ML20199D215
| ML20199D215 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 01/11/1999 |
| From: | Passwater A UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ULNRC-3938, NUDOCS 9901200031 | |
| Download: ML20199D215 (24) | |
Text
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.- Union Elzctric one Ameren Plaza 4
1901 Chouteau Avenue i PO 130x 66149 St. touis, M0 63166-0149 314 rtt.3222 January 11,1999 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop PI-137 Washington, DC 20555-0001 Gentlemen: ULNRC-3938 hl.
gg DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1
- E UNION ELECrR>C CO.
FACILITY OPERATING LICENSE NPF-30 RELIEF REQUEST TO ALLOW THE USE OF THE 1998 EDITION OF ASME SECTION XI. SUBSECTION TWE In the Federal Register dated August 8,1996, (Vol. 61, No.154, 41303) the Nuc1 car Regulatory Commission (NRC) amended its regulations to incorporate, by reference, the ASME Code,Section XI, Subsection IWE,1992 Edition, through the 1992 Addenda. Subsection IWE is titled " Requirements For Class MC and Metallic Liners of Class CC Components of Light-Water Cooled Plants".
Pursuant to the provisions of 10CFR 50.55a(a)(3)(i), AmerenUE hereby requests relief to use the 1998 Edition of ASME Section XI, Subsection IWE in lieu of the 1992 Edition and 1992 Addenda of the Code. The 1998 Edition to the Code has been approved by the American Society ofMechanical Engineers.
A summary describing the significant changes in the 1998 Edition from the 1992 Edition as well as the impact on Callaway Plant is attached. This summary demonstrates the acceptability of the 1998 Edition for maintaining the integrity of the containment stnicture. In addition, a paragraph by paragraph comparison of g\'
the 1998 code to the 1992 code is included to aid in your review. This comparison providesjustification for the use of the 1998 Code. Implementation of the 1998 Edition of ASME Section XI, Subsection IWE will reduce cost, radiation exposure and personnel risk, but will not reduce component safety, quality or integrity. x 9901200031 DR 990111 p ADOCK 05000483 PDR n 1
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a subsidiary of Ameren Corporation
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', . I ULNRC-3938 l 1
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I The next scheduled refueling outage is October 1999. In order to !
complete the development of plans and procedures for examination of {
containment surfaces for Refuel 10, approval is requested by August 6,1999. j
) l l c susss "
j I A. C. Passwater ,
Manager, Corporate Nuclear Semees ;
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' STATE OF MISSOURI ) . I
) SS CITY OF ST. LOUIS ) i l )
l' Alan C. Passwater, of lawful age, being first duly !
sworn upon oath says that he is Manager, corporate Nuclear !
Services for Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
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By ##
l Alan C. Passwater l Manager, Corporate Nuclear Services '
SUBSCRIBED and sworn to before me this of dw/a*/ ' , 1999.
bd day
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icn* GWP3 *mi PATRICIA L REYNOLDS MRMlY MSUC-4TATEOF MMBOUM ST. LOUIS COUNTY Mr(Xamme101tEXPifEB 08.22,2000 i
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i cc: M. H. Fletcher Professional Nuclear Consulting, Inc. ,
19041 Raines Drive Derwood, MD 20855-2432 p / .
Regional Administrator i l U.S. Nuclear Regulatory Commission :
- Region IV l
611 Ryan Plaza Drive l Suite 400 l i Arlington, TX 76011-8064 !
l l Senior Resident Inspector
! Callaway Resident Office U.S. Nuclear Regulatory Commission l 8201 NRC Road f
Steedman, MO 65077 Mr. Mel Gray (2)
Office of Nuclear Reactor Regulation :
L U.S. Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E16 j
- i. I1555 Rockville Pike
- Rockville, MD 20852-2738 l
l Manager, Electric Department Missouri Public Service Commission P.O. Box 360
! Jeff'erson City, MO 65102 l-
- ULNRC-3938 Attachment 1 RELIEF REQUEST ALTERNATIVE INSPECTION OF CONTAINMENT METALLIC LINER SYSTEM (S)/ COMPONENT (S) FOR WIIICH RELIEF IS REOUESTED
This relief request applies to the metallic containment and penetration liners and their integral attachments.
CODE REOUIREMENTS FOR WIIICII RELIEF IS REOUESTED:
American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI, Subsection IWE, " Requirements for Class MC and Metallic Liners of Class CC Components of Light-Water Cooled Power Plants," 1992 Edition and 1992 Addenda. :
PROPOSED ALTERNATIVE:
Perform the metallic liner inspections using the 1998 Edition of ASME Section XI, Subsection l
IWE.
HASIS FOR RELIEF:
The 1992 Edition with the 1992 Addendum of ASME Section XI, Subsection IWE governs the requirements for both Class MC and metallic liners of Class CC pressure retaining components of containment structures oflight-water cooled plants. Callaway Plant's containment structure is a Class CC post tensioned, reinforced concrete structure with a metallic liner, which falls under the requirements of this section of the ASME Code. The 1992 Edition with the 1992 Addenda of Subsection IWE contains requirements which impose difficulties in the transition from the current ISI program and Appendix J program to a program that includes containment ISI examinations. Development and implementation of a meaningful containment ISI program would be facilitated by adopting the examination requirements of the 1998 Edition of ASME Section XI, Subsection IWE. These alternative examinations provide for consistency with the existing programs in the qualification of nondestructive examination personnel as well as providing more practical requirements for the examination of containment pressure retaining l components.
