ML20203C314
| ML20203C314 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/20/1998 |
| From: | Terry C, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-98041, NUDOCS 9802250145 | |
| Download: ML20203C314 (104) | |
Text
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Log # TXX 98041 L.
2 File # 10010.1
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905.2 (clo)
Ref. # 10CFR50.55a(a)(3)(1) 7t# ELECTRIC' 10CFR50,55a(g)(5)(111)
February 20, 1998 C.1.amt let ry YI sl$N oltw U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555
SUBJECT:
C0HANCHE PEAK STEAH ELECTRIC STATION (CPSES)
UNITS 1 AND 2 DOCKET N05, 50 445 AND 50 446 RELIEF REQUESTS TO THE UNIT 1 INSERVICE INSPECTION PROGRAM (1986 EDITION OF ASME CODE SECTION XI, NO ADDENDA, INTERVAL START DATE: AUGUST 13. 1990, FIRST INTERVAL)
AND THE UNIT 2 INSERVICE INSPECTION PROGRAM I
(1986 EDITION OF ASME CODE, SECTION XI, NO ADDENDA, INTERVAL START DATE: AUGUST 3, 1993. FIRST INTERVAL)
REF:
- 1) Federal Register Notice, August 8, 1996 (Volume 61. Number 154 Page 41303), " Codes and Standards for Nuclear Power Plants:
Subsection IWE and Subsection IWL, Final Rule" TU Electric has determinud that the attached proposed alternatives provide an acceptable level of quality and is requesting relief in accordance with the requirements of 10CFR50,55a(a)(3)(i).
This transmittal submits relief requests Unit 1 E 1 and L 1 and Unit 2 E 1 and L 1 (Attachments 1, 2, 3, and 4 respectively) for your approval.- These relief requests will be incorporated into the Inservice Inspection Program after NRC approval, in accordance with Reference 1 the containment examinations required by Subsections IWE and IWL must be completed by September 9, 2001.
To comply with this requirement TV Electric must begin the containment examinations during the fourth refueling outage for Unit 2 (scheduled for the spring of 1999). 'The CPSES program implementation documents are scheduled to be developed in the summer of 1998 to support the upcoming Unit 2 refueling outage.
Therefore, TV Electric requests approval of the relief requests by gj \\
-June 30, 1998.
l I
9002250145 990220 "
DR ADOCK 050004 5 ll 1 ll Ilii,dilli,lll l
P O. flat 10:12 Olen Row. Tesai 7eou
TXX 98041 Page 2 of 2 If you have any questions, please contact Mr. Carl B. Corbin at (254) 897 0121.
Sincerely.
$. h.
y' C. L. Terry 3y:
M Roger D' Walker 4;
Regulatory Affairs Manager CBC:cc Attachments c-Mr. E. Herschoff, Region IV Hr. J. I. Tapia Region IV (clo)
Mr. T. J. Polich. NRR Hr. G.
Bynog. TDLR Resident Inspectors, CPSES Hr. J. C. Hair. ANII 1
Attachment I to TXX 98041 Page1of2 CPSES UNIT I REllEF REQUEST E-l A.
Item (s) for which relicfis requested:
hietallic containment shcIl and penetration liners and their integral attachments.
II.
Item (s) Code Class:
hic C.
Examination requirements from which relicfis requested:
1992 Edition,1992 Addenda of Subsection IWE," Requirements for Class h1C and hietallic Liners of Class CC Components of Light Water Cooled Power Plants", of Section XI, Division 1 of the American Society of hiechanical Engineers Boiler and Pressure Vessel Code (AShiE Code).
D.
Basis for relief:
1 The 1992 Edition with the 1992 Addenda of Subsection IWE contains requirements which impose difficulties in the transition from the current ISI 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 detailed below. These alfrmative examinations provide for consistency with the existing programs in the qualificat.n of nondestructive examination personnel as well as providing more practical requirements for the examination of containment bolting, seals and gaskets.
Some specific hardships imposed by the 1992 Edition, '92 Addenda ofIWE that are not compensated for by an increased level of plant quality and safety are as follows:
IWA 2300 requires the use of a written practice prepared in accordance with ANSI /ASNT CP-189 for the qualification and certification of containment nondestructive examination personnel. All other CpSES NDE and ISI activities, including those perfonned on the reactor vessel, are perfonned by personnel qualified and certified to written practices prepared in accordarse with SNT-TC-1 A as required by ash 1E XI 1986 Edition, No Addenda, the Code of record for ISI at CPSES. Utilizing the '92 Addenda oflWE would require the development of a separate written practice and the issuance and tracking of separate certifications for both TU Electric and contractors. Administration of the resulting duplicate programs could result in documentation inconsistencies and would be an impact to resources.
Containment bolting requires a VT 1 examination and a bolt torque or bolt tension test per Table IWE-25001. Detennination of bolt torque or tension requires the perfom1ance of a maintenance activity to un torque or un tension the bolt and then to re-torque or re tension the bolt. Boltedjoints are currently subject to Appendix J leak testing and a visual A
Attact ment I to TXX 98041 Page 2 of 2 examination to verify leak tight and structural integrity. Other bolted joints subjected to visual exmnination by ash 1E XI, including Code Class i bolting, do not require bolt torque or bolt tension testing. Performance af the maintenance activity would b; an impact to resources, increases radiation exposure and could result in damage to permanent plant equipment.
Seals and gaskets require specific VT 3 examinations per Table IWE 25001, Seals and gaskets are not part of the containment pressure boundary. Bolted joints and airlocks are currently subject to Appendix J leak testing and visual examinations to verify leak tight integrity. The performance of additional VT 3 examinations of seals and gaskets to detect conditions that may violate leak tight integrity is redundant, increases radiation exposure and would be an impact to resources.
The proposed alternative is to utilize the current ash 1E approved rewrite of Subsectian IWE of Section XI in its entirety. Utilizing the entire IWE rewnte incorporates other exceptions to the '92 addenda stated in NRC rulemaking and provides more cohesiveness than could be achieved by requesting relief on several individual subjects separately. The alternate examination requirements match the rewrite exactly and are included as Enclosure 1 of this relief request. These requirements were developed in accordance with the AShiE Code committee process with input from interested parties which included TU Electric, other utilities, manufacturers, engineering organizations, Authorized Nuclear inspection Agencies, EPRI and the NRC. The updating of regtdrements by this consensus process is intended to ensure the continued safe operation of nuclear power plants and specifically in this case the continued leak tight and structuralintegrity of metallic containment components. Therefore, the overall level of plant quality and safety will not be adversely affected by utilizing the requirements of the current ash 1E approved IWE rewrite. A detailed evaluation and line by line comparison of the differences between the 1992 Edition with the 1992 Addenda of Subsection IWE and the curren: AShiE approved rewrite is included as enclosure 2 of this relief request.
CPSES Unit 1 is in the third period of the first ten year ISI interval. Based on current plant refueling outage schedules and the requirement of the new rulemaking for full implementation by September 9,2001, a containment ISI examination program must be established immediately. Implementing this relief request now would reduce the overall impact to resources (both TU Electric's and the NRC's) versus incorporating the mandated edition and addenda ofIWE in conjunction with this initial establishment of a containment ISI program and then updating again to a later edition and or addenda or to a series of Code Cases upon fonnal NRC endorsement or on the next ten year ISI plan issuance.
E.
Alternate Examinations:
See Enclosure 1 of this relief request for the requirements of the current AShiE approved rewrite of Subsection IWE which defines the attemate examinations of this relief request.
F.
Anticipated impact on the overall level of plant quality and safety:
None.
- to CPSES Unit 1 Relief Request E-1 Page1of14 AR1lCLE 1000 SCOPE AND RESPONSlHil.lTY 1100 SCOPE 1his Subsection provides requirements for inservice ir.spection of Class MC pressure retaining components and their integral attachments, and of metallic sh:ll and penetration liners of Class CC pressure retaining components and their integral attachments in
. light water cooled plants.
1200 COMPONENTc SUHJECT TO EXAMINATf 0N
-1210 EXAMINATION REQUIREMENTS l
1he examination requirements of this Subsection shall apply to Class MC pressure retaining components and their integral ottachments and to metallic shell and penetration liners of Class CC pressure retaining components and their integral attachments.
These examinations shall apply to surface arees, inch. ding welds and base metal.
1220 COMPONENTS EXEMPTfD FROM EXAMINATION 1he following components (or parts of components) are exempted from the examination requirements of 20CO:
(a) vessels, parts, and appurtenances outside the boundaries of the containment system as denned in the Design SpeciGcations; (b) embedded or inaccessible portions of containment vessels, parts, and appurtenances that met the requirements of the original Conctruction Code; (c) portions of containment vessels, parts, and appurtenances that become embedded or inaccessible as a result of vessel j
repcir/ replacement activities if the conditions of 1232 and 5220 are met; I
(d) piping. pumps, and valves that are part of the containment system, or which penetrate or are attached to the containment l
.essel. 'these components shall be examined in accordance with the requirements ofIWH or IWC, as appn piiate to the claseincation denned by the Design Speci0 cations.
1230 ACCESSIBILITY FOR EXAMINATION 1231 Accessible Surface Areas (a) As a minimum, the follm,.ng portions of Class MC containment vessels, parts and appurtenances and Class CC metallic shell and penetration liners shall remain accessible for either direct or remote visual examination, from at least one side of the vessel, for the life of the plant:
(/) openings and penetrations; (2) structural discontinuities; (3) 80% of the pressure retaining boundary (excluding attachnents, structural reinforcement and areas made inaccessible during construction); and (4) surface areas identined in 1240.
(b) 'Ihe requirements of 1232 shall be met when accessibility for visual examination is only from the interior surface.
1232 Inaccessible Surface Areas (a) Portions of Class MC containment vessels, parts, and appurtenances that are e' edded in concreta or otherwise made
- inaccessible during construction of the vessel or as a result of vessel repair / replacement ativities are exempted from examination, provided:
(/) no openings or penetrations are embedded in the concrete; (2) all welded joints that are inaccessible for examination are double buttwelded and are fully radiographed and, pnot to being covered, are tested for leak tightness using a gas medium test, such as llalide Leak Detector Test; and (3) the vessel is leak rate tested atter completion of construction or repair / replacement activities to the leak rate requirements of the Design Specifications.
(b) Portions of Class CC ruetallic shell and penetration liners thm are embedded in concrete or otherwise made inaccessible during construction or as a resuh of repair / replacement activities are exempted from examination, provided:
Enclosure I to CPSES Unit i Relief Request E.1 Page 2 of 14
(/) all welded joints that are inaccessible for examination are examined in accordance with CC.5$20 and, prior to being covered or otherwise obstructed by adjacent structures, components, parts, or appurtenances, are tested for leak tightness in occordance with CC 5536; and (1) the containment is leak rate tested after cornpletion of construction or repair' replacement activities to the leak rate requirements of the Design Speci0 cations.
1240 SifRFACE AREAS RI:QlilRING Al'GhlENTED 1:XAf,IINATION 1241 Examination Surface Areas Surfaca areas hkely to experience accelerated degradation and aging require the augmented examinations identined in Table.
2500-1,1:xarnination Category li C. Such areas include the following:
(a) interior and exterior containment surface areas that are subject to accelerated conosion with no or minimal corrosion i
allowance or areas where the absence or repeated loss of protective coatings has resulted in substantial corrosion and pitting. Typical kications of such areas are those exposed to standing water, repeated wettmg and drying, persistent leakage, and those with geometries thct permit water accumulation, condensation, and microbiological attack. Such areas may include penetration sleeves, stiffeners, surfeces w etted during refueling, concrete to steel shell or liner interfaces, embedment rones, leak chase channels, drain areas, or sump liners.
(b) interior and exterior containment surface areas that are subject to excessive wear from abrasion or crosion that causes a loss of protective coatings, defonnation, or material loss. Typical hicatio~. such areas are those subject to substantial traf0c, sliding pads or supports, pins or clevises, shear lugs, seismic restraints, surfaces exposed to water jets from testing operations or safety relief valve discharges, and areas that experience w car from frequent vibrations.
(c) interior and exterior contamment surface areas identined in accordance with.2420(b).
1242 Ident:0 cation of lixanunation Surface Areas Surface areas requiring augmented examination shall be determined in accordance with 1241, and shall be identined in the Owner's Inspection Program.
Ihamination methods shall be in accordance with 2500(b).
ARTICl.E.2000 ENAhllNATION AND INSPECTION 3100 GENERAL, (a) 'Ihe requirements ofIWA.2000 apply, except the requirements of IWA 2210,IWA 2300, IWA.2500 and IWA 2600 are not nadatory for Table 25001 visual examinations.
2200 PRESERVICE ENAS11 NATION (a) thaminations listed in Table 2500-1 shall be completed pnot to initial plant startup. These preservice examinations shall include the pressure retaining portions of components not exempted by.1220.
(b) When visual examinations are rquired, these examinations shall be performed in accordance with.2600, following the completion of the pressure test required by the Construction Code and after application of protective coatings (e g., paint) when such coatings are required.
(c) When a s essel, Imer, or a portion thereof is subjected to a repair ' replacement activity during the service hfetime of a plant, the preservice exammatmn requuements for the portion of the vessel affected by the repair! replacement activity shall be met.
(/) When the repair' replacement activity is perfonned w hile the plant is not in service, the preservice examination shall be perfonned pnot to tesumption of service.
(1) When the repair' replacement activity is perfonned w hile the plant is in service, the preservice examination may be defened to the next scheduled plant outage, provided nondestructive examination in accordance with the Repair / Replacement Program is performed.
(3) When a system leakage test is requued by.5220, the preservice examination may be performed either prior to or following the te>t.
(d) Welds made as part of repair' replacement activities shall be examined in accordance with the requirements ofIWA-4000,
Enclosure I to CPSES Unit 1 Relief Request E 1 Page 3 of 14 cxcept that for w cids joining Class MC or Class CC components to items designed, constructed, and installed to the requirements of Section III, Class 1,2, or 3, the exarnination requirements ofIWil 2000, IWC 2000, or IWD-2000, as applicable, shall also apply.
(c) Preservice examination for a repair / replacement activity may be conducted prior to installation provided:
(/) the examination is performed after the pressure test required by the Construction Code has been completed; (2) the examination is conducted under conditions and with equipment and techniques equivalent to those that are expected to be employed for subsequent inservice examinations; and (3) the shop or field examination records are, or can be, documented and identified in a form consistent with that required byIWA 6000.
2300 VISUAL EXAMINATION, PERSONNEL, QUALIFICATION, AND RESPONSlHLE INDIVIDUAL 3310 visual esaminations (a) The Owner shall denne requirements for visual examination of containment surfaces.
(b) General sisual examinatiom shall be performed in accordance with 2500 and Table 25001, Examination Category E A to essess the general condition of containment surfaces.
(c) Detailed visual examinations shall be performed in accordance with 2500 and Table 2500-1, Examination Category E-C:
(/) to assess the initial condition of surfaces requiring augmented examination in accordance with 1241 and to determine the magnitude and extent of any deterioration and distress of these surfaces.
(2) to detennine the magnitude and extent of deterioration and distress of suspect containment surfaces initially detected by general visual examinations.
l (d) Detailed visual examinations shall also be performed in accordance with 5240 to assess the structural condition of areas affected by repair / replacement activities.
(c) For areas and items subject to detailed visual examination, the following criteria apply,
(/) Painted or coated areas shall be examined for evidence of naking, blistering, peeling, discoloration, and other signs of distress.
(1) Non-coated areas shall be examined for evidence of cracking, discoloration, wear, pitting, excessive conosion, gouges, surface discontinuities, dents, and other signs of st rface irregularities.
(3) Pressure retaining bolting materials shall be examined for conditions w hich may cause the bolted connection to violate either the containment leak tight or stmetural integrity, Examples of such conditions are bent, twisted, or deformed bolts or studs; missing or loose bolts, studs, nuts, or washers, fractured bolts, studs, or nuts; and degraded coatings on bolting surfaces accompanied by damage or degradation of the botting material.
(4) Moisture barriers shall be examined for wear, damage, erosion, tear, surface cracks, or other defects that may permit intrusion of moisture against inaccessible aicas of the pressure retaming surfaces of the metal containment shell or liner.
2320 RESPONSIHLE INDIVIDifAL (a) The Responsible Individual sh:ll be knowledgeable in the requirements for design, inservice inspection, and testing of Class MC and metallic liners of Class CC components.
(b) The Responsible Individual shall be responsible for the following:
(/) development of plans and procedures for examination of containment surfaces; (1) instruction, training, and approval of visual examination personnel; (3) performance or direction of general and detaibd visual examinations; (4) evaluation of examination results; (3) submittal or report to the Ow ner documenting results of examinations.
3330 PERSONNEL QUALIFICATION (a) lhe Owoer shall denne the qualineation requirements for peisonnel performing visual examinations.
(b) Visual examinations shall be performed either directly or remotely, with adequate illumination, by personnel with visual acuity sumcient to detect evidence of degradation.
2400 INSPECTION SCllEDULE 4 110 INSPECTION PROGRAM
i to CPSES Unit 1 Relief Request E 1 Page 4 of 14 Inservice examinations and system pressure tests rnay be perfortned during plant outages such as refueling shutdowns or rnointerinnec shutdowns. Tlie requirements of either inspection Program A or inspection Program 11 shall be met.
2411 Inspection Program A With the exception of the examinations that may be deferred until the end of an inspection interval, as specified in Table 2500-1, the required examinations shall be completed during each successive inspection interval, in accordance with Table 24 Il 1.
Following completion of Program A aller 40 years, successive inspection intervals shall follow the 10 year inspection interval of Program II.
TABl.E 2411 1 INSPECI'lON PROGRAM A Inspection Inspection Period, Minimum Maximum interval Calendar Years of Examinations Examinations Plant Sctrice Completed. %
Credited. %
1st 3
100 100 2nd 7
33 67 10 100 100 3rd 13 16 34 17 40 50 20 66 75 23 100 100 4th 27 R
16 30 25 34 33 50 67 37 75 100 40 100
. to CPSES Unit i Relief Request E 1 Page 5 of14 TAllLE 24121 INSPECTION PROGRAM 11 Inspection inspectian Period, Minimum Maximum Interval Calendar Years of Examinations Examinations Plant Service Completed. %
Credited. %
All 3
16 50 1
50 75 10 100 100 2412 Inspection Program !!
(a) With the exception of the examinations that may be deferred until the end of an inspection interval, as specified in Table -
25001, the acquired examinations shall be completed during each successive inspection interval,in accordance with Table 2412 1.
(b) Ifitenu or welds are added to the Inspection Progrem, examit stion shall be scheduled as follows.
(/) When items or welds are added during the first period of en interval, at inst 25% of the examinations required by the applicable Examination Category and item Number for the added items or w elds shall be performed during each of the second and third periods of that interval, Alternatively, if deferral of the examinations is permitted for the Examination Category and item Number, the second period examinations may be deferred to the third period and at least 50% of the examinations required by the applicable Examination Category and item Number for the added items or welds shall be performed during the third period.
- (2) When items or welds are added during the second period of an interval, at least 25% of the examinations required by We opplicable Examination Category and item Number for the added items or welds shall be performed during the third period of that inten al.
(3) When items or w elds are added during the third period of an interval, examinatioas shall be scheduled in accordance with 2412(a) above for successise intervals.
2420 SUCCESSIVE INSPECTIONS (a) The sequence of component examinations established during the first inspection interval shall be repeated during each successive inspection inten al,! the extent practical.
(b) When examination results require evaluation of flaws or areas of degradation in accordance with 3000, and the component is acceptable for continued service, the areas containing such flaws or areas of degradation shall be reexamined during the next inspection period listed in the schedule of the inspection program of -2411 or 2412, in accordance with Table -2500-1, Excmination Category E-C.
(c) When the reexaminations required by 2420(b) reveal that the flaws or areas of degradanon remain essentially unchanged for the next inspection period, these areas no longer require augmented examination in accordance with Table +2500-1, Examination Category E.C,
-3500 EXAMINATION AND PRESSt!RE TEST REQUIREhlENTS (a) Examination methods shall comply with Table 25001, except w hen alternative examination methods are used that meet the requirements ofIWA 2240.
(b> Methods for augmented examination of surface areas identified in 1242 shall comply with the following criteria:
(1) Areas accessible from both sides shall be visually examined using a detailed visual examination method.
s (2) Areas accessible from one side only shall be examined for wall thinning using an ultrasonic thickness measurement method in accordance with Section V, T 544.
I
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ to CPSES Unit 1 Relief Request E 1 Page 6 of 14 (3) When ultrasonic thickness measurements are performed, grids shall be used. Grid line spacing shall comply with the requirernents of Table 2500 2. ~lhe numbtr and location of the grids shall be determined by the Owner, Locations of grid line intersections to be examined may be marked on containment surfaces in lieu of marking grid lines.
(4) Ultrasonic thickness measurements shall be perfonned to determine the minimum wall thicknesses at locations specified in Table.2500 2. Mintmum wall thickness locations and locations of exas. ned grid line intersections shall be marked such that periodic reexamination of these locations can be perfonned in accordance with the requirements of Table.25001, fixamination Category l! C.
(c) pressure test requirements for components and parts of the pressure retaining boundary shall comply with the requirements of 5000.
2600 CONDITION OF StfRFACE TO llE EXAMINED (a) When a containment vessel or liner is painted or coated to protect surfaces from conosion, preservice and inservice visual excminations shall be performed without the removal of the paint or coating.
(b) When ternoval of paint or coating is required, it shall be removed in a manner that wi!! not reduce the base metal or weld thickness below the design thickness.
1 1
0
i l
l Enclosure I to CPSES Unit 1 Relief Request E-1 Page 7 of14 TABLE -2500-1 EXA\\lINATION CATEGORIES EXANfINATION CATEGORY E-A. CONTAINN1EST SURFACES Item Parts Exammation Exammation Acceptance Extent and Frequency of Eummatma Deferral of No.
Exammed Requirements /
Niethod Standard hispecten to End of Fig. No.
3 3, g 3,cc,33 g I"I# " I Interval Inspection Intervals El.10 Containment Vessel Pressure Retaining Boundary' El.11 Accessible Surface Areas
-2310 General Visual
-3510 100% Durmg each 100*; Durmg each N 'A Inspecten Period Insp-cten Pern!
El.12 Wetted Surfaces of Submerged Areas
-2310 General Visual
-3510 100 %
100 %
Permissible EI20 BWR Vent System
-2310 General Visual
-3510 100 %
1W; Pemussible Accessible Surface Areas 'l El.30 Stoisture Barriers'
-2310 General Visual
-3510 100% Durmg each IWe Durmg each N'A Fig. -2500-1 Inspecten Period Inspecten Period NOTES:
(I) Examination shall include all accessible interior and exterior surfacts of Class 3fC components, parts, and appurtenances, and metalhe sheII and penetration Imers of Class CC components. The following items shall be considered for exananatwn:
(a) integral attachments and structures that are parts of reinforcing structure, such as stiffening rings. manhole frames, and reinforcement around openmgs.
(b) surfaces of attachment w elds between structural attachments and the pressure retaining botandary or remforcing structure, except for nonstructural or tu.pn.uy attachments as dermed in NE-4435 and mmor gu.mncnt attachments ad dermed in CC-4543 4.
(c) surfaces of containment structural and press se boundary welds, mcludmg longitudinal welds (Category A). circumferentzal welds (Category B). flange welds (Category C). and nozzle-to.shell welds (Category D) as dermed in NE-3351 for Class A1C and CC-3840 for Class CC: and surfaces of Flued IIcad and Bellows Seal Circumferential Welds joined to the Penetration.
(d) pressure-retaining bolted connections including bolts, studs, nuts, bushings, washers, and threads in base meterul and flange ligaments between fastener holes.
Bolted coanections need not be disassembled for performance of e aminations, and boltmg may remam in place under tension.
(2) Inch es flow channelmg devices within contamment vessels.
