ML20203G427

Rev 0 to First Ten-Year Interval Containment Insp Program for Cns

ML20203G427
Person / Time
Site:	Cooper
Issue date:	02/24/1998
From:	NEBRASKA PUBLIC POWER DISTRICT
To:
Shared Package
ML20203G417	List: ML20203G412 ML20203G427
References
PROC-980224, NUDOCS 9803020309
Download: ML20203G427 (42)

Text

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FIRST TEN-YEAR INTERVAL CONTAINMENT INSPECTION PROGRAM FOR COOPER NUCLEAR STATION REVISION 0 NDIRA5KA l'UBl.IC POWER DISTRICT i

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l 1.0 TAHl.E OF CONTENTS  :

__ Section Description Page(s) -=

1 Table of Contents 11 2 Revision Sunimary Sheet 21 3 Introduction and Program Description 31 to 3 5  :

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4 Application of !!xemption Criteria 4-1

5 Containment inspection Technical Approach and 5 1 to 5-7 j Position Index Summary 6 Inservice Inspection Relief Requests 61 to 6-19 l

7 1.ist of Applicable Drawings and Diagrams 7-1 _

j 8 Nondestructive lixamination Procedure 1.isting 81

' 9 1 to 9-4 9 Component lixamination Sununary 1.isting j 10 Index of Abbreviations 10-1  :

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j 2.0 REVISION

SUMMARY

SilEET Section lif fective l' age (s) __ Revision _ Date j 1 initial issue 0 2/09/98 2 initial issue 0 2/09/98 3 initial issue 0 2/09/98  !

, 4 Initial Issue 0 2/09/98 5 initial Issue 0 2/09/98 6 initial issue 0 2/09/98 j 7 Initial issue 0 2/09/98 I

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9 Initial issue 0 2/09/98 10 Initial issue 0 2/09/98

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. ContaintnentInstwtionPrognun 3.0 INTROI)UCTION ANI) PROGRAh! I)ESCRIPTION 3.1 Introduction 3.1.1 This Program outlic:s the requirements for tiw Non 1)estructive lixamination of AShili Class h1C (metallic containments) components at Cooper Nuclear Station (CNS). The Primary Containment consists of the drywell, the suppression chamber (forus), and the connecting piping (vent headers). Process piping penetrating the Primary Containment is not addressed in this program.

3.12 The Ley features of this Program are the introduction and Program 1)escription, Relief Request:,, Teclinical Positions, and Summary Tables. The details of the Containment inspection Program are supported by other documents that are available at CNS. These documents include, but are r.ot limited to, component drawings, piping and instrumentation diagrams, procedures, and other records required to execute the Containment Inspection Program at CNS.

3.2. llaslLOLConD11tuttenLinsucctionJfrognun 3.2.I in the Ecdent! Register, dated August 8,1996 (61 FR 41303), the NRC amended its regulations (rule) to incorporate by reference the 1992 lidition and Add;:nda of Subsections IWi! and IW1. of Sect.1 XI of the AShil! Code. Subsections IWii and IWI. give the requirements for inservice inspection (ISI) of Class CC (concrete containments), and Class h1C of light water-cooled power plants. The amended rule became effective on September 9,1996; it requires the licensees to incorporate the new requirements into their ISI plans and to complete the first containment inspection within five years (i.e., no later than September 9, 2001). Any repa;r or replacement (R/R) activity to be performed on containments after the effective date of September 9,1996, has to be carried out in accordance with the respective requirements of Subsections IWi! and lWl.

3 2.2 The three inspection periods during the first inspection interval are as follows:

Fiist Period: September 9,1996 to September 8, 2001 Second Period: September 9, 2001 to I)ecember 8, 2004 Third Period: 1)ecember 9,20(kl to April 8,2007 3.2.3 This Program was developed in accordance with the requirements of 10 CFR 50.55a and the 1992 lidition.1992 Addenda of the American Society of hiechanical

!!ngineers (AShili) lloiler and Pressure Vessel Code.Section XI, Subsections IWA andIWii (3 1) Revision 0

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3.2.3.1 As allowed by 10CFR50.55a(c)(3) and USNRC Regulatory Guide >

1.147. Revision 11, cenain ASMl!Section XI code Cases have been  !

detennined acceptable for application to ISI Programs. The .

following Code Cases are icing adopted by CNS and incorporated in the Containment inspection Program. The use of Code Cases not  !

cunently identified in Regulatory Guide 1.147 is addressed as relief ,

requests in Secilon 6.  ;

1 Case N.45N . Magnetic Particle Examination of Coated Materials.

l Case N.4% - llelical coil Threaded inse'ts.

3.3. Primary.fwdalumenLDnign 3.3.1 The NRC issued the construction permit for the Cooper Ncclear Station (CNS) in June 1968. The plant design was completed when the Nebraska Public Power District (NPPD) applied for an operating license for CNS and submitted the Final Safety Analysis Report (FSAR) for the facility to the NRC in March 1971. This license was issued by the NRC in January 1974. The ASME Code, Section 111, .

Class 11,1965 Iklition,1967 Addenda, and Code Cases 1177 and 1330 were used for the design fabrication, crection, and testing of the Primary Containment. The

" General Design Criteria for Nuclear Power Plant Construction Pennits" was published for conunent in the Federal Register in July 1967. The final version of these design criteria were not incorporated into the Code of Federal Regulations (10CFR50, Appendix A) until February 1971, approximately the same time that NPPD submitted its FSAR to the NRC. As discussed in the NRC Safety Evaluation .

Report dated Febmary 14,1973, the license for CNS is based, in part, on the intent of the Draft General Design Criteria published in July 1967. ,

The current ASMll Code component classifications did not exist at the time of CNS design and construction. The ASMli Cale Class 1,2,3, and MC designations were added and defined in more recent editions of the ASME Holler and Prer.sure Vessel Code.

3.3,2 The primary containment structure is a portion of the General Electric (GE) Mark l Primary Containment Pressure Suppression System. The complete pressure 4

suppression system consists of the drywell which houses the reactor vessel and  !

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reactor coolant recirculation loops, the pressun: suppression chamber, the connecting vent system between the drywell and pressure suppression chamber, isolation valves, vacuum relief system, and containment cooling systems. The isolation valves and vacuum relief system are discussed elsewhere in this document.

3.3.3 - The drywell is a low leakage steel pessure vessel designed to confine the reactor

- coolant that would be released during a postulated pipe rupture, and prevent the 1

. gross release of radioactive materials to the environment. The lower portion of the l l

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. ContainmentinspxtionPnnnun drywell is spherical with a 65 foot diameter and the upper portion is cylindrical with a 35 foot,7 inch diameter. The overall height of the drywell is 110 feet.

The drywell is enclosed in reinforced concrete to provide the required radiological shielding during nonnal plant operations. The concrete also provides additional -

resistance to defonnation and buckling. Shielding above the drywell is provided by removable, segmented reinforced concrete plugs.

The drywell is designed for an internal design pressure of 56.0 psig (62.0 psig maximum code allowable), 2.0 psig external design pressure, and a maximum temtwrature of 281*F. The applicable dead, live, and seismic loads are imposed on the shell along with the above design conditions.

3.3.4 'lhe suppression chamber is a steel pressure vessel designed to hold a large volume of water for use as a heat sink for any postulated transient or accident conditions in which the normal heet sink is unavailable. The water volume (Suppression Pool) also serves as a heat sink for the !!igh Pressure Coolant injection (IIPCI) and P.cactor Core isolation Cooling (ItCIC) turbine exhaust. The suppression pool also serves as a water source for the limergency Core Cooling Systems. The suppression pool is the primary water source for the Core Spray (CS) and llesidual lleat itemoval (Illill) Systemt and a secondary water source for the llPCI and itCIC Systems.