The 1998 Edition of ASME Section XI, Subsection IWE has some significant changes from the requirements of the 1992 Addendum of this Code. These changes will provide for an effective !
inspection program at Callaway Plant while maintaining the structural integrity of the containment structure at a reasonable cost, keep radiation exposure ALARA and keep personnel safety risk to a minimum. Two of the more significant changes are summarized in detail below. i All the changes are compared on a paragraph by paragraph basis in our relief request along with thejustifications for using the 1998 addition in lieu of the 1992 Code.
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% ULNRC-3938 Attachment 1 l
l The first significant change in the 1998 Code from the 1992 Code is the addition of Section
! IWE-2100.
i IWE-2100 GENERAL ,
The requirements ofIIVA-2000 apply, except the requirements ofIIVA-2300, llVA- l 2500 andIIVA-2600 are not mandatoryfor Table llVE-2500 visual examinations. >
(1998 Code)
The significance of this addition to the 1998 Code will be discussed below.
- All of Section IWE-2300 is new to the 1998 Code, which spells out the requirements for visual examinations. The most significant change is Section IWE-2310 IWE-2310 VISUAL EXAMINATIONS (1998 CODE) l (a) The Owner shall define requirements for visual examination of containment surfaces.
i Section IWE-2310(a) gives plants some options from the strict requirements of the 1992 Code !
which require the use of ASME Section XI, Subsection IWA-2210 for visual inspections of the !
entire pressure boundary. IWA-2210 requires the visual inspection be made from a maximum l direct examination distance of four (4) feet with minimum illumination requirements. However, i final rule 10CFR50.55a(b)(2)(x)(B) allows for the examination to be made by remote methods ,
such as a camera or optical aids provided it can be demonstrated that the remote methods can j give equal or better results as the direct examination method. In an operating plant, the only time I this inspection can be made is during a plant shutdown such as a refueling outage. In order to l meet the 4 foot maximum examination distance, some sort ofinspection device would have to be j suspended from polar crane support beams or other structural points or a considerable amount of j scaffold would have to be erected to inspect the liner plate. This activity would add a significant amount of time and expense to any refueling outage. The polar crane would have to be taken out of service for safety reasons while the inspections are being performed. Consequently it will ,
take a considerable amount of time to complete the inspection by this method as well as l increasing radiation exposure and increasing personnel safety risk. If the remote inspection method is employed it would require the use of some sort of optical aids such as special video camerr.s, special binoculars or telescope in order to get resolution anywhere near what one could see from 4 feet. These systems are mostly untried with results less than desirable. While this method would eliminate or greatly reduce the personnel safety issue, it would still demand a considerable amount of resources and require a significant amount of time to complete due to the very small field of view of the optical aids. Furthermore, Section IWE-2310(b) states-i l
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ULNRC-3938 Attachment 1 I
(b) General visual examinations shall be performed in accordance with Ill'E-2500 and Table 1\l'E-2500-1, Examination Category E-A to assess the i general condition ofcontainment surfaces.
I l Under this section of the Code, General Visual examinations of 100% of the accessible pressure boundary components are required each period. This is also required by Final Rule, l 10CFR50.55a(b)(2)(x)(E) so it is not actually a change. Callaway Plant is a PWR with a dry l
containment and as such, the metallic liner is not subjected to areas of standing water, repeated i wettiny, and drying or other environmental factors that would accelerate corrosion. Therefore, <
l because Callaway Plant's liner plate is in a very low corrosive environment, an inspection ;
l program can be developed using a general visual examination that will detect any significant l l deterioration without exposing personnel to dangerous high fall hazards or impacting the outage I schedule. By using existing vantage points such as platforms, maintenance truss, and the polar l crane coupled with employing special lights and standard optical aids, Callaway Plant will be able to inspect 100% of the accessible surfaces of the liner plate each period. Callaway Plant will ,
define visual examination resolution requirements to be employed with the general visual examination that are meaningful and practical which will allow Inspectors to detect minor deterioration before it becomes significant. If the general visual inspection reveals " suspect" i areas of the pressure boundary, IWE-2310(c) states:
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(c) Detailed visual examinations shall be performed in accordance with Ill'E-2500 and Table 111'E-2500-1, Examination Category E-C: \
(2) to determine the magnitude and extent of deterioration and distress of suspect containment surfaces initially detected by general visual examinations.
l Under these conditions, AmerenUE would employ a detailed visual examination such as a VT-1 :
- or VT-3 depending on the conditions to assure structural integrity of the pressure boundary. I Callaway Plant's current inspection process, which is required under the Appendix J program, j l uses a general visual inspection method and has been effective in identifying minor problems in l l our pressure boundary. When minor problems were detected, they were closely inspected by an !
l Engineer knowledgeable in the design of the Reactor Building and corrected under Callaway l Plant's current work programs. To date only minor coatings problems have been detected. The l development of written visual inspection methods which are specifically fitted to Callaway Plant l conditions and ASME Section XI, Subsection IWE, will enhance and improve an inspection l program that is already working for Callaway Plant.
