500 No change N/A Owner-defined visual examination 3510 Reconciled acceptance standards Previously examination requirements do not provide with the IWE-2300 changes requirements were contained in the uniformity and consistency discussed above and the Table acceptance standards of IWE-3500.
industry wide. This is IWE-2500-1 changes discussed This has been corrected by the unacceptable unless the licensee below by: addition of IWE-2300 as discussed provides specific acceptance above.
standards. The licensee provided this information in its February 21, 2002, submittal. Acceptable.
The licensees visual examination Adding the requirement that the acceptance criteria are defined in owner shall define acceptance This change directly corresponds to Containment Relief Request CRR-criteria for visual examination of the addition of IWE-2310(a) as 08, Proposed Alternatives, item 3).
containment surfaces; discussed above. Acceptable.
The is editorial change of Removing the wording for rearranging the paragraph.
Responsible Individual and for This change directly corresponds to Acceptable.
personnel qualifications; the addition of IWE-2320; and the Combining 3510.2 and 3510.3 and addition of IWE-2310(e)(1) and (2) removing specific VT-1 and VT-3 as discussed above.
examination attribute wording; and
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination Incorporating IWE-3511;3513,3514 This is editorial change of and 3515 with changes into IWE- These changes correspond to the rearranging the paragraph.
3510. changes in the examination Acceptable.
categories of Table IWE-2500-1 and to the removal of examination standards paragraphs per the addition of IWE-2310(e)(3) and (4).
By the incorporation of IWE-3515 The examination of bolting, seals the acceptance standards for The resulting acceptance standards and gaskets to determine their bolting were changed from for bolting provide for more practical ability to maintain containment leak referencing material specs and containment ISI program tight integrity as a separate torque or tension limits to conditions implementation without adversely inspection is considered affecting leak tight or structural affecting containment leak tight or unnecessary. The Appendix J, integrity. structural integrity. The Appendix J, Type A test is considered sufficient Type A test is considered sufficient for determining the leak-tight for determining the leak-tight integrity of the penetration.
integrity of the penetration Acceptable.
Examination category E-B has 3511 Deleted subparagraph which Examination category E-B has been been merged with E-A, which is addressed examination category E- incorporated into examination with in consistent with the changes B. category E-A per the changes to to Table IWE-2500-1. The details Table IWE-2500-1 of changes in Table IWE-2500-1 are discussed in the below.
Acceptable This is editorial change as 3512 Renumbered subparagraph to IWE- The subparagraph was renumbered discussed in comments column 3511. Reconciled acceptance based on the deletion of previous under IWE-3511. Acceptable.
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination standards with the IWE-2300 IWE-3511 as discussed above.
changes discussed above and the Previously examination 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.
This change is based on regulatory requirements excluding containment welds, and elimination of any direct reference to containment weld examination in the Code. The licensees visual examination acceptance criteria are defined in Added the requirement that the relief request CRR-08, Proposed owner shall define acceptance This change directly corresponds to Alternative, item 3), Acceptable.
criteria for visual examination of the addition of IWE-2310(a) containment surfaces; discussed above.
This is a editorial change of rearranging the paragraphs.
Acceptable.
Combined 3512.2 and 3512.3 with changes into 3511.2 and removed These changes directly correspond specific VT-1 examination attribute to the addition of IWE-2310(e)(1) wording; and and (2) discussed above and Licensee states it will apply eliminate potential duplication or provisions of IWE-3511.3 to both contradiction of requirements. Class MC and metallic liners of Reworded ultrasonic examination Class CC components. This is subparagraph and limited the UT to This change eliminates the need to acceptable.
Class MC components. perform the UT examinations on metallic liners of Class CC
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination components.
3513 Deleted subparagraphs IWE-3513, Examination categories E-D, E-F 3514 3514 and 3515 which addressed and E-G have been incorporated Acceptable. The regulations do not 3515 examination categories E-D, E-F, into examination category E-A per require the examination of and E-G, respectively. the changes to Table IWE-2500-1 containment welds.
discussed below.
4100 No change N/A 5200 No change N/A 5210 No change N/A Editorial change has no safety or 5220 ASME XI generic change from Nonsignificant quality significance. Acceptable.
repair and/or replacement to repair/replacement activities.