(3) Examinatmn shall include moisture banier materials intended to prevent intrusion of moisture agamst inaccessible areas of the pressure retaining metal umtahmeet shell or liner at concrete-to-metal interfaces and at metal-to-metal interfaces which are not seal-welded. Contamment motsture bamer matenals include cauIking.
flashing. and other scalants used for this application.
Enclosure I to CPSES Unit 1 Relief Request E-I l
l Page S of14 TABLE -2500-1(CONT'D)
EXMilNATION CA EGORIEE EXAMINATION CATEGORY E-C, CONTAIN%fENT SURFACES REQUIRING AUGNIENTED EXA%1INAT10N Item Parts Exammation Examinatwn Amyi.uce Extent and Frequency of Exammation Deferralof No.
Examined Requirements /
Method Standard Inspectwn to End of Fig. No.
,,, g
%,g,
- I Interval Inspection Intervals E4.10 Containment Surface Areas' E4.11 Visible Surfaces
-2310(c)
Detailed Visual
-3511 100% ofSurface 100% ofSurface Not Permissible
-2500(b)(I)
Areas Areas idennfied by f
-2500(bX2)
Identified by
-12422
-1242' E4.12 Surface Area Grid Gral Line Intersections and
-2500(bX2)
Ultrasonie
-3511 100% ofGrid Line 100*4 of Grid Line -
Not Permissible Mmtmum
-2500(bX3) nickness Intersectwns and Intersectmas and Wall Hickness Locations
-2500(bX4)
Minimum Wa!!
Mmunum WaII Tbickness Thickness Imtens durmg Locatens durmg each Inspecten eachI mm,s Permd.estabhshed '
Period, estabhshed in acmd.uce wnh in accordance mth
-2500(b)(3)2and
-2500(bX3)2and
-2500(bX4)2
-2500(bX4)2 NOTES:
(1) Containment surface areas requiring augmented examination are those identified in -1240.
(2) The extent of examination shall be 100*4 for each inspecten period until the areas remain essentially unchanged for the next Lovecove penod. Such areas no longer require augmented examination in accordance with -2420(c).
Encicsure I to CPSES Unit 1 Relief Request E-1 Page 9 of11 TABLE -2500-2 ULTRASONIC TIIICKNESS MEASUREMENTS FOR AUGMENTED EXAMINATIONS Augmented Exammatmo Area Size (Contiguous)
Ex.muuten Rquusumus s 100 square feet 100% of Gnd Lme Intersectmns"*
> 100 square feet 100*e of Gnd Eme Iniersectmas'"*
Notes:
- 1. Locatmn and size of area to de eummed shall be dtimuucd by the Owner.
- 2. Grid ime spacmg sha!! not exceed 12 mches. and need not be less than 2 inches.
9
- 3. Gnd ime spacmg shall be selected such that a. i of 100 um.mmuxats are obtamed fmm withm each augmented cummatxe area. unless this reqmres selectmg a gnd Ime spacmg ofless than 2 mches.
- 4. In lieu of examimng 100% of the gnd ime mtersectens withm the augmented eummatmn area. an alte nate eummatmo plan may be developed as fo3ous:
(a) A sample area from within the augmented exammanon area may be selected for m..
aw,u. The locaten and size of the sample area shall be detemuned by the Owner, but shall consist of areas subject to the most ses ere service cvudduns withm the larger augu,.oi
- exammatmo area. 100%
of the gnd hne intersectens ulthm the sample area shall be exammed. and gnd Ime spacmg shall be selected such that a -
- of 100 measurements are cbtamed from withm the sample area.
(b) If the sample area exceeds 100 contiguous scuare feet the Oswer may develop a samping plan for exammatma of gnd ime mtersectens withm the sample arer. Locatxrts of ultrasonic thickness measurements to be taken at gnd ime mtersectmas shall be selected at random J Qa.ut the sample area. The mmirrmm number of neasurements shall be 100, or shall be sufTicient to ensure at least a 95% confalence level that the thickness of the base metal is reduced by no more than 10% of the nommal plate thickness at 95% of the gnd Ime mtersectens withm the sample area. 3 hachever is greater.
(c) If any ultrasonic thickness um.mnuguts 31thm the sample area reveal that the thickness of t' e base metal as reduced by more than 10% of the nommal plate thickness, all remammg gnd ime intersectwns wnhin the sample area shall be eummed, and additmaal UT cummatmes from outsmie of the sample ar-a shall be required. These additwnal LTT cummations shall be performed on another area from withm the larger augmented cummaten area that is at least as large as the mitial sample area. If any of these subsequent exammatens reveal that the thickness of the base metal is reduced by more than 10% of the nommal plate thickness additional areas from within the larger zugmented eummation area shaII be exammed until subsequent exammatens of additional areas reveal no measurements a here metal loss exceeds 10% of the nommal plate thickness, or until the entire augmented enmmation area has been eummed.
- 5. When an ultrasonic thickness measurement performed at a gnd ime intersecten reveals that the thickness of the base metal is reduced by more than 10% of the nominal plate thickness, the mmunum wall thickness shaII be determmed and located 3,thm each ad ommg gnd.
f
- 6. Measurements need not be obtamed at locations where obstructens interfere with gnd ime mtersectens
Enclosure I to CPSES Unit 1 Itcliefitequest E 1 Page 10 of 14 l
Enarnhaton a,ee A4 F4 essure retaining rnetal f,.
containment shell or utner a /
/
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Enclosure I to CPSES Unit 1 ReliefItcquest E 1 Page11of14 ARTICI.l; 4000 ACCEPTANCE STAND ARDS 4100 EVALUATION Or EXAMINATION RESUl/IS 4 110 PRESERVICE EXAMINATIONS dill General
'the preservice examination required by 2200 and performed in accordance with the procedures ofIWA 2200 shall be evaluated by the acceptance standards specined in 3500. Acceptance of components for service shall be in accordance with 3112 and.3114.
3112 Acceptance (a) A component whose examination either con 0rms the absence of or detects Daws or areas of degradation j
that do not exceed the acceptance standards of 3500 is acceptable for service, provided the Daws or areas of degradation are recorded in accordance with the requirements ofIWA 1400(h) and IWA 6230 in tems oflocation, size, shape, orientation, and distribution within the component.
(b) A component w hose examination detects Daws or areas cf degradation that do not meet the acceptance standards of 3500 is unacceptable for service unless the component is corrected by a repair / replacement activity, to the extent necessary to meet the acceptance standards, prior to placement of the component in service.
i al14 Repair / Replacement Activity and Reexamination ne sepairl eplacement activity and reexamination shall comply with the requirements of IWA-4000.
i Reexamination shall be conducted in accordance with the requirements ofIWA 2200. The recorded results shall demonstrate that the area subjected to the repair / replacement activity meets the acceptance standards of 3f00.
4120 INSERVICE EXAMINATIONS 4 121 Gencial inscruce examination results shall be compared with recorded resnits of the preservice examination and prior inservice examinations. Acceptance of the components for continued service shall be in accordance with 4122.
3122 Acceptance 4 122.1 Acceptance by Examination. A component whose exammation results meet the acceptance standards of 3500 shall be acceptable for continued service. Con 0rmed changes in Daws or areas of degradation from prior examinations shall be recorded in accordance with IWA 1400(h) and IWA 6230. A component that does not meet the acceptance standards of 3500 shall be corrected in accordance with the provisions shown in 2122.2 or 4 122.3.
3122.2 Acceptance by RepairReplacement Activity. A component whose examination detects Daws or areas of degradation that do not meet the acceptance standards of 3500 is unacceptable for continued service until the component is conectN by 7 repair / replacement activity to the extent necessary to meet the acceptance :tandards of 4 500 4 122.3 Acceptance by Engineering Evaluation (a) A component whose examination detects flaws or areas of degradation that do not meet the acceptance standards of 35'9 is acceptable for continued service without a repair! replacement activity if m engineering evaluation indicates tb9t the flaw or area of degradation is nonstructural in nature or has no unacceptable effect on the structural integrity on the containment. If either the thickness of the base metal in local areas is reduced by no nere than 10% of the nommal plate thickness or the reduced thickness can be shown by analysis to satisfy the requirements of the Design Specineations, the component is acceptable by engineerir 3 valuation.
Enclosure I to CPSES Unit 1 Relief Request E 1 Pcge 12 of14 (b) When flaws or areas of degradation are accepted by engineering evaluation, the area containing the flaw or degradation shall be reexarnined in secordance with.2420(b) and (c).
(c) When portions of later editions of the Construction Code or Section ill are used, all related portions shall be met.
3124 Repair / Replacement Activity and Reexamination The sepair/ replacement activity and reexamination shall comply with the requirements ofIWA 4000.
Reexa'nination shall be conducted in accordance with the requirements ofIWA.2200. The recorded results shall demonstrate that the area subject to the repair / replacement activity meets the acceptance standards of.3500.
3130 INSERVICE VIStJAl, EXAMINATIONS A component whose visual examinations as specified in Table.25001 detects areas that are suspect, shall be unacceptable for continued service unless, following verification of the suspect areas by the supplemental examination as required by 3200, the requirements of.3120 are satistled.
3200 StIPPl.EMENTAI, EXAMINATIONS lixaminations that detect flaws or evidence of degradation that require evaluation in accordance with the requirements of.3100 may be supplemented by other examination methods and techniques (IWA.2240) to determine the character of the flaw (i.e., sire, shape, and orientation) or degradation. Visual examinations that detect surface flaws or areas that are suspect shall be supplemented by either surface or volumetric examination, w ben specified as a result of the engineering evaluation performed in.3122.3.
3400 STANDARDS 3410 ACCEPTANCE STANDAHDS I
'the acceptance standards of.3500 shall be applied to evaluate the acceptability of the component for service following the preservice examination and each inservice examina* ion.
4 3430 ACCEPTAHil.lTY l laws or areas of degradation that do not exceed the allowable acceptance standards of.3500 for the respective exammation category shall be acceptable.
1-3500 ACCEPTANCE STANDARDS 3510 STANDARDS FOR EXAMINATION CATEGORY E.A. CONTAINMENT St!RFACES 3510.1 Visual !!xamination General, The Owner shall define acceptance criteria for visual exammation of containment surfaces.
3510.2 Visual lixamination of Coated and Non-coated Areas. The condition of the inspected area is acceptable if there is no evidence of damage or degradation which exceeds the visual examination acceptance criteria specified by the Owner. Areas that are suspect shall be accepted by engineering evaluation or corrected by repair / replacement activities ia iccordance with.3122. Supplemental examinations in accordance with.3200 shall be performed when specified a<. a result of the engineering evaluation.
1 Enclosure I to CPSES Unit 1 Relief Request E 1 Pcge 13 of14 1
35103 Visual Examination of Pressure. Retaining flolting. lixcept for loose bolting, bolting materials with 4
4 conditions that cause the bolted connection to violate either the containment leak tight or structuralintegrity shall bc corrected by repair / replacement activities.
3510.4 Visual !!xamination of Moisture liarriers. Moisture barriers with wear, damage, erosion, tear, surface cracks, or other defects that permit intrusion of moisture against inaccessible areas of the pressure retaining surfaces -
of the metal containment shell or liner shall be corrected.
3511 Standards for Examination Category E C, Containment Surfaces Requiring Augmented Exarnination 3511.2 Visual Examination of Coated and Non-coated Areas. The condition of the inspected area is acceptable if there is no evidence of damage or degradation w hich exceeds the visual examination acceptance criteria specified by the Owner.
3511.3 Ultrasonic Examination. Examinations of Class MC p. essure retaining components that detect material loss in a local area exceeding 10% of the nominal wall thickness, or material loss in a local area projected to exceed 10% of the nominal wall thickness prior to the next examination, shall be documented. Such local areas shall be accepted by engineering evaluation or corrected by repair / replacement activities in accordance with 3122.
Supplemental examinations in accordance with -3200 shall be performed w hen specified as a result of the engineering evaluation.
ARTICI.E 4000 REPAIR PROCEDURES
-4100 SCOPE
'the rules ofIWA 4000 apply.
ARTICI.E 5000 SYSTEM PRESSURE TESTS 5200 SYSTEM TEST REQUIREMENTS 5210 GENERAI, Except as noted in 5240, the requirements ofIWA 5000 are not applicable to Class MC or Class CC components.
5220 TESTS l'OI.l.OWING REPAIR / REPLACEMENT ACTIVITIES 5221 1.cakage Test Except as noted in -5222, repair / replacement activities performed on the pressure retaining boundary of Class MC or Class CC components shall be subjected to a pneumatic leakage test in accordance with the provisions of
- Title 10, Part 50 of the Code ofl'ederal Regulations, Appendix J. Paragraph IV.A.
5222 Deferral of t.calage Tests 1 cakage tests for the following minor repair / replacement activities performed on the pressure retaining boundary may be deferred until the next scheduled leakage test, provided nondestructive examination is performed in accordance with the Repair / Replacement Psogram and Plan:
- to CPSES Unit i Relief Request E 1 Pcge 14 of 14 (a) wcids of attachments to the surface of the pressure retaining toundary; (b) weld cavities, the depth of w hich does not penetrate the required design wall by more than 10%; and (c) welds attachmg penetrations that are NPS 1 or srnaller.
5240 VISUAI, EXASilNATION During the pressure test required by 5220, a detailed visual examination ( 2310) shall be perfonned on areas affected by repair / replacement activities.
5250 CORRI:C11VE ACTION If the leakage test requirements of 5221 cannot be satisfied, the source ofleakage shall be located and the area shall be exarnined to the extent necessary to establish the requirements for corrective action. Repair! replacement activities shall be performed in accordance with the requirements ofIWA-4000. l.cakage testing shall be reperformed as required by -$220, prior to returning the component to service.
ARTICl.E -7000 REPI.ACESIENTS 7100 Gl:NERAI, REQUIRE %lENTS 1he rules ofIWA 4000 apply.
I l
to CPSES Unit 1 Relief Request E 1 Page 1 of 13 Parn-Changes between IWE Significance of change and or hasis for graph 1992 Ed. '92 Ad. and the current IWE rewrite use as an alternative examination IWE-no change n/a 1100 1200 no change n/a 1210 no change n/a 1220 Changed "contain'nent" to " containment system" non significant 1230 no change n/a 1231 Removed item 3). " single welded butt joints These single welded butt joint was removed i
from the weld side"- as a specific item required as 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 boun.lary as discussed in the l
changes to Table IWE 25001 below.
Changed wording from "80% of the surface area" The exclusions from 80% incorporate an to "80% of the pressure retainiag boundary" and existing Table IWE 2500-1 note and clarify a ted 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.
1232 ASME XI generic change from repair and or non significant replacement to repair / replacement activities.
Deleted paragraph (a)(3) addressing inaccessible weldedjoints were removed as a separately welded joints.
listed examination items and are now included within the item for the pressure retaining boundary as discussed in the changes to Table IWE 25001 below.
1240 Added stiffeners and, by reference to IWE 2420, The additional areas subject to augmented flaws accepted by evaluatW, as areas requiring examination further assure containment augmented examination, integrity.
2000 uo change n'a
=
_ to CPSES Unit 1 Relief Request E 1 Page 2 of 13 l
Para.
Changes between IWE Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWE rewrite use as an alternative examination 2100 Added new Subarticle 2100 " General"- to The additional general requirements invoked provide reference to IWA 2000 with exceptions by reference to IWA 2000 where none were from IWA 2210,2300,2500 and 2600.
referenced previously further assure containment integrity. The exceptions provided are significant in that related requirements have been incorporated into lWE-2310,2320 and 2330. These changes are discussed below.
2200 Deleted paragraph c) which provided allowances The deletion of an allowance for an for the use of shop or field examinations in lieu ahernative examination ensures that proper of on site preservice examinations.
preservice examinations are performed and documented.
Deleted paragraple g) which required the The deletion of the requirement to document condition of new coating to be documented in the the condition of"new" non pressure retaining preservice examination record.
coatings in the preservice examination record provides for more efficient program implementation without affecting component integrity.
ASME XI generic change from repair and or non significant, replacement to repair / replacement activities.
2300 Added new Subanicle 2300 " Visual The paragraphs within this subarti',lc 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 Anicle IWE 2000 further ensures proper
" Examination and inspection" of areas impodant to containment integrity and provides consistancey with Subsections IWII, IWC and IWD. The specific paragraphs added are discussed below.
1 (E. - -
to CPSES Unit 1 Relief Request E 1 Page 3 of 13 Para.
Change., between IWE Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWE rewrite use as an alternative examination 2310 Added new paragraph 2310 Visual a) Adding requirements for the owner to Examinations - which a) states that the owner defme visual examination requirements shall define requirements for visual examination provides for more efficient containment ISI of containment surfaces; program implementation by allowing examinations that may be more consate.4 with existing IS1, containment coating, maintenance rule and Appendix J programs, b) and c) defines general and detailed visual b) and c) The VT general examination is examinations; and perfonned to indicate the general condition of the containment. The VT detailed examination is perfonned to determine the magnitude and extent of any deterioration or distress. Referring to visual examinations by new VT general and VT detailed tenus does not adversely affect the integrity of the containment components examined; d) and c) p.uvides the requirements for the d) and c) Previously these examination conditions of areas affected by repair / replacement requirements did not exist within the Article activities, painted or coated areas, non coated IWE 2000 but rather only in the acceptance areas, pressure retaining materials and moisture criteria of Article IWE 3000. Adding these
- barriers, specific attributes here ensure proper containment examinations 2320 Added new paragraph 2320 " Responsible a) The details for the responsible individual Individual" which a) states the qualification qualification requirements were previously requirements of the responsible individual and contained in the acceptance standards of IWE-3510.1.
b) defines the responsibilities of the responsible b) The added detailed responsibilities for the individual for the development of plans and responsP. 'e individual ensure proper procedures; instmetion, training and approval of perfonnance of those related activities.
visual examination personnel; perfonnance or Having an individual possessing the direction of visual examinations; evaluation of qualifications of a) performing the results and documenting results, responsibilities of b) increases plant quality and safety by assuring the reliable detection of conditions adverse to containment integrity.
_ to CPSES Unit 1 Relief Request E 1 Page 4 of 13 1
Para.
Changes between IWE Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWE rewrite use as an alternative examination 2330 Added new paragraph 2330 " Personnel a) Adding requirements for the owner to Qualification"- which a) states that the owner is define personnel quali6 cation requirements responsible for defining the quali6 cation provides for more efficient containment ISI requirements for personnel performing visual program implementation by pennitting exLminations and personnel perfonning containment examinations to be qualified to written practices that are more consistent to those used for other NDE personnel, b) provides minimum quali6 cation requirements b) Providing these details in the quali6 cation that were previously contained in the acceptance requirements paragranh focuses the criteria ofIWE 3510.1.
containment visual qualification on areas important to cornainment integrity.
2400 no change n/a 2410 no change n/a 2411 no change n/a 2412 Deleted a subparagraph discussing decreasing The deleted subparagraph climinates and extending inspection periods. Added a duplication with IWA-2400. The added subparagraph detailing requirements for the requirements for the scheduling of added scheduling of added welds or components.
welds or components ensures that a representative sampling of examinations is maintained.
2420 Removed repaired areas as areas requinng Repaired areas that are likely to experience reexaminations during the next successive accelerated degradation and aging are already inspection period.
subject to augmented examinations per IWE-1241. Some repairs may be located in non augmented areas and may be necessary to correct physical damage caused by construction or crafl activities. Not having to repeat examinations of these non augmented repaired areas provides for more efficient program implementation without adversely affecting component integrity.
2430 Deleted the paragraph - Additional Examinations The changes to Table IWE 2500-1 climinate
- 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%
iire identined during an examination.
examination. Therefore no items are available for additional cuminations.
~ to CPSES Unit 1 Relief Request E 1 Page5of13 Para-Changes between IWE Significance of change and or basis for graph 1992 Ed. 692 Ad. and the current IWE rewrPa use as an alternative examination 2500 Reworded the existing subparagraphs consistant The reworded subparagraphs add clarity and with the previouse paragraph changes and with provide consistancy within IWE.
Table IWE 25001 changes.
Deleted the requirement to examine paint or Not having to perform ASME examinations coatings prior to removal.
of non pressure retaining coatings prior to l removal provides for more efficient contamment ISI program implementation without adversely affecting the integrity of the pressure retaining base metal being exposed.
Replaced the requirement for one foot square The new Table IWE 2500 2 provides more grids in thickness measurements with a reference detailed requirements for thickness to Table IWE 2500 2.
measurement gridding and is discussed below.
Added a reference to IWE 5000 for pressure The added reference to IWE 5000 provides tests.
direction for the performance of pressure test.
2600 Deleted a sentence discussing compatibility of The removal of this sentence addressing paint and coating systems and a requirement to "new" non pressure retaining paint and examine the new paint.
coatings provides for more efficient containment ISI program implementation without adversely affecting component integrity.
3100 Removed the word nondestructive from the non significant heading.
3110 no change n/a 3111 Replaced the reference to Table IWE-3410-1 with Table IWE-34101 and paragraph IWE 3115 a reference to subarticle IWE 3500. Removed have been deleted and are discussed below.
reference to paragraph IWE-3115.
lWE 3500 adequately captures all of the information previously contained in the deleted table and paragraph.
3112 Replaced the reference to Table IWE-34101 with non significant a reference to subarticle IWE 3500. ASME XI generic change from repair and or replacement to -
g repair / replacement activities.
- to CPSES Unit i Relief Request E-1 Page 6 of 13 I
P. ira-Changes between IWE Significance of ch'nge and or basis for graph 1992 Ed. '92 Ad. and the current IWE rewrite use as an alternative examination 3114 Replaced the ieference to Table IWE-3410-1 with non significant 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 by authorities, deletion of the subparagraph.
3120 Removed the word nondestructive from the non significant heading.
3121 Removed the word nondestructive and deleted The removal of nondestructive is non references to IWE-3124 and IWE-3125 for the significant. The referenced subparagraphs did acceptance of Daws for continued service.
not actually apply to the acceptance of flaws for continued service.
3122 Replaced the references to Table IWE-2500-1 non significant - the changes are for clarity and to IWE-3000 with a reference to subarticle and to reconcile paragraph numbering. There IWE-3500. ASME XI generic change from were no submittal or retention requirements repair and or replacement to repair / replacement changed by the delction of the sentence activities. Reworded several sentences. Deleted addressing evaluation reviews.
sentence which addressed evaluations being subject to review by authorities.
3124 Replaced the reference to Table IWE-3410-1 with non significant a reference to subarticle IWE-3500. ASME XI generic change from repair and or replacement to repair / replacement activities.
3125 Deleted subparagraph which addressed repair non significant - there were no submittal or programs and reexamination results being subject retention requirements changed by the to review by authorities.
deletion of the subparagraph.
3130 no change n/a 3200 Added a statement to the end of the paragraph The adued statement clarifies requirements that states supplemental surface or volumetric and climinates potential duplication or examinations are required when specified by the contradiction of requirements ia stating that 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 with non significant a reference to subarticle IWE-3500.
3430 no change n/a
-maism imm
-. to CPSES ' nit 1 Relief Request E-1 Page 7 of 13 PCra.
Changes between IWE Significance of change and or basis for grcph 1992 Ed. '92 Ad. and the current IWE r write use as an alternative examination 3500 no change n/a 3$10 Reconciled acceptance standards with the Previously examination requirements were lWE-2300 changes discussed above and the contained in the acceptance standards of Table IWE-25001 changes discussed below by:
IWE-3500. This has been corrected by the Adding the requirement that the owner shall addition aflWE-2300 as discussed above. a) define acceptance criteria for visual examination This change directly corresponds to th:
of containment surfaces; addition ofIWE-2310(a) discussed abos e.
Removing the wording for responsible individual This change directly corresponds to the and for personnel qualifications; addition ofIWE-2320 discussed above.
Combining 3510.2 and 3510.3 and removing These changes directly correspond to the specific VT-1 and VT-3 examination attribute addition ofIWE-2310(e)(1) and (2) discussed wording; and above.