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. l ULNRC-3938 l Attachment 1 l The change in bolting inspection is the second significant change in the 1998 Code from the 1992 Code. Section IWE-3515 of ASME Section XI,1992 cc,de required pressure retaining i bolting, that has not been disassembled anytime during the period, have a bolt torque or bolt l tension test performed per Table IWE-2500-1 by the end of the interval. Performance of a i maintenance activity to disassemble electrical covers to access bolted connections that are l
generally not disassembled, verifying torque or bolt tension on each bolt, would be a major j impact on resources. The 1998 Code does not require the pressure retaining bolted connections J l
to have a bolt torque or bolt tension test performed each interval. The 1998 Code does require l however, that 100% of all bolted connections have a general visual inspection each period unless l the connection is disassembled for some other reason. In that case, the connection would have a
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l VT-1 inspection and a bolt torque or bolt tension test performed as required by both codes. l l
Bolted joints are currently subject to Appendix J leak testing to verify leak tightness and structural integrity. The integrity of the Callaway Plant's bolted connections is demonstrated by l' existing programs which include Local Leak Rate Tests, Appendh J Integrated Leak Rate Tests, and the general visual inspections which have been performed as part of the Appendix J ILRT's.
Incorporating the general visual inspection requirements of the 1998 Edition of ASME Section I XI, Subsection IWE Code into Callaway's programs for monitoring bolted connection performance will assure the structural integrity and leak tightness of the connections. !
CONCLUSION:
AmerenUE is seeking relief to implement the 1998 Edition of ASME Section XI, Subsection IWE in lieu of the 1992 Edition and 1992 Addendum of this Code. The 1998 Edition of the l ASME Section XI Code was developed in accordance with the ASME Code committee puess l l with input from utilities, manufacturers, engineering organizations Authonzed Nuclear Inspection Agencies, EPRI and the NRC. The updating of requirements by this process is l intended to ensure the continued safe operation of nuclear power plants and specifically in this case the continued leak-tight and structural integrity of the metallic liner of our Class CC containment component. The use of the 1998 Edition of ASME Section XI, Subsection IWE at Callaway plant will provide for an effective inspection program which will maintain the structural integrity of the containment structure at a reasonable cost while keeping radiation exposure ALARA and keeping personnel safety risk to a minimum.
IMPLEMENTATION SCllEDULE:
The development of plu and procedures for examination of containment surfaces is scheduled to be completed prior 'o the next scheduled refueling outage in October 1999.
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. Dallaway Plant Relief Request ULNRC-3938 Attachment 2 l
l Para- Changes between IWE 1992 Ed.1992 Ad. Significance of change and or basis for l graph and the current IWE 1998 rewrite use as an alternative examination l
l IWE- No change N/A 1100 1200 No change N/A 1210 No change N/A l 1220 Changed " containment" to " containment system" Non significant I i i 1230 No change N/A 1231 Removed item 3) " single welded buttjoints These single welded buttjoint was removed ,
from the weldside"- as a specific item required a:, a separately listed examination item and is '
to remain accessible for the life of the plant. now included within the item for the pressure retaining boundary as discussed in the i changes to Table IWE-2500-1 below. j l
Changed wording from "80% ofthe surface The exclusions from 80% incorporate an -
area" to "80% ofthe pressure retaining existing Table IWE 2500-1 note and clarify l boundary" and stated exclusions from that 80%. that areas made inaccessible during construction are also excluded.
! Reworded paragraph b). Change to b)is for clarity and is non-significant. i i
1232 ASME XI generic change from repair and or Non significant i replacement to repair / replacement activities.
Deleted paragraph (a)(3) addressing inaccessible Weldedjoints were removed as a separately weldedjoints. listed examination items and are now included within the item for the pressure retaining boundary as discussed in the
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changes to Table IWE-2500-1 below. i l
1240 Added stiffeners and, by reference to IWE- While these items were not included in the 2420(b), flaws accepted by evaluation as areas 1992 Code directly, they were implied. The L requiring augmented examination. 1998 Code simply clarifies the requirements l l- of additional areas subject to augmented
, examination, further assuring containment i
' integrity.
j 2000 No change N/A 1 2100 Added new Subarticle 2100 " General"- to This is the first significant change in the 1998 provide reference to IWA-2000 with exceptions Code from the 1992 Code. This section was from IWA-2210,2300,2500 and 2600, added to the 1998 Code, which allows a plant I
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- Callaway Plant Relief Request ULNRC-3938 Attachment 2 l
Para- Changes between IWE 1992 Ed.1992 Ad. Significance of change and or basis for i graph and the current IWE 1998 rewrite use as an alternative examination l
2100 to define their own requirements for visual ,
(cont.) examination of containment surfaces. The benefits of using the 1998 Code as it pertains to this section will be discussed under ;
Sec.2310. ;
2200 Deleted paragraph c) which provided allowances This paragraph in the 1992 Code dealt with :
for the use of shop or field examinations in lieu preservice construction inspections. Callaway {
of on site preservice examinations. Plant has been in operation since 1984; i l therefore, this paragraph of the Code is not applicable to our plant.
l Deleted paragraph g) which required the The coatings that would be applied to the ,
l condition of new coating to be documented in the liner plate at Callaway Plant fall under our l preservice examination record. safety related coatings program as required by Regulation Guide 1.54. Callaway procedures
! are in place that control the type of coating, ;
! painter qualification, surface preparation, ;
! coating application, atmospheric conditions I l as well as QC inspection points for safety ;
l related coatings. The level ofinspection j l under this program is much higher than that '
- required by the 1992 addition of the ASME
! Section XI Code. Therefore, using the 1998 l
Code without this section will not reduce the l reliability of the containment pressure boundary.
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Non significant.
ASME XI generic change from repair and or replacement to repair / replacement activities.
