ML20202E977

Submits Proposed Alternate Asme,Boiler & Pressure Vessel Code,Section XI Edition for Units 1 & 2,third 10-Yr ISI Intervals.Util Expects to Submit Third 10-Yr ISI Interval Program Plan to NRC by 990601

ML20202E977
Person / Time
Site:	Calvert Cliffs
Issue date:	01/29/1999
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9902030245
Download: ML20202E977 (45)

Text

. ,e, M' CHARLE3 II. QUSE Baltimore Gas and Electric Company l Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calven Cliffs Parkway Lusby, Maryland 20657 410 495-4455

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' Januar . N/

U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Proposed Alternate American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI Edition for Unit Nos. I and 2 Third Ten-Year Inservice Insnection Intervals

REFERENCES:

(a) Letter from Mr. C. H. Cruse (BGE) to Document Control Desk (NRC),

dated June 25,1998, " Extension of the Unit 1 Second Tea-Year Inservice Inspection Interval" (b) Letter from Mr. S. S. Bajwa (NRC) to Mr. C. H. Cruse (BGE), dated August 19,1998, " Request for Extension of the Second Ten-Year Inservice Inspection Interval - Calvert Cliffs Nuclear Power Plant, Unit No.1 (TAC No. MA1680)"

Pursuant to 10 CFR 50.55a(a)(3Xi), Baltimore Gas and Electric Company (BGE) proposes an alternative .

to the requirements of 10 CFR 50.55a(g) which requires revision of the inservice inspection (ISI) @

program for successive 120 month intervals to the edition of the American Society of Mechanical Engineers (ASME) Code incorporated by reference in 10 CFR 50.55a(bX2). Currently, the 1989 Edition of ASME Section XI is incorporated by reference in 10 CFR 50.55a(b)(2).

- Baltimore Gas and Electric Company requests to adopt the 1998 Edition of ASME Section XI (except for Subsections IWE and IWL, and Appendix VIII) as an alternative to the 1989 Edition of ASME Section.X1 for the third ten' year ISI interval, commencing July 1,1999, for Unit Nos. I and 2. For Subsections IWE and IWL, BGE will use the 1992 Edition with the 1992 Addenda of ASME Section XI, as requried by 10 CFR 50.55a(bX2Xvi). For ultrasonic examinations, BGE will use the provisions of the 1989 Edition of ASME Section XI.

In Reference (a), .BGE stated, in part, that "we have begun the process of evaluating editions of ASME Section XI published later than the 1989 Edition to apply to the third ISI intervals of both units at Calvert Cliffs Nuclear Power Plant. We expect to submit a line-by-line analysis of a proposed alternative Code edition by January 1999." Our evaluation, analysis, and classification of changes to the ASME j

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9902030245 990129 PDR ADOCK 05000317: l 0 PDR L J

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i. 4 e Documsnt Control Desk Janucry 29,1999 Page 2 i-

'Section XI Code since publication of the 1989 Edition are attached. We conclude from this evaluation and analysis that the proposed alternative Code edition (discussed above) provide:: an acceptable level of quality and safety.

! Baltimore Gas and Electric Company is currently developing its third ten-year ISI program plan for Unit Nos. I and 2 based upon the proposed alternative Code edition (discussed above). Baltimore Gas and Electric Company expects to submit this third ten-year ISI interval program plan to the Nuclear Regulatory Commission by June 1,1999.

Should you have questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours,

,ds ' ' at:eV CHC/RCG/bjd

Attachment:

(1) Analysis of ASME Code,Section XI,1989 to 1998 cc: R. S. Fleishman, Esquire H. J. Miller, NRC J. E. Silberg, Esquire Resident Inspector, NRC S. S. Bajwa, NRC R. I. McLean, DNR A. W. Dromerick, NRC J. H. Walter, PSC 1

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l ATTACHMENT (1) i ANALYSIS OF ASME CODE, SECTION XI,1989 TO 1998 l

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4 Calvert Cliffs Nuclear Power Plant Baltimore Gas and Electric Company January 29,1999 1

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5 J A'ITACHMENT (1)

ANALYSIS OF ASME CODE, SECTION XI,1989TO 1998 DISCUSSIO.N For purposes ofInservice Inspection, Baltimore Gas and Electric Company (BGE) proposes to adopt the 1998 Edition of 'American Society of Mechanical Engineers (ASME)Section XI, except for i Subsections IWE and IWL, and Appendix VIII. For Subsections IWE and IWL, BGE will use the 1992 Edition with the 1992 Addenda of Sectbn XI. For ultrasonic examinations, we will use the provisions of the 1989 Edition of Section XI.

EVALUATION OF SECTION XI FROM 1989 TO 1998 Baltimore Gas and Electric Company has carefully reviewed all of the changes to the ASME Section XI Code from the 1989 Edition through the 1998 Edition to determine the impact of each revision. To

_s properly understand these changes, it was necessary to review the Minutes of the ASME Boiler and l Pressure Vessel Committee and review each modified paragraph in the context of the change.

When ASME modifies requirements, the specific modification often includes several related paragraphs.

Also, it sometimes happens that two completely independent changes will modify the same paragraph.

Therefore, it is not always possible to describe any change as merely a modification to a paragraph.

Because of this, the evaluation cf Section XI changes (Table I of Attachment 1) is grouped by each action that was passed by the ASME Committee. The ASME descriptions of each action in the Minutes were helpful in determining which actions were editorial and which were clarification of the then current rules.

The attached evaluation lists the following five classifications of changes:

Errata: Basically this is correction of an ASME publication error. These changes do not affect requirements, because they are retroactive to the time the error was introduced.

l Editorial: These changes have no technical impact and are so simple that the ASME Main Committee and Subcommittee agree that they do not even warrant discussion at the Committee meetings.

l No Signifcant Change: These revisions consist of clarifications or editorial changes that are discussed and voted on at the Main Committee meeting.

Less Restrictive: These changes reduce the technical requirements of the Code. Documentation or procedural changes are not listed, as they have no technical impact. Justification is given for each of 1

' these changes.

More Restrictive: These changes increase technical requirements and therefore need no justification l for acceptance.

Because these categorizations may seem to be subjective, it was decided to use the categories as assigned i by the ASME Code Committee. Therefore, smy change made to Section XI from 1989 to 1998 was reviewed and analyzed using the minutes from each of the ASME Main Committee meetings. (These minutes are available to the public.)

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S. .A ATTACHMENT (1)

ANALYSIS OF ASME CODE, SECTION XI,1989 TO 1998 The evaluation describes why the reductions in requirements do not decrease safety. This evaluation is made by reviewing the change in requirements, using the Code Committee minutes, and considering all of the related Code requirements that must also be met.

We did not document the changes to Appendix VIII but did make an evaluation to determine whether or

l. not using Appendix VIII'or the changes to Appendix VIII would have an impact on other Code changes.

l We found that not using Appendix Vill does not have any adverse impact on the use of all the other i changes to Section XI.'

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j.  ; Because Subsections IWE and IWL stand on their own merittand will not be updated to the 1998 l Addenda, no evaluations have been made on the impact of changes. We have determined that other l

subsections are not affected by the decision not to update these two subsections.

L The evaluation shown in Table I was made to assess whether or not any of the changes made to Section XI, during the period from 1989 to 1998, reduced requirements in a ivay that would have a negative impact on safety.

I NRC ISSUES

. On December 3,1998, the Nuclear Regulatory Commission (NRC) issued a proposed rule incorporating

! the 1996 Addenda to Section XI into 10 CFR 50.5Sa. Five limitations to the use of the 1996 Addenda were proposed. The following addresses the acceptability of these five provisions for BGE's next inservice inspection (ISI) interval.

1. Engineering Judgment The 1992 Addenda revision to the Foreword did not reduce or change any existing Code requirements. Rather, the change to the Foreword documented ASME's long-standing policy.

These provisions were previously endorsed by the NRC with their acceptance of the introduction to Section XI from 1970 to 1974.

2. Quality Assurance The 1990 Addenda update to NQA-1-1989 made no substantial change in QA requirements.

Baltimore Gas and Electric Company _will apply its 10 CFR Part 50, Appendix B, QA Program to Section XI activities as required by the NRC. l l

3.- _ Class 1 Piping l The 1994 Addenda revision incorporating Cases N 198-1, N-322, and N-334 merely exempted j l from examination inaccessible welds that cannot be examined. Because these welds are l inaccessible, the use of the revision reduces the number of relief requests being sent to the NRC.

It has no impact on the number of examinations being performed.

' 4.~ Class 2 Piping

'. This revision does not incorporate the provisions to which the proposed rulemaking purports to

! take exception. The provisions about which the proposed rulemaking expresses concern were L added to IWC-1220, Table IWC-2500-1, Category C-F, and Figure IWC-2500-7, in the Winter i

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,. a ATTACHMENT (1)  ;

I ANALYSIS OF ASME CODE, SECTION XI,1989 TO 1998 I 1983 Addenda (W83), which was adopted by the NRC on May 5,1988, and has been used at almost every nuclear power plant in the U.S., without exception or limitation.