Editorial change has no safety or 5221 ASME XI generic change from Nonsignificant - the requirement to quality significance. Acceptable.
repair and/or replacement to meet the requirements of the 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.
Editorial change has no safety or 5222 ASME XI generic change from Nonsignificant quality significance. Acceptable.
repair and/or replacement to repair/replacement activities.
Referencing IWE-2300, visual 5240 Replaced a reference to IWA-5240 The types of examinations examination in lieu of IWA-5240, with requirements to perform performed in the containment visual examination provides more detailed visual examination of program are all contained in IWE-focuses on containment integrity repair/replacement areas during 2300. The requirements of IWA-than the general requirements pressure tests. 5240 to detect evidence of leakage
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination will be satisfied through the use of (IWA-5240). Acceptable.
the detailed visual examination of IWE-2300.
Editorial change has no safety or 5250 Changed Corrective Measures to Nonsignificant quality significance. Acceptable Corrective Action in the heading.
ASME XI generic change from repair and/or replacement to repair/replacement activities.
7100 No change N/A Table 2411-1 No change N/A Editorial change has no safety or Table 2412-1 Replaced the separate entries for Nonsignificant - The previous quality significance. Acceptable.
1st and successive intervals with requirements for the 1st and one entry for All intervals. successive intervals are identical.
Therefore combining the entries does not affect any requirements.
Added Note (1) which states that if Ensures allocations of examinations the first period completion are done throughout the 10-year percentage for any examination interval. The IWE change is This change provides more category exceeds 34%, at least consistent with changes made in flexibility in scheduling 16% of required examinations shall IWB, IWC, IWD, and IWF. examination, but ensures full be performed in the second period. examination. Acceptable.
By removing the requirement to Table 2500-1 E1.11 Revised frequency of Removing the requirement to coordinate examinations with type Cat. E-A examination from prior to each coordinate examinations with type A
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination type A test to 100% during each tests, and requiring a general visual A tests allows for more efficient period. every inspection period is more containment ISI program restrictive. This change corresponds implementation without adversely with the rule as stated in 10 CFR affecting containment integrity.
50.55a.
Appendix J, Option A, requires Also, the requirement to perform periodic (one each period) Type A general visual examinations every tests. Appendix-J, Option B, is inspection period increases the based on historical performance and total number of examinations on requires periodic visual inspection the containment surface in the for Type A tests.
interval. Acceptable.
Table 2500-1 Cat. E-A E1.12 Re-designated item from Replacing the accessible surface (cont) Acceptable with licensees accessible surface areas to area designation (which is now commitments for general visual wetted surfaces of submerged included in E1.11) with wetted examination requirements and areas. Replaced examination surface areas (which were acceptance criteria as stated in its method VT-3 with general visual. previously included in E1.12 footnote February 21, 2002, submittal.
- 4) does not eliminate or reduce any required examination areas. The 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
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination 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.
E1.20 Added BWR to item N/A description. Replaced examination This item is not applicable to the Table 2500-1 method VT-3 with general visual. Palisades containment.
Cat. E-A (cont) E1.30 Added item for moisture Acceptable with licensees barriers with a general visual Moisture barriers were previously commitments for general visual required each period. included in examination category E- examination requirements and D with a VT-3 required each interval. acceptance criteria as stated in its Examining moisture barriers more February 21, 2002, submittal.
frequently will assure reliable detection of conditions adverse to containment integrity.
This is editorial change.
All item no.s - Replaced reference Acceptable.
to IWE-3510 for examination Nonsignificant - Previously some requirements with IWE-2310. examination requirements were contained in IWE-3500. They now
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination exist in IWE-2300 as discussed This is editorial change.
Notes - Revised to specifically above. Acceptable.
include welds and bolting as part of the pressure retaining boundary Welds and bolting were previously requiring examination. included in examination categories E-B, E-F and E-G. Including these items in the examination category for the containment pressure retaining boundary provides for more efficient program implementation without adversely affecting component integrity.
10 CFR 50.55a makes Table 2500-1 Pressure retaining welds are now Deleted examination category containment weld inspections Cat. E-B included in examination category E-which addressed pressure retaining optional. Acceptable.
A as addressed above. 10 CFR welds.
50.55a makes containment weld inspections optional.