Incorporating IWE-3511;3513,3514 and 3515 These changes correspond to the changes in with changes into IWE-3510.
the examination categories of Table IWE-2500-1 as discussed below and to the removal s
of examination requirements from the acceptance standards paragraphs per the addition ofIWE-2310(e)(3) and (4) as discussed above.
By the incorporation of 3515 the acceptance The resulting acceptance standards for bolting standards for bolting were changed from provide for more practical containment ISI referencing material specs and torque or tension program implementation without adversely limits to conditions affecting leak tight or affecting containment leak tight or structural structural integrity, integrity.
3511 Deleted subparagraph which addressed Examination category E-B has been examination category E-B.
incorporated imo examination category E-A per the changes to Table IWE-2500-1 discussed below.
_ _ - _ _ _ to CPSES Uni: 1 Relief Request E-1 Page 8 of 13 Para.
Changes between IWE Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWE rewrite use as an alternative eramination 3512 Renumbered subparagraph to IWE-3511.
The subparagraph was renumbered based on Reconciled acceptance standards with the the deletion of previous IWE-3511 as IWE 2300 changes discussed above and the discussed above. Previously examination Table IWE-2500-1 changes discussed below requirements were contained in the acceptance standards ofIWE 3500. This has been corrected by the addition ofIWE-2300 l
as discussed above.
Added the requirement that the owner shall This change directly corresponds to the define acceptance criteria for visual examination addition ofIWE-2310(a) discussed above, of containment surfaces; Combined 3512.2 and 3512.3 witf shanges into These changes directly correspond to the 3511.2 and removed specific VT-1 examination addiuon ofIWE-2310(e)(1) and (2) discussed attribute wording; and above and eliminate potential duplication or contradiction of requirements.
Reworded ultrasonic examhation subparagraph.
This change is for clarity and is non-significant.
3513 Deleted subparagraphs IWE-3513,3514 a ' i Examination categories E-D, E-F and E-G 3514 3515 which addressed examination catege.cs have been incorporated into exemination 3515 E D, E-F, and E-G respectively.
category E-A per the changes to Table IWE-2500-1 discus;ed below.
4100 no change n/a 5200 no change n/a 5210 no change n/a
$220 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 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.
5222 ASME XI generic change from repair and or non significant replacement to repair / replacement activities.
_ _ _. to CPSES Unit i Relief Request E l Page 9 of 13 Para-Changes between IWE Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWE rewrite use as an alternative examination 5240 Replaced a reference to IWA 5240 with The addition of specific IWE examination requiremen2 to perform detailed visual requirements during pressure testing in lieu of examination of repair / replacement areas during referencing IWA general requirements pressure tests.
focusses requirements on issues specific to containmv... integrity and therefor provides 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 / replace:'ent activities.
7100 no change n/a Table no change n/a 2411-1 Tabit Replaced the separate entries for 1st and non significant - The previous requirements 2412-1 successive intervals with one entry for All for the 1st and successive intervals were intervals.
identical. Therefor combining the entries does not affect any requirements.
1 1
__________ ______________ ___ ___ - __ _ _ ___ - to CPSES Unit 1 Relief Request E-1 Page 10 of 13 Porn-Changes betweta IWE Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWE rewrite use as an alternative examination Table 2500-1 Revised all examination categories.
EA El.11 Revised frequency of examination from Removing the requirement to coordinate
" prior to each type A test" to "100% during each examinations with type A tests allows for period",
more efficient containment ISI program implementation without adversely affecting containment integrity.
El.12 Redesignated item from " accessible Replacing the accessible surface area surface areas" to " wetted surfaces of submerged designation (which is included in El.1 l) with areas". Replaced examination method VT-3 with wetted surface areas (which were previously general visual, included in El.12 footnote 4) does not eliminate or reduce any repred examination areas. Requiring a general VT in lieu of a VT-3 eliminates the more detailed VT of areas with satisfactory gener:d VT results.
The performance of the VT e, c.eral will identify any areas of deterioration or distress.
Any areas identified will then be subject to a VT detailed examination to determine the magnitude and extent of those conditions.
The VT general therefore allows for more efficient containment ISI program implementation i hout adversely affecting t
containment
.ty.
El.20 Added BWR to item description.
This item is not applicable to CPSES Replaced examination method VT-3 with general containments.
visual.
El.30 Added item for moisture barriers with a Moisture barriers were previously included in general VT required each period, examination category E-D with a VT-3 required each interval. Examining moisture barriers more frequently will assure reliable detection of conditions adverse to containment integrity.
- __ to CPSES Unit 1 Relief Request E-1 Pageilof13 Para-Changes between IWE Significance of change and or basis for grcph 1992 Ed,'92 Ad. and the current IWE rewrite use as an alternative examination All item no,'s - Replaced reference to IWE-3510 non signi6 cant - Previously some for examination requirements with IWE 2310.
examination requirements were contained in lWE-3500. They now exist in IWE-2300 as discussed above.
Notes - Revised to speci6cally include welds and Welds and bolting were previously included bolting as part of the pressure retaining boundary in examination categories E-B, E-F and E-G.
requiring examination.
Including these items in the examination category for the containment pressure retaining boundary provides for more ef6cient program implementation without adversely affecting component integrity.
Table E-B Deleted examination category which Pressure retainmg wi 'ds are now included in 2500-1 addressed pressure retaining welds, examination category E-A as addressed above.
_ _ _ _ _ _ to CPSES Unit 1 Relief Request E-1 Page 12 of 13 Pora-Changes between IWE Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWE rewrite use as an alternative examination EC E4.11 Replaced examination method VT-1 with Referring to the visual examination by the VT detailed visual.
detailed tenn does not adversely affect the integrity of the containment components examined.
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 numbers ensure proper requirements are applied to examinations.
Notes - Changed note 2 from requiring Three inspection periods cover a ten year augmented examination until an area remains interval. Performing augmented unchanged for three consecutive inspection examinations for at least two periods while periods to the next inspection period. Deleted continuing general visual examinations each note 3 which discussed inspection deferrals, period provides for more efficient program implementation without adversely affecting component integrity. Deletion of note 3 is non significant.
E-D Deleted examination category which-Moisture barriers have been included in addressed seals, gaskets and moisture barriers.
examinatien category E-A as addressed above. Seals and gaskets previously required examination once per an interval with effectively an acceptance criteria ofleak tightness. Leak tight iruegrity is verified during each 10CFR50 App. J leak test.
Removing these inspection items provides for more efficient program implementation without adversely affecting component integrity.
E-F Deleted examination category which Dissimilar metal welds are now included in addressed dissimilar metal welds.
examination category E-A as addressed above.
s.
J
1 to CPSES Unit 1 Relief Request E 1 Page 13 of 13 l
Para.
Changes between IWE Significance of change and or basis for
{
graph 1992 Ed. '92 Ad. and the current IWE rewrite use as an alternative examination j
E G Deleted examination category which Pressure retaining bolting is now included iii addressed pressure retaining bolting.
examination category E-A as addressed above.
E-P Deleted examination category which App J testing is mandated by plant technical addressed 10CFR50 App J testing for all pressure specifications. Removing this duplicate l
retaining components.
requirement from IWE does not adversely I
affect component integrity.
Added new Table 2500 2 - Ultrasonic Thickness The new requirements provide for Measurements For Augmented Examinations -
consistency and repeatability in obtaining which details gridding and thickness thickness measurements and thus assure the j
measurement requirements, reliable detection of conditions adverse to
]
containment integrity.
Table Deleted table.
non significant - the contents of the previous 3410 1 table are adequately addressed in IWE-3500.
I
! to TXX-98041 Page 1 of 2 CPSES UNIT 1 2
RELIEF REQUEST L-1 A. Item (s) for which reliefis requested:
Concrete containment components.
B. Item (s) Code Class:
CC C. Examination requirements from which reliefis requested:
1992 Edition with the 1992 Addenda of Subsection IWL," Requirements for Class CC Concrete Components of Light-Water Coo!cd Power Plants", of Section XI, Division 1, of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code).
D. Basis for relief:
The 1992 Edition with the 1992 Addenda of Subsection IWL contains requirements which impose difficulties in the transition from the current ISI 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 detailed belov'. These alternative examinations provide for consistency with the existing programs in the definition of visual examination methods and in the qualification of visual examination personnel as well as providing more practical requirements for the performance and scheduling of examinations.
Some specific hardships imposed by the 1992 Edition, '92 Addenda ofIWL that are not compensated for by an increased level of plant quality and safety are as follows:
IWA-2300 requires the use of a written practice prepared in accordance with ANSI /ASNT CP-189 for the qualification and certification ofcontainment nondestructive examination personnel. All other CPSES NDE and ISI activitics, including those performed on the reactor vessel, are performed by personnel qualified and certified to written practices prepared in accordance with SNT-TC-1 A as required by ASME XI 1986 Edition, No Addenda, the Code of record for ISI at CPSES. Utilizing the '92 Addenda ofIWL would require the development of a separate written practice and the issuance and tracking of separate certifications for both TU Electric and contractors. Administration of the resulting duplicate programs could result in documentation inconsistencies and would be an impact to to TXX 98041 Page 2 of 2 resources.
IWL-2310 and IWA 2210 require specific minimum illumination and maximum direct examination distances for concrete containment examinations. These requirements preclude the performance of remote examination. Performance of the inore stringent IWA-2210 direct examinations are not practical for much of the CPSES coritainment surface area, would be an impact to resources and would introduce a signincant risk to personnel safety.
The proposed alternative is to utilize the current ASME approved rewrite of Subsection IWL of ASME Section XI in its entirety. Utilaing the entire IWL rewrite provides more cohesiveness than could be achieved by requesting relief on several individual subjects separately. The alternate examination requirements match the rewrite exactly and are included as Enclosure 1 of this relief request. These requirements were developed in accordance with the ASME Code committee process with input from interested parties which included TU Electric, other utilities, manufacturers, engineering organizations, Authorized Inspection Agencies, EPRI and the NRC. The updating of requirements by this industry consensus process is intended to ensure the continued safe operation of nuclear power plants and specincally in this case the continued leak-tight and structural integrity of concrete containment components. Therefore, the overall level of plant quality and safety would not be adversely affected by utilizing the requirements of the current ASME approved IWL rewrite. A detailed evaluation and line by line comparison of the differences between the 1992 Edition with the 1992 Addenda of Subsection IWL and the current ASME approved rewrite is included as Enclosure 2 of this relief request.
CPSES Unit 1 is currently in the third period of the first ten year ISI interval. Based on current plant refueling outage schedules and tl.e requirement of the new rulemaking for full implementation by September 9,2001, a containment ISI examination program must be established immediately. Implementing this relief request now would reduce the overall impact to resources (both TU Electric's and the NRC's) versus incorporating the mandated edition and addenda ofIWL in conjunction with this initial establishment of a containment ISI program and then updating again to a later edition and or addenda or to a series of Code Cases upon formal NRC endorsement or on the next ten year ISI plan issuance.
E. Altemate Examinations:
See Enclosure 1 of this relief request for the requirements of the current ASME approved rewrite of Subsection IWL which defines the alternate examinations of this relief request.
F. Anticipated impact on the overall level of plant quality and safety:
None.
+
_. - _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ to CPSES Unit 1 Relief Request L-1 Page1of12 ARTICI.E -1000 SCOPE AND REhPONSIBILITY
-1100 SCOPE (a) This subsection provides requirements for preservice examination, inservice inspection, and repair / replacement activities of.
the reinforced concrete and the post-tensioning systems of Class CC components, herein referred to as concrete containments as defined by CC 1000.
(b) ne rules and requirements of this Subsection do not apply to the following:
(/) steel portions not backed by concrete; (2) shell metallic liners; (3) penetration liners extending the containment liner through the surrounding shell concrete.
1200 ITEMS SUHJECT TO EXAMINATION 1210 EXAMINATION REQUIREMENTS De examination requirements of this subsection shall apply to concrete containments.
1220 ITEMS EXEMPT FROM EXAMINATION
.he following items are exempt from the examination requirements of 2000; (a) tendon and anchorages that are inaccessible, subject to the requirements of-2521.1; (b) portions of the concrete surface that are covered by the liner, foundation material, or backfill, or are otherwise obstructed by adjacent structures, components, parts, or appurtenances.
ARTICI.E -2000 EXAMINATION AND INSPECTION
-2100 GEP'ERAL (a) He requirements ofIWA 2000 apply, except the requirements ofIWA-2210 and IWA-2300 are not applicable to visual examinations and qualification of visual examination personnel for concrete containments.
(b) Examinations shall be verified by an Authorized Nuclear Inservice inspector in accordance with IWA-2120 and ASME N626. Authorized Nuclear Inservice inspectors for concreie shall also meet the requirements of ASME N626.2.
2200 PRESERVICE EXAMINATION Preservice examination shall be performed in accordance with the following requiremsnts.
-2210 EXAMINATION SCIIEDULE Preservice examination shall be completed prior to initial plant startup.
-2220 EXAMINATION REQUIREMENTS
-2220.1 Concrete (a) Preservice examination shall be performed in accordance with -2510.
(b) The presen ic, examination shr.Il be performed following completion of the containment Structural Integrity Test.
-2220.2 Unbonded Post-Tensioning Systems. The following information shall be documented in the preservice examination records. His information may be extracted from construction records.
(a) Date on which each tendon was tensioned.
(b) Initial seating force in each tendon.
(c) For each tendon anchorage, the location of all missing or broken wires or stands and unseated wires.
Enclosure I to CPSES Unit i Relief Request L-1
- Page 2 of 12 (d) For each tendon anchorage ne location of all missing or detached buttonheads or missing wedges.
(c) The product designation for the corrosion protection medium used to fill the tendon duct.
2230 PRESERVICE FRAMINATION OF REPAIR /REPl.ACEMENT ACTIVITIES (a) When a concrete containment or a portion thereofis corrected or modined by repair / replacement etivitbiuring the service lifetime of a plant, the preservice examination requirements shall be met for the repair / replacement activity.
(b) When the repair / replacement activity is performed while the plant is not in service, the preservice examination shall be performed prior to resumption of service.
(c) When the repair / replacement activity is performed w hile the plant is in service, the preservice examination may b-to the next scheduled outage.
1 2300 VISUAL, EXAMINATION, PERSONNEL, QUAL.IFICATION, AND RESPONSlHl.E ENGINEER 2310 VISUAI, EXAMINATION AND PERSONNEL, QUALIFICATION (a) deneral visual examinations of concrete surfaces shall be performed to assess the general structural cond. tion of containments. The general visual examination shall be Irrformed in sufficient detail to identify areas cf concrc'e deterioration and distress, such as defined in ACI 201.1.
(b) Detailed visual examinationr shall be performed:
(/) to determine the magnitude and extent of deterioration and distress of suspect concrete surfaces initially detected by grneral visual examinations.
(2) to determine the condition and any deterioration of concrete surfaces at tendon anchorage areas.
(3) to detennine she condition (e.g., cracks, wear, or corrosion) of tendon wires or strands, and anchorage hardware, as described in.2524.1.
(4) to detennine the condition of concrete surfaces affected by repair / replacement activities,in accordance with 5250.
(c) Visual examinations shall be performed either directly or remotely, with adequate illumination, by personnel with visual acuity sufficicat to detect evidence of degradation.
(d) The Owner shall define qualification requirements for personnel performing examinations of concrete and tendon anchorage hardware, wires or stamds.
(c) The Owner shall define requirements for visual examination of tendon anchorage hardware, wires or strands.
-3320 RESPONSlHl.E ENGINEER The Responsible Engineer shall be a Registered Professional Engineer experienced in evaluating the condition of structural concrete. The Responsible Engineer shell have knowledge of the design and Construction Codes and other criteria used in design and construction of concrete containments in nuclear power plants.
'lle Responsible Engineer shall be responsible for tic following:
(a) development of plans and procedures for examination of concrete surfaces; (b) approval, instruction, and training of concrete examination personnel; (c) evaluation of examination results; (d) preparation or review of Repair / Replacement Plans and procedures; (c) review of pressure test procedures for pressure tests following repair / replacement activities;
(/) submittal of report to the Owner documenting results of examinations, repair / replacement activities, and pressure tests.
-2400 INSERVICE INSPECTION SCilEDULE
-3410 CONCRETE (a) Concrete shall be examined in accordance with -2510 at 1,3, and 5 years following the completion of the containment Structural Integrity Test CC-6000 and every 5 years thereafter.
(b) The 1,3 and 5 year examinations shall commence not more than 6 months prior to the specified dates and s..all be completed not more than 6 months after such dates. If plant operating conditions are such that examination of portions of the concrete cannot be completed within this stated time interval, examination of those portions may be deferred until the next regularly schedule plant oatage.
(c) The 10 year and subsequent examinations shall commence not more than 1 year prior to the specified dates and shall be
_ _ _ _. _ _ _ _ _ _ _ to CPSES Unit 1 Relief Request L-1 Page 3 of12 completed not more than 1 year after such dates. If plant operating conditions are such that examination of portions of the concrete cormot be completed within this stated time interval, examination of those portions may be deferred until the next regula.ly scheduled plant outage.
2420 UNHONDED POST-TENSIONING SYSTEMS (a) Unbonded post tens %ng systems shall be examined in accordance with -2520 at 1,3, and 5 years following the completion of the containment StructuralIntegnty Test and every 5 years thereafter.
(b) The I,3 and 5 year examinations shall commence not more than 6 months prior to the specified dates and shall be completed not more than 6 months after such dates. If plant operating conditions are such that examination of portions of the post-tensioning system cannot be completed within this stated time interval, examination of those portions may be deferred until th next regularly scheduled plant outage.
(c) The 10 year and subsequent examinations shall commence not more than 1 year prior a the specified dates and shall be completed not more than 1 year after such dates.
2421 Sites With Multiple Plants (a) For sites with multiple plants, the examination requirements for the concrete containments may be modified if the containments utilire the same prestressing system and are essentially identical in design, if post tensioning operations for each subsequent containment constructed at the site were completed not more than 2 years apart, and if the contai.unents are similarly exp.,ed to or protected from the outside environment.
(b) When the conditions of -2421(a) are met, the inspection dates and examination requirements may be as follows:
(1) For the containment with the first Structural InteHty Test, all examinatians required by -2500 shall be performed at 1, 3, and 10 years and every 10 years thereatler. Only the examinations required by 2524 and 2525 need be performed at 5 and 15 years and every 10 years thereafter.
(2) For each subsequent containment censtructed at the site, all examinations required by -2500 shall be performed at 1,5 and 15 years and every 10 years thereafter. Only the examinations required by -2524 and -2525 need be performed at 3 and 10 years and every 10 years thereafter.
Enclosure I to CPSES Unit 1 Relief Request L-1 Page 4 of 12
-3500 EXAMINATION REQUIREMENTS Examination shall be performed in accordance with the requirements of Table -2500-1.
-2510 SURFACE EXAMINATION (a) Concrete surface areas, includmg coated areas, except those exempted by -1220(b), shall be visually examined in accordance with 2310(a) for evidence of conditions indicative of damage or degradatio 1, such as defined in ACI 201.1 Selected areas, such as those that indicate suspect conditions, shall be visually examined in accordance with 2310(b).
(b) Tendon anchorage areas, including coated areas, except those exempted by 1220(a), shall be visually examined in cccordance with -2310(b)ior evidence of conditions indicative of damage or degradation. Selected areas, such as those that indicate suspect conditions, shall be subject to additional examinations, if specified by the Responsible Engineer.
(c) For containments with t.nbonded yst tensioning systems, the concrete surfaces and tendon end anchorages shall be excmined for conosion protection medium leakage, and the tendon end caps shall be examined for deformation.
(d) The examination shall be performed by, or undct the direction of the Responsible Engineer.
(c) Visual examinations may be performed from Doors, roofs, platforms, walkways, ladders, ground surface, or other vantage points, unless temporary close-in access is required by the inspection plan.
2520 EXAMINATION OF UNI;ONDED POST-TENSIONING SYSTEMS 2521 Tendon Selection (a) Tendons to be examined during an inspection shall be selected on a random basis except as noted in -2521(b) and (c). The population from w hich the random sample is drawn shall consist of all tendons of a particular type (as defined in Table -2521-1) which have not been examined during earlier inspections. The number of tendons to be examined during an inspection shall be as specified in Table -2521-1.
(b) One tendon of each type (as defined in Table -2521-1) shall be selected from the first year inspection sample and designated ca a common tendon. Each common tendon shall be examined s'uring each inspection. A common tendon shall not ' e detensioned unless required by -3300. If a common tendon is detensioned, another conanon tendon of the same type shall be r '
u from the first year inspection sample.
i (c) If a conuinment with a stranded post tensioning system is constructed with a predesignated number of detensionable
[
tendons, one tendon of each type shall be selected from among those which are detensionable. The remaining tendons shall be
}
celected from among those which cannot be detensioned.
-2521.1 Exemptions. The following requirements shall apply to tendon anchorages that are not accessible for examination because of safety or radiologicat hazards or because of structural obstructions.
(n) After the process of randomly selecting tendons to be examined, any inaccessible tendons shall be designated as exempt and remowd from the sample.
(b) Substitute tendons shall be selected for all tendons designated as exempt. Each substitute tendon shall be selected so that it is located as close as possible to the exempted tendon, and shall be examined in accord nce with
-2520.
(c) Each exempted tendon shall be examined in accordance with 2524 and -25L' to the extent that the end anchoinges of the exempt tendon are accessible either during operation or at an outage.
Enclosure I to CPSES Unit 1 ReliefRequest L Page 5 of12 TABLE I%L2500-1 EXAA11 NATION CATEGORIES i
EXAMINATION CATEGORY L-A, CONCRETE Item No. l Parts Examined Test or Examination Test or Examination Acceptance Extent of Frequency of Deferral of Requirement Method Standard Exammation Examinanon Eummation Lt.10 Concrete Surface Lt.Il All Accessible Surface IWL-2510 General Visual IWL-3210 IWL-2510 IWL-2410 NA Areas Ll.12 Suspect Areas IWL-2510 General Visual IWL-3210 I%L2510 IWL-2410 NA I
EXAMINATION CATEGORY L-B, UNBONDED POST-TENSIONING SYSTEAf Item No.
Parts Examined Test or Examination Test or Eumination Acceptance Extent of Frequency of Deferral of Requirement Method Standard Examination Examination Exammation L2.10 Tendon IWL-2522 IWL2522 I%L3221.1 I%L2521 IWL-2420 NA L2.20 Wire or Strand IWL-2523 IWL-2523.2 I%L3221.2 IWL-2523.1 IWL-2420 NA L2.30 Anchorage Ilardware and IWL-2524 Detailed Visual IWL-3221.3 IWL-2.524.1 IWL-2420 NA Surrounding Concrete L2.40 Corosion Protection IWL-2525 IWL-2525.2(a) 1%L3221.4 IWL-2525.l(a)
IWL-2420 NA Medium L2.50 Free Water IWL-2525 IWL-2525.2(b)
IWL-2525.l(b)
IWL-2420 NA
En:losure 1 to CPSES Unit 1 Relief Request L-1 Page 6 of 12 TAllLE IWL-2521-1 NUMi1ER OF TENDONS FOR EXAMINATION Inspection period Percentage'2 Requred Maximum l
of allTendora Minimum
- Required of Each Type' Number of Number of Each Type Each Type
{
1st Year 4
4 10 3rd Year 4
4 10 5th Year 4
4 10 10st Year 2
3 5
NOTES:
(1) Fractional tendon numbers shall be rounded to the next higher integer Actual Number exemnied shall not be less than the minimum requir~l number and need not be more than the maximum required number.
I (2) The reduced sample size listed for the 10th year and subsequent inspections is applicable only if the acceptance criteria of IWL-3221,1 have been met for the last 3 inspections.
(3) A tendon type is defined by its geomety and position in the contai g., hoop vertical, dome, helical, and inverted U.
(4) The number and percentage of tendons to be examined every 5th3
.eafter shall remain the same..