5. Reconciliation of Quality Requirements The NRC's concerns about the 1995 Addenda revision to IWA-4000 are based on the assumption that the revision permits an exception to 10 CFR Part 50, Appendix B, QA requirements. While BGE, believes this conclusion to be inaccurate, we find that the new Footnote (2) proposed for  !

Code Cases N-567 (passed by the Board on Nuclear Codes and Standards) and N-554 (currently under consideration by Main Committee) sufficiently addresses this concern. The text of the footnote is as follows:

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"This provision does not negate the requirement to meet the Owner's Qaafity Assurance l

Program and Commitments to the regulatory and enforcement authorities."

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Baltimore Gas and Electric Company will incorporate this footnote into our Repair / Replacement l Program.

l CONCLUSION The evaluation summarized in Table I shows that even though some changes to Section XI from 1989 to ,

1998 are classified as "less restrictive," the reductions in requirements have no impact on safety. This is l the conclusion of the ASME Boiler and Pressure Vessel Committee, and our conclusion based on our '

extensive evaluation of every change made to Section XI from 1989 to the 1998 Edition, I 3

TABLE I ~

EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 Item # Paragraphs Affected Description Classification Justification for Reduction 1998 EDITION (1) Table IWA-1600-1, Qualification and Certification of Visual Examination Personnel No significant IWA-2310, IWA-2350, - His revision incorporates the provisions of Case N-585. He change Appendix VI new provisions reflect the current practices being used in the nuclear industry regarding qualification of personnel performing visual examinations.

(2) IWA-2210 Visual Examinations - This revision provides that a battery No significant powered light may be verified, as being adequate, merely by change being able to view the procedure demonstration characters.

(3) IWA-2240 Alternative Examinations - His revision allows the user to No significant consider equivalent alternatives to the non-destructive change examination (NDE) methods defined in the Construction Code when performing repairs. His means ultrasonic examination may be able to be substituted for radiographic examination in some cases.

(4) IWA-5221 System Leakage Tests Boundary - This change consists of an No significant editorial revision to clarify requirements by changing the change reference from IWD-5240(d) to IWD-5240.

(5) Table IWB-2412-1, Required Percentages of Examinations - His revision modifies No significant Tab!e IWC-2412-1, the " Inspection Program B" Tables, to eliminate redundancy and change Table IWD-2412-1, provide more flexibility for scheduling inspections, by increasing Table IWF-2410-2 the

• Maximum Examinations Credited" percentages.

(6) IWC-5230, IWD-5222 System Pressure Tests - His revision incorporates the provisions Less restrictive He purpose of the test is to of Case N-534. He change pennits use of a leakage test at assure leak tightness, not to normal operating pressure for Class 2 and 3 pneumatic tests, in overstress the components, lieu of the hydrostatic test of 1.1 or 1.25 times the design which could cause problems.

pressure. He new test will still demonstrate leak tightness, so there is no impact on safety.

(7) IWD-1220 Components Exempt from Examination - This revision clarifies No significant that the exemption in the paragraph applies to the VT-1 visual change examination requirements ofIWD-2500.

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EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 t item # l Paragraphs Affected Description Classification Justification for Reduction (8) G-2120, G-2213, - Postulated Flaw Orientation - %e current Appendix G method No significant G-2214, G-2215 for pressure-temperature limits only considers axially-oriented change reference flaws. His change corrects the inconsistencies in I

assumed flaw orientatien for vessel girth welds by permitting circumferentially-oriented reference flaws to be assumed in circumferential welds. The revision incorporates the provisions  !

of Case N-588.

(9) Table IWB-2500-1 ERRATA t

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EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 Item # Paragraphs Affected Description Classification Justification for Reduction 1997 ADDENDA (1) IWA-1200 Jurisdiction, Construction Code vs.Section XI - This revision No significant clarifies that the Constmction Code requirements may be used, change in lieu of Section XI requirements, for administrative control of repair / replacement activities on an item after it has been completed and Code Stamped, but that has not yet been installed in a nuclear power plant.

(2) Table IWA-1600-1, ASME QAl-1, Qualifications of Authorized Inspection No significant IWA-2120 Agencies, Inspectors, and Supervisors - This revision changes change the reference in the Code from ASME N626 to the new ASME QAl-1-1995, which defines duties and responsibilities of Authorized Inspection Agencies, inspectors, and Supervisors.

(3) IWA-2223, IWA-2233, Surface Examinations - His change corrects errors made in the No significant IV-1100 1996 revision to Appendix IV that revised the scope of change Appendix IV and added a performance demonstration requirement for eddy current as a surface examination technique.

(4) IWA-2314 Recertification of Personnel - His revision provides that Level I Less restrictive ne extension to five years for and 11 personnel can be recenified on a five-year cycle rather recertification for LevelI and 11 than the current three-year cycle. The revision incorporates the personnelis consistent with the provisions of Case N-574. recertification time for Level 111 personnel.

(5) IWA-4110, IWA-4221 General Requirements for Repair / Replacement Activities - his Less restrictive His Subarticle previously had revision identifies three alternatives for determining which no rules for selection of a Constmetion Code may be used for repair / replacement activities. Construction Code for the his includes provisions for the addition of new systems under addition of new systems. As a the jurisdiction of ASME Section XI. result, the addition ofnew systems using the rules of Section XI was prohibited.  ;

This change provides rules for the selection of a Constmction Code for the new system based

on the system's function and l existing Constmetion Codes at t

the facility. Inclusion of these l

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• e TABLE I EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998' -

Item # Paragraphs Affected Description Classification Justification for Reduction provisions now permits the addition of new systems under thejurisdiction of ASME Section XI.

(6) IWA-4131.2 Alternative Requirements for Small Items - His change is to No significant clarify that the Owner is to document, in the Repair / Replacement change Program, the size of the Class I items to which the alternative requirements for small items are to be applied.

(7) IWA-4133, Mechanical Clamping Devices Used as Piping Pressure No significant Appendix IX Boundary - This revision incorporates the provision of change Case N-523-1. His revision provides rules for temporary clamping devices to stop leakage in piping without removing the source of the leakage.

(8) IWA-4143 Stamping for Installation - His revision adds provisions for No significant fabrication of parts, appurtenances, piping subassemblies, and change supports at the Owner's plant without the regiairement that these items be NPT Stamped.

(9) IWA-4150 Repair / Replacement Program and Plan - He 1995 and 19% No significant Addenda changes to IWA-4000 included new design change requirements. This revision clarifies that the RepuReplacement Plan is not required to be used during the design portion of a repair / replacement activity or for the repair / replacement activities that require design only.

(10) IWA-4311 Documentation of Repairs and Replacements - His revision More restrictive .

adds requirements for reconciliation of any difTerences between the design or configuration and the Owner's Requirements, Design Specification, or Design Report.

(11) IWA-4410, IWA-4420, Defect Removal - This revision adds requirements for defect No significant IWA-4430, IWA-4520 removal and NDE of the defect removal area associated with change repair / replacement activities. Previously, the Section XI defect removal provisions were not applicable to defect removal and welding performed in accordance with the applicable Construction Code.

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e TABLE I EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 -

Item # Paragraphs Affected Description Classification Justification for Reduction (12) IWA-4421, IWA-4422, Metal Removal- This revision adds provisions for metal removal More restrictive IWA-4460,IWA-4611 by material disintegration machining and electrical discharge machining. He change also adds alternative provisions in lieu of performing mechanical processing of thermally cut surfaces.

(13) IWA-4440 Transfer of Procedure Qualification Records Between Owners - No significant nis revision provides alternative requirements for welding change procedure qualification ne change allows Owners to use welding procedure qualifications performed and documented by other Owners. This change incorporates the provisions of Case N-573.

(14) IWA-4623, IWA-4633, Temper Bead Welding - his revision changes the baking No significant IWA-4643, IWA-4651 requirement for SMAW electrodes for temper bead welding. change ne change also allows covered electrodes from freshly opened hennetically sealed containers to be used for all four temper bead procedures without baking or holding in drying ovens.

(15) IWA-4661, IWA-4662, Underwater Welding - His revision adds provisions for No significant IWA-4663, IWA-4664, underwater welding of ferritic materials. He revision change IWA-4665 incorporates the provisions of Case N-516-1.

(16) IWA-4712 Heat Exchanger Tube Plugging - His revision changes the No significant performance qualification requirement for heat exchanger tube change plugging by fusion welding. He change clarifies that the performance qualification need only be performed to any one qualified tube plug welding procedure.

(17) IWA-4723 Fusion Welding Procedure Qualification - This revision clarifies No significant that the listed essential variable (a certain change in tubesheet change ligament) is only applicable when the sleeve weld is to be made within the tubesheet. He essential variable is not applicable to sleeve welds above or beyond the tubesheet.

(18) IWA-5110 System Pressure Test - This revision incorporates the provision No significant of Case N-522. He change exempts piping that penetrates the change containment vessel from the pressure test, when the piping and isolation valves that are part of the containment system are Class 2 and the balance of the piping system is outside the scope of Section XI.

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IABLE I .,.