Acceptable with licensees Table 2500-1 E4.11 Replaced examination The conditions of distress or commitments for detailed visual Cat. E-C method VT-1 with detailed visual. deterioration which would be examination requirements and detected by a VT-1 are the same acceptance criteria as stated in its conditions that will be detected by February 21, 2002, submittal.
the described detailed visual examination, as discussed in IWE-2300 above.
E4.12 Added grid line intersections The added wording clarifies The recommended ultrasonic to description of parts examined. inspection requirements and
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination Changed examination method from ensures repeatability in the location gridline sample requirements volumetric to ultrasonic thickness. of subsequent thickness provide a more practical approach measurement points. to augmented container examinations. Acceptable.
All item no.s - Added examination Previously no references existed for This is editorial change.
requirement paragraph number examination requirements. These references. Updated references in requirements have been added to Acceptable.
Acceptance Standard and Extent IWE-2300 and 2500 as discussed and Frequency columns. above. Adding new references and updating paragraph numbers ensure proper requirements are applied to examinations.
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.
Change from three consistent with the requirements for class 2 components.
Appendix J, Type A test is Table 2550-1 Deleted examination category Moisture barriers have been considered sufficient for Cat. E-D which addressed seals, gaskets included in examination category E-determining the leak-tight integrity and moisture barriers. A as addressed above. Seals and
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination 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.
10 CFR 50.55a makes Table 2550-1 Deleted examination category Dissimilar metal welds are now containment weld inspections Cat. E-F which addressed dissimilar metal included in examination category E-optional. Acceptable.
welds. A as addressed above.
1992 Edition required VT-1 of Table 2550-1 Deleted examination category Pressure retaining bolting is now bolting when a connection is Cat. E-G which addressed pressure retaining included in examination category E-disassembled. Licensee has bolting. A as addressed above.
committed to this. The licensee 1992 Edition required VT-1 of bolting provided this additional information when a connection is disassembled. regarding inspection of bolted The 1998 Edition requires general connections when connection is visual, in place, with no requirement disassembled in its February 21, when joint is disassembled. 2002, submittal.
Deleting Examination Cat. E-P, Table 2550-1 Deleted examination category Appendix J testing is mandated by provides relief to licensee without Cat. E-P which addressed 10CFR50 plant technical specifications.
affecting component integrity.
Appendix J testing for all pressure Removing this duplicate requirement Since Appendix J test is already retaining components. from IWE does not adversely affect
IWE Changes between IWE Licensees statement of significance Paragraph 1992 Edition/Addenda. and and/or basis for Comments (1992 Ed.) the 1998 Edition use as an alternative examination component integrity. required by Technical Specification. Acceptable.
The new requirements provide
Added new Table IWE-2500 The new requirements provide for consistency and repeatability in Ultrasonic Thickness consistency and repeatability in obtaining thickness measurements Measurements For Augmented obtaining thickness measurements and thus assure the reliable Examinations - which details and thus assure the reliable detection of conditions adverse to gridline spacing and thickness detection of conditions adverse to containment integrity.
measurement requirements. containment integrity.
Acceptable.
Table IWE- Deleted table. Nonsignificant - the contents of the This is a editorial change.
3410-1 previous table are adequately Acceptable.
addressed in IWE-3500.
PALISADES PLANT -- IWL COMPARISON IWL Changes between IWL Licensees statement of Paragraph 1992 Edition/Addenda. and significance and/or basis for Comments (1992) the IWL 1998 Edition use as an alternative examination This is editorial change. Acceptable.
1100 ASME Section XI generic Nonsignificant wording change from repair, replacement and/or modification terms to repair/replacement activities 1200 No change N/A 1210 No change N/A 1220 No change N/A This is editorial change. Acceptable.
2100 Changed Inspection to Nonsignificant General in heading.
Provided reference to IWA-2000 The additional general IWL examinations will not require the with exceptions from IWA-2210 requirements invoked by reference visual examinations identified in IWA-and 2300 for visual examinations to IWA-2000 where none were 2100. Personnel will not have to be and for qualification of visual referenced previously further certified to CP-189 (IWA-2300),
examination personnel. assure containment integrity. The whereas the NMC Containment exceptions from IWA-2210 and Inspection Program will specify the IWA-2300 are significant in that requirements for personnel the related previous requirements certification in accordance with SNT-have been changed and TC-1A and CP-189 as specified in its incorporated into IWL-2310. February 21, 2002, submittal. This is acceptable.