2522 Tendon Force and Elongation Measurements (a) The prestressing force in all inspection sample tendons shall be measured by lift-off or an equivalent test.
(b) Equipment used to measure tendon force shall be calibrated in accordance with a calibration procedure prior to the first tendon force measurement and following the final tendon force measurement of the inspection period. Accuracy of the calibration shall be within 1.5% of the specified minimum ultimate strength of the tendon. If the post-test calibration differs from the pretest calibration by more than the specified accuracy tolerance, the results of the examination shall be evaluated.
(c) During retensioning of a tendon, the tendon elongation shall be measured 2523 Tendon Wire arid Strand Sample Examination and Testing 2523.1 Tendon Detensioning and Sample Ren., val. One sample tendon of each type shall be completely detensioned. A single wire or strand shall be removed from each detensioned tendon.
2523.2 Sample Examination and Testing (a) Each removed wire or stund shall be examined over its entire length for corrosion and mechanical damage. The examination shall determine the location of most severe corrosion; if any Strand wire shall be examined for wedge slippage marks.
0
Enclosure I to CPSES Unit 1 Relief Request L-1 Page 7 of 12 (b) Tension tests shall be performed on each removed wire r strand: one at each end, one at midlength, and one in the location of the most corroded area,if any. The following information - ill be obtained from each test:
(/) yield strength l
t (2) ultimate tensile strength l
(3) clongation
{
l 2523.3 Retensioning. Tendons that have been detensioned shall be retensioned to at least the force predicted for the tendon at l
the time of the test. Ilowever, the retensioning force shall not exceed 70% of the specified rninimum ultimate tensile strength of the I
tendon based on the number of effective wires or strands in the tendon at the time of retensioning 2524 Examination of Tendon Anchorage Areas
-2524,1 Visual Examination. A detailed visual examination in accordance with -2310(b) shall be performed on the tendon anchorage hardware, including bearing plates, anchorheads, wedges, buttonheads, shims, and the concrete extending outward a dictonce of 2 feet from the edge of the bearing plate. The following shall be documented:
)
(a) concrete cracks heving widths greater than 0.01 in.;
j (b) corrosion, broken or protruding wires, missing buttonheads, broken strands, and cracks in tendon anchorage hardware; (e) broken wines or stranA, protrudmg wires and detached buttonheads following retensioning of tendons which have been detensioned.
-2524.2 Free Water Documentation. The quantity of free water contained in the anchorage end cap as well as any which drains l
from the tendon during the examination process shall be documented.
-3525 Esamination of Corrmion Protection Medium and Free Water l
-2525.1 Samples (as Samples of the corrosion pmiection medium shall be taken from each end of each tendon examined. Free water shall not be included in the samples.
(b) Samples of free water shall be taken where water is present in quantities sufficient for laboratory analysis.
_w
. _ _ _ _ _ _ - _ - _ _ _ - to CPSES Unit 1 Relief Request L-1 Page 8 of 12 TAhlE -2525-1 CORROSION PROTECTION hlEDIUhl ANAINSIS Characteristle Test Method Acceptance 1,lmit Water content ASTM D 95 10 percent maximum Water soluble chloride =
ASTM D 512 l Note (1)l or 10 ppm maximum ASTM D 4327 l Note (1)]
Water Soluble nitrates ASTM D 992 l Note (1)] or 10 ppm maximum ASTM D 3867 l Note (l)l or D 4327 l Note (1)]
Water soluble su"! des APilA 427 l Note (1)l or 10 ppm maximum APilA 4500-S l Note (1)]
Reserve alkalinity ASTM D 974 l Note (3)]
(Hase number)
Modified l Note (2)]
NOTES:
(1) li'ater Soluble ton Tests: The inside (bottom and sides) of a one (1) liter breaker, approx. OD 105 mm, height 145 mm, is thoroughly coated with 100 10 grams of the sample. The coated breaker is filled with approximately 000 ml of distilled water and heated in an oven at a controlled temperature of 100*F (37.8'C)12*F for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The water extraction is tested by the noted test procedures for the appropriate water soluble ions Results are reported as PPM in the extracted water.
(2) ASTM 974 Modified. Place 10 g of sample in a 500 ml Erlenmeyer flask Add 10 cc isopropyl alcohol and 5 cc toluene. IIcat until sample goes into solution. Add 90 cc distilled water and 20 cc iNil,SO+ Place solution on a steam bath for 1/2 hour. Stir well. Add a few drops ofindicator (1% phenolphthalein) and titrate with INNaOli until the lower layer just turns pink. If acid or base solutions are not exactly IN, the exact normalities should be used when calculating the base number. The Total Base Number (TBN), expressed as milligrams of KOli per gram of sample, is calculated as follows:
[(20)(Na)-(B)(N.)) 56.1 TBN =
W where B = milliliters NaOli N, = normality of11 S0 solution 2
4 N, = normality of NaOil solution li'= wi.ght of sample in grams (3) The base number shall be at least 50% of the as-installed value, unless the as-installed value is 5 or less, in which case the base number shall be no less than zero. If the tendon duct is filled with a mixture of materials having various as-installed base numbers, the lowest number shall govem acceptance.
-2525.2 Sample Analysis (a) Each corrosion protection medium sample-shall be thoroughly mixed and analyzed for reserve alkalinity, water content, and concentrations of water soluble chlorides, nitrates, and sulfides. Analyses shall be performed in accordance with the procedures specified in Table -2525-1.
(b) Free water samples shall be analyzed to determine pil.
s
Enclosure I to CPSES Unit 1 Relief Request L-1 Page 9 of 12 2526 Removal and Replacement of Corrosion Protection Medium (a) The amount of corrosion protection medium removed at each anchorage shall be measured and the total amount removed from each tendon (two anchorages) shall be recorded. The total amount replaced in each tendon shall be recorded and differences between amount removed and amount replaced shall be documented.
(b) Corrosion protection medium may be neplaced using a pressurized system or cold pack, by pouring, or by nonpressurized
- pumping on each end. The Responsible Engineer shall specify the maximum pressure to be used in a pres zed system.
ARTICI,E 3000 ACCEPTANCE STANDARDS
-3100 PRESERVICE EXAMINATION 3110 CONCRETE SURFACE CONDITION 3111 Acceptance by Examination The condition of the surface is acceptable if the Resp <msible Engineer determines that there is no evidence of damage or degradation sufficient to warrant further evaluation or performance of repair / replacement activities.
3112 Acceptance by Evaluation items with examination results that do not meet the acceptance standards of 31ii shall be evaluated as required by -3300.
3113 Acceptance by Repair / Replacement Activity Repair / replacement activities required to reestablish acceptability of an item shall be completed as required by -3300.
Acceptable completion of the repair / replacement sctivity shall constitute acceptability of the item.
I
-3120 UNilONDED P6ST-TENSIONING SYSTEM The condition of the unbonded post-tensioning system is acceptable if it met the requirements c'the construction specification at
- the time ofinstallation.
-3200 INSERVICE EXAMINATION
-3210 SURFACE CONDITION
-3211 Acceptance by Examination The condition of the concrete surface and tendon end anchorage areas is acceptable if the Responsible Engineer determines that there is no evidence of damage or degradation, corrosion protection medium leakage, or end-cap deformation sufficient to warrant further evaluation or performance ofrepair/ replacement activities.
3212 Acceptance by Evaluation items with examination results that do not meet the acceptance standards of -321I shall be evalusted as required by -3300.
3213 Acceptance by Repair / Replacement Activity Repair / replacement activities to reestablish the cceeptability of an item shall be completed as required by
-3300. Acceptable completion of the repair / replacement activity shall constitute acceptability of the item.
-3220 UNHONDED POST-TENSIONING SYSTEMS
-3221 Acceptance by Examination m
Enclosure I to CPSES Unit i Relief Request L-l Page 10 of 12 3221.1 Tendon Force and litongation. Tendon forces and elongation are acceptable if:
(a) the average of all measured tendon forces, inwluding those measured in 3221.l(b)(2), for each type of tendon is equal to or greater than the minimum required prestress specified at the anchorage for that type of tendon; (b) the measured force in each individual tendon is not less than 95% of the predicted force unless the following conditions are satisfied:
(/) the measured force in not more than one tendon is between 90% and 95% of the predicted force; (2) the measured forces in two tendons located adjacent to the tendon in -3221.l(b)(1) are not less than 95% of the predicted forces; and (3) the measured forces in all the remaining sample tendons are not less than 95% of the predicted force.
(c) the prentressing forces for each type of tendon measured in 3221.l(a) and (b), and the measurement from the previous examination, indicate a prestress loss such that predicted tendon forces meet the minimum design prestress forces at the next scheduled examination.
(d) th: measured tendon elongation varies from the last measurement, adjusted for : ffective wires or strands, by less than 10%.
-3221.2 Tendon Wire or Strand Samples. The condition of wire or strand samples is acceptable if:
(a) samples are free of physical damage; (b) sample ultimate tensile strength and elongation are not less than minimum specified values.
3221.3 Tendon Anchorage Areas. The condition of tendon anchorage areas is acceptable if; (a) there is no evidence of cracking in anchor heads, shims, or bearing plates; (b) there is no evidence of actisc cormsion; (c) broken or unscated wires, broken strands, and detached buttonheads were documented and accepted during a preservice examination o-during a previous inservice examination; (d) cracks in the concrete adjacent ot the bearing plates do not exceed 0.01 in. in width; (c) there is no evidence of free water.
-3221.4 Co~ ion protection Medium. Corrosion protection medium is acceptable when the reserve alkalinity, water content, and soluble n.;, concentrations of all samples are within the limits specified in Table 2525-l. The abss. lute differ-nce between the amount removed and the amount replaced shall not exceed 10%
of the tendon net duct volume.
3222 Acceptance by Evaluation Items with examination results that do not meet the acceptance standards of -3221 shall be evaluated as required by -3300.
3223 Acceptance by Repair / Replacement Activity Repair / replacement activities to reestablish acceptability of the condition of an item shall be completed as required by -3300.
Acceptable completion of the repair / replacement activity shall constitute acceptability of the item.
3300 EVAL.UATION 3310 EVALUATION REPORT ltems with examination results that do not meet the acceptance standards of -3100 or -3200 shall be evaluated by the Owner.
The Owner shall be responsible for preparation of an Engineering Evaluation Report stating the following:
(a) the cause of the condition which does not meet the acceptance standards; (b) the apphcability of the condition to any other plants at the same site:
(c) the acceptability of the concrete containment without repair of the item; (d) whether or not repair / replacement activity is required and, if required, the extent, method, and completion date for the repair! replacement activity; (c) extent, nature, and frequency of additional examinations.
_ to CPSES Unit i Relief Request L-1 Page11of12 ARTICI.E -4000 REPAIR /REPl.ACEMEnT AC11VITIES
-4100 GENERAL, I
-41 t J SCOPE
(
(a) This Article provides requirements for repair / replacement activities on concrete containments.
(b) Grease cups and installation screws are exempt from the requirements of tnis Article.
-4120 REPAIR /REPl.ACEMENT PROGRAM Repair /teplacement activities shall be performed in accordance with the Repair / Replacement Program and Plan required by IWA-4150.
'The Repair / Replacement Program shall address concrete material control.
-4200 REPAIR / REPLACEMENT Pl AN
-4210 RESPONSlHl.E ENGINEER The Repair / Replacement Plan shall be developed under the direction of a Responsible Engineer ( -2300).
-4220 CONCRETE (a) The Repair / Replacement Plan shall specify requirements for removal of defective material.
(b) The affected area shall be vhually examined to assure proper surface preparation of concrete and reinforcing steel prior to placement of concrete.
(c) When removal of defective material exposes reinforcing steel, the reinforcin; steel shall receive a detailed visual examination as defined in -2310(b). Reinforcing steel is acceptabic when the Responsible Engineer determines that there is no evidence of damuge or degradation suflicient to warrant further evaluation or repair. When required, reinforcing steel shall be repaired in accordance with -4230. Repair / replacement activities on exposed-end anchors of the post tensioning system shall be in cecordance with -4240 (d) New material shall be chemically, mechanically, and physically compatible with existing concrete.
(c) When detensioning of prestressing tendons is required for the repair / replacement activity on the concrete surface adjacent to the tendon, the Repair / Replacement Plan shall require the following:
(/) selection of new material to minimize stress and strain incompatibilities between new material and existing concrete; (2) procedures for application of new material; (3) procedures for detensioning and retensioning of prestressing tendons.
(/) The Repair / Replacement Pian shall specify requirements for in process sampling and testing of new material.
-4230 REINFORCING STEEL Damaged reinforcing steel shall be corrected by any method permitted in the original Construction Code or in Section 111, Division 2, with or without removal of the damaged reinforcing steel.
-4240 POST-TENSIONING SYSTEM (a) Welding of bearing plates and shim plates of the post tensioning system shall meet the applicable requirements ofIWA-4000. The corrosion protection medium shall be restored following the repair! replacement activity.
(b) The foliowing items, as applicable, shall be contained in the Repair / Replacement Plan:
(/) requirements for the removal ofitems; (2) surface preparation required prior to installation of items; (J) examinations required prior to installation ofitems; (4) detensioning and retensioning requirements for tendons affected by installation ofitems; (5) requirements and procedures applicable to installation ofitems; (6) in.procesr, sampimg and testing requinments to be performed during installatior. ofitems.
. to CPSES Unit 1 Relief Request L-1 Page 12 of 12
-4300 EXAMINATION Areas of repair / replacement activities shall be etamined in accordance with 2000 to establish a new preservice record and shall meet the acceptance standards of 3000.
ARTICLE -5000 SYSTEM PRESSURE TESTS
-5100 SCOPE nis article provides requirements for pressure testing concrete containments following repair / replacement activities.
5200 SYSTEM TEST REQUIREMENTS
-5210 GENERAL A containment pressure test shall be performed following repair / replacement activities unless any of the following conditions exist:
(a) The Engineering Evaluation Report (
3310) demonstrates that the structural integrity of containment in the prior to perfomiance of the repair / replacement activity condition has not been reduced below that required by the original design criteria.
l (b) The repair / replacement activity affects only the cover concrete extemal to the outermost layer of structural reinforcing steel or post-t nsioning tendons.
(c) ne repair / replacement activity involves only exchange of post-tensioning tendons, tendon anchorage hardware, shims, or corrosion protection medium.
5220 TEST PRESSURE The pressure test shall be conducted at the design % sis accident pressure, P.
-5230 LEAKAGE TEST A leakage test shall be conducted as required by IWE 5000.
5250 TEST PROCEDURE AND EXAMINATIONS ne Responsible Engineer shall review the pressure test procedure and shall authorize the commencement of the pressure test.
The surface of all containment concrete placed during repair / replacement activities shall be examined in accordance with -2310(b) prior to start of pressurization, at test pressure, and following completion of depressurization. Extended surface examinations, cdditional examinations during pressurization, other examinations, and measurements of structural response to pressure shall be conducted as specified by the Responsible Engineer.
-5260 CORRECTIVE ACTION If the surface examinations of -5250 cannot satisfy the requirements specified by the Responsible Engineer, the area shall be examined to the extent necessary to establish reouirements for corrective action. Repair / replacement activities shall be performed in occordance with -4000, and pressure testing shall be repeated in accordance with
-5200, prior to returning 'he containment to service.
-5300 REPORT A pressure test report shall be prepared under the direction of the Responsible Engineer. This report may be an addition to a previously-prepared Engineering Evaluation Report ( -3310). The report shall describe pressure test procedures and examination results and shall state whether or not the repairireplacement activity is acceptable. If the repair / replacement activity is not acceptable, the report shall specify corrective measures.
. _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ to CPSES Unit 1 Relief Request L-1 Page 1 of 8 Para.
Changes between IWL Signilleante of change and or basis for graph 1992 Ed. '92 Ad. and the current IWL rewrite use as an alternative examination lWL-ASME Section XI generic wording change from non significant 1100 repair, replacement and or modification terms to repair /replac ment activities 1200 no change n/a 1210 no change n/a 1220 no change n/a 2100 Changed " Inspection" to " General" in heading.
non significant (a) Provided reference to IWA-2000 with exceptions from IWA-2210 and 2300 for visual (a) The additional general requirements examinations and for qualification of visual invoked by reference to IWA 2000 where examination personnel, none were referenced previously further assure containment integrity. The exceptions from 1WA-2210 and IWA 2300 are significant in that the related previous requirements have been changed and incorporated into IWL-2310. The IWL-2310 changes are addressed below.
(b) Provided requirements for Authorized Nuclear Inservice Inspectors.
(b) The addition of Authorized Nuclear Inservice Inspector requirements ensures proper Inspector qualification.
2200 no change n/a 2210 no change n/a 2220 no change n/a 2230 ASME Section XI ge eric change from repair non significant and or replacement to repair / replacement activities.
2300 no change n/a
_ - _ ____ _-_ _ to CPSES Unit 1 Relief Request 1,-l page 2 of 8_
Pera-Changes between IWI, Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWI, rewrite use as an alternative examination 2310 These changes are related to the IWL-2100 changes addressed above and are considered significant.
(a) replaced VT-1C and VT-3C visual (a) Containment examinations are intended examination terminology with new VT general to identify indications of significant and VT detailed examination temis.
conditions over large areas. The VT general examination is performed to indicate the general structural condition for detemiining concrete deterioration and distress. The VT detailed examination is performed to detemline the magnitude and extent of the deterioration.
(b) replaced reference to IWA-2210 for (b) Direct visual examination is not practical illumination levels, examination distances and on all areas of containment surfaces. The resolution requirements with specific previous VT requirements precluded the examination attributes.
ability to demonstrate that remote visual examination was equivalent to direct visual examination. Providing specific examination attributes in IWL as opposed to referencing the generic requirements ofIWA focuses the visual examination on areas important to the verification of containment integrity.
(c) replaced reference to IWA-2300 for concrete (c) Invoking requirements comparable to CP-examination personnel qualification requirements 189 would complicate containment ISI with provisions for the owner to define the program development without a examination personnel qualification compensating increase in plant quality or requirements.
safety. Requiring an owner defined program provides for more eflicient program implementation by permitting personnel perfomling containment examinations te be qualified to written practices that are more consistent to those used for other NDE personnel.
.. -. =
..-. _._~ -
- to CPSES Unit 1 Relief Request L-1 Page 3 of 8
)
Para.
Changes between IWI,
- Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWI, rewrite use as an alternative examination 2320 Changed wording slightly, non significant - clarifies wording Made the ASME Section XI generic change from non significant repair e nd or replacement to repair / replacement activities.
Added a responsibility for the Responsible The added pressure test responsibilities for Engineer to review certain pressure test the Responsible Engineer ensures proper procedures, perfonnance of pressure testing activities.
2400 no change n/a 2410 no change n/a 2420 no change n/a 2421 Changed wording for sites with more than one non significant - clarifies wording and plant. Changed frequencies by adding "and every accommodates plant life extensions.
10 years thereafler".
2500 no change n/a 2510 Changed heading.
non significant Changed wording consistent with the changes to non significant IWL-2310 addressed above.
Added two subparagraphs providing more The added details ensure proper tendon detailed examination requirements for tendon anchorage area examinations. However, anchorage areas.
these changes do not apply to CPSES containments.
2520 no change n/a 2521 no change n/a 2522 Changed the heading and added a subparagraph The added details ensure proper tendon to address tendon clongation.
examinations. However, these changes do not apply to CPSES.
2523 no change n/a 2524 Changed wording consistent with the changes to non significant IWL-2310 addressed above.
2525 Changed wording for sample analysis.
non significant
_ _ _ _ _ _ _ _ to CPSES Unit 1 Relief Request L-1 Page 4 of 8 Para-Changes between IWI, Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWI, rewrite use as an alternative examination 2526 Added a subparagraph addressing replacement of The added details ensure tendon integrity, corrosion protection medium, However, these changes do not apply to CPSES containments.
3100 no change n/a 3110 no change n/a 3111 ASME Section XI generic change from repair non significant and or replacement to repair / replacement activities.
3112 no change n/a 3113 ASME Section XI generic change from repair non significant ar.J or replacement to repair / replacement activities.
3120 no change n/a 3200 no change n/a 3210 removed the word concrete from the heading non significant 3211 Added tendon end and anchorage areas to the The added details ensure proper tendon -
scope of the subparagraph and added corrosion examinations. However, these changes do protection medium leakage and end cap not apply to CPSES containments.
deformation as acceptance criteria attributes, ASME Section XI generic change from repair and or replacement to repair / replacement non significant, activities.
3212 no change n/a 3213 ASME Section X.' generic change from repair non significant and or replacement to repair /rrplacement activities.
3220 no change n/a 3221 Added acceptance criteria attributes for tendon The added details ensure proper tendon clongation, free water content and corrosion examinations. However, these changes do no protection medium reduction.
apply to CPSES containments.
3222 no change n/a to CPSES Unit 1 Relief Request L-1 Page 5 of 8 Para.
Changes between IWI, Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWI, rewrite use as an alternative examination 3223 ASME Secticn XI generic change from repair non significant and or replacement to repair / replacement activitics, 3300 no change n/a 3310 Added applicability for other plants at the same non significant
- site, ASME Section XI generic change from repair non significant and or replacement to repair / replacement activities.
3320 Deleted paragraph which addressed engineering non significant - there were no submittal or evaluations being subject to review by retention requirements changed by the authorities, deletion of the subparagraph.
4000 ASME Section XI change from repair and or non significant. all related repair and replacement to repair / replacement activities.
replacement requirements have been consolidated into IWL-4000.
4100 no change n/a 4110 Exempted grease cups and installation screws non significant - the exempted items are non from the scope, structural items and no not apply to CPSES containments.
ASME Section XI generic change from repair non significant and or replacement to repair / replacement activities.
4200 ASME XI generic change from repair and or non significant replacement to repair / replacement activities.
Added a new paragraph 4210 to require The added requirements ensure proper Repair / Replacement Plans to be developed under repair / replacement plan development, the direction of a Responsible Engineer.
1
. to CPSES Unit i Relief Request L 1 Page 6 of 8 Para-Changes between IWI, Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWI, rewrite use as an alternative examination 4210 Changed paragraph number to 4220, removed the non significant word repair from heading and changed referenced paragraph numbers consistent with the addition of a new paragraph 4210 above.
Changed wording consistent with the changes to non significant IWL-2310 addressed above.
ASME Section XI generic change from repair non significant and or replacement to repair / replacement activities.
Changed repair material to new material in non significant several places, 4220 Changed paragraph number to 4230.
non significant l
4230 Changed paragraph number to 4240 and clarified non significant by removing the word repair.
ASME Section XI generic change from repair non significant and or replacement to repair / replacement activities.
Added detailed requirements for the contents of a The added detailed requirements ensure repair / replacement plan.
proper repair / replacement plan development -
for post-tensioning systems. However, these changes do not apply to CPSES containments.
4300 ASME Section XI generic change from repair non significant and or replacement to repair / replacement activities.
5100 ASME Section XI generic change from repair non significant and or replacement to repair / replacement activities.
5200 no change n/a 5210 ASME Section XI generic change from repair non significant and or replacement to repair / replacement activities.
5220 no change n/a 1
Enclosurn 2 to CPSES Unit 1 Relief Request L-1 Page 7 of 8 Parn-Changes between IWis Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWI, rewrite une as an alternative examination
$230 Changed wording by removing some specific non significant the removed wording was IWE related requirements while maintaining the 1WE specific and is contained in IWE 5000.
reference to IWE 5000.
$240 Deleted paragraph which addressed the non significant the schedule of pressure tests scheduling of pressure tests, ve contained in IWE 5000 as referenced in IWL 5230.
$250 Changed wording regarding the role of the The clarified role of the Responsible Engineer Responsible Engi:qcer in pressure test activities, ensures proper pressure test procedures and examinations.
ASME Section XI generic change from repair non significant and or replacement to repair / replacement activities.
Changed VT tenninology consistent with the _
_The VT tenninology changes are discussed in changes to IWL-2310 addressed above.
IWL 2310 above.