1 EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 Item # Paragraphs Affected Description Classification Justification for Reduction (19) Table IWB-2500-1, Fig. Examinations for Integrally Welded Attachments - This revision Less restrictive Section XI once permitted the IWB-2500-13, Fig. incorporates the provisions of Case N-323-1. The revision examination to be performed IWB-2500-14 permits a one side surface examination in lieu of surface from one side. This provision examination from both sides or of volumetric examination of was inadvertently deleted in the attachment welds to vessels, when only one side of the Winter 1981 Addenda. He attachment weld is accessible for examination. revision reinstates the provisions previously accepted by the NRC.

(20) Table IWC-2500-1, Examination Category - His revision changes Categories C-H No significant Table IWD-2500-1 (All Pressure Retaining Components) and D-B (Systems in change Support of Emergency Core Cooling, Containment Heat Removal, Atmosphere Cleanup, and Reactor Residual Heat Removal) to clarify the pressure testing requirements for Class 2 and Class 3 storage tanks.

(21) IWF-31123, Acceptance by Examination - This revision clarifies that a No significant IWF-31223 component support which has been determined to be acceptable change for service by an evaluation or test, may have corrective measures performed to return the support to its design condition, without requiring additional examinations.

(22) Appendix IV, Eddy Current Examination - His is an editorial correction to No significant Supplement I paragraph 33.1.l(a). He change in text is from " measured from change a single flaw" to " compared to a single notch."

(23) A-4300 Fatigue Crack Growth Rate - The current procedure for handling More restrictive compressive load cycles (negative r-ratio transients) has been shown to be nonconservative for stress levels approaching the Section III allowable stress intensities for primary stress.

(24) Fig. J-1000-1, J-2000 Repair / Replacement Activities - Because of the addition of No significant expanded exemptions in IWA-4000, this revision updates the change t decision tree logic to include steps incorporating the decisions relating to the applicability of the new exemptions. In addition, the design activity of rerating is added to Appendix J.

(25) IWC-3125 EDITORIAL 6

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EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 I Item # Paragraphs Affected Description Classification Justification for Reduction 1996 ADDENDA.

(1) Table IWA-1600-1, Underwater Welding - his revision adds requirements for dry or No significant IWA-4610, IWA-4660 wet underwater welding for repair / replacement activities on change P-No. 8 and P-No. 4X materials. His change incorporates the provisions of Case N-516.

(2) IWA-2110 Terminology - This revision modifies the paragraphs to use No significant current terminology regarding repair / replacement activities and change programs.

(3) IWA-2315, Performance Demonstration Requirements for Eddy Current More restrictivi.,

Appendix IV Examination - His revision adds new requirements for performance demonstration of eddy current examination systems and personnel and moves the existing requirements for qualification of personnel for analysis of steam generator eddy current examination data from Appendix IV to IWA-2315. De revision also incorporates the provisions of Case N-307-1 and Case N-553.

(4) IWA-2430 Inspection Intervals - His revision incorporates the provisions of No significant Case N-535. His change permits performance of concurrent change inspections to satisfy requirements and schedules of two successive inspection intervals.

(5) IWA-4132 Alternative Requirements for items Rotated From Stock - De Less restrictive Here is no reduction in safety revision incorporates the provisions of Case N-508-1. His since the removed snubber or revision permits rotation of previously installed snubbers and relief valve undergoes testing relief valves from stock and installed on components without the to confinn its ability to meet need for a Repair / Replacement Plan, an Authorized Inspection, design and to detect any or a NIS-2 Data Report, provided the snubber or relief valve is degradation. Expanded removed from the component only for testing. examinations are required should any failure be detected, in which case, all the r provisions for Repair /

Replacement would then be invoked. His paragraph requires the Owner to maintain i traceability and to ensure the 8

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EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 Itent # ' Paragraphs Affected Description Classification Justification for Reduction rotated item is used in the same design application.

(6) IWA-4160, IWA-4180, Documentation of Repairs and Replacements - His revision More restrictive IWA-4311, IWA-4312 adds requirements for documentation of modifications to ensure that the configuration of the equipment is accurately reflected in the design. He revision also adds a requirement that the revised record be certified in accordance with the Construction Code requirements for certification of the original records.

(7) IWA-4221, IWA-4226 Reconciliation of Design Requirements - His revision identifies More restrictive how the Owner is to reconcile the technical aspects of repair and replacement work performed in accordance with a later Code Edition or Addenda than used for constmction.

(8) IWA-4420, IWA-4610 Metal Removal- His editorial revision clarifies that the No significant Section XI defect removal provisions are not applicable to defect change removal and welding performed in accordance with the applicable Construction Code.

(9) IWA-4622, IWA-4632 Procedure Qualification Test Assembly for Temper Bead No significant Welding - His revision clarifies the dimensional requirements change for the procedure qualification test assembly for qualification of temper bead welding of similar materials.

(10) IWA-4634 Examination - His change relaxes the examination requirements No significant for alternative welding methods for dissimilar metals. Instead of change requiring radiography, and if practical, ultrasonic examination, any volumetric examination method may now be used.

(II) IWB-3641, C-3300 Acceptance Criteria for Austenitic Steel Piping - His revision Less restrictive This revision is based on new removes the penalties for flux welds. Service experience and test data which shows that the additional fracture toughness data havejustified increasing the penalty for flux welds was not alt max limit of 0.60 for flux welds to 0.75 for austenitic justified. Therefore the change materials. has no impact on safety.

(12) IWB-3740, Appe:ndix L Analytical Evaluation of Operating Plant Events - Operating No significant Plant Fatigue Assessment - his ravision adds guidance for change evaluation of plant operating events f'or acceptability of components for which fatigue usage limits may have been exceeded or for which fatigue may be a concern.

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EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 Item # Paragraphs AfTected Description Classification Justification for Reduction (13) IWC-3200, IWF-3200 Supplemental Examinations - This revision makes IWC-3200 Nop nificant g

and IWF-3200 consistent with IWB-3200 and IWE-3200, change regarding supplemental examination. He change is editorial in nature, but makes supplemental examination optional.

.(14) 1-2110, Table 1-2000-1 Examination Requirements - His revision clarifies the No significant examination requirements for reactor-vessel-to flange welds, change closure-head-to-flange welds, and reactor vessel CRD housing welds.

(15) A-4300, A-5100, Fatigue Crack Growth - His change provides consistency with No significant '

A-5200, A-5300 the previous approach to fatigue crack growth, in which both the change length and the depth are calculated, allowing for flaw shape change during grow 1h.

(16) G-2120, G-2214, Stress Intensification Factors - his revision provides an No significant G-2215, G-2222 improved method for calculating the stress intensity factor K. change Appendix G is used for development of pressure-temperature limit curves for operating plants. He existing calculation methodology was developed in the early 1970's.

(17) J-3000 Maintenance Requiring Subsequent Tests or Examination - His No significant revision identifies that safety and relief valve set point change adjustment is not considered a Section XI repair / replacement activity.

(18) IWA-4150, IWB-2411, EDITORIAL IWB-2411. IWB-2412, [

IWB-2412, IWB-2430, IWB-3122, IWB-3122, IWB-3142, IWB-3420  ;

(19) IWA-2220, IWA-4110, ERRATA IWA-4120, IWA-4131, IWA-4180, IWA-4221, IWA-4530, IWA-4621, IWA-4641, K-5220, K-5300 10 i

TABLE I EVALUATION OF REVISIONS TO ASME SECTION XI ' CODE - 1989 to 1998 ' I Item # Paragraphs Affected Description Classification Justification for Reduction 1995' ADDENDA?

(1) IWA-1000, IWA ' t 10, Elimination of Repair, Replacement, and Modification No significant IWA 2430,IWA-2500, Classifications - This rewrite clarifies what activities are required change IWA-4000, IWA-5120, for any kind of repair, replacement, or modification activity.

IWA-5214, IWA-5250, Combining IWA-4000 and IWA-7000,in the 1991 Addenda, IWA-6210, IWA-6230, thus combining some of the differing requirements for repair and IWA-9000, IWB-1100, replacement, reduced the need for the two different IWB-2420, IWB-310G, classifications, repair and replacement, as well as the third, ,

IWB-3200,IWC-1100, modification. '

IWC-2420, IWC-3100,

• IWC-3200, IWD-1100, IWF-2220, IWF-3112, IWF-3122, IWF-5100 IWF-5400, Appendix II, D-1100, Appendix J *

(2) IWA-4110 nrough-Wall Leakage - This revision provides that when No significant discrepancies (such as through-wall leakage at other than at change mechanical connections) are to be repaired, any repair / replacement activities ate to be performed in accordance with IWA-4000.

(3) IWA-2220, IWA-2223 Eddy Current Examination - nis revision incorporates the No significant I provisions of Case N-485-1. He change permits use of eddy change current as a surface examination technique. ,

(4) IWA-2221, IWA-2222 Magnetic Particle Examination of Coated Materials - His No significant change allows use of the yoke method for magnetic particle change examination on coated ferritic materials, without removing the coating. He revision incorpc-ates the provisions of Case N-458,

" Magnetic Particle Examination of Coated Materials,Section XI, Division 1," by reference to Section V. He Case provisions were added to Section V, Article 7, Appendix I, in the 1992  ;

Addenda.