ATTACHMENT 2
IWL Changes between IWL Licensees statement of Paragraph 1992 Edition/Addenda. and significance and/or basis for Comments (1992) the IWL 1998 Edition use as an alternative examination This is editorial change. Acceptable.
2200 Deleted reference to IWL-2500. The reference to IWL-2500 in the 1992 Addenda was incorrect. The preservice examination requirements were always to be performed in accordance with IWL-2210, IWL-2220, and IWL-2230.
This is a non-significant change associated with a subsequent inquiry.
2210 No change N/A 2220 No change N/A 2230 This is editorial change. Acceptable.
ASME Section XI generic Nonsignificant change from repair and/or replacement to repair/replacement activities.
The specific paragraphs IWL-2310, 2300 No change; content changes are The philosophy of Subsection IWL and IWL-2320 are changed as in IWL-2310. to be an engineering inspection discussed below. The NMC has program under the direction of the submitted additional commitments, as Responsible Engineer is contained detailed in Containment Relief in this revised subarticle. This Request CRR-09. Reference to the individual will be accountable for applicable additional commitments are the entire inspection program identified in the discussion below.
which will meet or exceed the level of quality and safety defined in the
IWL Changes between IWL Licensees statement of Paragraph 1992 Edition/Addenda. and significance and/or basis for Comments (1992) the IWL 1998 Edition use as an alternative examination 1992 Edition.
2310 The changes to IWL-2310 are summarized by the following four items:
(a) replaced VT-1C and VT-3C (a) The VT-3C and VT-1C The owner-defined visual examination visual examination terminology inspections of IWL have been requirements of the 1998 Edition do with new general visual and replaced by Owner (Responsible not provide uniformity and consistency detailed visual examination Engineer) defined general and throughout the industry. The general terms. detailed visual examinations, and detailed visual examinations are respectively. The general and equivalent to the VT-3C and VT-1C detailed visual examinations are examinations in terms of assessing equivalent to the VT-3C and VT-the general condition and potential for 1C examinations in terms of deterioration within the containment assessing the general condition system. The licensee provided details and potential for deterioration of its visual examination methods in its within the containment system.
February 21, 2002, submittal. The The definition of critical licensees proposed alternative is examination items and acceptable acceptable.
conditions has not changed.
Therefore, any conditions adversely affecting quality or safety are not impacted by this change.
(b) Eliminated reference to IWA- (b) Direct visual examination is not The licensee's visual examination 2210 for illumination levels, practical on all areas of requirements addressing illumination,
IWL Changes between IWL Licensees statement of Paragraph 1992 Edition/Addenda. and significance and/or basis for Comments (1992) the IWL 1998 Edition use as an alternative examination examination distances and containment surfaces. The examination distances, and resolution resolution requirements. previous VT-3 requirements requirements are defined in precluded the ability to Containment Relief Request CRR-09, demonstrate that remote visual Proposed Alternatives, item 2), in its examination was equivalent to February 21, 2002, submittal. This is direct visual examination. acceptable.
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- (c) Requiring an owner defined The licensee will meet all the 2300 for concrete examination program provides for more efficient requirements of IWA-2300 of the 1992 personnel qualification program implementation by Addendum as specified in requirements with provisions for permitting personnel performing Containment Relief Request CRR-09, the owner to define the containment examinations to be Proposed Alternative, item 2, in its examination personnel qualified to written practices that February 21, 2002, submittal. This is qualification requirements. are more consistent to those used acceptable.
for other NDE personnel.
(d) Added requirement for the (d) Examination of wires or strands The licensee will meet all the Owner to define requirements for are performed by qualified requirements of IWA-2300 of the 1992 visual examination of tendon subcontract quality control Addendum as specified in anchorage hardware, wires, or personnel as part of a tendon Containment Relief Request CRR-09, stands. surveillance inspection contact. Proposed Alternative, item 2, in its The examinations meet the February 21, 2002, submittal. This is
IWL Changes between IWL Licensees statement of Paragraph 1992 Edition/Addenda. and significance and/or basis for Comments (1992) the IWL 1998 Edition use as an alternative examination requirements of IWL-2523.2. acceptable.
This is editorial change. Acceptable.
2320 Changed wording slightly. Nonsignificant - clarifies wording Made the ASME Section XI Nonsignificant This is editorial change. Acceptable.
generic change from repair and/or replacement to repair/replacement activities.