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2300 Added new Subarticle 2300 " Visual The paragraphs within this subarticle are Examination, Personnel Qualification and considered significant and contain Responsible Individual" requirements that either did not previously exist or that were contained in other areas.
- Placing these requirements within Article IWE-2000 further ensures proper I
" Examination and Inspection" of areas important to containment integrity and provides consistency with Subsections IWB, IWC and IWD. The specific paragraphs added are discussed below.
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- . hollsway Plant Relief Rcquest ULNRC-3938 H Attachment 2 Para- Changes between IWE 1992 Ed.1992 Ad. Significance of change and or basis for graph and the current IWE 1998 rewrite use as an alternative examination 2310 Added new paragraph 2310 - Visual a) Section 2310 gives plants some options !
Examinations - which a) states that the owner from the strict requirements of the 1992 Code shall define requirements for visual examination which require the use ofIWA-2210 for visual i of containment surfaces; inspections. IWA-2210 requires the visual ;
, inspection be made from a maximum direct f examination distance of four (4) feet with minimum illumination requirements. The !
Code also allows for the examination to be i
made by remote methods such as a camera provided it can be demonstrated that the i remote methods can give the same results as ;
i the direct examination method. In an ,
operating plant, the only time this inspection i can be made is during a plant shutdown such !
as a refueling outage. In order to meet the 4 ,
foot maximum examination distance, a considerable amount of very high scaffolding would have to be erected to access the liner ;
plate for inspection, or some sort ofinspection t device, such as a man lift, would have to be suspended from polar crane support beams or other structural points to inspect the liner plate. Consequently the scaffold builders and inspectors will be placed at significant personal risk and increased radiation exposure for no apparent increase in Nuclear Safety over that which will be provided by the 1998 Code. Furthermore, this activity would add a ;
significant amount of time and expense to any refueling outage.
l The 1998 Edition of ASME Section XI, Subsection IWE-2310 (a) allows the Owner to ;
define the requirements for visual inspection of containment surfaces. Allowing the owner 1 l to define visual examination requirements provides for more efficient containment ISI program implementation by allowing examinations that may be more consistent l with existing ISI, containment coating, l-maintenance rule and Appendix J programs.
Callaway Plant is a PWR with a dry 4
containment and as such, the metallic liner is not subjected to areas of standing water, l
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- Callaway Plant Relief Request ULNRC-3938 Attachment 2 l Para- - Changes between IWE 1992 Ed.1992 Ad. Significance of change and or basis for graph and the current IWE 1998 rewrite use as an alternative examination 2310 repeated wetting and drying or other i (cent.) environmental factors that would accelerate j corrosion. Therefore, an inspector, using ,
special lights and optical aids from existing vantage points will be able to assure the !
integrity of the liner plate using the 1998 l Code.
l b) and c) defines general and detailed visual b) and c) The VT general examination, which ;
examinations; and would be defined as required by paragraph a), !
is performed to indicate the general condition j of the containment. Should any suspect areas }
be indicated during the general examination, a '
more detailed examination would be warranted. The VT detailed examination I would then be performed, as required by paragraph c) to determine the magnitude and extent of any deterioration or distress. This method ofinspection is practical from both an ALARA aspect as well as cost. A dry PWR containment, such as Callaway Plant, has large vast areas of the liner plate for which a general inspection is adequate to identify any I
deterioration of the liner. This method of inspection will provide a safe, reliable method I ofinspection while maintaining the integrity of the containment structure. )
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d) and e) provides the requirements for the d) and e) Previously these examination l
- conditions of areas afTected by requirements did not exist within the Article repair / replacement activities, painted or coated IWE-2000 but rather only in the acceptance '
areas, non-coated areas, and pressure retaining criteria of Article IWE-3000. Adding these materials and moisture barriers. specific attributes ensures proper containment examinations.
2320- Added new paragraph 2320 " Responsible a) The details for the responsible individual !
l Individual"- which a) states the qualification qualification requirements were previously i
- requirements of the responsible individual and contained in the acceptance standards of !
l IWE-3510.1. !
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'.. Callaway Plant Relicf Request ULNRC-3938 Attachment 2 i
l Para- Changes between IWE 1992 Ed.1992 Ad. Significance of change and or basis for i graph and the current IWE 1998 rewrite use as an alternative examination i
i 2320 b) Defines the responsibilities of the responsible b) The added detailed responsibilities for the !
(cont.) individual for the development of plans and responsible individual ensure proper ;
procedures; instruction, training and approval of performance of those related activities.
visual examination personnel; performance or Having an individual possessing the direction of visual examinations; evaluation of qualifications required by Section a) results and documenting results. performing the responsibilities required by [
- l. Section b) increases plant quality and safety ,
l by assuring the reliable detection of conditions adverse to containment integrity.
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- 2330 Added new paragraph 2330 " Personnel a) Adding requirements for the owner to
- define personnel qualification requirements Qualification"- which a) states that the owner is , ,
- responsible for defining the qualification provides for more efficient containment ISI '
requirements for personnel performing visual program implementation by permitting l ' examinations and personnel performing containment examinations to be qualified to written practices that are more consistent to those used for other NDE personnel.
l b) Provides minimum qualification requirements b) Providing these details in the qualification
- that were previously contained in the acceptance requirements paragraph focuses the
- criteria ofIWE-3510.1. containment visual qualification on areas important to containment integrity. l 2400 INSPECTION SCHEDULE -
l 2410 No change N/A l
2411 Deleted a subparagraph (b) discussing decreasing The deleted subparagraph eliminates i and extending inspection periods. duplication with IWA-2400. l l l 2412 The 1998 Code added a subparagraph detailing The added requirements for the scheduling of )
requirements for the scheduling of added welds added welds or components ensures that a {
or components. representative sampling of examinations is maintained. This is more restrictive than the l 1992 Code.