5260 Changed heading f rom Corrective Measures to non significant Corrective Action.
ASME Section XI generic change from repair non significant and or replacement to repair / replacement activities.
5300 i ASME Section XI generic change from repair non significant and or replacement to repair / replacement activitics.
7000 Deleted Anicle including IWL-7100,7110. 7120 non significant - all related repair and consistent with the IWL-4000 changes above, replacement requirements have been j
, incorporated into lWL-4000.
Table Changed item 1.1.11 from all areas to all Changing item 1.1.11 provides Ihr more 2500-1 accessible areas, practical examination implementation than previous requirements.
Chmged V j exam method terminology The VT terminology changes are discussed in consistent with the paragraph IWL 2310 changes IWL 2310 above.
above.
_ to CPSES Unit i Relief Request L 1 Page 8 of 8 Para.
Changes between IWL Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWI, rewrite use as an alternative examination Table Changed inspection periods to state every 5th non significant accommodates plant life 2521-1 year in lieu oflisting out each year and changed extensions for tendon examinations.
note 2 for having to meet acceptance criteria from flowever, these requirements do no apply to "cach of the earlier inspections" to "for the last 3 CPSES contamments, inspections".
Table Added optional test methods for corrosion non significant additional test method 25251 protection medium analysis options provides for more practical test implementation, liowever, thesc i
requirements do not apply to CPSES
)
containments.
aus
_______ ______________________________ to TXX 98041 Page 1 of 2 CPSES UNIT 2 RELIEF REQUEST E.1 A. Item (s) for which reliefis requested:
j Metallic containment shell and penetration liners and their integral attachments.
B. hemp) Code Class:
MC C. Examination requirements from which reliefis requested:
1992 Edition,1992 Addenda of Subsection IWE, " Requirements for Class MC and Metallic Liners of Class CC Components of Light Water Cooled Power Plants", of Section XI, Division 1, of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code).
D. Basis foi relief:
1 The 1992 Edition with the 1992 Addenda of Subsection IWE contains r quirements which impose difficulties in the transition from the current ISI program to a program that includes containment ISI examinations. Development and implementation of a me.mingful
'ontainment ISI program would be facilitated by adopting the examination requirements J iailed below. These alternative examinations provide for consistency with the existing j
rograms in the qualification of nondestructive examination personnel as well as providing
. ore practical requirements for the examination of containment bolting, seals and gaskets.
Some specific hardships imposed by the 1992 Edition, '92 Addenda ofIWE that are not compensated for by an increased level of plant quality and safety are as follows:
lWA 2300 requires the use of a written practice prepared in accordance with ANSI /ASNT CP 189 for the qualification and certification of containment nondestructive examination personnel. All other CPSFS NDE and ISI activities, including those performed on the reactor vessel, are performed by personnel qualified and certified to written practices prepared in accordance with SNT TC-1 A as required by ASME XI 1986 Ldition, No Addenda, the Code of record for ISI at CPSES. Utikmg the '92 Addenda oflWE would require the development of a separate written practice and the issuance and tracking of separate certifications for both TU Electric and cont ictors. Administration of the resulting duplicate programs could result in documentation inconsistencies and would be an impact to resources.
Containment bolting requirca a VT-1 examination and a bolt torque or bolt tension test per Table IWE-2500-1. Determination of bolt torque or tension requires the performance of a maintenance activity to un-torque or un tension the boh and then to re torque or re-tension the bolt. Boltedjoints ar: currently subject to Appendix J leak testing and a visual a
to TXX 98041 Page 2 0f 2 examination to verify leak tight and structural integrity. Other bolted joints subjected to visual examination by AShiB XI, including Code Class I bolting, do not require bolt torque or bolt tension testing. Perfonnance of the maintenance activity would be an impact to resources, increases radiation exposure and could result in damage to pennanent plant equipment.
Seals and gaskets require specific VT 3 examinations per Table IWE-25001. Seals and gaskets are not part of the containment pressure boundary. Bolted joints and airlocks are currently subject to Appen{x J leak testing and visual examinations to verify leak tight integrity. The perfonnance of additional VT-3 examinations of seals and gaskets to detect conditions that may violcte leak tight integrity is redundant, increases radiation exposure and would be an impact to resources.
l The proposed alternative is to utilize the emTent ASME approved rewrite of Subsection IWE of Section XI in its entirety. Utilizing the entire IWE rewrite incorporates other exceptions to the '92 addenda stated in NRC rulemaking and provides more cohesiveness than could be achieved by requesting relief on several individual subjects separately. The alternate examination requirements match the rewrite exactly and are included as Enclosure 1 of this relief request. These requirements were developed in accordance with the ash 1E Code committee process with input from interested parties which included TU Electric, other utilitics, manufacturers, engineering organizations, Authorized Nuclear inspection Agencies, EPRI and the NRC. The updating of requirements by this consensus process is intended to ensure the continued safe operation of nuclear power plants and specifically in this case the continued leak tight and structural integrity of metallic containment components. Therefore, the overall level of plant quality and safety witi not be adversely affected by utilizing the requirernents of the current AShiE approved IWE rewrite. A detailed evalua% and line by line comparison of the differences between the 1992 Edition with the 1992 Addenda of Subsection IWE and the current ASME approved rewrite is included as Enclosure 2 of this reliefrequest.
CPSES Unit 2 is in the second period of the Grst ten year ISI interval. Based on current plant refueling outage schedules and the requirement of the new rulemaking for full implementatica by September 9,2001, a containment ISI examination program must be established immediately. Implementing this relief request now would reduce the overall impact to resources (bo'h TU Electric's and the NRC's) versus incorporating the mandated edition and addenda ofIWE in conjunction with this initial establishment of a containment l
ISI program and then updating again to a later edition and or addenda or to a vries of Code Cases upon fomial NRC endorsement or on the next ten year ISI plan iwuance.
E. Alternate Examinations:
See Enclosure 1 of this relief request for the requirements of the curmnt AShiE approved rewrite of Subsection IWE which dennes the alternate examinations of this relief request.-
F. Anticipated impact on the overall level of plant quality and safety:
Nt ne.
.. to CPSES Unit 2 Relief Request E.1 Page1of14 ARTICl.E.1000 SCOPE ANI) RESPONSlHil.lTY 1100 SCOPE His Subsection provides requirements for inservice inspection of Class MC pressure retaining components and their integral attachments, and of metallic shell and pc tration liners of Class CC pressure retaining components and their integral attachments in light water cooled plants.
120tl COMPONENTS SUHJECT TO EXAMINATION l
1210 EXAMINATION REQUIREMENTS He examination requisements of this Subsection shall apply to Class MC pressure retaining components and their integral attachments and to metallic shell and penetration liners of Class CC pressure retaining components and their integral attachments.
nese examinations shall apply to surface areas, including welds and base metal.
1220 COMPONENTS EXEMPTED FROM EXAMINATION The following components (or parts at,omponents) are exempted from the examination requirements of.2000:
(a) vessels, parts, and appurtenances outside the boundaries of the containment system as denned in the Design Specifications; -
(b) embedded or inaccessible portions of containment vessels, parts, and appurtenances that met the requirements of the original Construction Code; (c) portions of cont::inment vessels, parts, and appurtenances that become embedded or inaccessible as a result of vessel repair /teplacement activities if the conditions of.1232 and.$220 are met; (d) piping, pumps, and valves that are part of the containment system, or which penetrate or are attached to the containment =
sessel. These components shall be examined in accordance with the requirements ofIWH or IWC, as appropriate to the classi0 cation denned by the Design Specifications.
1230 ACCESSlHILITY FOR EXAMIN ATION 1231 Accessible Surface Areas (a) As a minimum, the following portions of Class MC containment vessels, parts and appurt: nances and Class CC metallic shell and penetratior liners shall remain accessible for either direct or remote visual examinat'.on, from at least one side of the vessel, for the life of the plant:
(1) openings and penetrations; (2) structuraldiscontinuities; (3) 80% of the pressure retaining boundary (excluding attachments, structural reinforcement and areas ma le inaccessible during construction); and (4) surface areas identined in 1240.
(b) The requirements of 1232 shall be met when accessibility for visual examination is only from the interior surface.
1232 Inaccessible Surface Areas (a) Portions of Class MC containment vessels, parts, and appurtenances that a.. ~ mbedded in concrete or otherwise made inacce.sible during construction of the vessel or as a result of vessel repair /replacemsat activities are exempted from exarnination, provided:
. (/) no openings or penetrations are embedded in the concrete; (1). all welded joints that are inaccessible for examination are double buttwelded and are fully radiographed and, prior to being covered, are teted for leak tightness using a gas medium tes'., such as llalide Leak Detector Test; and (3) the vessel is leak rate tested after completion of construction or repaitheplacement activities to the leak rate
- requiremena of the Design Sp.ci6 cations.
(b) Portions of Class CC metallic shell and penetration liners that are embedded in concrete or otherwise made inaccessible dcring construction or as a result of repair / replacement activities are exempted from examination, provided:
4 Enclosure I to CPSES Unit 2 Relief Request E 1 Page 2 of14 (1) all welded joints that are inaccessible for examination are examined in accordance with CCJ520 and, prior to being covered or mherwise obstructed by adjacent emetures, components, parts, or appurtenances, are tested for leak tightness in accordance with CC 5536; and (1) the containment is leak rate tested afler co npletion of construction or repair / replacement activities to the leak rate requirements of the Design Specifications.
1240- SURFACE AREAS REQUIRING AUGMENTED EXAMIN. ilON 1241 fixamination Surface Areas Surface areas likely to experience accelerated degradation and aging require the augmented examinations identined in Table.
2500-1, fixamination Category !! C. Such areas include the following:
(a) interior and exterior containment surface areas that are subject to accelerated corrosion with no or minimal conosion allowance or areas u here the absence or repeated loss of protective coatings has resulted in substantial corrosion and pitting. Typical kications of such areas are those exposed to standing water, repeated wetting and drying, persistent leakage, and those with geometrics that permit water accumulation, condensation, and microbiological attack. Such areat may include penetration sleeves, stiffeners, surfaces wetted during refueling, concrete to-steel shell or liner interfaces, embedment rones, leak chase channels, drain areas, or sump liners.
(h) interior and exterior crmtainment surface areas that are subject to excessive wear from abrasion or erosion that causes a loss of protective coatings, defonnation, or tr.aterial loss. Typical locations of such areas are those subject to substantial traffic, sliding pads or suppotts, pins or clevises, shear lugs, seismic restraints, surfaces exposed to water jets from testing operations or safety relief valve dacharges, and areas that experience wear from fre.luent vibrations.
(c) interior and exterior containment surface areas identified in accordance with.2420(b).
1242 Identification of fixamination Surface Areas Surface areas requiring augmented examination shall be detennined in accordance with.1241, and shall be identified in the Owner's inspection program.
lixamination methods shall be in accordance with.2500(b).
ARTICI.E -2000 EXAMINATION ANDINSPECTION 2100 GENERAL.
(a) The requirements ofIWA 2000 apply, except the requirements ofIWA4210, IWA.2300, IWA.2500 and IWA 2600 are not mandatory for Table.25001 visual examinations.
2200 PRESERVICE EXAMINATION (a) lixaminations listed in Table 25001 shall be completed prior to initial plant startup. These preservice examinations shali include the pressure retaining portions of components not exempted by.1220.
(b) When visual examinations are required, these examinations shall be performed in accordance with.2600, following the completion of the pressure test required by the Construction Code and afler application of protective coatings (e.g., paint) when such coatings are required.
(c) When a vessel, liner, or a portion thereofis subjected to a repair / replacement activity during the service lifetime of a plant, the preservice examination requirements for the poition of the vessel affected by the repair / replacement activity shall be met.
(1) When the repair / replacement activity is performed while the plant is not in service, the preservice examination shall be performed prior to resumption of service.
(2) _ When the repair / replacement activity is performed while the plant is in service, the presenice examination may be deferred to the next scheduled plant outage, provided nondestructive examination in accordance with the Repair / Replacement Program is perfonned.
(3) When a system leakage test is required by.5220, the preservice examination may be performed either prior to or following the test.
(d) Welds made as part of repair / replacement activi:ies shall be examined in accordance with the requirements et iWA-4000, except that for welds joining Class MC or Class CC components to items designed, constructed, and installed to the r:quirements of Section 111, Class 1, 2, or 3, the examination requirements of IWib2000, IWC 2000, or IWD-2000, as applicable, shall also apply.
l Enclosure I 10 CPSES Unil 2 Relief Regtiest E 1 i
Page 3 of14 (c) Preservice examination for a repair / replacement activity may be conducted prior to installation provided:
(/) the examination h performed after the pressure test required by the Construction Code has been completed; (1) the examination is conducted under conditions and with equipment and techniques equivalent to those that are expected to be employed for subsequent inservice examinations; and (3) the shop or Ocid examination records are, or can be, documented and identined in a fonn consistent with that required by IWA4000.
3300 VISUAL, EXAMIN ATION, PERSONNEL, QUAL.lFICATION AND RESPONSillt.E INDIVIDUAL, 2310 VISUAL, EXAMINATIONS 1
(a) 'the Owner shall define requirements for visual examination of containment surfaces.
(b) General viwal examinations shall be performed in accordance with.2$00 and Table.2500-1, Examination Category !!.A to assess the general condition of containment surfaces.
(c) Detailed visual examinations shall be performcd in accordance with.2$00 and Table.25001. Examinati n Category E-C:
o
(/) to assess the initial condition of surfaces requiring augmented examination in accordance with 1241 and to determine the magnitude and extent of any deterioration and distress of these surfaces.
(2) to deteimine the rnagnitude and extent of deteriorati;m and distress of suspect containment surfaces initially detected by general visual examinations, (d) Detaded visual examinations thall also be performed in accordance with.5240 to assess the structural condition of areas alTected by repair / replacement activities.
(c) For areas and items subject to detailed visual examination, the following criteria apply,
(/) Painted or coated areas shall be examined for evidence of Haking, blistering, peeling, discoloration, and other signs of distress.
(1) Non-coated areas shall be examined foi evidence of cracking, discolorati n, wear, pitting, excessive conosion, gouges, surface discontinuities, dents, and other signs of surface inegularities.
(3) Pressure retaining bolting materials shall be examined for conditions which may cause the bolted connection to violate either the containment leak tight or structural integrity. Examples of such conditions are bent, twisted, or defonned bolts or studs; missing or loose bolts, stud <, nuts, or washers, fractured bolts, studs, or nuts; and degra. led coatings on bolting surfaces accompanied by damage or degradation of the bolting taaterial.
(4) Moisture barriers shall be examined for wear, damage, erosion, tear, surface cracks, or other defects that may permit intrusion of moisture against inaccessible areas of the pressure retaining surfaces of the metal containment shell or liner.
2320 RESPONSillt.E INDIYlDUAI, (a) The Responsible Individual shall be knowledgeable in the requirements for desivt, inservice inspection, and testing of Class MC and metallic liners of Class CC components.
(b) 'the Responsible Individual shall be responsible for the following:
(/) devc opment of plans and procedures for examination of containment surfaces; i
(1) instruction, training, and approval of visual examination personnel; (3) performance or direction of general and detailed visual examinations; (4) evaluation of examination results; (3) submittal or report to the Owner documenting results of examinations.
2330 PERSONNEL, QUAI.IFit ATION (a) The Owner shall define the quali6 cation requirements for personnel performing visual examinations.
(b) Visual examinations shall be perfonned either directly or remotely, with adequate illumination, by personnel with visual acuity suf0cient to detect evidence of degradition.
2400 INSPECTION Sr.,put,g 2410 INSPECTION PROGRAM inservice examinations and system pressure tests may be performed Juring plant outages such as refueling shutdowns or
~
- to CPSES Unit 2 Relief Request E 1 Page 4 of14 maintenance shutdowns. 'the requirements of either Inspection Program A or inspection Program 11 shall be met.
2411 Inspection Program A With the exception of the examinations that may be deferred utstil the end of an inspection interval, as specifkd in Table.2500 1, the requi*cd examinations shall be comple'.ed during each successive inspection interval, in accordance with Table.2411 1.
l'ollowing completion of Program A after 40 years, successive inspection intervals shall follow the 10 year inspection interval of Program 11.
TAl3LE.2411 1 j
INSPECT 10N PROGRAM A l
Inspection Inspection Period, Minimum Maximum Interval Calendar Years of Examinations Examinations Plant Service Comnleted. %
Credited. %
l 1 51 3
~100 100 2nd 7
33 67 10 100 100 3rd 13 16 34 l7 40 50 20 66 75 23 100 100 4th 27 8
16 30 25 34 33 50 67 37 75 100 40 100 L
. to CPSES Unit 2 Relief Request E 1 Page 5 of14 TAllLE 24121 INSPECTION PROGRAM 11 Inspection inspection Period, Minimum Maximum Interval Calendar Years of Examinations Examinations Plant Service conmleted. %
Credited. %
All 3
16 50 7
50 75 10 100 100 2412 Inspection Program II (a) With the exception of the examinations that may be deferred until the end of an inspection. interval, as specified in Table -
25001, the required examinations shall be completed during each successive inspection internt, in accordance with Table 2412 1.
(b) Ifitems or welds are added to the inspection Program, examination shall be scheduled as follows.
(/) When items or welds are added during the first period of an interval, at least 25% of the examinalbns required by the applicable Examination Category and item Number for the added items or welds shall be perfonned during eat of the second and third periods of that interval. Alternatively, if deferral of the examinations is permitted for the Examination Category and Item Number, the second period examinations may be deferred to the third period and at least $0% of the examinations required by the applicable Examination Category and item Number for the added items or welds shall be performed during the third period.
~ (2) _ When items or welds are added during the second period of an inten al, at least 25% of the examim.tions required by the applicable Examination Category and item Number for the added items or welds shall be performed during the third period of that interval.
(3) When items or welds are added during the third period of an interval, examinations shall be scheduled in accordance with 2412(a) above for successive intervals.
2420 SUCCESSIVE INSPECTIONS (a) The sequence of component examinations established during the first inspection interval shall be repeated during each successive inspection interval, to the extent practical.
(b) When examination results require evaluation of flaws or areas of degradation in accordance with 3000, and the component is acceptable for continued service, the areas containing such flaws or areas of degradation shall be reexamined during the next inspection period listed in the schedule of the inspection program of -2411 or 2412, in accordance with Table 25001, Examination Category E-C, (c) When the reexaminations required by 2420(b) reveal that the flaws or areas of degradation remain essentially unchanged for the next inspection period, these areas no longer require augmented examination in accordance with Table 2500-1, Examination Category E-C.
2500 EXAMINATION AND PRESSURE TEST REQUIREMFNTS (a) Examination methods shall comply with Table 2500-1, except when attemative examination methods are used that meet the requirements ofIWA 2240.
(b) Methods for augmented examination of surface areas identified in 1242 shall comply with the following criteria:
(/) Areas accessible from both sides shall be visually examined using a detailed visual examination method.
(2) _ Areas accessible from one side only shall be examined for wall thinning using an ultrasonic thickness measurement method in accordance with Section V, T 544.
(3) When ultrasonic thickness measurements are performed, grids shall be used. Grid line spacing shall comply with the requirements of Table _1500 2. De number and location of the grids shall be determined by the Owner, Locations of grid line intersections to be examined may be marked on containment surfaces in lieu of marking grid lines.
(4) Ultrasonic thickness measurements shall be performed to determine the minimum wall thicknesses at locations specified in Table -2500-2. Minimum wall thickness locations and kications of examined grid line intersections shall be marked such that periodi: reexamination of these locations can be performed in accordance with the requirements of Table 25001, Examination Category E C.
.- to CPSES Unit 2 Relief Request E-1 Page 6 of 14 (c) pressure test requirements for components and parts of the pressure retaining boundary shall cornply with the requirernents of 5(XXL 2600 CONDITION OF SUHFACE 'IO IIE EXAMINI:D (a) When a containment s essel or liner is painted or coated to protect surfaces front corrosion, preservice and inservice visual exarrJnations shall be performed without the removal of the paint or coating.
(b) When removal of paint or coating is iequired, it shall be removed in a manner that will not reduce the base nietal or w cld thickness below the design thickness.
Enclosure I to CPSES Unit 2 Relief Request E-1 Page 7 of14 TABLE -2500-1 EXAMINAllON CATEGORIES EXAMINATION CATEGORY E-A, CONTAINMENT SI'RFACES l
Item Parts Examination Exammation Acceptance Extent and Frequency of Examination Deferral of i
No.
Examined R u p u m e nts/
Method Standard Inspecten to Fig. N -
End of 1st inspection Successrve Interval Int-val Inspection Intervals i
EI.10 Containanent Vessel Pressure Retainhig Boundary' El.11 Accessible Surface Areas
-2310 General Visual
-3510 100*4 Durmg each 100"& Durmg each N/A
[
Inspectwn Period Inspecnon Period e
i E1.12 Wetted Surfaces of Submerged Areas
-2310 General Visual
-3510 100*4 100's Pemussible El.20 BWR Vent System
-2310 General Visual
-3510 100*6 100*4 Permrssible Accessible Surface Area > '
El.30 Moisture Barriers'
-2310 General Visual
-3510 100*& During each 100"; Durmg each N'A Fig. -2500-1 Inspecten Penod Inspection Penod NOTE &
(1) Examination shall include all accessible interior and extenor surfaces of Class M F cuugmxuts, parts. ar d appurtenances, and metallic shell and penetration lmers of Class CC components. The following items shall b-considered for exammatiotr (a) integral attachments and structures that are parts of remforcing structure, such as stiffenmg rmgs, manbe e frames, and remforcement around muy (b) surfaces of attachment welds between structural attachments and the pressure retaining boundary or :emforcing structure, except for nonstructural or tw3m.uy attachments as defined in NE-4435 and minorm usst attachments ad defined in CC-4543.4.
(c) surfaces of containrnent structural and pressure boundary welds, including longitudmal welds (Ca egory A), circumferential welds (Category B) flange melds (Category C), and nozzle-to-shell welds (Category D) as defined in NE-3351 for Class MC and CC-3S40 for Class CC; and surfaces of Flued 11ead and Bellows l
Seal Circumferential Welds joined to the Penetration.
(d) pressure-retaining bolted connections, including bolts, studs. nuts, bushings, washers, and threads in base material and flange ligamena between fastener holes.
Bolted connections need not be disassembled for performance ofexaminations, and boltmg may remain in place under tension _
(2) Includes flow channeling devices within containment vessels.
f (3) Examina* ion shall include moisture barrier materials intended to prevent intrusion of moisture agamst inaccessible areas of the pr ssure retaining metal contamment shell or liner at concrete-to-metal interfaces and at metal-to-metal interfaces uhich are not scal-welded. Contamment moisture barner materials include caulkmg.
f flashing. and other scalants used for this application _
3 t
_ _ te CPSES Unit 2 Relief Request E Pap 8 of14 -
TABLE -2500-1(CONTD)
EXAMINATION CATEGORIES EVAMINATION CATEGORY E-C, CONTAINMENT SURFACES REQUIRING AUGMENTED EXAMINATION
' Item Parts Exammation Exananation Awwe Extent ani Fwquy of Exannnaten Deferralof No.
'.xammed Ryuuuwnts/
Method Standard Inspecten to I
End of Fig. No.
33, g.,,33;y,
.u.
Interval Inspecten Intervals E4.10 Containment Surface Areas' E4.11 Visible Surfaces
-2310(c)
Detailed Visual
-3511 100% of Surface -
100% ofSurface '
' Not Permrssible
-2500(bX1)
Areas Areas identified by 2
-2500(bX2)
Identified by
-1242
-1242' E4.12 Surface Area Grid Grid Line Intersections and
-2 40(bX2)
Ultrasonic
-3511 100*& of Gnd Lme 100*6 of Grid Line.