Added a responsibility for the The added pressure test The added additional responsibility for Responsible Engineer to review responsibilities for the Responsible the Responsible Engineer ensures certain pressure test procedures. Engineer ensures proper completeness and consistency in performance of pressure testing pressure testing activities.
activities. Acceptable.
N/A 2400 No change N/A Acceptable, licensee states that credit 2410 Added to paragraph (c) a This change insures that all for both intervals will not be taken.
condition which allows for surfaces that can be inspected are deferral of concrete visual examined, but recognizes the examinations to the next personnel safety of the inspectors.
scheduled plant outage for inaccessible portions of concrete surface.
2420 No change N/A This is editorial change. Acceptable.
2421 Changed wording for sites with Nonsignificant - clarifies wording more than one plant. Changed and accommodates plant life
IWL Changes between IWL Licensees statement of Paragraph 1992 Edition/Addenda. and significance and/or basis for Comments (1992) the IWL 1998 Edition use as an alternative examination frequencies by adding and extension.
every 10 years thereafter.
2500 No change N/A This is editorial change. Acceptable.
2510 Changed heading. Nonsignificant Changed wording consistent with Nonsignificant This is editorial change. Acceptable.
the changes to IWL-2310 addressed above.
In (a), eliminated the reference This is an editorial change for This is editorial change. Acceptable.
to the specific revision (R-68) of consistency in the Code. The ACI 201.1. revision of referenced documents are contained in Table IWA-1600-1 which still requires the same revision as specified in the 1992 Addenda.
Added two new subparagraphs The added details ensure proper The added details ensure proper (b) and (c) providing more tendon anchorage area tendon anchorage area examinations.
detailed examination examinations. The addition of (c) The addition of (c) is consistent with requirements for tendon is consistent with the rule in 10 the rule in 10 CFR 50. Increase level anchorage areas. CFR 50. of quality and safety of examinations.
Acceptable.
2520 No change N/A This is editorial change. Acceptable.
2521 Changed random sample Nonsignificant - the random
IWL Changes between IWL Licensees statement of Paragraph 1992 Edition/Addenda. and significance and/or basis for Comments (1992) the IWL 1998 Edition use as an alternative examination wording in (a) sample was always by type of tendon as shown in Table IWL-2521-1.
The added details ensure proper 2522 Changed the heading and added The added details ensure proper tendon examinations. Acceptable.
a subparagraph to address tendon examinations.
tendon elongation.
2523 No change N/A Acceptable with licensees 2524 Changed wording consistent with Nonsignificant commitments for visual examination the changes to IWL-2310 requirements and acceptance criteria addressed above.
as stated in its February 21, 2002, submittal.
This is editorial change. Acceptable.
2525 Changed wording for sample Nonsignificant analysis.
The added details ensure tendon 2526 Added a subparagraph The added details ensure tendon integrity . Acceptable.
addressing replacement of integrity and provide the corrosion protection medium. Responsible Engineer options from which to specify corrosion medium replacement.
3100 No change N/A 3110 No change N/A This is editorial change. Acceptable.
3111 ASME Section XI generic Nonsignificant change from repair and/or
IWL Changes between IWL Licensees statement of Paragraph 1992 Edition/Addenda. and significance and/or basis for Comments (1992) the IWL 1998 Edition use as an alternative examination replacement to repair/replacement activities.
3112 No change N/A This is editorial change. Acceptable.
3113 ASME Section XI generic Nonsignificant change from repair and/or replacement to repair/replacement activities.
3120 No change N/A 3200 No change N/A This is editorial change. Acceptable.
3210 Removed the word concrete Nonsignificant from the heading.
The added details ensure tendon 3211 Added tendon end and The added details ensure tendon integrity . Acceptable.
anchorage areas to the scope of integrity and provide the the subparagraph and added Responsible Engineer options from corrosion protection medium which to specify corrosion medium leakage and end cap replacement.
deformation as acceptance criteria attributes.
ASME Section XI generic Insignificant This is editorial change. Acceptable.
change from repair and/or replacement to repair/replacement activities.
3212 No change N/A
IWL Changes between IWL Licensees statement of Paragraph 1992 Edition/Addenda. and significance and/or basis for Comments (1992) the IWL 1998 Edition use as an alternative examination This is editorial change. Acceptable.