1 2420 (c) Removed " repaired" areas as areas requiring First of all, subparagraph (c) refers to areas !
l reexaminations and changed the duration for that indicated flaws or degradation and were I
reexamination of areas that remain essentially evaluated and found to be acceptable as is per !
! unchanged from "three consecutive inspection subparagraph (b) of this same section. Any i periods " to "the next successive inspection area that is repaired would not fall under this periott'. subparagraph because once the repairs are i
completed in accordance with approved plant procedures and inspected in accordance with j
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allaway Plant Relief Request- ULNRC-3938 Attachment 2
( Para- Changes between IWE 1992 Ed.1992 Ad. Significance of change and or basis for graph and the current IWE 1998 rewrite use as an alternative examination 2420 the Code, the effected area of the containment (cont.) structure is considered to be returned to "as designed condition". Areas that require {
reexamination per IWE-2420(b) are areas located in non augmented areas. Since these areas are falling under IWE-2420(c) they i have already been evaluated as acceptable as i is and if the augmented inspection on the next period (3 years) indicated no change, it would !
revert back to a general visual at the next inspection period. Since the entire pressure boundary is required to be inspected each period, amas affected by this section of the Code will continue to be inspected every ,
period for the life of the plant. This will , I proved a high level of assurance that the pressure boundary will remain sound.
2430.' Deleted the paragraph - Additional Examinations The changes to Table IWE 2500-1 eliminate
- which discussed adding examinations items of several examination categories. The the same category if flaws or areas of degradation categories that remain all require 100%
are identified during an examination. examination. Therefore no items are available for additional examinations.
2500 Reworded the existing subparagraphs consistent The reworded subparagraphs add clarity and with the previous paragraph changes and with provide consistency within IWE.
Table IWE-2500-1 changes.
1 i
Deleted the requirement to examine paint or Coatings are non-pressure retaining coatings prior to removal. components. Their primary function is to i provide a barrier to protect the substrate from ;
corrosion. Should some of the indicators that i X problems exist on the liner appear in the coatings such as cracking, peeling or i discoloration, the coating must be removed in order to determine the actual condition of the pressure boundary. Not having to perform 1 ASME examinations of non-pressure retaining coatings prior to removal provides ]
for a more efficient containment ISI program p
implementation without adversely affecting the integrity of the pressure retaining base metal being exposed.
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i LL 'Callaway Plant Relief Request ULNRC-3938 Attachment 2 Para- Changes between IWE 1992 Ed.1992 Ad. Significance of change and or basis for graph and the current IWE 1998 rewrite use as an alternative examination l 2500 2500(b)(1) changed the visual examination Subsection IWA-2240 allows the use of l (cont.) requirements for augmented examination of alternate examination methods for augmented i
surface areas identified in IWE-1242 from a . examinations using newly developed .
l VT-1 to " detailed visual". techniques provided the inspector is satisfied that the results are demonstrated to be equivalent or superior to a VT-1. This
- change will provide the same level of )
I inspection for augmented surfaces, it only i provides some options in the method as how l this is done.
Replaced the requirement for one foot square The new Table IWE 2500-2 provides more l grids in thickness measurements with a reference detailed requirements for thickness l to Table IWE 2500-2. measurement gridding and is discussed below.
I Added a reference to IWE-5000 for pressure The added reference to IWE-5000 provides l tests. direction for the performance of pressure test.
L 2600 Deleted a sentence discussing compatibility of Non pressure retaining paint and coatings are paint and coating systems and a requirement to covered in Callaway Plant's Safety Related examine the new paint. Coatings program. The removal of this sentence eliminates duplication of programs j thereby providing for a more efficient I containment ISI program for the same reason stated for paragraph 2200(g).
3000 ACCEPT & JT ANDARDS 3100 Rei r;ed the word nondestructive from the Non significant heading.
3110 PRESERVICE EMMINATIONS 3111 Replaced the n.ference to thble IWE-3410-1 Table IWE-3410-1 and paragraph IWE-3115 with a reference to subarticle IWE-3500. have been deleted and are discussed below.
Removed reference to paragraph IWE-3115. IWE-3500 adequately captures all of the ,
information previously contained in the deleted table and paragraph. !
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allaway Plant Relief Request ULNRC-3938 Attachment 2 Para- Changes between IWE 1992 Ed.1992 Ad. Significance of change and or basis for graph and the current IWE 1998 rewrite use as an alternative examination 3112 Replaced the reference to Table IWE-3410-1 Non significant with a reference to subarticle IWE-3500. ASME XI generic change from repair and or replacement to repair / replacement activities.
3114 Replaced the reference to Table IWE-3410-1 Non significant with a reference to subarticle IWE-3500. ASME XI generic change from repair and or >
replacement to repair / replacement activities.