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• e TABLE I ,

I EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 Item # Paragraphs Affected Description Classification Justification for Reduction f (5) IWA-2310, IWA-2323 Qualification of Nondestructive Examination Personnel - His No significant revision clarifies that NDE personnel qualified to IWA-2300 of change any Edition and Addenda of Section XI are qualified to all earlier Editions and Addenda.

(6) IWA-4120, IWA-4132, Applicability of Repair / Replacement Requirements - His No significant IWA-4530 revision adds repair / replacement activity exemptions for the change identified support items, as well as making corrections and ,

clarifications to the current exemption provisions. Clarification is added to require preservice inspections and tests of snubbers following a repair / replacement activity.

(7) IWA-4131,IWA-4132 Replacement of Small Items - Prior to this revision,Section XI More restrictive provided an exemption, or alternative, less restrictive requirements for NPS 1 (makeup capacity size for Class 1) and -

smaller replacement items and installation thereof. Repairs were not similarly exempted. This revision removes the inconsistency by applying the alternative requirements for replacement to all repair / replacement activities. He revision incorporates the provisions of Case N-544.

(8) IWA-4220, IWA-4223, Evaluations of Components - His revision clarifies that the More restrictive IWA-4224, IWA-4225, Owner is required to document an evaluation or reanalysis when IWA-4311 the design or configuration of an item or system is changed. He evaluations or analyses are required to be certified in accordance with requirements of the Construction Code and Owners Requirements.

(9) IWA-4221, IWA-4222, Code Reconciliation - In the past, some reconciliation efforts No significant IWA-4223, IWA-4224, have concentrated on administrative and documentation issues change IWA-4225, IWA-4226, that have no effect on adequacy of the pressure boundary. His IWA-9000 revision adds specific requirements for reconciliation oflater Editions and Addenda of the Construction Code, or revised Ownets Requirements, for procurement of components, parts, and material.

12 i

e TABLE .I I

EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 ta 1998 Item # Paragraphs Affected Description Classification Justification for Reduction -

(10) IWA-4311, IWA-4312, Rerating Pressure Retaining Equipment - %e Code provides More restrictive IWA-9000 specific requirements for repair / replacement activities ofitems, but has not provided any requirements for rerating ASME Code equipment and systems. His revision specifies requirements for rerating of existing Code items in aperating plants.

(11) IWA-4451 Helical Coil nreaded Inserts - His revision provides new No significant requirements for helical coil threaded inserts. Use of these change inserts has previously been identified as neither required nor prohibited, with no requirements nor guidance provided for contmiling design or material properties. He revision incorporates the provisions of Case N-4%.

(12) IWA-5213(a) Test Condition Holding Time - This revision eliminates the No Significant holding time requirements after attaining test pressure and Change.

temperature for system leakage tests. Hold times were inadvertently added during the previous rewrite ofIWX-5000.

('3) IWA-5244 Buried Components - His revision simplifies and clarifies the No significant requirements for pressure testing buried components with and change without isolable valves. He provisions now address redundant ,

systems with isolable buried components.

(14) IWA-9000, IWB-2500-1 Examination Category B-F(Pressure Retaining No significant Table IWB-2500-1 Dissimilar Metal Welds in Vessel Nozzles) & B-J (Pressure change Retaining Welds in Piping) - This revision adds a definition for dissimilar metal weld, and revises the tables to be consistent with the fact that the glossary now contains the definition.

(15) IWA-9000 Owner - his revision revises the definition of Owner to be No significant consistent with the definition in Section 111 and other ASME change Nuclear Codes and Standards.

13 i

..-_ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ . _ . _ - _ . - _ _ _ _ _ _ _ _ . _ _ _ _ _ _ - _ _ - _ . . . _ _ . _ _ _ . . _ _ . - , _ ~ . .

• i TABLE I

• EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 198910 1998 -

Item # Paragraphs Affected Description Classification Justification for Reduction (16) IW3-1100, IWB-1210, Integrally Welded Attachments - This revision clarifies use of No significant IWB-2500, the term " integrally welded attachments" to provide consistency change Table IWB-3410-1, with the provision in Section III, Subsection NF.

IWB-3516, IWB-3520, IWB-3522, IWC-1100, IWC-1210, IWC-2500, Table IWC-2500-1, Fig.

IWC-2500-5, Table .

lWC-3410-1, IWC-3512, IWD-1100, t IWD-1210, IWD-2500, Table IWD-2500-1, IWF-1300, Fig. IWF-1300-1 (17) IWB-1220 Emergency Core Cooling Systems and Makeup Capacity - This No significant revision clarifies that emergency core cooling systems are change excluded from calculation of makeup capacity, because they do not operate under normal plant operating conditions.

(18) IWB-2411, IWB-2412, Inspection Schedule - This revision incorporates the provisions L.ess restrictive Industry experience IWB-2420, IWB-2430, of Case N-509. The change modifies the examinations to be demonstrates that Welded IWB-2500, IWC-2411, performed on welded attachments for Examination Attachments, even if failure IWC-2412, IWC-2420, Categories B-K, C-C, and D-A. The extent of examinations for occurs, do not violate the IWC-2430, welded attachments to piping, pumps, and vessels is reduced pressure retaining function of Table IWC-2500-1, from 10084 of all welded attachments to 10%. For the system that it is attached to.

IWD-2411, IWD-2412, Category D-A, the 10% must include those welded attachments By concentrating on Welded IWD-2420, IWD-2430, most susceptible to corrosion. Attachments most susceptible Table IWD-2500-1 to corrosion and sampling 10%

within each system, adequate assurance of detection of degradation is maintained.

Additionally, the thickness exemption is eliminated so more welded attachments are in the pool for selection. Further examination for cause is requtred whenever a failure of 14 4

_.-_-__u-_ _ _ . _ _ _ _ - _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ - _ _ _

.f TABLE I .

EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 -

Item # Paragraphs Affected Description Classification Justification for Reduction the attachment is discovered and additional exams are required.

(19) Table IWD-2500-1 Examination Method - His revision incorporates the provisions More restrictive of Case N-509. For Examination Category D-A, the required examination of a welded attachment is now a VT-1. Previously, a VT-3 was required.

(20) Table IWB-2500-1 Inspection of Nozzle to Vessel Welds - His re- ision No significant incorporates the provisions of Case N-521. His change permits change deferral of PWR reactor vessel nozzle welds and inside radius ,

sections to the end of the interval. It applies to all but the first ,

inspection interval.

(21) Table IWB-2500-1 Examination of Control Rod Housing Bolting - This revision Less restrictive A detailed VT-2 in accordance incorporates the provisions of Case N-547. He revision with BGE's Boric Acid eliminates the requirement for VT-1 visual examination of CRD Inspection program will be housing bolting. performed in lieu of the VT-1 visualexamination. He elimination of the visual examination of the CRD 1 housing bolting is not significant because any indication of boric acid residue in the area requires the bolting to be evaluated and corrective actions taken.

(22) Table IWB-2500-1, Examination of Longitudinal Welds - His revision incorporates Less restrictive Experience has shown that Table IWC-2500-1 the provisions of Case N-524. He revision reduces the extent of reduction in length of inservice examination oflongitudinal piping welds in Class I longitudinal weld to be and 2 piping from the lesser of one pipe diameter or 12 inches to examined does not affect safety the portion of the longitudinal weld within the examination because the area most i boundary of the intersecting circumferential weld required to be vulnerable to problems is at the examined. intersection of the longitudinal and girth welds, which is the area to be investigated.

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15

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TABLE I

+e EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 ~ ~--

t item # - Paragraphs Affected . Description Classification- Justification for Reduction Fig. lWB-2500-15, Fig. Examinations Around Supports - His revision adds a footnote to  ;

.(23) Less restrictive - Expenence has shown that -

IWC-2500-5, permit examination of welded attachments without removing any welded attachments can be Fig. IWD-2550-1 support member covering part of the surface area to be properly examined without .

examined. removing support members . .;

covenng part of the surface t area to be examined, because

. any cracks would be initiated at  ;

the attachment weld, not under the support member. >

(24) Table IWB-3410-1, Category B-E - his revision corrects the provisions to reflect No significant

, IWB-3522 deletion of Examination Category B-E in the 1993 Addenda. change.

Table IWC-2500-1, Fig.  !

(25) Examination Requirements - His revision incorporates the No significant IWC-2500-1, provision of Case N-435-1. His revision permits surface change. j Fig. lWC-2500-2 examination in lieu of volumetric examination for thicknesses l/5 in. or less. l (26) Table IWC-2500-1 Dissimilar Metal Attachments - His revision clarifies the No significant provisions regarding examination of dissimilar metal change t attachments.

(27) IWF-1230, IWF-2510 Support Exemptions - His revision clarifies that supports on No significant ~ l piping that is exempted from volumetric, surface, or VT-1 or change "!

VT-3 visual examination are also exempted from examination.  !

(28) Appendix III, III-2300 Written Procedure Requirements - His change clarifies that it is - No significant not necessary for the ANII to approve NDE procedures. change  !