Transient conditions which require the operation of the Main Steam (MS) relief a valves will transfer energy to the suppression pool via the relief valve discharge piping. Postulated pipe ruptures in the drywell will transfer energy to the suppression pool tla the vent system, in each case the steam now is discharged below the surface of the suppresion pool and condensed. Any non condensable gases and fission products are released to the suppression chamber air space.

The suppression chamber is a toroidal shape kicated below and completely encircling the drjwell with a cemerline diameter of 102 feet with a cross sectional dumeter of 28 feet, 9 inches. The suppression chamber (torus) is constructed of 16 mitred sections to climinate the need for compound curves in the shell.

'llw shell is stilfened by sixteen (16) internal ring girders located at the miter joints.

The torus is supported by sixteen (16) pairs of reinforced W14x136 columns at the ring girder kieations. The suppression chamber is designed to the same material and code requirements as the drywell.

3.3.5 Tiw drywell and suppression chamber are connected with eight (8) 5'-l1" diameter circular vent pipes anchored at the drywell. The vent pipes are located at 45' intervals and penetrate the suppression chamber shell at alternating segments midway between the ring girders. Tlw vent pipes are provided with expansion joints to accommodate differential movement of the drywell and suppression chamber, and (3-3) ltevision 0

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. ContainmentinspectionProgram jet dellectors located at the drywell entrance to the vent to prevent damage which might occur due to jet forces associated with a pipe break in the drywell.

The vent pipes connect to a 4' 2" diameter vent header contained in the air space of the suppression ch:unber. Projecting downward from the vent header to a minimum submergence depth of 3'-0" are 80 downcomer pipes, 24 inches in diameter to direct steam flow to the suppression pool for conJensation.

The vent system is designed to the same pressure and temperature requhement as the drywell and torus. The Mark I containment Program Plant Unique Analysis Report for Cooper Nuclear Station provides additional design information and a summary of modilications perfonned to meet the originally intended design safet) margins for the redefined hydrodynamic loads not explicitly included in the original design.

3.3.6 The Personnel Airlock serves as an access into or out of the Primary Containment Vessel (Drywell). The airlock was furnished as an assembly and consists of a cylinder with a stilfened bulkhead at each end containing a door. The doors are hinged so a positive pressure inside containment tends to seat the doors. !!ach door is equipped with an elastomer pasket to provide a positive seal. The doors are equipped with a positive latch mechanism. The control mechanism is interlocked such that only one door may be opened at a time unless the interhick is intentionally bypassed when primary containment integrity is not required.

3.3.7 The drywell liner and the torus were designed and constructed to the requirements of the ASMiiiloiler and Pressure Vessel Code and therefore have certain additional plate thickness in the shell for corrosion allowance. As a matter of good practice the interior of the drywell and toms were coated to provide protection against corrosion of the surface.

3.4. Contents.0LCuntaintnenLinwrc1[on Prograin The Containment inspection Program addresses the requirements for inspection of the containment shell, suppression chamber, vent headers, and access hatches. Containment pressure testing is conducted in accordance with 10CFR50 Appendix J and Technical Specification requirements, Although some sections of the Program are common, the specific requirements for components are addressed senarately. The applicability of each of the sections identified in this ISI Program is as follows:

3.4.1 Section 1 - Table of Contents Provides the organizational format for the Containment inspection Program.

3.4.2 Section 2 - Revision Summary Sheet Provides the revision status of the effective sections in the Program.

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3.4.3 Section 3 Introduction and Program Description Provides details on the background, scope, basis and contents of the Program, i

3.4.4 Section 4 Application of themption Criteria Provides the basis for determining the Class MC components exempted from visual >

and volumetric examination requirements per IWII 1200.

3.4.5 Sections 5 Containment Impection Technical Approach and Position Index Summaries CNS has reviewed general licensing /repulatory requirements and industry practices to determine a practicable method of implementing the Code requirements. The technical positions contained in this section have been provided to clarify CNS's implementation of ASMii Section XI requirements for Containment inspection.

3.4.6 Section 6 Containment inspection Relief Requests This section contains relief requests for impracticable nondestmetive examinations in accordance with 10 CFR 50.55a(g)(5). If examination requirements are determined to be impracticable during the course of the interval, additional or modined relief requests will be submitted in accordance with 10 CFR 50.55a (g)(5).

3.4.7 Section 7 1.ist of Applicable Drawings and Diagrams Provides a listing of drawings corresponding to portions of containment subject to examination under this Program.

3.4.8 Section 8 Nondestructive lhamination Procedure 1.isting This section contains the listing of nondestructive examination procedures in accordance with Code and regulatory requirements.

3.4.9 Section 9 - Component ihamination Summary 1.isting This section contains the tables and schedule for examination of components and component supports in accordance with the requirements of ASMi!Section XI.

3.4.10 Section 10 - Index of Abbreviations

' This section contains the abbreviations used in the preceding tables.

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. ContainmentinspectionPrognun 4.0 APPL.lCATION OF EXEMPTION CRITERIA 4.1. Sed 10tLNI Clahs MC_Exentatioits 4.1.1 IWE 1220 gives specific guidance for exempting components from the examination requhements ofIWE-2500 if they are: outside of the boundaries of containment as defined in the design specifications; embedded or inaccessible portions of containment vessels, pads, and appurtenances with welds that meet the requirements of the otiginal Construction Code; portions of containment vessels, parts, and appurtenances with welds that become embedded or inaccessible as a result of vessel repair or replacement if the requirements of IWE 1232 and IWE-

$220 are met: piping, pumps, and valves that are part of the containment system, or which penetrate, or are attached to the containment vessel.

4.1.2 1he concrete biological shield and the shield plugs are not part of the containment design and are, therefore excluded from this program.

4.1.3 1he portion of the drywell below the concrete floor is inaccessible. The welds in -

the lower head were double buttwelded and radiographed in accordance with the Constmetion Code. Therefore, the lower head of the drywell below the concrete ther is exempt.

4.1.4 Integral attachments to components which are exempt from examination under IWE 1220 are also exempt from the examination requirements of IWE 2500 and Table IWE 2500-1.

4.1.5 Integral attachments to components which are classified as ASME 1,2 or 3 are examined under the niles of IWil, IWC, or IWD as applicable.

4.1.6 Moisture barriers are not past of the containment pressure boundary (NE-2110(b).

The placement of the concrete and the moisture barrier for the exterior biological shield was not subject to Code rules during construction in response to IN 86 77 and Gl. 87-05, CNS performed a special test of the drywell sand cushion. No

moisture was detected. Funhennore, the moisture banier external to the containment

! is not accessible for examination Therefore, the moisture barrier external to the drywell is exempt.

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I 5.0 INSERVICE INSPECTION .

i TECilNICAl, POSITION INI)EX ,

, Pmithm Rev. Summary l CT-01 0 Remote Visual Examinations CT-02 0 Pressure Retaining Welds and Pressure Retaining Dissimilar Metal i Welds CT 03 0 Additional Examinations .t CT-04 0 Minimum Wall Thickness location J CT 05 .O Preservice inspection  :

CT-06 0 Containment Supports  :

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, ContainmentingstionPmgnun TECHNICAL, APPROACil AND POSITION NUMBERt CT-01, REVISION 0 '

CO3tPONENT IDENTIFICATION Code Class: MC

Reference:

Table IWA 22101 Examination Category: All item Numbers: All

Description:

Remote Visual Examinations CODli.REQLilREhiENI Table IWA 22101 specifies the minimum illumination and maximum distance for direct visual examination.