3115 Deleted subparagraph which addressed repair Non significant - there were no submittal or programs and evaluations being subject to review retention requirements changed by the i by authorities. deletion of the subparagraph. These evaluations are covered in Subsection IWA. ;
3120 Removed the word nondestructive from the Non significant heading. !
3121 Removed the word nondestructive and deleted The removal of nondestructive is non- i references to IWE-3124 and IWE-3125 for the significant. The referenced subparagraphs i acceptance of flaws for continued service. did not actually apply to the acceptance of flaws for continued service. j i
3122 Replaced the references to Table IWE-2500-1 Non significant - the changes are for clarity l and to IWE-3000 with a reference to subarticle and to reconcile paragraph numbering. There l IWE-3500. ASME XI generic change from were no submittals or retention requirements repair and or replacement to repair / replacement changed by the deletion of the sentence ;
activities. Reworded several sentences. Deleted addressing evaluation reviews.
sentence which addressed evaluations being subject to review by authorities.
l 3124. Replaced the reference to Table IWE-3410-1 Non significant i with a reference to subarticle IWE-3500. ASME l XI generic change from repair and or l replacement to repair / replacement activities. 1 i
3125 Deleted subparagraph which addressed repair Non significant - there were no submittal or i programs and reexamination results being subject retention requirements changed by the !
to review by authorities. deletion of the subparagraph.
3130 No change - N/A !
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'Callaway Plant Relief Request ULNRC-3938 Attachment 2 l
Pcra- Changes between IWE 1992 Ed.1992 Ad. Significance of change and or basis for !
graph and the current IWE 1998 rewrite use as an alternative examination 3200 Added a statement to the end of the paragraph The added statement clarifies requirements i that states supplemental surface or volumetric and eliminates potential duplication or examinations are required when specified by the contradiction of requirements in stating that 1 engineering evaluation. the engineering evaluation requirements of IWE-3122 determine what and when supplemental examinations are required.
3410 Replaced the reference to Table IWE-3410-1 Non significant l
with a reference to subarticle IWE-3500. !
3430 No change N/A 3500 ACCEPTANCE STANDARDS 3510 Reconciled acceptance standards of this Section Previously, examination requirements were j with the addition of Section IWE-2300 and contained in the acceptance standards of changes made to Table IWE-2500-1 by: IWE-3500. This has been corrected by the addition of Section IWE-2300 VISUAL EXAMINATION, PERSONNEL
- QUALIFICATION, ANDRESPONSIBLE INDIVIDUAL.
l Adding the requirement in IWE-3510.1 that a) This change directly corresponds to the l l
The owner shall define acceptance criteriafor addition ofIWE-2310(a). The 1992 Code I visual examination ofcontainment surfaces; gave some general acceptance criteria that defined a " suspect" area, then stated such areas shall be accepted by engineering L evaluation. The 1998 Code permits the ;
Owner to spell out these acceptance criteria more in detail in their ISI Containment Inspection Program. Not all conditions can be !
defined in an inspection program, therefore l engineering evaluations will still be used.
Therefore, this change is considered minor i and non-significant. !
Removing the wording from IWE-3510.1 of the This wordhg is not contained in the new ]
1992 Code for responsible individual and for Section IWE-2320 and is simply a change in personnel qualifications; locating within the Code.
Combining 3510.2 and 3510.3 and removing Section IWE-3510.2 and IWE-3510.3 split specific VT-1 and VT-3 examination attribute the acceptance criteria for coated and non-wording; and coated surfaces into two different sections.
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dallaway Plant Relief Request ULNRC-3938 Attachment 2 Para- Changes between IWE 1992 Ed.1992 Ad. Significance of change and or basis for graph and the current IWE 1998 rewrite use as an alternative examination 3510 Section IWE-3510.1 of the 1998 Code (cont.) requires the Owner to define acceptance !
criteria for visual examinations; therefore ,
there is no need to differentiate between the two. i l By the incorporation of 3515 the acceptance All pressure retaining components are subject standards for bolting were changed from to a general visual inspection under the 1998 referencing material specs and torque or tension Code. This includes bolted connections. i limits to conditions affecting leak tight or 110 wever, if a bolted connection is not i structural integrity. disassembled for other maintenance activities,
)
it is also not subject to a torque or tension test. All bolted connections at Callaway Plant ,
are subject to Appendix J inspection. To . j date, the LLRT inspections performed on the i
, bolted connections have produced excellent j L results, indicating that Callaway Plant does not have a problem with the bolted l connections. Furthermore, the entire pressure boundary, which includes bolted connections, is subject to an ILRT once every period. The successful completion of this test, coupled with a general visual examination will assure structural integrity and leak tightness of the system while keeping radiation exposure ALARA and minimizing the impact on outage schedule. Ilowever, bolted connections that are disassembled anytime during the period are still subject to VT-3 inspections, which is unchanged from the ]
1992 Code. j i
3511 Renumbered paragraph IWE-3512 of the 1992 The subparagraph was renumbered based on
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Code to IWE-3511 in the 1998 Code. Reconciled the deletion of previous Section IWE-3511 of acceptance standards with the addition of Section the 1992 Code. Previously, examination ;
IWE-2300 changes to Table IWE-2500-1. requirements were contained in the j acceptance standards ofIWE-3500. This has 1 been moved to Section IWE-2300 of the 1998 Code. I c
Added the requirement that the owner shall The 1992 Code gave some general acceptance !