3213 ASME Section XI generic Nonsignificant change from repair and/or replacement to repair/replacement activities.
3220 No change N/A This is enhancement to the 3221 Added acceptance criteria The additions to the acceptance acceptance examination. Acceptable.
attributes for pre-stress loss criteria of IWL-3221 have provided prediction, tendon elongation, further assurance that the free water content and corrosion Responsible Engineer will evaluate protection medium reduction. all potential conditions that could impact the post-tensioning system integrity. These enhancements to the 1998 Edition increase the level of quality of the inspection program and have no adverse impact on the safety of the inspection program described in 1992 Edition. These additions are consistent with the requirements of the rule as stated in 10 CFR 50.55a. .
3222 No change N/A This is editorial change. Acceptable.
3223 ASME Section XI generic Nonsignificant change from repair and/or replacement to repair/replacement activities.
IWL Changes between IWL Licensees statement of Paragraph 1992 Edition/Addenda. and significance and/or basis for Comments (1992) the IWL 1998 Edition use as an alternative examination 3300 No change N/A This nonsignificant change is for site 3310 Added applicability for other The NMC is a single unit site.
with more than one unit. Acceptable.
plants at the same site. Nosignificant ASME Section XI generic Nonsignificant The is editorial change. Acceptable.
change from repair and/or replacement to repair/replacement activities.
Acceptable. The regulations do not 3320 Deleted paragraph which Nonsignificant - there were no require licensees to submit their addressed engineering submittal or retention requirements containment inspection programs.
evaluations being subject to changed by the deletion of the review by authorities. subparagraph. The regulations do not require licensees to submit their containment inspection programs.
This is editorial change. Acceptable.
4000 ASME Section XI changes from Nonsignificant - all related repair repair and/or replacement to and replacement requirements repair/replacement activities. have been consolidated into IWL-4000.
4100 No change N/A The exempted items are non structural 4110 Exempted grease cups and Nonsignificant - the exempted items. Acceptable.
installation screws from the items are non structural items.
scope.
IWL Changes between IWL Licensees statement of Paragraph 1992 Edition/Addenda. and significance and/or basis for Comments (1992) the IWL 1998 Edition use as an alternative examination ASME Section XI generic Nonsignificant change from repair and/or This is editorial change. Acceptable.
replacement to repair/replacement activities.
This is editorial change. Acceptable.
4120 Reworded to use the new Nonsignificant repair/replacement activity wording and combined paragraph (a) and (b). Changed the paragraph reference to the Repair/Replacement Program and Plan to address paragraph renumbering in IWA-4000.
This is editorial change. Acceptable.
4200 ASME XI generic change from Nonsignificant repair and/or replacement to repair/replacement activities.
Added a paragraph number Nonsignificant, this is a paragraph This is editorial change. Acceptable.
(IWL-4210) to the information numbering change from the 1992 included under IWL-4200 and Edition.
changed terminology from repair and/or replacement to repair/replacement activities.
Changed paragraph number to This is editorial change. Acceptable.
4210 Nonsignificant 4220, removed the word repair from heading and changed referenced paragraph numbers
IWL Changes between IWL Licensees statement of Paragraph 1992 Edition/Addenda. and significance and/or basis for Comments (1992) the IWL 1998 Edition use as an alternative examination consistent with the addition of a new paragraph 4210 above.
This is editorial change. Acceptable.
Changed wording consistent with Nonsignificant the changes to IWL-2310 addressed above.
This is editorial change. Acceptable.
ASME Section XI generic Nonsignificant change from repair and/or replacement to repair/replacement activities.
This is editorial change. Acceptable.
Changed repair material to new Nonsignificant material in several places.
This is editorial change. Acceptable.
4220 Changed paragraph number to Nonsignificant 4230.
This is editorial change. Acceptable.
4230 Changed paragraph number to Nonsignificant 4240 and clarified by removing the word repair.
ASME Section XI generic Nonsignificant This is editorial change. Acceptable.
change from repair and/or replacement to repair/replacement activities.
Added detailed requirements for The added detailed requirements The added detailed requirements the contents of a ensure proper repair/replacement ensure proper repair/replacement plan
IWL Changes between IWL Licensees statement of Paragraph 1992 Edition/Addenda. and significance and/or basis for Comments (1992) the IWL 1998 Edition use as an alternative examination repair/replacement plan. plan development for post- development for post-tensioning tensioning systems. systems. Acceptable.