POSITION 10CFR50.55a(b)(2)(x)(II) allows the following alternative the Table IWA 22101:

When T:rforming remotely the visual ceaminations required by Subacetion IWE, the :naximum direct examination distance specified in Table IWA 2210-1 may be extended and the minimum illumination seguirements specified in Table IWA 22101 may be decreased provided that the conditions or indications for which the visual examination is performed can be detected at the chosen distance and illumination

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TECIINICAl, APPROACil AND POSITION NUMilER: CT 02, REVISION 0 COMPONENT IDENUEICAHON  ;

Code Class: MC I

Reference:

Table IWB 2500-1 Examination Category: E II, E F llem Numbers: E3.ll, E3.12. E.3.13. E.3.20, E.3.30 E7.10

Description:

. Pressure Retaining Welds and Pressure Retaining Dissimilar Metal Welds CODE _REQUlHEh1ENI 1 Table IWE-2500-1 specifies examination requireinents for pressure retaining welds and pressure

. retaining dissimilar metal welds in containments.  ;

l'OSlHON 1

10CFR50.55a(b)(2)(x)(C) states that the examinations specified in Categories E B, Pressure Retaining Welds, and E-F Pressure Retaining Dissimilar Metal Welds, are optional. CNS does not include these examination categories in this program, i

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TECliNICAL APPROACil AND TOSITION NUMHER: CT-03, REVISION 0 COA 11'ONENT IDENTIFICATION Code Class: MC I

Reference:

IWii2230 Exam; nation Category: All item Numbers: All

Description:

Additional Examinations CODitJEQUIREhlEN't' IWi! 2430 states that examinations performed during any one inspection that reveal indications that exceed the acceptance standards of Table IWr:-3410-1 shall be extended to include an additional numtwr of areas equal to the number of areas initially examined during the inspection.

IDSIIl0N 10CFR50.55a(b)(2)(x)(D) allows the following alternative the IWE 2430:

(1) If the examinations reveal flaws or areas of degradation exceeding the acceptance standards of Table IWE-34101, an evaluation shall be performed to determine whether additional component examinations are required, For each Daw or area of degtadation identified which exceeds acceptance standards, the licensee shall provide the following in the ISI Summary Report tequired by IWA 600(h (i) A desciiption of each flaw or area, including the extent of degradation, and the conditions that led to tw degradation; (ii) The acceptability of each flaw or aira, and the need for additional examinations to verify that similar degradation does not exist in similar components, and; (ill) A description of necessary corrective actions.

(2) The number and type of::dditional examinations to ensure detection of similar degradation in similar components.

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. Containmertinspectionl%giam TECilNICAL APPROACil AND POSITION NUMBER: CT-04, REVISION 0 -

C(L\1?ONENT IDENTIFICATION Code Class: MC

Reference:

IWE-2500(c)(4)

Examination Category: E-C llem Numbers: E4.12

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Description:

Minimum Wall Thickness Location CODE _REOUIREPic1T IWE-2500(c)(4) states that ultrasonic measurements shall be used te determine the minimum wall thickness within each grid. The location of the minimum wall thickness shall be marked such that peri (xlic recxamination of that location can be performed in accordance with the requirements of Table IWE-2500-1, Examination Category E-C.

POSITION The location of grid lines decs not have to be permanently marked on the containment wall.

Ilowever, the location of the minimum wall thickness within the grid lines shall be marked.

Ultrasonic measurements performed during reexaminations need only be performed within each grid square at a single location designated as the minimum wall thickness during previous examinations.

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. ContainmentInspedionProgram TECIINICAL APPROACil AND POSITION NUMBER: CT-05, REVISION 0 COMPONENT II)ENTIFICATION Code Class: MC

References:

IWE-2200 Table IWE-2500-1

. Examination Category: All

Item Numbers

All

Description:

Preservice inspection CODE REOUIREMENT IWE-2200 requires that the examinations listed in Table IWE-2500-1 be completed prior to initial plant startup.

LT)SITION 10CFR50.55a(g)(6)(ii)(B) allows the examinations that are performed during the first inspection interval to serve the same purpose for operating plants as the preservice examination specified for plants not yet in operation. CNS interprets this to mean that the acceptance standards of IWE-3110 Preservice Examinations, do not apply to existing conditions. The acceptance standards of IWE-3120, Inservice Examinations, will be used for the first interval examinations.

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Cooper Station 1st Interval e ContainmentinspectionPmgmm TECIINICAl, APPROACil AND POSITION NUMBER: CT-06, REVISION 0 COMPONENT IDENT[FICATION Code Class: MC

References:

IWF 2510, Table IWF-25001 Examination Category: F-A Item Numbers: All

Description:

Containment Supports CODE REOUIREMENT IWF-2510 requires that the examination < 'isted in Table IWF-2500-1 be performed for those components not exempted by IWE-1220.

EOSITION When 10CFR$0.55a(g)(4) was amended to require inspection of the containment, the scope was limited to components classified as Class MC pressure retaining components and their integral attachments. Containment supports are not included. In response to a question by the Nuclear Etergy Institute (NEI), the NRC stated "The question of repair / replacement of supports arises for a Mark I toms. Figure IWF-1300-1 of Subsection IWF shov+ that the support welds to the torus are included as part of the IWE examination component. Thus any repair / replacement activity associated with the support welds is covered by the regulation. The visual examination of the rest of the supports for ensuring their integrity is included in section V of Appendix J of 10CFR50 and in the plant's technical specification requirements."

Based on the NRC's response to NEI's question and the specific wording of the rule, inspection of metal containment supports in accordance with ASME Section XI, Subsection IWF, is not required.

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~ 6.0 CONTAINMENT INSPECTION RELIEF REQUESTS i

- Per the requirements of 10CFR50.55a(g)($)(iii), if a licensee determines that conformance to certain

- Code requirements is impracticable for the facility the licensee shall notify the Commission and submit, 1

as specified in 10CFR50.4, information to support the determination. Relief Requests will be prepared in accordance with Appendix F and submitted to the NRC per 10CFR50.55a.

The following pages contain relief requests written in accordar.cc with 10CFR50.55a(a)(3) and (g)(5) when specific ASME Section XI requirements for inservice inspection are considered impracticable or '

pose an undo burden on the licensee. The relief requests contained are subject to change during the course of the ten year inspection interval as a result of changes in technology, plant design or as a result of installed modifications. If examinations or tests are determined to be impracticable, or result in hardship or unusual difficulty without a commensurate increase in the level of quality or safety, during the course of the interval, additional or modified relief requests will be submitted in accordance with 10CFR50.55a(a)(3) and (g)(5).

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. The following Table summarizes each relief request and provides for sequential numbering to maintain continuity for the remainder of the inspection interval.

i' Relief Hev. Summary Revision

. Request Date RC-01 0 Qualification ot' Nondestructive Examination Peisonnel Initial Issue RC-02 0 Seals and Gaskets initial issue C-03 0 Visual Examination of Paint or Coatings Initial Issue RC-04 0 Successive Examination of Repairs initial Issue RC-05 0 llolt Torque Tests initial issue

RC-06 0 VT-2 Visual Examination initial Issue i

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. Containment inspection Program CONTAINMENT INSPECTION RELIEF REQUESTS RELIEF REQUEST NUMHER: RC-01, REVISION 0 COMPONENT IDENTIFICATION Code Class: MC

References:

IWA-2300 Examination Category: All Item Numbers: All

Description:

Qualification of Nondestructive Examination Personnel Component Numbers: All CODE REOUIREMENT IWA-2300 requires personnel performing nondestructive examinations (NDE) and visual inspections to be qualified and certified in accordance with a written practice prepared in accordance with ANSI /ASNT CP-189, Standard for Qualification and Certification of Nondestructive Testing Personnel.

IIASIS FOR RELIEF Specisic relief is requested from the provisions of IWA-2300 on the basis that the proposed alternative would provide an acceptable level of quality and safety.