(29) Appendix III,III-3410 Alternative Requirements for Piping Calibration Block No significant -;

nickness - This revision incorporates the provisions of change' ,

Case N-461. He change permits a piping calibration block thickness tolerance of plus or minus 25%.

(30) Appendix VII, Examination Questions and Test Specimens - His revision No significant '

VII-4310 clarifies that a random selection process controlled by the change .

employer's written practice may be used to ensure that no j individual takes the same examination more than once. De  ;

revision also clarifies that " grading units" may be considered a :l test specimen for the practical examination.

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TABLE I EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 -

• I Item # Paragraphs Affected - Description Classification Justification for Reduction i

(31) K-1200, K-1300, Assessments of Reactor Vessels - His revision modifies the No significant K-2200, K-2300, method for evaluating the reactor coolant pressure boundary for change ,

K-2400, K-4100, continued service when the predicted upper shelfimpact energy K-4210, K-4220, level, as defined in ASTM E 185, decreases below a specified  ;

Table K-4320-1, value. He change also adds requirements for evaluating Fig. K-4320-1, K-4321, Level C and Level D service loadings. De revision incorporates K-4332, K-5000, the provisions of Case N-512, IWA-2110, IWA-2110, .

K-5100, K-5200, IWB-2200, IWB-2412(b), IWC-2412(b), IWD-2412(b),

K-5300, K-5400 IV-2000, Vil-4223, VII-4223 EDI1DRIAL  ;

(32) IWB-2200, IWB-2412, EDITORIAL IWC-2412, IWD-2412 (33) IWC-1223 ERRATA i

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TABLE I

, -l

EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 19981 - *' >

L Item # Faragraphs Affected Description Classification' Justification for Reduction '

11994 ADDENDA s 1

• s

r (1) .

IWA-2420,IWA-6220 Substitute Examinations and Tests - His change deletes the No significant -

reference to substitute examinations and tests. change (2) IWA-4150 Verification of Acceptability - his p sy.ph has been changed No significant I to exempt modifications and like-for-like replacements, which change- '[

are not associated with service induced failures, from the -

• verification requirements ofIWA-4150.

(3) IWA-4170 Alternative Rules for Repairs, Replacements and Modifications No significant I His revision requires that when specific provisions oflater change Editions and Addenda of Section XI are used for performing .i 1

repair, replacement, and modification activities, all related i requirements are to be met. De revision incorporates the [

provisions of Case N-389-1.

l (4) IWA-4810,IWA-4820 Examination and Preservice Inspection - his revisica clarifies No significant j

the examination and preservice inspection requirements for both change repairs and installation of replacements may be performed i concurrently with the preservice inspections required by - 1 l IWA-4820.  ;{

(5) IWA-7000, IWB-4000,- Repair and Replacement - De 1991 Addenda consolidated No significant j

.I IWB-7000, IWC-4000, repair and replacement rules into IWA4000. His revision change IWC-7000, IWD-4000, deletes the above Articles, which are no longer needed. [

IWD-7000, IWF-4000,  !

IWF-7000 ..

(6) IWA-9000 Definition of Owner - His revision modifies the definition of No significant

? Owner" to be consistent with other nuclear Codes and change Standards. .

(7) IWB-1220, IWC-1223, Exemption from Examination - This revision exempts welds or Less restrictive Dese provisions exempt welds  !

IWD-1220 portions of welds, which are located inside penetrations, from inside guard pipes from -!

examination. He change incorporates the provisions of ' examination. He welds are i Case N-198-1, Case N-334, and Case N-322. inaccessible and could never be i i examined without extensive demolition of the guard pipe.

Baltimore Gas and Electric -

t 18 l i

I i

TAELE I EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 -

• Itern # Paragraphs Affected Description Classification Justification for Reduction Company examines the nearest accessible weld. He number ofexaminations are not reduced, therefore the change has no safety /technicalimpact on the quantity or quality of examinations.

(8) IWB-2411, IWB-2412, inspection Programs - His change clarifies the requirements for ' No significant Table IWB-2500-1 partial deferral ofitems from the inspection program. change ,

(9) IWB-2412, IWC-2412, inspection Program B - His revision provides requirements for More restrictive IWD-2412 adding items or welds to the inspection schedule.

(10) Table IWB-2500-1 Examination Categories - This revision changes the tables to No significant clarify provisions and provide consistency. change (1I) Table IWB-2500-1 Pump and Valve Internal Surface VT-3 Examination - his More restrictive revision continues to allow partial examination of pump and valve casing internals when only partial disassembly is perfonned, but requires full examination to be made at a later date when disassembly of the component permits a full examination.

(12) IWB-3710 Analytical Evaluation of Plant Operating Events - His revision More restrictive changes the scope statement to include operational integrity issues.

(13) IWF-2410 Inspection Programs - His revision adds rules to provide for More restrictive adding items or welds to the inspection schedule.

(14) Appendix 1, Calibration Blocks for Examination of Parts with Curved More restrictive Supplement 3 Surfaces - His revision reinstates requirements previously specified in the 1986 Edition of Section XI regarding calibration blocks for examination of parts with curved surfaces.

(15) Vll-6000 Authorized Nuclear Inspector - His paragraph has been deleted No significant because it is redundant with the provisions contained in change i IWA-2100.

e l

19

TABLE I e EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 ~ -

Item # Paragraphs Affected Descripdon Classification Justification for Reduction (16) A-3000 Method for K iDetennination - This revision modifies A-3000 to Less restrictive The less conservative approach allow the user to use a more accurate and less conservative is acceptable because it has formulation for determining stress intensity factors for any been verifiedto be more gradient stress distribution over the flaw face. accurate based on published studies. Also,these provisions are nonmandatory.

(17) C-3220 EDITORLAL (18) IWA-5250, IWF-2500, ERRATA 11-1300, Table 11-5310-1, Table 11-5310-2, '

11-5420, Table 11-5410-1, Table 11-6310-1, Table 11-6310-2, K-4210 1

20

TABLE I ,

EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 -

Item # Paragraphs Affected Description Classification Justification for Reduction

' 1993 ADDENDA 1 (1) IWA-1400, Footnote i Tenninology, Nuclear Power Plant - His revision changes the No significant term ' power system' to ' nuclear power plant,' for consistency change with other changes to ' nuclear power plant"in the 1991 Addenda and the 1992 Edition.

(2) Table IWA-1600-1, Referenced Standards and Specifications - De reference to No significant Appendix A, A-4400 ASTM E 185 is clarified to the 1982 Edition, and the title is change corrected to "Stmdard Practice for Conducting Surveillance Tests for Light-Water Cooled Nuclear Power Reactor Vessels."

(3) IWA-2216 Remote Visual Examination - His change adds requirements for More restrictive color resolution for remote visual examination. When using remote visual examination, it is necessary to detect conditions such as corrosion. With black and white cameras, corrosion byproducts could be missed.

(4) IWA-2233, Eddy Current Examination - His revision referencesSection V, No significant Appendix IV Article 8, Appendix II for eddy current examination because the change Section XI, Appendix IV provisions were added to Section V in the 1992 Addenda.Section XI, Appendix IV still contains additional personnel requirements.

(5) IWA-2430, IWB-2411, Interval Extensions - His revision clarifies that inspection No significant IWB-2412, IWF-2410 periods may be adjusted by up to one year to coincide with plant change outages.

(6) IWA-4130 Responsibilities, Repair Organization's Quality Assurance More restrictive Program - His revision adds requirements for a Quality Assurance Program for a repair organization when the organization is other than the Owmer.

(7) IWA-4130, IWA-4140, Definition of Construction Codes - Previously,Section XI No significant IWA-4150, IWA-4170, defined Construction Code in such a way that many people change IWA-4310, IWA-4422, interpreted Construction Code to include the Design IWA-4423, IWA-4424, Specifications or Owner's Specifications. This revision clarifies IWA-4425, IWA-4512, that the Design Specifications and Owmer's Requirements, IWA-4542, IWA-4621, although required by some Construction Codes, are not part of IWA-4910, IWA-9000 the Constmetion Code.

21

.g.

TABLEI ,

EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 -

Item # Paragraphs Affected Description Classification ' Justification for Reduction

-(8) IWA-4140 Repair / Replacement Program and Plan - His revision clarifies No significant that reference points are required to be recorded for repairs only change when required by IWA-2600.

(9) IWA-4180 Material- This revision deletes IWA-4180 because the No significant ,

provisions are redundant and unnecessary change (10) Table IWA-5210-1, System Leakage Test Boundary - His revision provides for a Less restrictive ne purpose of the test is to IWA-5221, system leakage test in lieu of a system hydrostatic test for Class I assure leak tightness, not to Table IWB-2500-1, and 2 systems once during each inspection interval. He change overstress the components,

!WB-5210, IWB-5220, incorporates the provisions of Case N-498. which could cause problems.

IWB-5230, ne new test will still Table IWB-5230-1, demonstrate leak tightness, so IWB-5240, there is no irupact on safety.