Not Pernussible Minunum
-2500( iX3)
Thickness '
Intersectens and Imuwhons and WallThickne~ 1.ocations
-2500(bX4)
Mmmmm WaII Mmunum Wall Hickness Thickness Locations durmg
- Locations durmg eachI + Lou each L+cuva Period, established Penod. established m accordance wrth in a u. h e w uh
-2500(bX3)2and
-2500(bX3)2and
-2500(bX4):
-2500(bX4)
NOTES f1) Containment surface areas requiring augmented exammaten are those idenuried in -1240.
(2) The extent of examination shall be 100% for each mspecten pened until the areas remam essentially unchanged for the next in.p penod_ Such areas no longer require augmented exammation in accordance math -2420(c).
_- 2 t
__._.__m__
Enclosure i to CPSES Unit 2 Relief Regt'est E-1 Page 9 of14 l
l TABLE -2500-2 ULTRASONIC TIIICKNESS 51EASUREAfEN'IS l
FOR AUGA1ESTED EXAA11 NATIONS Augmented Exammation Area Size (Contiguous)
Exammation R+o-ots s 100 square feet 100*6 of Grid Line Intersecuens"*
> 100 square feet 100% of Grid Line Intersectwns
Notes:
- 1. Location and size of area to be exariined shall be determined by the Owner.
- 2. Grid line spacing shall not exceed 12 inches, and need not be less than 2 inches.
- 3. Grid line spacing shall be selected such that a minimum of 100 neunuxnts are obtained from within each augment d examinanon area. unless this requires selectmg a grid line spacing ofless than 2 inches.
- 4. In lieu of examining 100% of the grid line intersections within the augmented examination area, an alternate eummaten plan may be developed as follows:
(a) A sample area from within the augmented examination area may be selected for examination. The location and size of the sample area shall be determined by the Owner, but shall consist of areas subject to the most severe sers ice conditmns w. thin the larger augmented examination area. 100%
of the grid hue intersections within the sample area shall be examined, and grid ime spacing shall be selected such that a muumum of 100 measuremen s are obtained from within the sample area.
(b) If the sampie ares exceeds 100 contiguous square feet, the Owner may develop a samphng plan for cumination of grid line intersectwns within the sample area. Locations of ultrasonic thickness measurements to be taken at gnd Ime intersections shall be selected at random throughout the sample area. The minimum number of measurements shall be 100, or shall be sufficient to ensure at least a 95% confidence level that the thickness of the base metal is reduced by no more than 10% of the nommal plate thiciness at 95% of the grid Ime intersections within the sample area, w hitbever is greater.
(c) If any uhrasonic thickness measurements withm the sample area reveal that the thickness of the base metal is reduced by more than 10% of the nominal plate thickness, all remaining grid line intersections within the sample area shall be exammed, and additmaal UT exammations from outside of the sample area shall be required. 'Ihese additional UT exammations shall be perfor.ned on another area from withia the larger aug;nented exammation area that is at least as large as the initial sample aru. If any of these subseqtwit exammatmns reveal that the thickness of the base metal.3 reduced by more than 10% of the nominal plate thickness, additional areas from within the larger augmented exammation area shall be exammed unni subsequent examinations of additional areas reveal no measurements u here metal loss exceeds 10% of the nommal plate thickness, or until the entire augmented examination area has been examined.
- 5. When an ultrasonic thickness measurement performed at a grid ime intersection reveals that the thickness of the base metal is reduced by more than 10% of the nominal plate thickness, the minimum wall thickness shall be determined and located within each adjoming grid.
- 6. Afeasurements need not be obtained at locations where obstructions interfere with grid ime intersections.
j
Enclosure I to CPSES Unit 2 Relief Request E-1 Page 10 of 14 Examination are. A-ts Westure tehMG MW fy s
contelnment shell et lliner hb
=
tniemes concret.to-meisi
,\\
l etertece moisture bemee N g
/
p Eneminai on eres c.o i
p j c
/ [ iniemei..ne,eie.te.meiei intertece manture borner ten-
., ~,
nws h w answru W J FIG. 2500-1 liXAMINATION AREAS 1 OR MOISRTRE BARRIERS
Enclosure I to CPSES Unit 2 Relief Request E.1 Pcge 11 of14 ARTICI.E.3000 ACCEPTANCE STANDARDS 3100 EVALUATION OF EXAMINATION RESULTS 3110 PRESERVICE EXAMINATIONS 3111 Gen ral
- lhe preservice examination required by.2200 and performed in accordance with the procedures ofIWA 2200 Shall be evaluated by the acceptance standards specined in.3500. Acceptance of components for service shali be in accordance with.3112 and.3114.
3112 Acceptance (a) A component whose examination either confirms the absence of or detects flaws or areas of degradation that do not exceed the acceptance standards of.3500 is acceptable for service, provided the flaws or areas of l
der;radation are recorded in accordance with the requirements ofIWA.1400(h) and IWA.6230 in terms of location, ure, shape, orientation, and distribution within the component.
l (b) A component w hose examination deteca flaws or areas of degradation that do not meet the acceptance standards of.3MO is unacceptable for service unless the component is corrected by a repair / replacement activity, to the extent necessan to meet the acceptance standards, prior to piacement of the component in service.
3114 Repair / Replacement Artisity and Reexamination The repair / replacement activity and reexamination shall comply with the requirer. ants ofIWA-4000.
Reexamination shall be conducted in accordance with the requirements ofIWA.2200. The recorded rt sults shall demonstrate that the area subjected to the repair / replacement activity meets the acceptance standards of.3500.
f 3120 INSERYlCE EXAMINATIONS 3121 General inservice examination results shall be compared with recorded results of the preservice examination and prior inservice examinations. Acceptance of the components for continued service shall be in accordance with.3122.
3122 Acceptance 3122.1 Acceptan:e by Examination. A component whose examination results meet the acceptance standards of.3500 shall be acceptable for continued service. Confirmed changes in flaws or areas of degradation from prior examinations shall be tecorded in accordance with IWA 1400(h) and IWA 6230. A component that does not meet the acceptance standards of.3500 shall be corrected in accordance with the provisions shown in 2122.2 or 3122.3.
3122.2 Acceptance by Repair / Replacement Activity. A component whose examination detects flaws or areas of degradation that do not meet the acceptance standards of.3500 is unacceptable for continued service until the compo.cnt is corrected by a repair / replacement activity to the extent necessary to meet the acceptance standards of
.3500.
-3122.3 Acceptance by Engineering Evaluation (a) A component whose examination detects flaws or areas of degradation that do not meet the acceptance standards of.3500 is acceptable for continued service without a repair / replacement activity if an engineering evaluation indicates that the flaw or area of degradation is nonstructural in nature or has no unacceptable effect on the structural integrity of the containment. If either the thickness of the base metal in local areas is reduced by no more than 10% of the nominal plate thickness or the reduced thickness can be shown by analysis to satisfy the requirements of the Design Specifications, the component is acceptable by engmeerin3 evaluation.
L Enclosure I to CPSES Unit 2 Relief Request E-1 Page 12 of14 (b) When flaws or areas of degradation are necepted by engineering evaluation, the area containing the flaw or degradation shall be reexamined in accordance with 2420(b) and (c).
(c) When portions oflater editions of the Construction Code or Section ill are used, all related portions shall be met.
3124 Repair / Replacement Activity and Reexamination
'the sepair/replacen'ent activity and reexamination shall comply with the requirements of IWA 40.
Reexamination shall be conducted in accordance with the requirements ofIWA.2200. The accordea results shall demonstrate that the area subject to the repair / replacement activity meets the acceptance standards of.3500.
3130 INSERVICE YlSUAl, EXAMINATIONS A component whose visual examinations as specified in Table 2500-1 detects areas that are suspect, shall be unacceptable for continued service unless, following verification of the suspect areas by the supplemental examination as required by 3200, the requirements of 3120 are satisGed.
3200 SUPPI.EMENTAl, EXAMINATIONS Examinations th.: detect flaws or evidence of degradation that tryuite evaluation in accordance with the requirements of 3100 may be supplemented by other examination methods and techniques (IWA 2240) to determine the character of the flaw (i.e., size, shape, and orientation) or degradation. Visual examinations that detect surface flaws or areas that are suspect shall be supplemented by either surface or volumetrie examination, when specined as a result of the engineering evaluation performed in 3122.3.
3400 STANDARDS
-3410 ACCEPTANCE STANDARDS 4
The acceptance standards of 3500 shell be applied to evaluate the acceptability of the component for service following the preservice exandnation and each inservice examination.
3430 ACCEPTAllit.lTY Flaws or areas of degradation that do not exceed the allow able acceptance standards of 3500 for the respective examination category shall be acceptable, 3500 ACCEPTANCE STANDARDS
-3510 STANDARDS FOR EXAMINATION CATEGORY E A, CONTAINMENT SURFACES 1
3510.1 Visual Examination General. The Owner shall define acceptance criteria for visual examination of containment surfaces.
3510.2 Visual Examination of Coated and Non-coated Areas. The condition of the inspected area is acceptable if there is no evidence of damage or degradation which exceeds the visual examination acceptance criteria specified by the Owner. Areas that are suspect shall be accepted by engineering evaluation or corrected by repair / replacement activities in accordance with 3122. Supplemental examinations in accordance with 3200 shall be performed when specified as a result of the engineering evaluation.
to CPSES Unit 2 Relief Request E 1 Page 13 of 14
-3510.3 Visual Examination of Pressure Retaimng flolting. Except for loose bolting, bolting materials with conditions that cause the bolted connection to violate either the (ontainment leak tight or structural integri'y shall be corrected by repair / replacement activities.
3510.4 Visual Examination of Moisture Ilarriers Moisture baniers with wear, damage, crosion, tear, smface crads, or other defects that permit intrusion of moisture against inaccessible areas of the pressure retaining surftces of the metal containtnent shell or lines shall be corrected.
3511 Standards for Examination Category E C, Containment Surfaces Requiring Augmented Examination 3511.2 Visual Examination of Coated and Non-coated Areas. "Ihe condition of the impected area is acceptable if there is no evidence of damage or degradation which exceeds the visual examination acceptance criteria specined by the Onner.
3511.3 Ultrasonic Examination. Examinations of Class MC pressure retaining components that detect material loss in a local area exceeding 10% of the nominal wall thickness, or material loss in a local area projected to exceed 10% of the nominal wall thickness prior to the next examination, shall be documented. Such local area
- Shall be accepted by engineering evaluation or corrected by repair! replacement activities in accordance with 3122.
Supplemental examinations in accordance with 3200 shall be performed when specined as a result of the engineering evaluation.
ARTICI.E -4000 REI"..R PROCEl> TIRES
-4100 SCOPE The rules ofIWA-4000 apply.
ARTICI.E 5000 SYSTEM PRESSt!RE TESTS I
5200 SYSTEM TEST REQL!IREMENTS 5210 GENERAL, Except as noted in $240, the requirements ofIWA-5000 are not applicable to Class MC or Class CC components.
5220 TESTS IDI.l.OWING REPAIR /REPl.ACEMENT ACTIVITIES 5221 1 eakage Test Except as noted in 5222, repair / replacement activities perfomied on the pressure retaining boundary of Clasi MC or Class CC components shall be subjected to a pneumatic leakage test in accordance with the provisions of Title 10, Part 50 of the Code of Federal Regulations, Appendix J. Par
- ph IV.A.
5222 Deferral of 1.eakage Tests g
f 1 calage tests for the following minor repair / replacement activities performed on the pressure retaining boundary may be deferred until the next scheduled leakage test, provided nondestructive examination is performed j
in accordance with the Repair /Replacemer.t Program and Plan:
_ to CPSES Unit 2 Relief Request E-1 Page 14 of 14 (a) welds of attachments to the surface of the pressure retaining boundary; (b) weld cavities, the depth of w hich does not penetrate the required design wall by more than 10%; and (c) welds attaching penetrations that are NPS 1 or smaller.
5240 VISUAI, EXAMINATION l
During the pressure test required by $220, a detailed visual examination (.2310) shall be performed on areas l
affected by repair /nplacement activities.
5250 CORRECTIVE ACTION If the leakage test requirements of 5221 cannot be satisficJ, the source ofleakage shall be loca.
.d the area shall be examined to the extent necessary to establish the requirements for corrective action. Repair /res cement activities shall be performed in accordance with the requirements ofIWA 4000. Leakage testing shall be reperfonned as required by $220, prior to retuming the componeno service.
ARTICI.E 7000
- v. EPI,ACEMENTS 7100 GENI:RAl, REQUIREMENTS The rules of IWA-4000 apply.
1 1
. Enclosure 2 to CPSES Unit 2 Relief Request E 1 Page 1 of 13 Para.
Changes between IWE Significance of change and or hasis for graph 1992 Ed. '92 Ad. and the current IWE rewrite use as an alternative examination j
IWE.
no change n/a j
1100 j
1200 no change n/a 1210 no change n/a l
1220 Changed " containment" to " containment system" non significant 1230 no change n/a 1231 Removed item 3). " single welded butt joints These single welded buttjoint was removed from the weld side". as a specific item required rs 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 boundaiy as discussed in the changes to Table IWE 25001 below.
4 Changed wording from "80% of the surface area" The exclusions from 80% incorporate an to "80% of the pressure retaining boundary" and existing Table IWE 25001 note and clerify stated exclusions from that 80%,
that areas made inaccessible during construction are also excluded, i
Reworded paragraph b).
Change to b)is for clarity and is non significant.
1232 ASME XI generic change from repair and or non significant replacement to repair / replacement activities, i
Deleted paragraph (a)(3) addressing inaccessible weldedjoints were removed as a separately welded joints, listed examination items and are now included within the item for the pressure i
retaining boundary as discussed in the changes to Table IWE.2500-1 below.
1240 Added stiffeners and, by reference to IWE-2420, The additional areas subject to augmented l
flaws accepted by evaluation as areas requiring examination funher assure containment augmented examination, integrity.
2000 no change n/a 1
i
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-_ to CPSES Unit 2 Relief Request E 1 Page 2 0f l3 Para.
Changes between IWE Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWE rewrite use as an alternative examination 2l00 Added new Sutianicle 2l00 " General"- to The additional general requirements invoked provide reference to IWA 2000 with exceptions by reference to IWA 2000 where none were from IWA 2210,2300,2500 and 2600.
referenced previously further assure containment integrity. The exceptions provided are significant in that related requirements have been incorporated into IWE 2310,2320 and 2330. These changes
]
are discussed below.
2200 Deleted paragraph c) which provided allowances The deletion of an allowance for an for the use of shop or field examinations in lieu alternative examination ensures that proper of on site preservice examinations.
preservice examinations are performed and documented.
Deleted paragraph g) which required the The deletion of the requirement to document condition of new coating to be documented in the the condition of"new" non pressure retaining preservice examination record.
coatings in the preservice examination record provides for more efficient program implementation without affecting component integrity.
ASME XI generic change from repair and or non significant, replacement to repair / replacement activities.
2300 Added new Subarticle 2300 " Visual The paragraphs within this subarticle are Examination, Personnel Quali0 cation 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 Adicie IWE 2000 further ensures proper
" Examination and Inspection" of areas important to containment integrity and provides consistancey with Subsections IWB, IWC and IWD. The specific paragraphs l
added are discussed below.
?
.. to CPSES Unit 2 Relief Request E 1 Page 3 of 13 Para.
Changes between IWE Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWr.ewrite use as an alternative examination 2310 Added new paragraph 2310 Visual a) Adding requirements for the owner to Examinations which a) states that the vner define visual examination rr icments shall define requirements for visual exan ation provides for more efficient containment ISI of containment surfaces; program imp'ementation by allowing examinations that may be more consistent with existing 151, containment coating, maintenance rule and Appendix J programs.
b) and c) defines general and detailed visual b) and c) The VT general examination is examinations; and perfomted to indicate the general condition of the containment. The VT detailed examination is perfonned to determine the magnitude and extent of any deterioration or distress. Referring to visual examinations by new VT general and VT detailed terms does not adversely affect the integrity of the containment components examined; d) and c) provides the requirements for the d) and c) Previously these examination conditions of areas affected by repair / replacement requirements did not exist within the Article activities, painted or coated areas, non coated IWE 2000 but rather only in the acceptance areas. pressure retaining materials and moisture criteria of Article IWE-3000. Adding these
- barriers, specific attributes here ensure proper containment examinations 2320 Added new paragraph 2320 "Respons.ble a) The details for the responsible individual Individual"- which a) states the qualification qualification requirements were previously requirements of the responsible individual and contained in the acceptance standards of IWE-3510.1.
b) defines the responsibilities of the responsible b) The added detailed responsibilities for the 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 liaving an individual possessing the direction of visual examinations; evaluation of qualifications of a) perfomiing the results and documenting results, responsibilities of b) increases plar.t quality and safety by assuring the reliable detection of conditions adverse to containment integrity.
=
F
! to CPSES Unit 2 Relief Request E-1 Page 4 of 13 Para.
Changes between IWE S!gn licance,f change and or basis for graph 1992 Ed. '92 Ad. and the current IWE rewrite r,e as ar alternative examination 2330 Added new paragraph 2330 " Personnel a) Addng Nguirements for the owner to Qualification"- which a) states that the owner is define personnel qualification requirements responsible for defining the qualification provides for more efficient containment ISI requirements for personnel performing visual program implementation by permitting examinations and personnel performing containment examinations to be qualified to written practices that are more consistent to those used for other NDE personnel.
b) provb minimum qualification requirements b) Providing these details in the qualification i
that were previously contained in the acceptance requirements paragraph focuses the criteria ofIWE 3510.1.
containment visual qualification on areas important to containment integrity.
2400 no change n/a 2410 no change n/a 2411 no change n/a 2412 Deleted a subparagraph discussing decreasing The deleted subparagraph climinates and extending inspection periods. Added a duplication with IWA-2400. The added subparagraph detailing requirements for the requirements for the scheduling of added scheduling of added welds or components, welds or components ensures that a representative sampling of examinations is maintained.
2420 Removed repaired areas as areas requiring Repaired areas that are likely to experience reexaminations during the next successive accelerated degradation and aging are already inspection period.
subject to augmented examinations per IWE-1241. Some repairs may be located in non augmented areas and may be necessary to correct physical damage caused by construction or craft activities. Not having to repeat examinations of these non augmented repaired areas provides for more efficient program implementation without adversely affecting component integrity.
2430 Deleted the paragraph - Additional Examinations The changes to Table IWE 2500-1 climinate
- 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.
_-_____ to CPSES Unit 2 Relief Request E 1 Page 5 of 13 Para.
Changes between IWE Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWE rewrite use as an alternative examination 2500 Reworded the existing subparagraphs consistant The reworded subparagraphs add clarity and with the previouse paragraph changes and with provide consistancy within IWE.
Table IWE 25001 changes.
Deleted the requirement to examine paint or Not having to perform ASME examinations coatings prior to removal, of non pressure retaining coatings prior to removal provides for more efficient containment ISI program implementation without adversely affecting the integrity of the pressure retaining base metal being exposed.
Replaced the requirement for one foot square The new Table IWE 2500 2 provides more grids in thickness measurements with a reference detailed requirements for thickness to Table IWE 2500 2.
measurement gridding and is discussed l
below.
1 Added a reference to IWE 5000 for pressare The added reference to IWE-5000 pro vides
- tests, direction for the performance of pressure test.
2600 Deleted a sentence discussing compatibility of The removal of this sentence addressing paint and coating systems and a requirement to "new" non pressure retaining paint and examine the new paint.
coatings provides for more eflicient containment ISI program implementation without adversely affecting component integrity.
3100 Removed the word nondestructive from the non significant heading.
3110 no change n/a 3111 Replaced the reference to Table T 'E-34101 with Table IWE-3410-1 and paragraph IWE-3115 a reference to subarticle IWE 35
- 8. Removed have been deleted and are discussed below, reterence to paragraph IWE-3115.
lWE-3500 adequately captures all of the information previously contained in the deleted table and paragraph.
3112 Replaced the reference to Table IWE 3410-1 with non significant a reference to subarticle IWE-3500. ASME XI generic change from repair and or replacement to
, repair / replacement activities.
.. to CPSES Unit 2 Relief Request E-l Page 6 of 13 Pr.ra.
Changes between IWE Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWE rewrite use as an alternative examination 3114 Replaced the reference to Table IWE 3410-1 with non significant a reference to subarticle IWB 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 by authorities.
deletion of the subparagraph.
3120 Remosed the word nondestructive from the non significant heading.
3121 Removed the word nondestructive and deleted The removal of nondestructive is non references to IWE-3124 and IWE 3125 for the significant. The referenced subparagraphs did acceptance of flaws for continued service, not actually apply to the acceptance ofliaws for continued service.
3122 Replaced the references to Table IWE 25001 non significant the changes are for clarity and to IWE 3000 with a reference to subarticle and to reconcile paragraph numbering. There IWE 3500. ASME XI generic change from were no submittal 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 bewg subject to review by authorities.
3124 Replaced the reference to Table IWE 3410-1 with non significant a reference to subarticle IWE 3500. ASME XI generie change from repair and or replacement to repair / replacement activities.
3125 Deleted subparagraph which addressed repair non significant there were no submittal or programs and reexamination results being subject retention requirements changed by the to review by authorities.
deletion of the subparagraph.
3130 no change n/a 3200 Added a statement to the end of the paragraph The added statement clarifies requirements that states supplemental surface or volumetric and climinates potential 6uplication or examinations are required when specified by the contradiction of requirements in stating that 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 with non significant a reference to subarticle IWE 3500.
3430 no change n/a
i to CPSES Unit 2 Relief Request E-1 Page 7 of 13 i
1 Para.
Changes between IWE Significance of change and or basis for j
graph 1992 Ed. '92 Ad. nad the current IWE rewrite use as an alternative examination 3500 no change n/a 3510 Reconciled acceptance standards with the Previously examination requirements were IWE 2300 changes discussed above and the contained in the acceptance standards of Table IWE 25001 changes discussed below by:
IWE 3500. This has been corrected by the Adding the requirement that the owner shall addition oflWE 2300 as discussed above a) define acceptance criteria for visual examination This change directly corresponds to the of containment surfaces; addition oflWE-2310(a) discussed above.
2 Removing the wording for responsible individual -
This change directly corresponds to the i
and for personnel qualifications; addition ofIWE 2320 discussed above.
Combining 3510.2 and 3510.3 and removing These changes directly correspond to the i
specific VT 1 and VT-3 examination attribute addition ofIWE 2310(e)(1) and (2) discussed l
wording; and above.
Incorporating IWE-3511:3513,3514 and 3515 These changes correspond to the changes in with changes into IWE-3510.
the exaniination categories of Table IWE-2500-1 as discussed below and to fhe removal j
of examination requirements from the j
acceptance standards paragraphs per the addition ofIWE-2310(c)(3) and (4) as discussed above.
i By the incorporation of 3515 the acceptance The resulting acceptance standards for botting standards for bolting were changed from provide for more practical containment ISI i
referencing unterial specs and torque or tension program implementation without adversely limits to conditions affecting leak tight or affecting containment leak tight or structural l
structural integrity.
integrity, j
3511 Deleted subparagraph which addressed Examination category E B has been examination category E-B.
incorporated into examination category E-A per the changes to Table IWE-2500-1 discussed below.
l 4
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__.______ __.____ to CPSES Unit 2 Relief Request E 1 Page 8 of 13 Para.
Changes between IWE Significance of change and or basis for graph 1992 Ed. 692 Ad. and the current IWE rewrite use as an alternative examination
~
3512 Renumbered subparagraph to IWE 3511.
The subparagraph was renumbered based on Reconciled acceptance standards with the the deletion of previous IWE 3511 as IWE 2300 changes discussed above and the discussed above. Previously examination Table IWE-25001 changes discussed below requirements were contained in the acceptance standards ofIWE-3500. This has been corrected by the addition ofIWE 2300 as discussed above.
Added the requirement that the owner shall This change directly corresponds to the define acceptance criteria for visual examination addition ofIWE 2310(a) discussed above.
of containment surfaces; Combined 3512.2 and 3512.3 with changes into These changes directly correspond to the 3511.2 and removed specific VT 1 examination addition ofIWE 2310(c)(1) and (2) discussed attribute wording; and above and climinate potential duplication or contradiction of requirements.