The CNS Third Ten-year Inservice Inspection Program conforms to the requirements of ASME Section XI,1989 Edition as required by 10CFR50.55a. Personnel performing NDE for Inservice Inspection of Code Class 1,2, and 3 components and component supports are qualified and certified in accordance with a written practice prepared in accordance with ASNT SNT-TC-1 A, Personnci Qualification and Certification in Nondestructive Testing,1984 Edition. Personnel performing visual examinations are qualified and certified to comparable levels of qualification as defined in SNT-TC-1 A and the employer's written practice. The 1992 Edition of ASME requires the use of ANSI /ASNT CP-189, Standard for the Qualification and Certification of Nondestructive Testing Personnel.

The format of SNT-TC-1 A and CP-189 are similar. Ilowever, SNT-TC-1 A is a recommended practice, its guidance can be modified as necessary to meet the user's needs. CP-189 establishes minimum requirements that must be met. CI'-189 also requires Level Ill personnel to hold an ASNT level 111 Certificate with a current valid endorsement for each NDE method used. Weighting factors are permitted by SNT-TC-1 A but not by CP-189, in addition, CP-189 requires all practical examinations to be administered using a written checklist. There are also changes to the minimum experience levels. CP-189 requires more hours of experience where as SNT-TC-1 A specifies months (work level per time). Initial training is uniform under CP-189 where as SNT-TC-1 A training is based on education. Furthermore, IWA-2310 in the 1992 Edition,1992. Addenda, states,

" Certifications based on SNT-TC-1 A are valid until recertification is required."

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Cooper Station 1st Interval e Containment inspection Program CONTAINNIENT INSPECTION RELIEF REQUESTS RELIEF REQUEST NUMHER: RC-01, REVISION 0, CONTINUED Visual examination is the primary nondestructive examination method required by Subsections IWE.

Neither CP-189 nor SNT-TC-1 A specifically includes visual examination; thus, the Code requires qualification and certification to comparable levels as defined in CP-189 or SNT-TC-1 A, as applicable, and the Employer's written practice. Development and administration of a second program would not enhance safety or quality and would serve as a burden, particularly in developing a second written practice, tracking of certifications, duplication of naperwork, etc. This duplication would also apply to NDE vendor programs. Updating to the 1992 Edition,1992 Addenda, for Subsections IWil, lWC, etc., would require a similar request for relief.

A Comparison of SNT-TC-1 A-84 vs CP-189-91 is attached.

Relief is requested in accordance with 10 CFR 50.55a(a)(3)(ii). Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

PROPOSED ALTERNATE As an alternate, CNS will qualify and certify NDE Testing personnel in accordance with IWA-2300 of the 1989 Edition of ASME XI.

ALTLLCAllLE TlME PERIOD Relief is requested for the first ten-year interval of the Containment inspection Program for CNS.

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CONTAINMENT INSPECTION RELIEF REQUESTS ANSI /ASNT CP-189-91 COSIPARISON WITH SNT-TC-1A 83 1--Scope CP-189 is a comprehensive revision that establishes itself as a " STANDARD" with minimum mandatory requirements. Whereas SNT-TC-1 A is a " Recommended Practice" and defines itself only as a guide.

2--Definitions -

lxvels I and 11 are defined as being certified in accordance with this standard, Level III is defined as being a holder of a valid ASNT lxvel 111 certificate and being certified in accordance with this standard, 3--Ixvels of Qualification CP-189 describes Trainee, and levels I,11,111 in similar language to SNT-TC-1 A but goes on to ,

describe "NDT Instructor" which is a new level of certification.

Note: IWA-2380 of the 1992 Addenda requires the NDT Instructor meet the requirements of Appendix Vil  ;

4--Qualification Requirements 4.1.2 Training, levels I, il CP-189, Appendix "A" replaces SNT-TC-1 A, Table 6.3.1. The training hours in Appendix "A" are not dependent on previous education, as in SNT-TC-1 A, and are more or less comparable to the  ;

hours shown in Table 6.3.1 for high school graduation equivalent. The training hours for level 1 1 PT have been increased from 4 to 8; the hours for Ixvel II ET have been increased from 8 to 40; the hours for lxvels I and 11 AE have been reduced from 60 and 65 respectively, to 40; the hours for level I leak Test, Technique HT, have been increased from 2 to 4 and the hours for Level 11 Leak Test, Technique BT, have been reduced from 4 to 2.

4.1.4 Training, Level III CP-189 requirements are satisfied if the individual holds a current ASNT level lit certificate in the specific NDT method.

4,2.1 Experience, Levels I, Il i

. The total hours of experience in NDT shown in CP-189, Appendix "A", are less than the total work time in the method shown in SNT-TC-1 A, Table 6.3.1, for all methods; however minimum hours

- are specified for each method in CP-189 whereas experience hours may be gained simultaneously in two or more methods under SNT-TC-189. The minimum experience hours in the method are half the total required hours in NDT for all methods for CP-189. There appears to be a mistake in Appendix "A" as the total NDT experience hours shown for Level 1 in AE are less than the minimum required hours in the method. This error has been corrected in CP-IS9-1995.

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Cooper Station 1st interval l c Containment inspection Program CONTAINMENT INSPECTION REl,IEF REQUFETS i ANSI /ASNT CP _189 91 COMPAl{ISON WlIll SNT-TC-1 A 4.2.2 Experience, Ixvel 111 CP-189 requirements are satisfied if the individual holds a current ASNT level 111 certificate in the specific NDT method.

Note: IWA 2340,1989 Edition, is more e.tplicit in the education requirementsfor Level 111(high school).

4.4 NDT Instructor Since this is a new level there is no comparison with SNT-TC-1 A: however, within the parameters described in CP-189 for education and experience the NDT Instructor is 6esignated by a level 111.

5 -Qualification and Certi0 cation The SNT-TC-1 A term " Written Practice" has been dropped and is referred to as a " Procedure" in CP-189. There is more detail about what the procedure should contain than was provided in SNT-

- TC 1 A for the Written Practice and the procedure must be approved by a NDT level 111.

NOTE: IWA-2311,1992 Addenda, continues to refer to " Written Practice' 6--Examinations 6.1 Vision CP-189 requires visual acuity capable of reading a Jaeger Number I chart instead of the Jaeger Number 2 chart required by SNT-TC-1 A. CP-189 also requires that vision examinations shall be administered in accordance with a procedure, and by personnel approved by a designated NDT i Level Ill. This infers a written procedure that is not mentioned by SNT-TC-1 A.

NOTE: IWA-2321,1989 Edition, also requires the Jaeger Number I chart or equivalentfor near -

distance visual acuity and adds afar-distance visual acuity requirement.

IWA- 2322,1992 Addenua, addsfurther requirements (distance and character height)for the qualification of the near-distance visuai acuity chans.

6.2 level 111 Examinations 6.2.1 Initial Requirement CP-189 requires that the candidate hold a curremly valid ASNT Ixvel ill certificate for each method for which certification is desired. SNT-TC-1 A allows certification by (1) testing by the employer, (2) waiver of examination based on demonstrated ability, achievement, experience and l education, or (3) a valid ASNT level 111 certificate for each method for which certification is- '

desired.

6.2.2 Specific Examination (for each method) l CP-189 requires that the employer administ:r a 30 question written examination i SNT-TC-1 A requirements are included in those shown above under " Initial Requirements" (6-5) Revision 0 -

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Cooper Station ist Interval

.- Containment Inspection Program CONTAINMENT INSPECTION REl.lEF REQUESTS ANSI /ASNT CP-189-91 COMPARISON WITil SNT-TC-1 A 6.2.3 Practical Examination CP-189 requires the candidate to prepare a NDT Procedure or documented experience may be substituted by employer. SNT-TC-1 A requirements are included in those shown above under " Initial Requirements" 6.2.4 Demonstration Examination CP-189 requires that if the Ixvel 111 will be required to perform tests or evaluate test results the Practical Examination (above) shall include demonstration of the candidates ability to perform the seguired activity. SNT-TC-1 A does not require demonstration examinations.

NOTE: IWA 2322,1989 Edition, does not require demonstration examinations.