Table IWC-2500-1, IWL-5210, IWC-5210, IWC-5220, IWC-5230, IWC-5240, IWD-5240 >

(11) IWA-5211, IWC-5210, System Pressure Tests, System Pneumatic Tests - His revision No significant IWD-5210 clarifies that a pneumatic test may be performed in lieu of a change system leakage test or a system hydrostatic test for Class 2 or 3 ,

steam systems, after repair, replacement, or alteration.

(12) IWA-5250 Corrective Action - His revision clarifies that the requirement to No significant g remove a bolt and perform a VT-3 inspection when leakage is change }

found at a boltedjoint does not apply to gaseous systems.

(13) IWA-9000 Glossary - This revision deletes definitions for " full stroke time," ' No significant

" functional pressure differential (valve)," and " operating change ,

convenience."

(14) Table IWB-2500-1, Weld Examinations - His revision clarifies that welds must be No significant Table IWC-2500-1 examined, to the extent practical, in the same sequence in change ,

successive intervals as the sequence in which they were examined in the first interval.

(15) IWB-2500, IWC-2500 Examination Categories - His revision changes the No significant identification lettering on the outside surfaces of the figures to change make them consistent.

I

TABLE I EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998

• Item # Paragraphs Affected Description Classification Justification for Reduction

-(16) IWB-3730, Appendix K Fracture Toughness Criteria for Protection Against Failure - his Less restrictive He Code revision allows an change provides acceptance criteria and evaluation procedures evaluation to demonstrate for assessment of reactor vessels when the predicted upper shelf equivalence with vessels which Charpy impact energy level is below 50 ft-lbs. have Charpy impact energy levels above 50 ft-lbs. De new method is based on more advanced technology and therefore there is no reduction in safety.

(17) IWF-2420, IWF-2430 Successive Inspections, Additional Examinations - His revision No significant clarifies when successive inspections and additional change examinations are required for supports by providing more specific cross-references and expanding the description of the conditions that require these examinations.

(18) Appendix 11 Data Report Forms - His revision adds guidance for completing No significant the NIS-1 and NIS-2 Owner's Report Forms, similar to that change provided in other sections of the Code.

(19) Appendix VII, Qualification of NDE Personnel for Ultrasonic Examinations - No significant Vll-3300, VII-4240 His revision clarifies the intent of'outside agency' for large change companies administering the examinations required by Vll-4342 and clarifies that no examination is required to meet the requirements for annual training.

(20) Appendix Vil, Training Course Content and Duration - His revision provides M- - *rictive VII-4220 requirements for training of ultrasonic examination personne!

previously qualified under a written practice not meeting the additional requirements of Appendix Vll.

(21) A-4300 Fatigue Crack Growth Rate - The current provisions for fatigue More restrictive crack growth procedures do not clearly specify how compressive loads are to be handled. The revision adds a reliable method to accot.at for compressive loads by accounting for crack closure effects.

23

TABLEI EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 Item # Paragraphs Affected Description Classification Justification for Reduction (22) A-5200, A-9000 Flaw Analysis - His revision accommodates possible flaw shape More restrictive change due to fatigue crack growth and clarifies the plastic zone correction for fatigue growth analysis. He definition of

'end-of-period flaw size'is clarified.

(23) Appendix F Inspection Plan Contents, Substitute Examinations or Tests - No significant His revision deletes the provisions for addressing substitute change examinations or tests in the inspection plan. He provisions were deleted because substitute examinations or tests are not permitted by Section XI.

(24) F-2500 Inspection Plan Contents, Containment Examinations - His No significant revision adds a new Supplement 5 to specifically address change containment vessels and containment liners.

(25) G-2215 Low Temperature Overpressure Protection Systems - This No significant revision adds guidance for low temperature overpressure change protection systems. The revision incorporates the provisions of Case N-514, " Low Temperature Overpressure Protection,Section XI, Division 1," into Appendix G.

(26) Fig. IWA-4546-1, EDITORIAL Fig. lWA-4546-2, IWA-5250, IWB-3132, IWC-3122, IWF-3122, A-Il00 (27) IWA-4412, IWA-4910, ERRATA Fig. IWB-3641-1, A-4300, C-3210, ,

C-3320, C-3420, C-3420

• 24

a-TABLE I EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998

• _ Item # Paragraphs Affected Description Classification Justifict. tion for Reduction .

1992 ADDENDA :

(1) Table IWA-1600-1, Qualification and Certification of NDE Personnel - This revision More restrictive IWA-2310, IWA-2320, adopts a new ASNT Standard CP-189 for qualification and IWA-2330, IWA-2350, certification of NDE personnel.

IWA-2360, IWA-2370, IWA-2380, Appendix Vil (2) Table IWA-1600-1, Referenced Standards and Specifications - This change clarifies No significant IWF-5200, IWF-5300 the references to OM Part 4 (1987 + OMa-1988 Addenda) and change adds reference to ASTM D974-1987.

(3) IWA-2216 Visual Examination Cleaning Requirements - IWA-2216 was No significant deleted because the requirements for cleaning prior to visual change examination have been added to Section V.

(4) IWA-2350 Limited Certification - This revision clarifies the definition of No significant limited certification and permits deletion of training topics with change corresponding reductions in training hours, examination content, and required experience. The change incorporates the provisions of Case N-503.

(5) IWA-4110, IWA-4120 Repairs and Replacements - This revision expands and clarifies No significant the exemptions from the scope of the repair and replacement change rules.

(6) IWA-4111, IWA-4120, Alternative Requirements for Small items - This revision deletes More restrictive IWA-4710 the exemption from the provisions oflWA-4000 for Class 1, NPS I and smaller items, and replaces it with alternative provisions to provide assurance that the item will function as designed. If the failure of a Class I, NPS I and smaller item, could result in a leak rate exceeding the makeup capability limit for the plant, it is no longer exempt (even ifless than NPS 1).

Heat exchanger tubing, sleeves, or welded tube plugs for heat exchanger tubing are not exempted regardless of size.

25

et TABLE I EVALUATION OF REVISIONS TO ASME SECI' ION XI CODE - 1989 to 1998 Item # Paragraphs Affected Description Classification Justification for Reduction (7) IWA-4412, IWA-4413 Tube and Tubesheet Hole Plugging - Tnis revision combines the No significant two paragraphs, because they contain similar requirements for change-applicability, qualification, and performance for Class I welded tube and tubesheet hole plugging.

(8) IWA-4512, IWA-4513, Gas Tungsten-Arc Welding - His change involves lowering the No significant i IWA-4522, IWA-4532 post-weld temperature maintenance for the gas tungsten-arc change temperbead weld repair process from a range of450*F to 550*F to a minimum temperature of 300*F.

(9) IWA-5265 Location of Pressure Measuring Devices - This revision was No significant "

made to incorporate Intent Interpretation XI-1-89-66 regarding change the lowest test pressure during a system pressure test. It clarifies that the 106 percent overpressurization limit takes priority over achieving the minimum pressure throughout the system.

(10) IWA-9000, Definition - Tnis revision moves the definition of" belt line No significant i Table IWB-2500-1 region," from Table IWB-2500-1 to IWA-9000. change (11) IWA-9000 Glossary - His revision adds definitions of" post tensioning," No significant

" prestressed concrete," " reinforced concrete," " tendon," change i

" structural integrity test," and "unbonded tendons" and deletes

" active valve," " exercising," " maintenance," " passive valve,"

" routine servicing," and " system resistance."

(12) IWB-1220 Scope and Responsibilities - His revision deletes the reference No significant to 10 CFR Part 50 for definition of the reactor coolant pressure charge boundary and changes the definition of"in piping" to agree with Subsections IWC and IWD. ,

(13) Table IWB-2500-1 Examination Categories - He table was revised to clarify that No significant Examination Categories B-H and B-K-1 are never required to change have volumetric examinations. ,

(14) IWD-5222 System Hydrostatic Test - His revision exempts safety or safety No significant relief valve piping that discharges into a containment pressure change suppression pool from any kind of pressure test. He previously required pneumatic test did not provide a meaningful test of this piping.

26

as TABLE I EVALUATION OF REVISIONS TO ASME SECTION XI CODE '- 1989 to 1998 '

Item # . Paragraphs Affected Description Classification Justification for Reduction (15) 1-2500 Ultrasonic Rickness Measurements - Section XI does not More restrictive include provisions for measuring thickness using ultrasonic ,

equipment. This change provides guidance for performing any -;

UT thickness measurements required by Section XI.

(16) A-4200, K ic Curves - This revision modifies the K ci curve in No significant Fig. A-4200-1 Figure A-4200-1 to agree with the source equations in change Section Ill, Appendix G.

(17) IWA-9000, ERRATA Fig. IWB-2500-20, IV-2700, A-9000, l

H-4221, Fig. J-1000-1 k

27

a TABLE I EVALUATION OF REVISIONS TO ~ASME SECTION XI CODE 1989 to 1998 Item # Paragraphs Affected Description Classification Justification for Reduction As.  : 1992 EDITION- 2 (1) Table IWA-2210-1 Visual Examinations - The units for character height were No significant changed from mils to inches for consistency with other Code change dimensional units.

(2) Table IWB-2500-1 Dissimilar Metal Welds - This revision clarifies that No significant Category B-F applies to dissimilar metal welds only in vessel change nozzles, not in piping.