This is editorial change. Acceptable.
4300 ASME Section XI generic Nonsignificant change from repair and/or replacement to repair/replacement activities.
This is editorial change. Acceptable.
5100 ASME Section XI generic Nonsignificant change from repair and/or replacement to repair/replacement activities.
5200 No change N/A This is editorial change. Acceptable.
5210 ASME Section XI generic Nonsignificant change from repair and/or replacement to repair/replacement activities.
5220 No change N/A This is editorial change. Acceptable.
5230 Changed wording by removing Nonsignificant - the removed some specific IWE related wording was IWE specific and is requirements while maintaining contained in IWE-5000.
the reference to IWE-5000.
This is editorial change. Acceptable.
5240 Deleted paragraph which Nonsignificant - the schedule of addressed the scheduling of pressure tests are contained in
IWL Changes between IWL Licensees statement of Paragraph 1992 Edition/Addenda. and significance and/or basis for Comments (1992) the IWL 1998 Edition use as an alternative examination pressure tests. IWE-5000 as referenced in IWL-5230.
This is editorial change. Acceptable.
5250 Changed wording regarding the The clarified role of the role of the Responsible Engineer Responsible Engineer ensures in pressure test activities. proper pressure test procedures and examinations.
ASME Section XI generic Nonsignificant change from repair and/or This is editorial change. Acceptable.
replacement to repair/replacement activities.
Changed visual examination The visual examination Acceptable with licensees terminology consistent with the terminology changes are commitments for visual examination changes to IWL-2310 addressed discussed in IWL-2310 above.
requirements and acceptance criteria above.
as stated in its February 21, 2002, submittal.
This is editorial change. Acceptable.
5260 Changed heading from Nonsignificant Corrective Measures to Corrective Action.
This is editorial change. Acceptable.
ASME Section XI generic Nonsignificant change from repair and/or replacement to
IWL Changes between IWL Licensees statement of Paragraph 1992 Edition/Addenda. and significance and/or basis for Comments (1992) the IWL 1998 Edition use as an alternative examination repair/replacement activities.
This is editorial change. Acceptable.
5300 ASME Section XI generic Nonsignificant change from repair and/or replacement to repair/replacement activities.
This is editorial change. Acceptable.
7000 Deleted Article including IWL- Nonsignificant - all related repair 7100, 7110, 7120 consistent with and replacement requirements the IWL-4000 changes above. have been incorporated into IWL-4000.
Table The changed item L1.11provides for Changed item L1.11 from all The addition of accessible areas 2500-1 more practical examination areas to all accessible areas. provides consistency with the implementation than previous requirements of the scope, of IWL-requirements. Acceptable.
1000.
Changed the VT-3C, VT-1C, and The visual examination Acceptable with licensees VT-1 examinations with general terminology changes are commitments for visual examination and detailed visual examination discussed in IWL-2310 above. The requirements and acceptance criteria respectively, to be consistent acceptability of the change to the as stated in its February 21, 2002, with the terminology in general and detailed visual submittal.
paragraph IWL-2310 changes inspections is discussed with IWL-above. 2310.
Note: the item L1.12 examination method in the 1998 Edition contains a publication error. The "general visual" should be "detailed visual".
IWL Changes between IWL Licensees statement of Paragraph 1992 Edition/Addenda. and significance and/or basis for Comments (1992) the IWL 1998 Edition use as an alternative examination The repetitive periods of tendon Table Changed inspection periods to Nonsignificant - accommodates inspection every 5th year is provided in 2521-1 state every 5th year in lieu of plant life extensions for tendon Note 4 instead of previously shown in listing out each year and examinations.
the table. Acceptable.
changed note 2 for having to meet acceptance criteria from each of the earlier inspections to for the last 3 inspections.
The additional test method options Table Added optional test methods for Nonsignificant - additional test provides for more flexibility.
2525-1 corrosion protection medium method options provides for more Acceptable.
analysis. practical test implementation.
Added acceptance criteria for Previous acceptance criteria was Table water content. noted as "in course of 2525-1 preparation." Providing the Providing the acceptance criteria of (cont) acceptance criteria assures water contents assures consistent in consistent implementation. implementation. Acceptable.