IWA 2323,1992 Addenda, adds considerable detail to the testing requirementsfor Level 111 qualification but not much substance.

6.2.5 Administration of level 111 Examinations CP 189 requires the employer's representative who administers Lesel 11 examinations to possess a current ASNT lxvel 111 certificate in the method for which the examination is administered.

i SNT-TC-1 A does not have this requirement.

6.3 lxvel I, II Examinations 6.3.1 General CP-189 requirements are generally similar to SNT-TC-1 A although the number of questions under each subdivision of leak Testing have been expanded for level 1.

6.3.2 Sp:cific CP-189 requirements are generally similar to those of SNT-TC-1 A except the number of questions for Level i ET has been increased from 20 to 30, 6.3.3 Practical level 1 CP-189 requirements are generally similar to those of SNT-TC-1 A.

lxvel 11 CP-189 requires demonstration of the method in examining at least one sample per technique and a minimum of two samples per method.

SNT-TC-1 A requires demonstration on only one sample per method.

Note: IWA 2311,1989 Edition, requires UT examination Personnel be trained, qualified and certifiedin accordance with Appendix VII (6-6) Revision 0 I .

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Cooper Station 1st Interval e Containment inspection Program CONTAINMENT INSPECTION REI lEF REQUESTS ANSI /ASNT_CP-189-91 COMPARJSON WITH SNT-TC-1 A

- 6.4 Administration and Grading 6.4.1 Responsibilities CP-189 requirements are generally similar to those of SNT-TC-1 A except that a Ixvel 111 shall approve, administer and grade all level I,11 excminations (administration and grading of multiple-choice questions may be delegated by the level III if so documented) and level III specific and practical examinations must be developed, administered and graded by a lxvel III.

SNT-TC-1 A gives the employer somewhat more latitude in this area.

6.4.2 Employer Examinations CP 189 requires a minimum grade of 70% on each test and an average grade of 80% on all employer administered certification examinations. All examinations have equal weight.

SNT TC-1 A allowed the use of weighting factors for the various examinations and provides allowable ranges for these factors.

i Note: IH'A- 2324,1989 Edition, requires a passing grade of 80% for each examination administeredfor certification 6.4.3 Prerequisite:; for Passing Practical Examinations CP-189 requires detection of discontinuities or conditions previously specified by the NDT level 111 as a prerequisite to passing the Ixvel 1,11 practical examination, For the Ixvel III practical examination, detection, if performance of testing is required, and correct evaluation, if evaluation is

- required, of the discontinuities or conditions previously specified by the NDT level 111 is required.

SNT-TC-1 A does not address this subject.

6.4.4 lxvel I Practical Examinations CP-189 requires the use of a written checklist by the NDT level ill when administering and grading level I practical examinations and spec.ifies what the checklist must address.

SNT-TC-1 A does not address this subject.

Note: 1989 Edition iH'A-2323 requires a Practical Examination.

6.4.5 Level 11 Practical Examinations CP-189 requires the NDT lxvel 111 to use a written checklist when administering and grading Level 11 practical examinations and specifies what the checklist must address.

SNT-TC-1 A does not address this subject.

Note: IWA- 2323,1989 Edition, requires a Practical Examination 6.4.6 level 111 Practical Examinations CP-189 requires the use of a written checklist when administering level III practical examinations and specifies what the checklist must address. SNT-TC-1 A does not address this subject.

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. Containment Inspection Program CONTAINMENT INSPECTION RELIEF REQUESTS ANSI /ASNT CP-189 91 COMi%RISON WITH SNT-TC-I A 6.5 Reexamination CP-189 requirements are generally similar to SNT-TC-1 A except, the candidate may not be reexamined using same examination or specimen that were previously failed.

6.6 Administration of Examirntions CP 189 does not allow an examination to be prepared or administered by one's self or by one's subordinate.

7.--Expiration, Suspension, Revocation, and Reinstatement of Employer Certification 7.1 Expiration

- Per CP-189, certifications shall expire when employment is tenninated, at the end of three years for levels I,11, when ASNT level 111 has expired. Per SNT-TC-1 A, expiration of certification is at the discretion of the employer and is governed by the employers written practice with recommended maximum recertification intervals of three years for levels I,11 and five years fw level 111.

Note: IWA-2313,1989 Edition, requires Level 1,11 recertification by qualification examinations every three years and Level 111 recertification by qualification examinations every fire years.

4 7.2 Suspension Per CP-189, the employer shall suspend an individuals certification if vision examination interval exceeds one year, (SNT-TC-1 A is essentially the same in that an annual vision examination is required in order to maintain certiGcation) if individual has not performed duties in method during f consecutive twelve month period (SNT-TC-1 A is governed by written practice) documented inadequate performance in method or technique, (SNT-TC-1 A does not address) or when Level III's ASNT certificate has expired.

7.3 Revocation Per CP-189, the certificate shall be revoked (by employer) when the individual has not performed duties in method during any consecutive twenty four month period, (SNT-TC-1 A is governed by written practice) lxvel lil's ASNT certificate has been revoked (SNT-TC-1 A does not address). or for unethical or incompetent conduct (SNT-TC-1 A does not address).

. 7.4 Reinstatement

-7.4.1 Suspended Certifications Per CP-189, Level 1,11 reinstatement of certificate shall be detennined by the Level 111 and for Level 41 reinstatement of the Level III certificate shall be determined by tile employer except that ASNT Leve' Ill certification may not be waived. SNT-TC-1 A does not address reinstatement of certifications.

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Cooper Station ist Interval o Containment Inspection Program CONTAINMENT INSPECTION REl,IEF REQUESTS

- ANSI /ASNT CP-189 91 COMPARISON WITil SNT-TC-1 A 7.4.2 Expired or Revoked Certifications Per CP-189, expired or revoked certifications rnay be reinstated by complying with Section 6 which is basically the same as initial certification. SNT-TC-1 A does not address reinstatement of certifications.

8. Employer Recertification 8.1 CP-189 requires 1.cvel 1,11 recertification to be in accordance with Section 6 which is basically the same as initial certification. SNT-TC-1 A allows recertification based on documented satisfactory performance or by reexamination as deemed necessary by the employer's lxvel 111.

8.2 CP-189 requires level ill personnel to be recertified by the employer every five y~. by verification that the individual's ASNT level 111 certificate is current for the method.

Note: IWA-2313,1989 Edition, requires LevelI,11 recertification by qualification examinations every three years and Level til recertification by quahfication exarninations everyfive years.

9.--Records 9.1 Responsibility for Documentation CP-189 requires the employer to document certifications in accordance with CP-189.

SNT-TC-1 A leaves this to the employers written practice.

9.2 Contents of Documentation 9.2.1 Certification Record CP-189 req:..rements are similar to those of SNT-TC-I A except that a copy of the level Ill's ASNT cenificate must be included and the results of all employer examinations that the individual has taken must be documented.

9.2.2 NDT Training Record 1 CP-189 has very explicit requirements, whereas SNT-TC-1 A requirements are not very explicit with regard to training records, j 9.2.3 Experience Record CP-189 requirements are similar to SNT-TC-1 A but more explicit.

9.2.4 Record of Previous Experience CP-189 requires documentation if previous training or experience are being used to satisfy any part of the requirements of CP-189. SNT-TC-1 A lumps all experience into one category and is not very precise about the details of its documentation.