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28

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..e

' EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 Item # Paragraphs Affected Description Classification Justification for Reduction

"~

1991 ' ADDENDA' (1) IWA-2110, IWA-2200, - Examination and Inspection - His revision adds coverage for More restrictive IWA-2430 concrete containments under the general provisions for examination and inspection.

(2) Table IWA-1600-1, Qualification of Authorized Inspection a,,$. _, revision No significant IWA-2120 updates the reference to ASME N626 to the 1991 Addenda and change makes accreditation of the Authorized Inspection Agency in accordance with the new provisions of ASME N626 mandatory.

(3) IWA-2321, IWA-2322, Vision Tests - His revision changes the eye examination test No significant .

IWA-2323, IWA-2324, requirements for near vision from Jaeger J-l to Snellen 20/25 change IWA-2325 and provides qualification requirements for the required near-distance test chart. His revision incorporates the provisions of Case N-490-1.

(4) IWA-2323, IWB-2411, Level III Personnel; Inspection Program - His revision clarifies No significant IWB-2412 the provisions for recertification of Level 111 NDE personnel and change corrects the term " inspection period" to " inspection interval" in IWB-2411 and IWB-2412.

(5) IWA-2410 Code Edition and Addenda for Inservice Inspection - His No significant revision deletes paragraphs that conflicted with NRC change requirements in 10 CFR 50.55a.

(6) IWA-4000, IWA-5120, Repairs and Replacements - This revision consists of a complete No significant IWA-5250, IWA-6340, rewrite ofIWA-4000 and IWA-7000 into one Article, change IWA-7000, IWB-3113, IWA-4000. Provisions from IWP-4000 and IWF-4000 IWB-3123, IWB-3133, regarding repairs are also moved into the new Article.

IWB-3143, IWB-4100, IWB-4200, IWB-4300, IWB-7100, IWB-7300, IWC-3113, IWC-3124, IWC-3133, IWC-7100, IWD-7100, IWF-4100, IWF-4200, IWF-4300, IWF-4400, IWF-$400, IWF-7100 29

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TABLE I I

=w EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 Item # Paragraphs AfTected Description Classification Justification for Reduction -

(7) IWA-4110, Appendix J Guide to Section XI Repair and Maintenance Activities - His No significant revision adds a new Nonmandatory Appendix J to provide change guidelines for distinguishing plant maintenance work from Section XI repair and replacement activities.

(8) IWA-4120 Exemptions - His revision clarifies that heat exchanger tubing, No significant and sleeves and welded plugs used for heat exchanger tubing, are change not exempt from the requirements ofIWA-4000 for replacement items.

(9) IWA-4310 Defect Removal Procedure - After defect removal, IWA-4310 No significant allows the resulting reduced section thickness to be evaluated. change His revision clarifies that the evaluation techniques given in some of the Section XI Appendices may be used. The change also removes the requirement for surface examination of the removal cavity when the full thickness of the weld is removed and the back side of thejoint is inaccessible.

(10) IWA-4500 Temperbead Weld Repair - His revision incorporates the No significant provisions of Case N-432. He changes include addition of the change GTAW temperbead repair techniques and additional limits on I the permissible depth and area of temperbead repairs.

(11) Fig. IWA-4513.1-1 Temperbead Weld Repair - His revision adds a figure that No significant should have been included when IWA-4500 was revised in the change 1990 Addenda.

(12) IWA-5110, IWA-5120, System Pressure Tests - His revision clarifies the system No significant IWA-5210, IWA-5220, pressure test requirements for Class 1,2, and 3 systems and change IWA-5246, IWA-5250, components. Most of the changes are editorial, but this revision IWA-5260, IWA-5300, replaces the system functional test and the system inservice test Table IWB-2500-1, with the system leakage test.

IWB-5210, IWB-5222, IWB-5240, Table IWC-2500-1, IWC-5210, IWC-5220, IWC-5240, Table IWD-2500-1, IWD-5210, IWD-5220, IWD-5240 __

30

TABLE I EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 Item # Paragraphs Affected Description Classification Justification for Reduction (13) IWA-5240 VT-2 Visual Examination - his revision makes the terminology No significant for VT-2 visual examination consistent. change (14) IWA-9000 Glossary - Ihis revision adds definitions for " design life" and No significant

" design lifetime " change (15) IWB-1220, IWC-1223, Inaccessible Integral Attachments - his revision adds provisions No significant IWC-1230, IWD-1210, to exempt integral attachments that are inaccessible for change IWD-1220, inspection.

Table IWD-2500-1 (16) IWB-2411, IWB-2412, inspection Programs - This revision clarifies that under No significant Table IWB-2500-1, inspection Program B it is permissible to defer inspection of change IWC-2412, IWD-2412 shell-to-flange and head-to-flange welds to the end of each inspection interval.

(17) IWB-2420, IWC-2420, Successive Inspections - This revision corrects the terminology No significant IWD-2420, F-2200 in IWB-2420 and IWC-2420 to be consistent with IWB-3000 change and IWC-3000. In addition, similar provisions for successive examinations are added for Class 3 components.

(18) IWB-2430, IWC-2430, Additional Examinations - His revision changes and clarifies More restrictive IWD-2430 the extent of additional examinations to be performed upon discovery of a flaw or relevant condition that exceeds the acceptance criteria. He change also adds requirements for additional examinations when flaws or relevant conditions are found in Class 3 components.

(19) IWC-1220 Components Exempt From Examination - His revision clarifies No significant the exemptions for components within the RHR, ECC, and CHR change systems.

(20) IWC-5222 System flydrostatic Test - This revision adds provisions for No significant combining the hydrostatic test of the Class 2 portion of the BWR change Main Steam System with the hydrostatic test of the Class I portion of the Main Steam System, whcn the Class 2 portion cannot be isolated. He change incorporates the provisions of N-479.

31

TABLE I ..

EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 Item # Paragraphs Affected Description Classification Justification for Reduction (21) IWC-5222 Exemptions to System Hydrostatic Tests - This new paragraph Less restrictive His change eliminates a test exempts open ended vent and drain lines and open ended safety that really was meaningless and relief valve discharge lines from a flow path test. Rese because the piping must be lines were required to be subjected to a flow path test, in lieu of a examined by other means hydrostatic test, beyond the last shutoff valve. during installation.

(22) IWD-1210, IWD-1220, Examination Requirements - His revision modifies the Tables No Significant IWD-2200, IWD-2500, for the examination requirements of Class 3 systems by Change.

Table IWD-2500-1 consolidating the examination requirements of Examination Category D-A (Systems in Support of Reactor Shutdown Function), D-B (Systems in Support of Emergency Core Cooling, Containment Heat Removal, Atmosphere Cleanup, and Reactor Residual Heat Removal), and D-C (Systems in Support of Residual Heat Removal from Spent Fuel Storage Pool), and clarifies which other Class 3 systems are required to meet the inservice examination requirements of Section XI.

(23) IWF-2200 Adjustment, Repair, and Replacement - His revision adds new More restrictive requirements for examination of component supports following adjustment, repair, or replacement. This revision also permits preservice examination of some component supports prior to initial heating.

(24) III-I100 Ultrasonic Examination Calibration Blocks - His revision No significant clarifies that calibration block materials need not be the same change grade as the material to be examined, as required by 1I1-3411, provided the provisions ofIWA-2240 are met.

(25) Table IWA-1600-1 ERRATA IWA-2110, IWA-2430, Fig. IWA-4513.1-1, Table IWB-2500-1, IWB-3112, ,

IWB-3132.1, Table IWC-2500-1, IWC-3112, IWC-3122.1, IWF-2410, IWF-2420 32

.T

- TABLE I EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 Itern # Paragraphs AfTected Description Classification Justification for Reduction 1990 ADDENDAS (1) IWA-1400, IWA-6100, Records and Reports - his revision clarifies the Owner's No significant IWA-6210, IWA-6220, responsibilities for preparation of plans, schedules, summary change IWA-6230, IWA-6240, reports, and Fonns NIS-1 and NIS-2 Owner's Reports. It also IWA-6340 adds requirements for the content of the abstract of examinations required for the Form NIS-1.

(2) IWA-1400, IWA-2420, Inspection Reports, Schedules and Plans - His revision changes No significant IWA-2440, IWA-6230, the provisions for the preparation and submittal, to the regulatory change IWA-6240 and enforcement authorities, of preservice and inservice inspection reports, schedules and plans to clarify that schedules are required to be prepared but not submitted.

(3) IWA-1400 Owner's Responsibilities for Flaw Evaluation - His revision No significant adds provisions to indicate that the Owner is responsible for flaw change evaluation calculations. IWA-1400(p) provides that the Owner -

is responsible for maintaining pennanent records of flaw evaluations when the flaw exceeds the acceptance criteria of Section XI.

(4) IWA-2210 Qualifications for Visual Examination - This revision replaces No significant the provisions in Section XI regarding qualification of personnel change for visual examination with reference to the provisions in Article 9 of Section V, with supplementary provisions for Section XI use.