Reworded ultrasonic examination subparagraph.
This change is for clarity and is non-significant.
3513 Deleted subparagraphs IWE-3513,3514 and Examination categories E D, E F and E G 3514 3515 which addressed examination categories have been incorporated into examination i
3515 E D, E F, and E-G respectively, category E-A per the changes to Table IWE-2500-1 discussed below.
4100 no change n/a 5200 no change n/a 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 replacement to repair / replacement activities.
reqairements 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.
5222 ASME XI generic change from repair and or non significant replacement to repair / replacement activities.
~
i 4 to CPSES Unit 2 Relief Request E 1 Pagc 9 0f l3 l
Para.
Changes between IWE Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWE rewrite use as au alternative examination 5240 Replaced a reference to IWA $240 with The addition of t.[ceific IWE examination requirements to perform detailed visual requirements during pressure testing in lieu of i
examination of repair / replacement areas during referencing IWA general requirements pressure tests, focusses requirements on issues specific to containtnent integrity and thercror provides 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 repali/ replacement activities.
7100 no change n/a Table no change n/a 2411-1 Table Replaced the separate entries for ist and non significant The previous requirements 2412 1 successive intervals with one entry for All for the 1st and successive intervals were intervals.
identical. Therefor combining the entries does not affect any requirements.
i w
w w -wgy-m-w-g
--myyw+,,.-wwww----um-y w-----r-.,,3y.i r
-.-m srry
-ww----w-yy--cy v
v pw--gg-wg-mpw
--y----ew-,--,.=c-w r.-i
. _ _ _. to CPSES Unit 2 Rehef Request E 1 Page 10 of13 Para.
Changes between IWE Significance of change and or basis for graph 1992 Ed. *92 Ad. and the current IWE rewrite use as an alternative examination Table 1
25001 Revised all examination categories.
EA El.ll Revised frequency of examination from Removing the requirement to coordinate
" prior to each type A test" to "100% during each examinations with type A tests allows for period".
more efficient containment ISI program implementt. tion without adversely affecting containment inty rity.
Bl.12 Redesignated item from " accessible Replacing the accessible surface area surface areas" to " wetted surfaces of submerged designation (which is included in El.11) with l
areas". Replaced examination method VT-3 with wetted surface areas (which were previously l
general visual.
included in El.12 footnote 4) does not climinate or reduce any required examination areas. Requiring a general VT in lieu of a VT 3 eliminates the more detailed VT of areas with satisfactory general VT results.
The perfonnance of the VT general will identify any areas of deterioration or distress.
Any areas identified will then be subject to a VT detailed examination to detennine the magnitude and extent of those conditions.
The VT general therefore allows for more efficient containment ISI program implementation without adversely alTecting containment integrity.
El.20 Added BWR to item description.
This item is not applicable to CPSES Replaced examination method VT-3 with general containments.
visual.
El30 Added item for moisture barriers with a Moisture barriers were previously included in generd VT required each period.
examination category E D with a VT-3 required each interval. Examining moisture barriers more frequently will assure reliable detection of conditions adverse to containment integrity.
. _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _. to CPSES Unit 2 Relief Request E-l Page11of13 4
Para.
Changes between IWE Significance of change and or basis for graph 1992 Ed. 92 Ad. and the current IWE rewrite use as an alternative examination All item no.'s - Replaced reference to IWE-3510 non significant - Previously some
{
for examination requirements with IWE-2310.
examination requirements were contained in j
IWE-3500. They now exist in IWE-2300 as l
discussed above, l
Notes - Revised to specifically include welds and Welds and bolting were previously included bolting as part of the pressure retaining boundary in examination categories E-B, E-F and E-G.
requiring examination.
Including these items in the examination l
category for the containment pressure retaining boundary provides for more efficient program implementation without adversely affecting component integrity.
Table E B Deleted examination category which Pressure retaining welds are now inciuded in 2500-1 addressed pressure retaining welds, examination category E-A as addressed above.
to CPSES Unit 2 Relief Request E-1 Page 11 of 13 Para.
Changa between IWE Significance ct change and or basis for graph 1992 Ed. '92 Ad. and the current IWE rewrite use as an alternative examination E-C E4.11 Repir.ced examination method VT-1 with Referring to the visual examination by the VT detailed visual.
detailed term does not adversely affect the integrity of the containment components examined.
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 i
acceptance standard references.
requirements have been added to IWE 2300 and 2500 as discussed above. Adding new references and updating paragraph numbers ensure proper requirements are applied to examinations.
Notes - Changed note 2 from requiring Three inspection periods cover a ten year augmented examination until an area remains interval. Perfomling augmented unchanged for three consecutive inspection examinations for at least two periods while periods to the next inspection period. Deleted continuing general visual examinations each note 3 which discussed inspection deferrals.
period provides for more efficient program implementation without adversely affecting component integrity. Deletion ofnote 3 is non significant.
E-D Deleted examination category which Moisture barriers have been included in addressed seals, gaskets and moistore barriers.
examination category E-A as addressed above. Seals and gaskets previoudy required examination once per an interval with-effectively an acceptance criteria ofleak tightness. Leak tight integrity is verified during each 10CFR50 App. J leak test.
Removing these inspection items provides for i
more efficient program implementation without adversely affecting component integrity.
E F Deleted examination ce which Dissimilar metal welds are now included in addressed dissimilar metal w examination category E-A as addressed 4
above.
u
... to CPSES Unit 2 Relief Request E 1 Page 13 of 13 Para-Changes between IWE Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWE rewrite use as an alternative examination E-G Deleted examina.un category which Pressure retaining bolting is now included in addressed pressure retaining bolting.
examination category E-A as addressed above.
E P Deleted examinc. tion category which App J testing is mandated by plant technical addressed 10CFR50 App J testing for all pressure specifications. Removing this duplicate retaining components.
requirement from IWE does not adversely affect component integrity.
Added new Tsble 2500 2 - Ultrasonic Thickness The new requirements provide for 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.
Tabie Deleted table.
non significant - the contents of the previous 3410-1 table are adequately addressed in IWE-3500.
to TXX-98041 Page 1 of 2 CPSES UN:T 2 RELIEF REQUEST l
L-1 l
A. Item (s) for which reliefis requested:
Concrete containment components.
B. Item (s) Code Class:
CC C. Examination requirements from which reliefis requested:
1992 Edition with the 1992 Addenda of Subsection IWL," Requirements for Class CC Concrete Components of Light-Water Cooled Power Plantr", of Section XI, Division 1, of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code).
D. Basis foi relief:
The 1992 Edition with the 1992 Addenda of Subsection IWL contains requirements which impose difficulties in the transition from the current ISI 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 detailed below. These alternative examinations provide for consistency with the existing programs in the definition of visual examination methods and in the qualification of visual examination personnel as well as providing more practical requirements for the performance and scheduling of examinations.
Some specific hardships imposed by the 1992 Edition, '92 Addenda ofIWL that are not compensated for by an increased level of plant quality and safety are as follows:
IWA-2300 requires the use of a written practice prepared in accordance with ANSI /ASNT CP-189 for the qualification and certification of containme it nondestructive examination personnel. All other CPSES NDE and ISI activities, including those performed on the reactor vessel, are p" formed by personnel qualified and certified to written practices prepared in accordance vith SNT-TC-I A as required by ASME XI 1986 Edition, No Addenda, the Code of record for ISI at CPSES. Utilizing the '92 Addenda ofIWL would require the development of a separate written piactice and the issuance and tracking of separate certifications for both TU Electric and contractors. Administration of the rentting duplicate programs could result in documentation inconsistencies and would be an impact to
. to TXX-98041 Page 2 of 2 resources.
IWL-2310 and IWA-2210 require specific minimum illumination and maximum direct examination distances for concrete containment examinations. These requirements preclude the performance of remote examination. Performance of the more stringent IWA 2210 direct examinations are not practical for much of the CPSES containment surface area, would be an impact to resources and would introduce a significant risk to personnel safety.
The proposed attemative is to utilize the current ASME approved rewrite of Subsection IWL of ASME Section XI in its entirety. Utilizing the entire IWL rewrite provides more cohesiveness than could be achieved by requesting relief on several individual subjects separately. The attemate examination requirements match the rewrite exactly and are included as Enclosure i of this relief request. These requirements were developed in accordance with the ASME Code committee process with input from interested parties which included TU Electric, other utilities, manufacturers, engineering organizations, Authorized Inspection A encies, EPRI and the NRC. The updating of requirements by this industry b
consensus process is intended to ensure the continued safe operation of nuclear power plants and specifically in this case the continued leak-tight and structural integrity of concrete containment components. Therefore, the overall level of plant quality and safety would not be adversely affected by utilizing the requirements of the current ASME approved IWL rewrite. A detailed evaluation and line by line comparison of the differences between the 1992 Edition with the 1992 Addenda of Subsection IWL and the current ASME approved rewrite is included as Enclosure 2 of this relief request.
l CPSES Unit 2 is currently in the second period of the first ten year ISI interval. Based on l
current plant refueling outage schedules and the requirement of the new rulemaking for full implementation by September 9,2001, a containment ISI examination program must be established immediately. Implementing this relief request now would reduce the overall impact to resources (both TU Electric's and the NRC's) versus incorporating the mandated edition and addenda ofIWL in conjunction with this initial establishment of a containment ISI program and then updating again to a later edition and or addenda or to a series of Code Cases upon formal NRC endorsement or on the next ten year ISI plan issuance.
E. Altemate Examinations:
See Enclosure 1 of this relief request for the requirements of the current ASME approved rewrite of Subsection IWL which defines the alternate examinations of this relief request.
F. Anticipated impact on the overall level of plant quality and safety:
None.
n
Enclosure I to CPSES Unit 2 Relief Request L-1 Page1of12 ARTICII -1000 SCOPE AND RESPONSlHil.lTY
-1100 SCOPE (a) This subsection provides requirements for preservice examination, inservice inspection, and repair / replacement activities of the reinforced concrete and the post tensioning systems of Class CC components, herein referred to as concrete containments as defined by CC 1000.
(b) He rules and requirements of thic Subsection do not apply to the following:
(/) steel portions not backed by concrete; (2) shcIl metallic liners; (3) penetration liners extending the containment liner through the surrounding shell concrete.
1100 ITEMS SUHJECT TO EXAMINATION 1210 EXAMINATION REQLilREMENTS ne cxamination requirements of this subsection shall a" ply to concrete containments.
-1220 ITEMS EXEMPT FROM EXAMINATION The following items are exempt from the examination requirements of 2000:
(a) - tendon and anchorages that are inaccessible, subject to the requ;rements of-2521.1; (b) portions of the concrete surface that are covered by the liner, foundation material, or backfill, or are otherwise obstructed by Odjacent structures, components, parts, or appurtenances.
ARTICI.E 2000 EXAMINATION AND INSPECTION
-3160 GENERAL (a) The requirements ofIWA 2000 apply, except the requirements of IWA-2210 and IWA 2300 are not applicable to visual examinations and qualification of visual examination personnel for concrete containments.
(b) Examinations shall be verified by an Authorized Nuclear Inservice Inspector in accordance with IWA-2120 and ASME N626. Authorized Nuclear Inservice inspectors for concrete shall also meet the requirements of ASME N626.2.
-2200 PRESERVICE EXAMINATION Preservice examination shall be performed in accordance with the following requirements.
2210 EXAMINATION SCilEDUI E Preservice examination shall be completed prior to initial plant startup.
-3220 EXAMINATION REQUIREMENTS 2220.1 Concrete (a) Preservice examination shall be performed in accordance with -2510.
(b) He preservice examination shall be performed following completion of the containment Structural Integrity Test.
2220.2 Unbonded Post Tensioning Systems. The following information shall be documented n the preservice examination records. This information may be extracted from construction records.
(a) Date on which each tendon was tensioned.
(b) Initial seating force in each tendon.
(c) For each tendon anchorage, the location of all missing or broken wires or stands and unseated wires.
Enciosure I to CPSES Unii 2 Relief Request L-1 Page 2 of12 (d) for each tendon anchorage, the location of all missing or detached buttonhesds or missing wedges.
(e) De product designation for the corrosion protection medium used to fill the tendon duct.
2230 PRESERVICE EXAMINATION OF REPAIR / REPLACEMENT ACTIVITIES (a) When a concrete containment or a portion thereofis corrected or modified by repair / replacement activities during the service lifetime of a plant, the preservice exammation requirements shall be met for the repair / replacement activity.
(b) When the repair / replacement activity is performed while the plant is not in service, the preservice examination shall be performed prior to resumption of service.
(c) When thc repair /replac. ment activity is performed while the plant is in service, the preservice examination may be deferred to the next scheduled outage.
-2300 VISUAL EXAMINATION, PERSONNEL QUALIFICATION, ANls RESPONSlHLE ENGINEER
-2310 VISUAL EXAMINATION AND PERSONNEL QUALIFICATION (a) General visual examinatio ts of concrete surfaces shall be performed to assess the general structural condition of containments. The general visual examination shall be performed in st#.cient detail to identify areas of concrete deterioration and distress, such as defined in ACI 201.1.
(b) Detailed visual examinations shall be performed:
(1) to detumine the magnitude and extent of deterioration and distress of suspect concrete surfaces initially detected by general visual examinations.
(2) to determine the condition and any deterioration of concrete surfaces at tendon anchorage areas.
(3) to determine the condition (e.g., cracks, wear, or corrosion) of tendon wires or strands, and anchorage hardware, as described in -2524.1.
l (4) to determine the condition of concrete surfaces affected t.y repair / replacement activities, in accordance with -5250.
I (c) Visual examinations shall be performed either directly or remctely, with adequate illumination, by personnel with visuai ccuity sufficient to detect evidence of degradation.
(d) The Owner shall define qualification requirements for personnel performing examinations of concrete and tendon anchorage hardware, wires or strands.
(e) The Owner shall define requirements for visual examination of tendon anchorage hardware, wires or strands.
2320 RESPONSlHLE ENGINEER The Responsible Engineer shall be a Registered Professional Engineer experienced in evaluating the condition of structural concrete. The Responsible Engineer shall have leawledge of the design and Construction Codes and other criteria used in design and construction of concrete containments in nuclear power plants.
The Responsible Engineer shall be responsible for the following:
(a) development r f plans and procedures for examination of concrete surfaces; (b) approval, inuruction, and training of concrete examination personnel; (c) evaluation of examination results; (d) preparation or review of Repair / Replacement Plans and procedures; (c) review of pressure test procedures for pressure tests following repair / replacement activities; (f) submittal of report to the Owner documenthig results of examinations, repair / replacement activities, and pressure tests.
-2400 INSERVICE INSPECTION LCilEDULE
-2410 CONCRETE (a) Concrete shall be examined in accordance with 2510 at 1,3, and 5 years following the completion of the containment StructuralIntegrity Test CC-6000 and every 5 years thereafter.
(h) The 1,3 and 5 year examinations shall commence not more than 6 months prie r to :he specifed dates and shall be completed not more than 6 months after such dates If plant oper.ing conditions are such that examination of portions of the concrete cannot be completed within this stated time interval, esaminati. a of those portions may be deferred until the next regularly schedule plant outage.
(c) The 10 year and subsequent examinations shall commence not more than 1 year prior to the specified dates and shall be
.. to CPSES Unit 2 Relief Request L-1 Page 3 of 12 completed not more than 1 year after such dates. If plant operating conditione are such that examinatior, of portions of the concretc cannot be completed within this stated time interval, examination of those portions may be d(ferred until the next regularly scheduled plant outage.
2420 UNHONI)ED POST-TENSIONING SYSTEMS (a) Unbonded post tcusionir.g systems shall be examined in a:cordance with -2520 at 1,3, and 5 years following the completion of the containment Structural Integrity Test and every 5 year, thereafter.
(b) The 1,3 and 5 year examinations shall commence not more than 6 months prior to the specified dates and shall be completed not more than 6 months after such dates. If plant operating conditions are such that examination of portions of the post-tenri~ ing system cannot be completed within this stated time interval, exan : nation of those portions may be deferred until the ne.<t regularly scheduled plant outage.
(c) The 10 year and subsequent examinations shall commence not more than 1 year prior to the specified dates and shall be completed not raore than 1 year aller such dates.
-2421 Sites With Multiple Plants (a) For sites with multiple plants, the examination rc 'uirements for the concrete containments may be modified if the containments utilize the same prestressing system and are essentially identical in design, if post-tensioning operations for each subsequent containment constructed at the site were completed not more than 2 years apart, and if the containments are similarly exposed to or protected from the outside environment.
(h) When the conditi3ns of 2421(a) are met, the inspection dates and examination requirements may be as follows:
(/) For the containment with the first Structural Integrity Test, all examinations required by -2500 shall be performed at 1, 3, and 10 years and every 10 years thereafter. Only the examinations required by -2524 and
-2525 need be performed at 5 and 15 years and every 10 years thereafter.
(.?) For each subsequent containment constructed at the site, all examinations required by -2590 shall be performed at 1,5 and 15 years and every 10 years therealler. Only the examinations required by 2524 and 2525 need be performed at 3 and 10 years and every 10 years there ier.
i
Enclosure I to CPSES Unit 2 Relief Request L-1 Page 4 of12
-2500 EXAMINATION REQUIREMENTS Examinat'on shall be performed in accordance with the requirements of Table 2500-1,
-2510 SURFACE EXAMINATION (a) Concrete surface 4.nas, including coated areas, except those exempted by -1220(b), shall be visually examined in occordance with 2310(a) for evidence of conditions indicative of damage or degradation, such as denned in ACI 201.1. Selected arecs, such as those that indicate suspect conditions, shall be visually examined in accordance with -2310(b).
(b) Tendon anchorage areas, including coated areas, except those exempted by -1220(a), shall be visually examined in cccordance with 2310(b) for evidence of conditions indicative of damage or degradation. Selected areas, such as those that indicate suspect conditions, shall be subject to additional examinations, if specified by the Responsible Engineer.
(c) For containments with unbonded post.teraioning systems, the concrete surfaces and tendon end anchorages shall be examined for corrosion protection medium leakage, and the tendon end caps shall be examined for deformation.
(d) The examination shall be perfomied by, er under the direction of the Responsible Engineer.
(c) Visual examinations may be performed from floors, roofs, platforms, walkways, ladders, ground surface, or other vantage points, unless temporary close in access is required by the inspection plan.
-2530 EXAMINATION OF UNBONDED POST TENSIONING SYSTEMS 252i Tendon Selection (a) Tendons to be examined during an inspection shall be relected on a random basis except as noted in 2521(b) and (c). The population from which the random sample is drawn shall consist of all tendons of a particu:ar type (as denned in Table -2521-1) which have not been examined during earlier inspections. The number of tendons to be examincd during an inspection shall be as specified in Table 2521-1.
(b) One tendon of each type (as denned in Table -2521-1) shall be selected from the first year inspection sample and designated as a common tendon. Each common tendon shall be examined during each inspection. A common tendon shall not be detensioned unless required by 3300. If a common tendon is detensioned, another common tendon of the same type shall be selected from the first year inspection sample.
(c) If a containment with a stranded post-tensioning system is constructed with a predesignated number of detensionable tendons, one tendon of each type shall be selected from among those which are detensionable. The remaining tendons shall be selected from among those which cannot be detensioned.
2521.1 Exemptions. Jrhe following requirements shall apply to tendon anchorages that are not accessible for examination because of safety or radictogical hazards or because of structural obstructions.
(a) 'Afler the process of randomly selecting tendons to be exammed, any inaccessible tendons shall be aesignated as exempt and removed from the sample.
(b) Substitute tendons shall be selected for all tendons designated as exempt. Each substitute tendon shall be selected so that it is located as close as possible to the exempted tendon, and shall be examined in accordance with 2520.
(c) Each exempted tendon shall be examined in accordance with -2524 and.2525 to the extent that the end anchorages of the
~
exempt tendon are accessible either during operation or at an outage.
p 4
W
Enclosure I to CPSES Unit 2 Relief Request L-1 Page 5 of12 TABLE 1%L2500-1 EXAN11 NATION CATEGORIES r
EXAMINATION CATEGORY L-A, CONCRETE Item No.
Parts Examined Test or Examination Test or Exanunation Acceptance Extent of Frequency of Deferra! of Requirement Method Standard Exammation Eumination Exammanon L1.10 Concrete Surface Ll.11 All Accessible Surface IWL-2510 General Visual IWL-3210 Iwb2510 I%L2410 NA Areas Lt.12 Suspect Areas IWL-2510 General Visual I%L3210 IWL-2510 I% 1-2410 NA EXAMINATION CATEGORY L-B, UNBONDED POST-TENSIONING SYSTENI Item No.
Parts Exammed Test or Examination Test or Eummation Acceptance Extent of Frequency of Deferral of Requirement Method Standard Eummaton Eummation Eumination L2.10 Tendon IWL-2522 1%L2522 I% L3221.1 IH L2521 IWL-2420 NA L2.20 Wire or Strand I%L2523 IWL-2523.2 IWL-3221.2 Iwb2523.1 IWL-2420 NA L2.30 Anchorage liardware and IWL-2524 Detailed Visual IWL-3221.3 IWL-2524.1 IWL-2420 NA Surrounding Concrete L2.40 Corosion Protection IWL-2525 IWL-2525.2(a)
Iwb3221.4 IWL-2525.l(a)
IWL-2420 NA Medium L2.50 Free Water IWL-2525 IWL-2525.2(b)
I%1-2525.l(b)
IWL-24'O NA P
Enclosure I to CPSES Unit 2 Relief Request L-1 Page 6 of12 TABLE IWL-2521 1 NUMBER OF TENDONS FOR EXAMINATION Inspection Period Percentage'2 Required Maximum of all Tendons Minimum
- Required of Each Type' Number of Number of Each Type Each Type 1st Year 4
4 10 3rd Year 4
4 10 5th Year 4
4 to 10st Year 2
3 5
NOTES:
(1) Fractional tendon numbers shall be rounded to the next higher integer. Actual Number examnied shall not be less than the minimum required number and need not be more than the maximum required number.
(2) The reduced sample size listed for the 10th year and subsequent inspections is applicable only if the acceptance criteria of IWL-3221.1 have been met for the last 3 inspections.
(3) A tendon type is defined by its geomety and position in the containment; e.g., hoop vertical, dome, helical, and inverted U.
(4) The number and percentage of tendons to be examined every 5th year thereaAer shall remain the same..
-2522 Tendon Force and Elongation Measurements (a) The prestressing force in all inspection sample tendons shall be measured by lift-off or an equivalent test.
(b) Equipment used to measure tendon force shall be calibrated in accordance with a calibration procedure prior to the fir t tendon force measurement and following the final tendon force measurement of the inspection period. Accuracy of the calibration shall be within 1.5% of the specified mimmum ultimate strength of the tendon, if the post test calibretion differs from the pretest calibration by more than the specified accuracy tolerance, the results of the examination shall be evaluated.
(c) During retensioning of a tendon, the tendon clongation shall be measured j
.-2523 Tendon Wire and Strand Sample Examination and Testing
)
-2523.1 Tendon Detensioning and Sample Removal. One sample tendon of each type shall be completely detensioned. A single wire or strand shall be removed from each detensioned tendon.
-2523.2 Sample Examination and Testing (a) Each removed wire or strand shall be examined over its entine length for corrosion and mechanical damage. The examination shall determine the location of most severe corrosion; if any Strand wire shall be examined for wedge slippage marks.
to CPSES Unit 2 Relief Request L-1 Page 7 of12 (b) Tension tests shall be performed on each removed wire or strand: one at each end, one at midlength, and one in the location of the most corroded area, if any, The following information shall be obtained from each test:
(1) yield strength (2) ultimate tensile strength (3) elongation 2523.3 Retensioning. Tendons that have been detensioned shall be retensioned to at least the force predicted for the tendon at the time of the test, flowever, the retensioning force shall not exceed 70% of the specified minimum ultimate tensile strength of the tendon based on the number of effective wires or strands in the tendon at the time of retensioning.