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,; Cooper Station 1st Interval-Jo Containment inspection Program

CONTAINMENT INSPECTION REl,IEF REQUESTS l ANSI /ASNT CP-189 91 COMPARISON WITH SNT-TC-1A _;

10 Referenced Publications .

, 10.1 CP-189, by referencing th'e documents listed below, has incorporated the provisions of these

~

documents into CP-189. l e ASNT Recommended Practice SNT-TC-1 A,1988 Edition.- i

+ ASNT Level 111 Certification documents CP 3-89, CP-4-86, CP-5 89, CP-6 86 i

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. Containment inspection Program CONTAINMENT INSPECTION RELIEF REQUESTS RELIEF REQUEST NUMBER: RC-02, REVISION 0 i CMIPONENT IDENTIELCATION Code Class: MC

References:

IWE-2500, Table IWE-2500-1 Examination Category: ED ltem Numbers: E5.10. E5.20, E5.30

Description:

Seals and Gaskets -

Component Numbers: N/A ,

CODE REQUIREMENT IWE-2500: Table IWE-25001 requires seals and gaskets on airlocks, hatches, and other devices to

- be visually examined (VT-3) once each interval to assure containment leak-tight integrity.

lIASIS FOR RELIEE Specific relief is requested on tir: basis that (Se proposed alternative would provide an acceptable level of quality and safety.

Seals and gaskets receive a 10 CFR 50 Appendix J, test. As noted in 10 CFR 50 Appendix J, the purpose is to measure leakage of containment or penetrations whose design incorporates resilient seals, gaskets, sealant compounds, and electrical penetrations fitted with flexible metal seal assemblies. Physical examination of the seals and gaskets require the joints, which are proven adequate through Appendix J testing to be disassembled. For electrical penetrations, this would involve a pre-maintenance Appendix J test, determin.uion of cables at electrical penetrations if enough cable slack is not available, disassembly of the joint, removal and examination of the seals and gaskets, reassembly of the joint, re-termination of the cables if necessary, post maintenance testing of the cables, and a post maintenance Appendix J test of the penetration. The work required for the Containment llatches would be similar except for the determination, re-termination, and testing of cables. Not only does this require the use of outage staff hours, but also imposes the risk that equipment could be damaged. The 1992 Edition,1993 Addenda, of Section XI recognizes that disassembly of joints to perform these examinations is not warranted. Note 1 in Examination Category E-D was modified to state that sealed or gasketed connections need not be disassembled solely for performance of examinations. Ilowever, without disassembly, the most of the surface of the seals and gaskets would be inaccessible.

For those penetrations that are routinely disassembled, a Type B test is required upon final assembly

- and prior to start-up. Since the Type B test will assure the leak integrity of the connection, the performance of a visual examination would not increase the level of quality or safety.

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-m Containment Inspectic.: Program CONTAINMENT INSPECTION REl.lEF REQUESTS REl,lEF REQUEST NUMHER: RC-02, HEYlSION 0. CONTINUED Seals and gaskets are not part of the containment pressure boundary under current Code rules (Nii-2110 (b)). When the airlocks and hatches containing these materials are tested in accordance with 10 CFR 50, Appendix J, degradation of the seal or gasket material would be revealed by an increase in the leakage rate. Corrective measures would be applied and the component retested.

Furthermore, repair or replacement of seals and gaskets is not subject to Code rules in accordance with IWA-4111(b)(5)(1992 lidition,1992 Addenda).

The visual examination of seals and gaskets in accordance with IWII-2500. Table IWi!-25001 is a burden without any compensating increase in the level of sately or quaiity.

Relief is requested in accordance with 10 CFR 50.55a(a)(3)(ii), compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

ALIERNATIVE EXAMINN[jQN(S)2 f

As an alternative, the leak-tightness of seals and gaskets will be tested in accordance with 10 CFR 50, Appendix J. No additional alternatives to the visual examir,ation, VT-3, of the seals and gaskets will be performed.

APPLICAllLE TIME PERIOD Relief is requested for the first ten year interval of the Containment inspection Frogram for CNS.

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• Containment Inspection Program CONTAINMENT INSPECTION RELIEF REQUESTS RELIEF REQUEST NUMilER: RC-03, REVISION 0 COMPONENT IDENTIFICATION Code Class: MC

References:

IWE-2200(g), IWE-2500(b)

Examination Category: N/A Item Numbers: N/A DescHption: Visual Examination of Paint or Coatings Couponent Numbers: N/A CODE REQUIREMENT IWE-2200(g) requires that when paint or coatings are reapplied, the condition of the new paint or coating shall be documented in the preservice examination records.

IWE-2500(b) requires that when paint or coatings are to be removed, the paint or coatings shall be visually examined in accordance with Table IWE-2500-1 prior to removal.

HASIS FOR RELIEF Paint and coatings are not part of the containment pressure boundary under current Code rules because they are not associated with the pressure retaining function of the component (NE-2110(b)(5). Neither paint nor coatings contribute to the structural integrity or leak tightness of the containment. Furthermore the paint and coatings on the containment pressure boundary were not subject to Code rules when they were originally applied and are not subject to ASME XI rules for repair or replacement (IWA-4111(b)(5)). The adequacy of applied coatings is verified through the CNS Primary Containment Maintenance Painting Procedure. This procedure provides administrative controls for the qualification of painters, surface preparation, paint application, and painting inspection Recording the condition of a reapi ed li coating in the preservice record is redundant to this procedure and does not substantiate the containment structural integrity. Should de.:rioration of the coating in the reapplied area occur, the area will require additional evaluation regardless of the preservice record. Furthermore, additional measures would have to be employed to determine the nature and extent of any degradation, if present. The application of ASME XI rules for the removal of paint or coatings when unrelated to a Section XI rep:ir or replacement activity is a burden without a compensating increase in the level of quality or safety.

SECY 96-080, response to Comment 3.2 regar: ling IWE-2200(g) states, "In the NRC's opinion, this does not mean that a visual examination must be performed with every application of paint or coating. A visual examination of the topcoat should be sufficient."

Relief is requested in accordance with 10CFR50.55a(a)(3)(i). The CNS Pcimary Containment Mainternance Painting Procedure provides an adequate level of quality and safety.

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' Containment inspection Program CONTAINMENT INSPECTION RELIEF REQUESTS RELIEF REQUEST NUMBER: RC-03, REVISION 0, CONTINUED EROPOSED ALTERNATE EXAMINATIOS Paint or coatings will be inspected in accordance with the CNS Primary Containment Maintenance Painting Procedure requirements. If degradation of the coating is identified, additional measures will be applied to determine if the containment pressure boundary is affected. Although repairs to paint or coatings are not subject to the repair / replacement rules of ASME XI, repairs to the primary containment boundary, if required, would be conducted in accordance with Code rules.

AEPLICABLE T1.\lE PERIOD Relief is requested for the first ten-year interval of the Containment inspection Program for CNS.

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' Containment inspection Program CONTAINhlENT INSPECTION REl.lEF REQUESTS REl,lEF REQUEST NUS1HER: RC-04, REVISION 0 COh1N)NENT ll)ENTIFICATION Code Class: MC

References:

IWE-2420(b), IWE-2420(c)

Examination Category: N/A Item Numbers: N/A

Description:

Successive Examinations Component Numbers: N/A CODE REQUIREh1ENT IWi/2420(b) and IWE-2420(c) state that when component examination results require evaluation of Daws, areas of degradation, or repairs in accontance with IWE-3000, and the component is found to be acceptable for continued service, the areas containing such flaws, degradation, or repairs shall be reexamined during the next inspection period listed in the schedule of the inspection program of IWE-2411 or IWE-2412, in accordance with Table IWE-2500-1, Examination Category E-C.

BASIS FOR RELIEl<

The purpose of a repair is to restore the component to an acceptable condition for continued service in accordance with the acceptance standards of IWE-3000. IWA-4150 requires the owner to conduct an evaluation of the suitability of the repair including consideration of the cause of failure. This requirement for successive examination presupposes that the rcpair was not suitable. If the repair has restored the component to an acceptable condition, successive examinations are not warranted.