! define acceptance criteriafor visual examination criteria that delined a " suspect" area, then l ofcontainment surfaces; stated such areas shall be accepted by Page 10 of 16
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- Dallaway Plant Relief Request ULNRC-3938 Attachment 2 Ptra- Changes between IWE 1992 Ed.1992 Ad. Significance of change and or basis for graph and the current IWE 1998 rewrite use as an alternative examination 3511 engineering evaluation. The 1998 Code i (cont.) permits the Owner to spell out these l acceptance criteria in more detail in their ISI Containment Inspection Program. Not all conditions can be defined in an inspection program, therefore engineering evaluations will still be used. Therefore, this change is considered minor and non-significant.
Combined 3512.1 and 3512.2 with changes into These changes directly correspond to the 3511.2 and removed specific VT-1 examination addition ofIWE-2310(e)(1) and (2) discussed attribute wording; and above and eliminate potential duplication or contradiction of requirements.
Reworded ultrasonic examination subparagraph This change states that only Class MC stating that Class MC pressure retaining Pressure retammg components are subject to components that ultrasonic examinations detect the 10% material loss criteria. Metallic liners material loss in local areas exceeding 10% of the of Class CC pressure retaining components nominal wall thickness shall be documented. are not subject to this same requirement. The structural element of a Class MC containment is the metal shell. However, on a metallic liner of a Class CC containment, the structural element is the reinforced, post-tensioned concrete shell, therefore, the liner plate is a non-structural element and serves only as an air seal. At Callaway Plant the maximum load the liner plate would ever see is stress from wet concrete during construction of the plant because the liner was also used as a concrete form. The l pressure from a design basis accident is only 48.1 psi., therefore, a 10% reduction of the i liner plate is not significant to the structural !
integrity of containment. The liner plate is required to have a general visual inspected under the 1998 Code per Subsection IWE-l 2310. Any areas found that show any signs of deterioration would require further i evaluation per the Owners acceptance criteria as defined in their ISI program and required per IWE-3500. This would assure that the liner plate integrity would be maintained throughout the life of the plant.
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t Callaway Plant Relief Request ULNRC-3938 Attachment 2 Para- Changes between IWE 1992 Ed.1992 Ad. Significance of change and or basis for -
graph : and the current IWE 1998 rewrite use as an alternative examination l
l 3513 Deleted paragraph Section IWE-3513 of the 1992 Seals and gaskets previously required Code form the 1998 Code, which required examination once per interval for defects that L examination of seals, gaskets, and moisture - may violate leak-tight integrity. Leak-tight barriers. integrity is verified during each 10CFR50 App. J leak test. There are seals in electrical penetrations that would require disassembly H and determination of safety related electrical L circuitry, which could result in potential j L significant Nuclear Safety concerns.
- Furthermore, the 1992 Code, in Table 2500-1 for examination category E-G, note 5 states that bolt torque or tension test is required only l for bolted connections that have not been disassembled and reassembled during the inspection interval. This implies that the Owner is not expected to take apart every _.
bolted connection on the pressure boundary to perform inspections. Seals and gaskets can not be inspected unless thejoint is i l disassembled. Therefore, seals and gaskets -
- that are in bolted connections that are not l otherwise disassembled and pass the L
Appendix J leak testing are considered satisfactory..
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L 3511 & ~ Deleted paragraphs Section IWE-3511 and The Final Rule,10CFR50.55a(b)(2)(x)(C),.
3514 of Section IWE-3514 of the 1992 Code from the states that examinations in Category E-B and 1992_
1998 Code which dealt with examination of E-F are optional. The basis for this allowance I
pressure retaining welds and pressure retaining is that there is no evidence of problems Code.
dissimilar metal welds. associated with welds of this type and that radiation exposure required to conduct these examinations cannot be justified. The items I will be examined as part of the general visual l examination and the leak tightness verified i through 10CFR50, Appendix J testing. j Therefore, there is no change in the Final ;
, Rule as a result of these deletions. ;
e
! 4100: No change N/A J
e L l Page'12 of 16 l
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Callaway Plant Relief Request ULNRC-3938 Attachment 2 Para- Changes between IWE 1992 Ed.1992 Ad. Significance of change and or basis for graph and the current IWE 1998 rewrite use as an alternative examination 5200 SYSTEM TEST REQUIREMENTS 5210 No change N/A 5220 ASME XI generic change from repair and or Non significant replacement to repair / replacement activities.
5221 ASME XI generic change from repair and or Non significant - the requirement to meet the l replacement to repair / replacement activities. requirements of the Appendix J paragraph Removed the quotation of 10 CFR 50 Appendix J referenced is not affected by removing the paragraph IV.A. quoted App J paragraph. l 5222 ASME XI generic change from repair and or Non significant I replacement to repair / replacement activities.
5240 Replaced a reference to IWA 5240 with The addition of specific IWE examination requirements to perform detailed visual requirements during pressure testiag in lieu of examination of repair / replacement areas during referencing IWA general requirements pressure tests. focuses requirements on issues specific to ;
containment integrity and therefore provides l added assurance of the integrity of repaired / replaced areas.
5250 Changed Corrective Measures to Corrective Non significant Action in the heading. ASME XI generic change from repair and or replacement to repair / replacement activities.
7100 No change N/A l l
TABLE CHANGES :
Table No change N/A 2411-1 Table Replaced the separate entries for 1st and Non significant - The previous requirements l 2412-1 successive intervals with one entry for All for the 1st and successive intervals were ,
intervals. identical. Therefore combining the entries does not affect any requirements.