-2524 Esamination of Tendon Anchorage Areas 2524.1 Visual Examination. A detailed visual examination in accordance with 2310(b) thall be performed on the tendon anchorage hardware, including bearing plates, anchorheads, wedges, buttonheads, shims, and the concrete extending outward a distance of 2 feet from the edge of the bearing plate. The following shall be documented:
(a) concrete ciacks having widths greater than 0.01 in.;
(b) corrosion, broken or protruding wires, missing buttonheads, broken strands, and cracks in tendon anchorage hare ware; (c) broken wires or strands, protruding wires and detached buttonheads following retensioning of tendons which have been detensioned.
2524.2 Free Water Documentation. The quantity of free water contained in the anchorage end cap as well as any which drains I
fmm the tendnn during the examination process shall be documented.
\\
l
-2525 Examination of Corrosion Protection Medium and Free Water i
-2525.1 Samples
'(a) Samples of the corrosion protection medium shall be taken from each end of each tendon examin W. Free w ater shall not be included in the samples.
(b) Samples of free water shall be taken where water is present in quantities sufficient for laboratory analysis.
I f
Enclosure I to CPSES Unit 2 Relief Request L-1 Page 8 of 12 TABli 2525-1 CORROSION PRLfECTION MEDIUM ANALYSIS Characteristic Test Method Acceptance Limit Water content ASTM D 95 10 percent maximum I
Water soluble chlorides ASTM D 512 l Note (1)] or 10 ppm maximum ASTM D 4327 [ Note (1)l Water Soluble nitrates ASTM D 992 l Note (1)] or 10 ppm maximum ASTM D 3867 l Note (1)] or D 4327 l Note (1)]
Water soluble sulfides APIIA 427 l Note (1)l or 10 ppm maximum i
APilA 4500-S l Note (1)]
Reserve alkalinity ASTM D 974 l Note (3)]
(Base number)
M9dified l Note (2)l NOTES:
(1) Water Soluble /on Tests: The inside (bottom and sides) of a one (1) liter breaker, approx. OD 105 mm, height 145 mm, is thoroughly coated with 100 10 grams of the sample. The coated breaker is filled with approximately 900 ml of distilled water and heated in an oven at a controlled temperature of 100*F (37.8'C)12*F for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The water extraction is tested by the j
noted test procedures for the appropriate water soluble ions. Resul's are reported as PPM in the extracted water.
l (2) ASTAI 974 Afodifed. Place 10 g of sample in a 500 ml Erlenmeyer flask. Add 10 cc isopropyl alcohol and 5 cc toluene. IIcat l
until sample goes into solution. Add 90 cc distilled water and 20 cc INil,SO. Place solution on a steam bath for 1/2 hour. Stir 4
well. Add a few drops ofindicator (1% phenolphthalein) and titrate with 1NNaOll until the lower layerju::t :ums pink, if acid or base solutions are not exactly IN, the exact normalities.hould be used when calculating 'he base number '...e Total Base Number (TBN), expressed as milligrams of KOII per gram of sample, is calculated as follows:
[(20)(N )-(B)(Na)] 56.1 3
i TBN =
W where B = milliliters NaOli Na = normality of11 S0, solution 2
N, = normality of NaOli solution W = v ight of sample in grams (3) The bec number shall be at least 50% of die as-installed value, unless the as-installed value is 5 or less, in which case the base number shall be no less than zero. If the tendon duct is filled with a mixture of materials having various as-installed base numbers, the lowr.,t number shall govem acceptance.
-2525.2 Sample Analysis (a) Each corrosion protection medium sample-shall be thoroughly mixed and analyzed for reserve alkalinity, water coment, and concentrations of water soluble chlorides, nitrates, and sulfides. Analyses shall be performed in accordance with the procedures specified in Table -2525-1.
(b) Free water samples shall be analyzed to determine pil.
t
__ to CPSES Unit 2 Relief Request L-1 Page 9 of 12
-2526 Removal and Replacement of Corrosion Protection Medium (a) The amount of corrosion protection medium removed at each anchorage shall be measured and the total amount removed from each tendon (two anchorages) shall be recorded. The total amount replaced in each tendon shall be recorded and differences between amount removed and amount replaced shall be documented.
(b) Corrosion protection medium may be replaced using a pressurized system or cold pack, b, pouring, or by nonpressurized pumping on each end. The Responsible Engineer shall specify the maximum pressure to be used in a pressurized system.
ARTICLE -3000 ACCEPTANCE STANDARDS
-3100 PRESERVICE EXAMINATION
-3110 CONCRETE SURFACE CONDITION
-3111 Acceptance by Examination The condition of the surface is acceptable if the Responsible Engineer determines that there is no evidence of damage or degradation sufncient to warrant further evaluation or performance of repair / replacement activities.
-3112 Acceptance by Evaluation Items with examination results that do not meet the acceptance standards of-311I shall be evaluated as required by -3300.
-3113 Acceptance by Repair / Replacement Activity Repair / replacement activities required to reestablish acceptability of an item shall be completed as required by -3300.
Acceptable completion of the repair / replacement activity shall constitute acceptability of the item.
-3120 UNHONDED POST-TENSIONING SYSTEM The condition of the unbonded post-tensioning system is acceptable ifit met the requirements of the construction specincation at the time ofinstallation.
-3200 INSERVICE EXAMINATION
-3210 SURFACE CONDITION
-3211 Acceptance by Examination The condition of the concrete surface and tendon end anchorage areas is acceptable if the Responsible Engineer determines that there is no evidence of damage or degradation, corrosion protection medium leaka;e, or end-cap deformation sufncient to warrant further evaluation or performance of repair / replacement activities.
3212 Acceptance by Evaluation Items with examination resula that do not meet the acceptance standards of -3211 shall be evaluated as required by 3300.
-3213 Acceptance by Repair / Replacement Activity Repair / replacement activities to reestablish the acceptability of an item shall be completed as required by 3300. Acceptable completion of the repair / replacement activity shall constitute acceptability of the item.
-3220 UNHONDED POST-TENSIONING SYSTEMS
-3221 Acceptance by Examination
_ to CPSES Unit 2 Relief Request L-1 Page 10 of12
-3221.1 Tendon Force and Elongation. Tendon forces and elongation are acceptable if:
(a) the average of all measured tendon forces, including those measured in 3221.1(b)(2), for each type of trndon is equal to or greater than tbc minimum required prestress specified at the anchorage for that type of tendon; (b) the measured fo ce in each individual tendon is not less than 95% of the predicted force unless the following conditions are satisfied:
(/) the measured force in not more than one tendon is between 90% and 95% of the predicted force; (1) the measured forces in two tendons located adjacent to the tendon in 3221.l(b)(1) are not less than 95% of the predicted forces; and
-(J) the measured forces in all the remaining sample tendons are not less than 95% of the predicted force.
(c) the prestressing forces for each type of tendon measured in -3221.l(a) and (b), and the measurement from the previous examination, indicate a prestress loss such that predicted tendon farces meet the minimum design prestress forces at the next scheduled examination.
(d) the measured tendon clocgion varks from the last measurement, adjusted for effectise wires or strands, by less than 10%.
3221.2 Tendon Wire or Strand Samples. The condition of wire or strand sampics is acceptable if:
(a) samples are free of physical damage; (b) sample ultimate tensile strength and elongation are not less than minimum specified values.
-3221.3 Tendon Anchorage Areas. The condition of tendon anchorage areas is acceptable if:
(a) there is no evidence of cracking in ane' or heads, shirns, or bearing plates; (b) there is no evidence of active Carrosion; (c) broken or unscated wires, broken strands, and detached buttonheads were documented and accepted durmg a preservice examination or durmg a previous inservice examination; (d) cracks in the concrete adjacent ot the bearing plates do not exceed 0.01 in. in width; (c) there is no evidence of free water.
3221.4 Corrosion Protection Medium. Corrosion pmtection medi.m is acceptable when the reserve alkalinity, water content, and soluble ion concentrations of all samples are within the limits specified in Table
-2525-1. The absolute ditTerence between the amount removed and the amount replaced shall not exceed 10%
of the tendon net duct volume.
-3222 Acceptance by Evaluation items with examinatiun results that do not meet the acceptance standards of -3221 shall be evaluated as required by 3300.
-3223 Acceptance by Repair / Replacement Activity Repair / replacement activities to reestablish acceptability of ne condition of an item shall be completed as required by -3300.
Acceptable completion of the repair / replacement activity shall constitute acceptability of the item.
-3300 EVALUATION
-3310 EVALUATION REPORT ltems with examination results that do not meet the acceptance standards of -3100 or -3200 shall be evaluated by the Owner.
The Owner shall be responsible for preparation of an Engineering Evaluation Report stating the following:
(a) the cause of the condition which does not meet the acceptance staadards; (b) the applicability of the condition to any other plants at the same site:
(c) the acceptability of the concrete cc,tainment without rspair of the item; (d) whether or not repair / replacement activity is required and, if required, the extent, method, and completion date for the repair / replacement activity; (c) extent, nature, and frequency of additional examinations.
Enclosure I to CPSES Unit 2 Relief Request 1-1 Page 11 of12 ARTICI.E -4000 REPAIR / REPLACEMENT ACTIVITIES
-4100 GENERAL
-411'l SCOPE (a) This Article provides requirements for repair / replacement activities on concrete containments.
(b) Grease cups and installation screws are exempt from the requirements of this Article.
-4120 REPAIR / REPLACEMENT PROGRAM Repair / replacement activities shall be performed in accordance with the Repair / Replacement Program and Plan required by IWA-4150.
The Repair / Replacement Pmgram shall address concrete material control.
-4200 REPAIR / REPLACEMENT PIAN
-4210 RESPONSlHLE ENGINEER Tha Repair / Replacement Plan shall be developed under the direction of a Responsible Engineer ( 2300).
-4220 CONCRETE (a) The Repair / Replacement Plan shall specify requirements for removal of defective material.
(b) The affected area shall be visually examined to assure proper surface preparation of concrete and reinforcing steel prior to placement of concrete.
(c) When removal of defective material exposes reinforcing steel, the reinforcing stee shall receive a detailed visual examination as defined in -2310(b). Reinforcing steelis acceptable when the kespomible Engineer determines that there is no evidence of damage or degradation sufHcient to warrant further evaluation or repair, When required, reinforcing steel shall be repaired in accordance with -4230. Repair / replacement activities on exposed-end anchors of the post tensioning system shall be in accordance with -4240.
(d) New material shall be chemically, mechanically, and physically compatible with existing concrete.
(c) When detensioning of prestressing tendons is required for the repair / replacement activity on the concrete surface adjacent to the tendon, the Repair / Replacement Plan shall require the following:
(1) selection of new material to minimize stress and strain incompatibilities between new material and existing concrete; (2) procedures for application of ncw material; (3) procedures for detensioning and retensioning of prestressing tendons.
(/) The Repair / Replacement Plan sha'l specify requirements for in-process sampling and testing of new material.
-4220 REINFORCING STEEL Damaged reinforcing steel shall be corrected by any method permitted in the original Construction Code or in Section 111, Division 2, with or without removal of the damaged reinforcing steel.
-4240 POST-TENSIONING SYSTEM (a) Welding of bearing plates and shim plates of the post-tensioning system shall meet th' 1pplicable requirements ofIWA-4000. The corrosion protection medium shall be restored following the repair / replacement acmity.
(b) The following items, as applicable, shall be contained in the Repair / Replacement Plan:
(i) requirements for the removal ofitems; (2) surface preparation required prior to installation ofitems; (3) examinations required prior to mstallation ofitems; (4) detensioning and retensioning requirements for tendons alTected by installation ofitems; (5) requirements and procedures applicable to installation ofitems; (6) in process sampling and testing requirements to be performed during installation of items.
Enclosure I to CPSES Unit 2 Relief Request L-1 Page 12 0f l2
-4300 EXA511 NATION Areas of repair / replacement activities shall be examined in accordance with 2000 to establish a new preservice record and shall meet the acceptance standards of 3000.
ARTICI.E 5000 SYSTE31 PRESSURE TESTS
-5100 SCOPE This Article provides requirements for pressure testing concrete containments following repair / replacement activities.
-5200 SYSTE51 TEST REQUIRE 51ENTS 2
5210 GENERAL, A containment pressure test shall be peiformed following repair / replacement activities unless any of the following :enditions exist:
(a) The Engineering Evaluation Report (
-3310) demonstrates that the structural integrity of containment in the prior to performance of the repair / replacement activity condition has not been reduced below that required by the original design criteria.
(b) ne repair / replacement activity affects only the cover concrete external to the outermost layer of structural reinfor:ing steel or post-tensioning tendons.
(c) The repair / replacement activity involves only exchange of post tensioning tendons, tendon anchorage hardware, shims, or corrosion protection medium.
-5220 TEST PRESSURE He pressure test shall be conducted et the design basis accident pressure, P,.
-5230 1.EAKAGE TEST A leakage test shall be conducted as required by IWE 5000.
-5250 TEST PROCEDURE AND EXA511 NATIONS The Responsible Engineer shall review the pressure test procedure and shall authorize the commencement of the pressure test.
The surface of all containment concrete placed dur;ng repair / replacement activities shall be examined in accordance with -2310(b) prior to start.,f pressurization, at test pressure, and following completion of depressurization. Extended surface examinations, additional examinations during pressurization, oth r examinations, and measurements of structural response to pressure shall be conducted as specified by the Responsible Engineer.
-5260 CORRECTIVE ACTION If the surface examinations of 5250 cannot satisfy the requirements specified by the Responsible Engineer, the area shall be examined to the extent necessary to establish requirements for corrective action. Repair / replacement activities shall be performed in accordance with -4000, and pressure testing shall be repeated in accordance with
-5209, prior to returning the containment to service.
-5300 REPORT A pressure test report shall be prepared under the direction of the Responsible Engineer. This report may be an addition to a previously-prepared Engineering Evaluation Report ( -3310). The report shall describe pressure test procedures and examination results and shall state whether or not the repair / replacement activity is acceptable. If the repair' replacement activity is not acceptable, the report shall specify corrective measures.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ to CPSES Unit 2 Rel' f Request L-1 Page 1 of 8 Para-Caanges between IWL Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWL rewrite use as an alternative examination IW1. -
ASME Section XI generic wording change from non significant 1100 repair, replacement and or modification terms to repair / replacement activities 1200 no change n/a 1210 no change n/a 1220 no change n/a 2l00 Changed " Inspection" to " General" in heading.
non significant (a) Provided reference to IWA 1000 with (a) The additional general requirements exceptions from IWA-2210 and 2300 for visual invoked by reference to IWA 2000 where examinations and for qualification of visual none were referenced previously further examination personnel, assure containment integrity. The exceptions from IWA-2210 and IWA-2300 are significant in that the related previous requirements have been changed and incorporated into IWL-2310. The IWL-2310 changes are addressed below.
(b) Provided requirements for Authorized (b) The addition of Authorized Nuclear Nuclear Inservice Inspectors.
Inservice Inspector requirements ensures j
proper Inspector qualification.
2200 no change n/a 2210 no change n/a 2220 no change n/a 2230 ASME Section XI generic change from repair non significant and or replacement to repair / replacement activities.
2300 no change n/a J
_ _ _ - _ _ - _ _ _ _ _ - _ _ _ _ to CPSES Unit 2 Relief Request L-1 Page 2 of 8 Para.
Changes between IWL Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWL rewrite use as an alternative examination 2310 These changes are related to the IWL-2100 changes addressed above and are considered significant.
(a) replaced VT-lC and VT-3C visual (a) Containment examinations are intended examination terminology with new VT general to identify indications of significant and VT detailed examination terms, conditions over large areas. The VT general examination is performed to indicate the general structural condition for determining concrete deterioration and distress. The VT detailed examination is performed to determine the magnitude and extent of the deterioration.
(b) replaced reference to IWA-2210 for (b) Direct visual examination is not practical illumination levels, examination distances and on all areas of containment surfaces.' The resolution requirements with specific previous VT requirements precluded the examination attributes, ability to demonstrate that remote visual examination was equivalent to direct visual examination. Providing specific cxamination attributes in IWL as opposed to referencing the generie requirements ofIWA focuses the visual examination on areas it.. :ortant to the verifica: ion of containment integrity.
(c) replaced reference to IWA-2300 for concrete (c) Invoking requirements comparable to CP-examination personnel qualification requirements 189 would complicate containment ISI with provisions for the owner to define the program development without a examination personnel qualification compensating increase in plan; quality or requirements, safety. Requiring an owner defined program provides for more efficient program implementation by permitting personnel performing containment examinations to be qualified to written practices that are more consistent to those used for other NDE personnel.
, to CPSES Unit 2 Relief Request L-1 Page 3 of 8 Para.
Changes between IWL Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWL rewrite use as an alternative examination 2320 Changed wording slightly.
non significant - clarines wording Made the ASME Section XI generic change from non signi0 cant repair and or replacement to repair / replacement activities.
Added a responsibility for the Responsible The added pressure test responsibilities for Engineer to review certain pressure test the Responsible Engineer ensures proper procedures.
performance of pressure testing activities
'400-no change n/a 2410 no change n/a 2420 no thange n/a 2421 Unanged wording for sites with more than one non significant - clarines wording and plant. Changed frequencies by adding "and every accommodates plant life extensions.
10 years thereafter".
2500 no change n/a 2510 Changed heading.
non significant Changed wording consistent with the changes to non significant IWL-2310 addressed above.
Added two subparagraphs providing more The added details ensure proper tendon detailed examination requirements for tendon anchorage area examinations. However, anchorage areas.
these changes do not apply to CPSES containments.
2520 no change n/a 2521 no change n/a 2522 Changed the heading and added a subparagraph The added details ensure proper tendon to address tendon elongation.
examinations. However, these changes do not apply to CPSES.
2523 no change n/a 2524 Changed wording consistent with the changes to non significant IWL-2310 addressed above.
2525 Changed wording for sample analysis.
non significant
_ to CPSES Unit 2 Relief Request L-1 Page 4 of 8 Para-Changes between IWL Significance of change and or basis for graph 1992 Ed. '92 Ad and the current IWL rewrite use as an alternative examination 2526 Added a subparagraph addressing replacement of The added details ensure tendon integrity, corrosion protection medium.
However, these changes do not apply to CPSES containments.
3100 no change n/a 3110 no change n/a 3111 ASME Section XI generic change from repair non significant and or replacement to repair / replacement activities.
3112 no change n/a 3113 ASME Section XI generic change from repair non significant
.ad or replacement to repair / replacement activities.
3:20 no change n/a 3200 no change n/a 3210 removed the word concrete trom the heading non significant 3211 Added tendon end and anchorage aaas to the The added details ensure proper tendo.i scope of the subparagraph and added corrosion examinations. Howevet, these changes do protection medium leakage and end cap not apply to CPSES containmenta.
deformation as acceptance criteria attributes.
ASME Section XI generic change from repair non significant, and or replacement to repair / replacement activities.
3212 no change n/a 3213 ASME 3ection XI generic change from repair non significant -
and or replacement to repair /replaecment activities.
3220 no change n/a 3221 Added acceptance criteria attril>utes for tendon The added details ensure proper tendon clongation, free water content and corrosion examinations. However, these changes do no protection medium reduction, apply to CPSES containments.
3222 no change n/a t
to CPSES Unit 2 Relief Request L-1 Page 5 of 8 i
Para.
Changes between lWL Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWI rewrite use as an alternative examination 3223 ASME Section XI generic change from repair non significant and or replacement to repair / replacement activities.
3300 no change n/a 3310 Added applicability for other plants at the same non significant site.
ASME Section XI generic change from repair non significant and or replacement to repair / replacement activities.
3320 Deleted paragraph which addressed engineering non significant - there were no submittal ei evaluations being subject to review by retention requirements changed by the authorities.
deletion of the subparagraph.
4000 ASME Section XI change frr
'nair and or non significant - all related repair and replacement to repair /repicmiem activities.
replacement requirements have been consolidated into IWL-4000.
4100 no change n/a 4110 Exempted grease cups and installation screws non significant - the exempted items are non frein the scope, structural items and no not apply to CPSES containments.
ASME Section XI generic change from repair non significant and or replacement to repair / replacer nt activities.
4200 ASME XI generic change from repair and or non significant replacement to repair / replacement activities.
Added a new paragraph 4210 to require The added requirements ensure proper Repair / Replacement Plans to be developed under repair / replacement plan development, the direction of a Responsible Engineer.
. to CPSES Unit 2 Relief Request L-1 Page 6 of 8 Para-Changes between lWL Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current iWL rewrite use as an alternative examination 4210 Changed paragraph number to 4220, removed the non significant word repair from heading and changed referenced paragraph numbers consistent with the addition of a new paragraph 4210 above.
Changed wording consistent with the changes to non significant IWL-2310 addressed above.
AShiE Section XI generic change from repair non significant and or replacement to repair / replacement activities.
Changed repair material to new material in non significant several places.
4220 Changed paragraph number to 4230.
non significant 4230 Changed paragraph number to 4240 and clarified non significant by removing the word repair.
AShiE Section XI generic change from repair non significant and or replacement to repair / replacement activities.
Added detailed requirements for the contents of a The added detailed requirements ensure rep..ir/ replacement plan.
proper repair / replacement plan development for post-tensioning systems. However, these changes do not apply to CPSES -
containments.
4300 AShiE Section XI generic change from repair non significant and or replacement to repair / replacement activities.
5100 AShiE Section XI generic change from repair non significant and or replacement to repair / replacement activities.
5200 no change n/a 5210 ASNIE Section XI generic change from repair non significant and or replacement to repair / replacement activities.
5220 no change n/a
Enc!asure 2 to CPSES Unit 2 Relief Request L-1 Page 7 of 8 Para-Changes between IWL Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWL rewrite use as an alternative examination
$230 Changed wording by removing a me specific non significant - the removed wording was IWE related requirements while maintaining the IWE specific and is contained in IWE-5000.
reference to IWE-5000.
5240 Deleted paragraph which addressed the non significant - the schedule of pressure tests scheduling of pressure tests.
are contained in IWE-5000 as referenced in IWL-5230, 5250 Changed wording regarding the role of the The clarified role of the Responsible Engineer Responsible Engineer in pressure test activities.
ensures proper pressure test procedures and examinations.
ASME Section XI generic change from repair non significant and or replacement to repair / replacement activities.
Changed VT terminology consistent with the The VT terminology changes are discussed in changes to IWL-2310 addressed above.
IWL-2310 above.
5260 Changed heading from Corrective Measures to non significant Con:ctive Action.
ASME Section XI generic change from repair non significant and or replacement to repair /replacemnt activities.
5300 ASME Section XI generic change from repair non significant and or replacement to repair / replacement activities.
7000 Deleted Article including IWL-7100,7110,7120 non significant - all related repair and consistent with the IWL-4000 changes above.
replacement requirements have been incorporated into IWL-4000.
Table Changed item 1.1.11 from all areas to all Changing item 1.1.11 provides for more 2500 1 accessible areas.
practical examination implementation than previous requirements.
Changed VT exam method tenninology The VT terminology changes are discussed in consistent with the paragraph IWL-2310 changes IWL-2310 above.
above.
I to CPSES Unit 2 Relief Request L 1 Page 8 of 8 Para-Changes between IWL Significance of change and or basis for graph 1992 Ed. '92 Ad. and the current IWL rewrite use as an alternative examination Table Changed inspection periods to state every 5th non significant - accommodates plant life 2521-1 year in lieu oflisting out each year and changed extensioris for tendon examinations, note 2 for having to meet acceptance criteria from liowever, these requirements do no apply to "cach of the earlier inspections" to "for the last 3 CPSES containments.
inspections".
Table Added optional test methods for corrosion non significant - additional test method 2525-1 protection medium analysis options provides for more practical test implementation, liowever, these requirements do not apply to CPSES containments.
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