If the repair was not suitable, then the repair does not meet code requirements and the component is not acceptable for continued service. Neither IWib2420(b), IWC-2420(b), nor LWD-2420(b) requires a repair to be subject to successive examination requirements. The successive examination of repairs in accordance with IWE-2420(b) constitutes a burden without a compensating increase in quality or safety, in SECY 96-080, response to Comment 3.3 regarding IWE-2420, the NI?C stated, "The purpose of IWE-2420(b) is to manage components found to be acceptable for continued seivice (meaning no repair or replacement at this time) as an Examination Category E C component...lf the component had been repaired or replaced, then the more frequent examination would not be needed."

Relief is requested in accordance with 10CFR50.55a(a)(3)(ii). Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

PROPOSED ALTERNATE EXAh11 NATION Successive examinations in accordance with IWE-2420(b) are not required for repairs made in accordance with IWA-4000.

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• - Containment inspection Program  :

CONTAINNIENT INSPECTION RELIEF REQUESTS RELIEF HEQUEST NUS111ER: RC 04, REVISION 0, CONTINUED AITLLCAllLE.1131E.I'ERIOD Relief is requested for the first ten-year interval of the Containment Inspection Program for CNS.

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.*. Containment inspection Program CONTAINMENT INSPECTION RELIEF REQUESTS REl lEF REQUEST NUMHER: RC-05, REVISION 0 COM]DNENT IDENTIFICATION Code Class: MC

References:

IWE 2500, Table IWE-2500-1 Examination Category: EG ltem Numbers: E8.20

Description:

lloited Connections Component Numbers: All CODE REOUIREh]ENT IWE-2500, Table IWE 2500-1 requires bolt torque or tension tests to be performed on 100% of the bolts when the connection has not been disassembled and reassembled during the interval.

]) ASIS FOR RELIEE The bolted connections are leak rate tested i1 accordance with 10CFR50 Appendix J to demonstrate the leak sight integrity of the connection. In addition the bolted connections are visually examined once per interval. No other subsection of ASME XI requires torque tests of bolted connections. An in situ test of an undisturbed connection would be 'neaningless. Paint or corrosion on the bolted connection would result in a higher indicated torque and would not be representative of the preload on the connection, in order to perform a torque test the connection would have to be disassembled, the bolt cleaned, the gasket or seal replaced, the connectior cassembled, and then retorqued.

Another leak rate test would also be required after the connection was reassembled. The 10CFR50 Appendix J test itself proves that the bolt torque or tension remains adequate to provide a leak rate within acceptable limits. The torque or tension value of bohing only becomes an issue if the leak rate is excessive. Once a bolt is torqued or tensioned it is not subject to dynamic loading that could cause it to experience significant change. The torque or tension testing of bolting constitutes a burden without d compensating increase in quality or safety.

Relief is requested in accordance with 10CFR50.55a(a)(3)(ii). Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety.

IMQ]OSED ALTERNATE EXAMINATION The following examinations and tests required by Subsection IWE ensure the structural integrity and leak-tightness of Class MC pressure retaining bolting, and, therefore, no additional alternative examinations are proposed:

_(1) Exposed surface of bolted connections shall be visually examined in accordance with the requirements of Table IWE-2500-1, Examination Category E-G, Pressure Retaining Bolting, Item No. E8.10, and (6-17) - Revision 0 ,

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• . Containment inspection Program.

CONTAINMENT INSPECTION RELIEF REQUESTS REl.lEF REQUEST NUMBER: RC-05, REVISION 0, CONTINUED ,

l (2) Iiolted connections shall meet the pressure test requirements of Table IWE-2500-1, Examination '

l Category E-P All Pressure Retaining Components, item E9.40, and

+

(3) A general visual examination of the :ntire containment shall be conducted each inspection period in accordance with 10 CFR 50.55a(b)(2)(x)(E).

APPLICABLE TIAIE PFalOD Relief is requested for the first ten-year interval of the Containment Inspection Program for CNS.

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Cooper Station 1st Interval Containment inspection Program CONTAINMENT INSPECTION RELIEF REQUESTS RELIEF REQUEST NU5!HER: RC-06, REVISION 0 COMPONENT IDENTIFICATION

, Code Class: MC

References:

IWE-5240 Examination Category: E-P ltem Numbers: All

Description:

VT-2 Visual Examination Component Numbers: All CODE REOUlitEMENT IWE-5240 states that the requirements of IWA-5240 are applicable following repair, replacement, or modification. IWA-5240 requires a visual examination, VT-2 in conjunction with the pressure test.

IIAS11 EOR RELIEF Paragraph IWE-5210 states that, except as noted within Paragraph IWE-5240, the requirements of Article IWA-5000 are not applicable to Class MC components. Paragraph IWE-5240 states that the requirements of IWA 5240 are applicable. Paragraph IWA-5240 requires a "VT-2" visual examination. VT-2 examinations are conducted to detect evidence of leakage from pressure retaining components, with or without leakage collection systems, during the conduct of a system pressure test, in addition, personnel performing VT-2 examinations are required to be qualified in accordance with Subarticle IWA-2300 at ASME Section XI. Table IWE-2500-1, Category E-P, identifies the examination method as 10CFR50 Appendix J, and does not specifically require a VT-2 visual examination.10CFR50 Appendix j provides the requirements for testing as well as the acceptable leakage criteria. These tests are performed by qualified test personnel using calibrated equipment to determine the leakage rate. In addition,10CFR50.55a(b)(2)(x)(E) requires a general visual examination of the containment each inspection period. This inspection would identify any structural degradation the may contribute to leakage. A VT-2 visual examination will not provide additional assurance of safety beyond that of current Appendix J requirements.

Relief is requested in accordance with 10CFR50.55a(a)(3)(i). Pressure testing in accordance with 10CFR50 Appendix J, provides an adequate level of quality.

PROPOSED AIJERNATE EXAMINATK)N Pressure testing shall be conducted in accordance with 10CFR50 Appendix J in lieu of Paragraph APPI.ICAHLE TIME PEIRQI)

Relief is requested for the first ten-year interval of the Containment inspection Program for CNS.

IWE-5240.

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• - ContainmentInspectionProgram 7.0 LIST OF APPLICAHl.E DRAWINGS AND DIAGRAMS CB&l TITLE OF DIAGRAhi DRAWING NUhiBER S

68-2211 Sh 1-116 Suppression Containtnent Vessel 05241 Sh 1-131 hiark i Torus hiodifications 117C3346 Penetration Seal-hiedium Voltage Power l 117C3364 Electrical Penetration-Neutron hionitoring CNS-PC-54 Torus Electrical Penetrations (X209A-D) i 4

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" Containment Inspection Program 8.0 NONDESTRUCTIVE EXAMINATION PROCEDURE LISTING The following nondestructive examination (NDE) procedures are used by the CNS Containment inspection Program. All NDE procedures listed below are on file at CNS. The most current revision of a referenced procedure approved by the CNS Station Operations Review Committee (SORC) will be used CNS reserves the option to use other procedures than those listed provided they meet Code requirements and are approved by SORC and the Authorized Nuclear Inservice inspector (ANil),

PROCEDURE REVISION PROCEDURE

, EUMiiER EQ TITLE VT-CNS 100 0 Procedure for General Visual Examination VT-CNS 101 0 Procedure for VT-1 Visual Examination VT-CNS-103 0 Procedure for VT-3 Visual Examination ___

GE-UT-600 0 Procedure for Ultrasonic Thickness Measurements of Nuclear Components GE-UT-601 0 Procedure for Ultrasonic Thickness Measurements for Erosion / Corrosion GE ADM 1001 0 Procedure for Performing Linearity Checks on Ultrasonic Instruments GE-ADM-1002 0 Procedure for Review Process and Analysis of Recorded Indications GE-ADM-1005 0 Procedure for Zero Reference and Data Recording for Non-Destructive Examination (8-1) Revision 0

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• - ContainmentInspectionProgram 9.0 COMPONENT EXAMINATION SUMMAltY LISTING All portions of the primary containment potentially subject to inservice NDE examination under this program are contained in the following Tables.