Table 2500-1 Revised EXAMINATION CATEGORIES E-A CAT. -
E-A Table l
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Callaway Plant Relief Request ULNRC-3938 ;
Attachment 2 l
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Para- Changes between IWE 1992 Ed.1992 Ad. Significance of change and or basis for !
graph and the current IWE 1998 rewrite use as an alternative examination :
2500-1 El.11 Revised frequency of examination from A general visual of 100% of the pressure CAT. " Prior to each type A test" to "100% during each retaining boundary is already required each j E-A PerimI'. period per 10CFR50.55a. This will include l an mspection pncr to a type A test.
(cont.) . l Therefore, is not a change from what is t already required and specific reference to the i Type A Test is not required.
l El.12 Redesignated item from " accessible Accessible surface area designation is now ;
l surface areas" to " wetted surfaces ofsubmerged included in El.11. Wetted surface areas were i areas". Replaced examination method VT-3 previously included in El.12 footnote 4. '
! with general visual. These changed do not eliminate or reduce any required examination areas. Requiring a !
general visual examination in lieu of a VT-3 i examination eliminates the more detailed examinations of areas with satisfactory ;
t general visual inspection results. The performance of the general visual will ,
L identify any areas of deterioration or distress. i l !
Any areas identified will then be subject to a t VT detailed examination to determine the magnitude and extent of those conditions.
The general visual inspection therefore allows for more efficient containment ISI program implementation without adversely affecting L containment integrity.
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L El.20 Added BWR to item description. This item is not applicable to Callaway Replaced examination method VT-3 with general Plant's containment because Callaway Plant L visual. is a PWR plant.
This item is not applicable to Callaway L E1.30 Added item for moisture barriers with a -
Plant's contamment, because we have no general VT required each period.
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' !- Dallaway Plant Relief Request ULNRC-3938 l Attachment 2 Para- ' Changes between IWE 1992 Ed.1992.Ad. Significance of change and or basis for j graph and the current IWE 1998 rewrite use as an alternative examination j Table All item no.'s - Replaced reference to IWE-3510 Non significant - Previously some j 2500-1 for examination requirements with IWE-2310. examination requirements were contained in CAT. IWE-3500. They now exist in IWE-2300.
E-A i Notes - Revised to specifically include welds and we:ds and bolting were previously included i (cont.) bolting as part of the pressure retaining boundary, in examination categories E-B, E-F and E-G. l requiring examination. Including these items in the examination j category for the containment pressure retaining boundary provides for more :
efficient program implementation without .
adversely affecting component integrity. j l
Table E-B Deleted examination category which Pressure retaining welds are now included in 2500-1 addressed pressure retaining welds. examination category E-A as discussed in ,
CAT. table revision Table 2500-1 Category E-A '
1 E-B l Table Revised EXAMINATION CATEGORIES E-C l 2500-1 ,
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CAT. E4.11 Replaced examination method VT-1 with Referring to the visual examination by the VT detailed visual. detailed term does not adversely afTect the E-B integrity of the containment components examined as discussed under item IWE-2500.
E4.12 Added grid line intersections to description The added wording clarifies inspection of parts examined. Changed examination method requirements and ensures repeatability in the from volumetric to ultrasonic thickness. location of subsequent thickness :
measurement points. .
All item no.'s - Added examination requirement Previously no references existed for paragraph number references. Updated examination requirements. These ;
acceptance standard references, requirements have been added to IWE 2300 and 2500 as discussed above. Adding new references and updating paragraph mmbers ensure proper requirements are aprslied to examinations.
Notes - Changed note 2 from requiring This note clarifies the requirements ofIWE-augmented examination until an area remains 2420(c) as discussed under that section. ;
l unchanged for three consecutive inspection
- periods to the next inspection period.
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- Callaway Plant Relief Rcquest ULNRC-3938 Attachment 2 l
i l Para- Changes between IWE 1992 Ed.1992 Ad. Significance of change and or basis for graph and the current IWE 1998 rewrite use as an alternative examination Table Deleted note 3, which discussed inspection Under the 1998 Code, no deferrals are 2500-1 deferrals. allowed. This is more restrictive than the l CAT. 1992 Code. i E-B
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(cont.)
Table E-D Deleted examination category which Moisture barriers have been included in 2500-1 addressed seals, gaskets and moisture barriers. examination category E-A as addressed Table :
CAT. 2500-1 Cat. E-A. Seals and gaskets E-D Previously required examination once per '
interval for defects that may violate leak-tight I integrity. Leak-tight integrity is verified l during each 10CFR50 App. J leak test. See l Section 3115 for more detail. !
E-F Deleted examination category which Dissimilar metal welds are not required to be i addressed dissimilar metal welds. VT-1 inspected per 10CFR50.55a(b)(2)(x)(C) i of the Final Rule l E-G Deleted examination category which Pressure retaining bolting is now included in I addressed pressure retaining bolting. examination category E-A See Section 3511 for more details.
l Appendix 3 testing is mandated by plant E-P Deleted examination category which technical specificat,ons.
i Removing this addressed 10CFR50 App J testing for all pressure ,
duplicate requirement from IWE does not retaining components. ,
adversely affect component integnty.
Table Added new Table 2500 Ultrasonic Thickness The new requirements provide for 2500-2 Measurements For Augmented Examinations - consistency and repeatability in obtaining which details gridding and thickness thickness measurements and thus assure the measurement requirements. reliable detection of conditions adverse to containment integrity.
I Table Deleted table. Non significant - the contents of the previous 3410-1 table are adequately addressed in IWE-3500.
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Page 16 of16
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