(5) IWA-2322, VII-4322, Practical Examination Provisions for Level III NDE Personnel - No significant VII-4330, VII-4342 SNT-TC-1 A provides for practical examinations of NDE Level I change and Level II qualifications. His change requires practical examinations for qualification and recertification of Level III NDE personnel for Section XI. His revision incorporates the provisions ofCase N-489.

(6) IWA-4500, Repair Welding - His revision updates the temperbead welding No significant Fig. IWA-4513-1, requirements and replaces half bead welding with temperbead change Fig. IWA-4531.1-1, welding, for greater consistency with the welding requirements Fig. IWA-4532.1-1 in Section Ill.

33

_ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ = _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ - - _ . - _ _ _ _ .

TABLE I c6 EVALUATION OF REVISIONS TO ASME SECTION XI CODE '- 1989 to 1998 Item # Paragraphs Affected Description Classification Justification for Reduction  ;

(7) IWA-5250 Corrective Action to be Taken for Leaks in Bolted Connections - No significant His revision changes the requirements to be more specific as to change which bolts should be examined when evidence ofleakage is found in a bolted connection during the system pressure test.

(8) IWC-3513 Allowable Flaws for Volumetric Examination of Studs and No significant Bolts - His revision clarifies that for subsurface flaws in studs change and bolts, the standards of Table IWC-3513-1 apply.

(9) IWF-1210,1%T-1230, Sampling Plans for Inspection of Component Supports - His Less restrictive His revision allows a sampling IWF-2200, IWF-2410, revision adds a sampling plan for inspection ofcomponent ofsupports, rather than a 100%

IWF-2420, IWF-2430, supports. In most cases, this change will cause a decrease in the examination, based on the IWF-2500, IWF-3112, number of piping supports to be examined, and an increase in the results ofevaluations made in IWF-3122, IWF-3410 number of other component supports to be examined. His the past. Here have been no revision incorporates the provisions of Case N-491. significant problems with the supports and sampling provides a realistic means to provide appropriate evaluations.

(10) Appendix IV Eddy Cunent Examination of Nonferromagnetic Steam No significant Generator Heat Exchanger Tubing - His revision is a rewrite of change Appendix IV which incorporating latest multifrequency techniques for eddy current examination. His revision incorporates the provisions of Case N-401-1.

(11) A-1100, A-5200, Definition ofTerms Relating to Flaw Evaluation - His revision No significant A-5300, A-9000 adds and modifies definitions relating to flaw evaluation and change acceptance.

(12) A-4300 Fatigue Crack Growth Rate - His change provides fatigue crack Less restrictive ne new methodology provides growth curves for ferritic steel in an air and water environment. an equivalence with the current nis revision incorporates the provisions of Case N-463-1. procedures.

(13) Fig. A-4400-1 Effect of Fast Neutron Fluence and Copper Content Shift on No significant RTsor - His revision deletes the figure which was noted, "In change Course of Preparation."

(14) IWA-9000, IWB-4332, EDITORIAL Table IWD-2500-1 34

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^

TABLE I

'C EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 Item # Paragraphs Affected Description Classification Justification for Reduction (15) IWA-2110, IWA-5214, ERRATA IWA-7210, Fig. IWB-3610-1, IWB-4241, IWB-4242, Table IWC-2500-1, Table IWC-3510-1, Table IWC-3511-1, Fig.

G-2210-1, H-1300, H-3210, Table H-4211-1, H-4221,  ;

Table H-5310-1, '

Table H-5310-2, H-5420, Table H-5410-1, Table H-5410-2, H-6310, H-6320, Table H-6310-2 k

l t

35

. . _ s . _. _, .

I TABLE I EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 Item # Paragraphs Affected Description Classification Justification for Reduction 1989 ADDENDA-(1) IWA-1400, IWA-4130, Repair Program - His revision adds new rules that require the More restrictive IWA-6220 Owner to have both a Repair Program and Repair Plans. He Repair Program contains managerial and administrative (QA) controls, while the Repair Plans contain requirements and procedures specific to each repair.

(2) Table IWA-1600-1 Referenced Standards - Updated ANSI /ASME N626 to 1988. No significant change (3) IWA-2110 Duties of the Inspector - This revision deletes the reference to the No significant inspection Specialist, because this designation is no longer used change in ANSI /ASME N626. His change deletes the requirement for the Inspector to obtain assistance in reviewing technical content of NDE procedures.

(4) IWA-2200 Examination Methods - His revision adds a reference to No significant Nonmandatory Appendix D for surface preparation prior to change NDE.

(5) IWA-2340 Level til Education - His revision provides that a high school No significant equivalency examination need not be a federal or state change administered standardized test.

(6) IWA-2430, lWA-9000 Inspection intervals - his revision clarifies the definition of No significant

" commercial service" for determining the start of each inspection change interval.

(7) IWA-2431, IWA-2432, Inspection Program - His revision deletes the 40 year limit on No significant IWB-2411, inspection Programs A and B. The deletion of this limit change Table IWB-2412-1, provides continuing inservice inspection requirements for plants Table IWB-2500-1, after they have been operating for 40 years.

IWC-2411, Table IWC-2412-1, '

IWD-2411, Table IWD-2412-1 36

_ _ _ . _ _ . _ _ _ . _ _ . _ _ . _ _ _ _ . _ _ _ _ _ _ ~ _ _ _ ___________z_- ___ __.__ _

' e .?

TABLE I E EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 Item # Paragraphs Affected Description Classification Justification for Reduction (8) IWA-4322 Removal of Burned Surfaces - his revision clarifies that when No significant metal is thermally cut, removal of the burned surface must be by change mechanical means.

(9) IWA-4700, IWA-9000 Pressure Testing of Seal Welds - His revision exempts seal No significant l welds from the system hydrostatic test requirements following change repair by welding.

(10) (WA-4700 Pressure Testing of Half-bead Weld Repairs - His revision No significant provides an exemption from the hydrostatic test for vessel repairs change of up to 10 percent of the design thickness made by the half-bead welding technique.

(11) IWA-7320, IWA-9000 Installation - His revision adds provisions for the installation More restrictive and testing of replacements that are attached to the pressure boundary by mechanical means.

(12) IWA-9000 Glossary - Definitions are added for " overpressure protection" No significant and " safety function." change (13) IWB-2500, IWB-3512, Category B-D - His revision clarifies that the examination No significant Table IWB-2500-1, provisions apply to the specified areas of full penetration welded change Table IWB-3410-1 nozzles in vessels and are not restricted to only the welds.

(14) Table IWB-2500-1, Fig. Pressure Retaining Dissimilar Welds in Vessel Nozzles - This No significant IWB-2500-8, Table revision clarifies that Examination Category B-F applies to change IWB-3410-1, dissimilar metal welds only in vessel nozzles, not in piping.

IWB-3514 (15) Table IWB-2500-1 Pressure Retaining Bolting Greater han 2 Inches In Diameter - No significant His revision replaces the surface examination requirement for change reactor vessel closure head nuts (ltem B6.10) with a VT-1 visual examination meeting the acceptance criteria ofIWB-3517. Prior to this revision, there was no acceptance criteria given for the surface examination.

37

es TABLE 'I EVALUATION OF REVISIONS TO ASME SECTION XI CODE - 1989 to 1998 Item # Paragraphs Affected . Description Classification Juetification for Reduction (16) Table IWB-2500-1, Examination of Pitssure Retaining Welds in Piping - This No significant Table IWC-2500-1 revision clarifies that pressure retaining welds in carbon and low change alloy steel piping are to be examined by ultrasonic examination for transverse indications only when reportable transverse indications were found during the preservice examination.

(17) IWB-3650, Appendix H Acceptance Criteria for Flaws in Ferritic Piping - His revision Less restrictive The new methodology provides provides evaluation techniques and acceptance criteria for an equivalence with the current evaluating flaws in ferritic piping that exceed the acceptance procedures, standards ofIWB-3514.2. This revision incorporates the ,

provision 9fCase N-463.

(18) IWB-4300 Heat Exchanger Tubing - This revision adds provisions for repair More restrictive of heat exchanger tubing by sleeving. He sleeving methods include explosive welding, fusion welding brazing, and mechanical, hydraulic, or explosive expansion.

(19) IWC-1221, IWC-1222, Compments Exempt From Examination - His revisivn was Less restrictive The revision incorporates the IWD-1220 iatended to clarify the existing provisions regarding exemptions provisions of Case N-408-2 from examination for Class 2 and 3 piping systems. However, which has been accepted by the the revision expanded the exemption to include vessels of all NRC. He change merely sizes in exempt piping. provides that componenn in an exempt piping system are also exempt from the inservice examinations. His change does not reduce safety.

, (20) IWF-5400 Repairs and Replacements for Snubbers - His revision deletes No significant reference to O&M-1987, Part 4 (Rev.1) for repair and change replacement of snubbers because the repair and replacement requirements of O&M Part 4 are not consistent with Section XI requirements.

(21) Appendix F Valve Test Tables - This revision adds a new Footnote to No significant reference ANSI /ASME OM, Part 10,5210 and 5320 for change identifying sa'ves required to be exercised.

38

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