The tables identify those components selected for examination during the third inspection interval and provides a sched ale by period, for the applicaSle required examination to be performed. The components selected are those scheduled to be examined during the third interval. The total number of components for each Code Category and item number are provided in the tables.

Where regulatory requirements or specific CNS commitments impose additional examinations or use NDE techniques exceeding Cede requirements, these augmented requirements are shown in the tables. The examination data will be used to satisfy both Code and augmented requirements.

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Co , Stanon taineen,w ,

t Contamme,* in.oecnon program .

COMPONENT EXAMINATION SCHEDULE .

Contamumt Section Code Code Exam Method Schedule Relief Drawing Number Remarks Cat- Item Date Request Contartnert mael E-A E111 General Visual RF018 RA 68-R11 Sh 1 Once each penod. pnar to each Type A Test .f Drywen Heed E-A E1.12 VT-3 RFO24 N/A 68-2211 SK3 Accessbie fmm both sdes

, 04eed Flange E-A E1.12 VT-3 RFO24 N/A 68-2211 Sh 11 Accessable from both sedes .i Lower Bulb E-A E112 VT-3 RF024 N/A 68-2211 Sh 6 Below equator (911 ft) l

. Rrig Girder Attachment Weids E-A E1.12 VT-3 RFO23 WA 68-2211 Sh 15 includes overlay areas shown on Dwgs 05241 Sh 31-39 '[

Saddle Attachment Weids E-A E1,12 VT-3 RFO23 N/A 05241 Sh 100-131 -1 Shed Flange E-A E1,12 VT-3 RFO24 N'A 68-2211 Sh 11 Accessable from both sdes Stabitaer Attachment Weios E-A E1.12 VT-3 RF024 N'A 68-2211 Sh 16 817 Support Column Attachment Welds E-A E112 VT-3 RFO23 KA 68-2211 Sh 52 {

t iTorus Sectm A E-A . E1,12 VT-3 RF023 N/A 68-2211 Sh 50-54 Accessde from both sades. Ad,acent to Vent Heeder X5A Vorus Sectm B E-A E1.12 VT-3 RFO23 N/A 68-2211 Sh 50-54 Accessule from both sdes. Adpecent to Vent Heeder X5B 't Tous Sechon C E-A E1,12 VT-3 RF023 KA 68-2211 Sh 50-54 Accessde frorn both sades. Adjacent to Vent Hender X5C  ;

Torus Sectm D E-A E1.12 VT-3 RFO23 4A 68-2211 Sh 50-54 Accessde from oath sades Adgacent to Vent header X5D .I Torus Sechon E E-A E1.12 VT-3 RFO23 EA 68-2211 Sh 50-54 Accessbe from both sdes. Adpacent to Vent Header X5E i Torus Secta F E-A E1.12 VT-3 RF023 NA 68-2211 Sh 50-54 Accessable from both sedes. Adpacent to Vent Header X5F  !

Torus Secta G E-A E112 VT-3 RFO23 NA 68-2211 Sh 50-54 Accessde from both sdes Adpacent to Vent HeaderX5G Torua Sectm H E-A E1.12 VT-4 RFO23 NA 68-2211 Sh 50-54 Accessbe from t,ath sedes Adgacent to Vent Header X5H j Upper Bulb E-A E1.12 VT-3 RF024 N'A 68-2211 Sh 6 Above equator (911 ft)  !

' i Upper Cyhnder E-A E1.12 VT-3 RF024 NA 68-2211 Sh 6 h- se X5A E-A E120 VT-3 RF023 N/A 68-2211 Sh 56 5 Pars per Torus Serton Downcomers X5B E-A E120 VT-3 RFO23 N 'A 68-2211 Sh 56 5 Pars per Torus Secbon '}

Downcomers X5C E-A E120 VT-3 RF023 KA 68-2211 Sh 56 S Pars pe Torus Sechert Dawrmomers X5D E-A E120 VT-3 RFO23 N 'A 38-2211 Sh 56 5 Parrs per Torus Secte :l C- w.sa X5E E-A E120 VT-3 RF023 RA 68-2211 Sh 56 5 Pars per Torus Sectm ,

h w,isa X5F E-A E120 VT-3 RF023 N/A 68-2211 Sh 56 5 Pan per Torus Sechon.

h wsa X5G E-A E1.20 VT-3 RF023 MA 68-2211 Sh 56 5 Pars per Torus Sectori Downcomers X5H E-A E120 VT-3 RF023 N/A 68-2211 Sh 56 5 Pars per Torus Sedtert i Drartage Channets E-A E120 VT-3 N/A NA 68-2211 Sh 50-54 Insped with associated weit heeder piping Etpension Belows X5A E-A E120 VT-3 RF024 N/A 68-2211 Sh 66 Expansion Bekms X58 E-A E120 VT-3 RFO24 WA 68-2211 Sh 66 Expansion Belows X5C E-A E120 VT-3 RF024 N/A 68-2211 Sh 66

• Expansion Belows X5D E-A E120 VT-3 RF024 N 'A 68-2211 Sh 66 j Eapansion Belows X5E E-A E120 VT-3 RF024 MA 68-2211 Sh 66 Expansson Belows X5F E-A E120 VT-3 RF024 WA 68-2211 Sh 66  !

Expansion Belows X5G E-A E120 VT-3 RF024 NA 68-2211 Sh 66 B:pansion Bekms X5H E-A E120 VT-3 RF024 WA 68-2211 Sh 66 i Vent Hender Support Attachment Wetds E-A E120 VT-3 RFO24 N/A 68-2211 SH 52 .

t Vent Header X5A E-A El20 VT-3 RF024 N/A $8-2211 Sh 50-54 includes flow channeing dences [

Vent Header X5B E-A E120 VT-3 RF024 N/A 68-2211 Sh 50-54 includes flow c-4 devices  !

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4 Cooper Stuen tointen,al -

Cm.s.anspect,on Program .

COMPONENT EXAMINATION SCHEDUU: .

ContaenmeM Section ' Code Code . Esam Method Schedule Reisef Drawing Number Remarks i Cat. Item Date Request Vent Heeder X5C E-A E120 VT-3 RF024 EA -

68-2211 Sh 50-54 includes firir c r sa 9 dewees Vent Header X50 E-A E1.20 VT-3 RF024 MA 68-2211 Sh 50-54 includes flow Jm.a 9 dewees Vent Header X5E E-A E1.20 VT-3 RF024 N'A 68-2211 Sh 50-54 includes flow J .as dewees vert Header X5F E-A E1.20 VT-3 RF024 N/A 68-2211 Sh 50-54 includes flow channefog dewces ,

Vent Header X5C E-A E1.20 VT-3 RF024 MA 68-2211 Sh 50-54 include- flow C. .a 9 dewees Vent Header X5H E-A E1.20 VT-3 RFO24 NA 68-2211 Sh 50-54 includes flow channeing dewees  !

Nurr" 7 of Sections in Caiw E-A = 45 '

Shea Flange E-C E411 VT-1 RFO18 WA 68-2211 Sh 11 Surface sutrne ged dunng refuehng operabons Torus Submerged Section A E-C E411 VT-1 RF018 KA 68-2211 Sh 50-54 Random areas of surface corrosson and locahzed peng Torus Submerged Secten B E-C E411 VT-1 RF018 MA 68-2211 Sh 50-54 Random areas of surface corrosen and locahzed peng Torus Submerged Section C E-C E411 VT-1 RF018 N/A 68-2211 Sh 50-54 Rar.Jom areas o' surface corrosson and locahzed pat!ng Torus Submerged Section D E-C E411 VT-1 RFO13 MA 68-2211 Sh 50-54 Random areas of surface corrosson and locakzed peng Varus Submerged Secten E E-C E411 VT-1 RFO18 N/A 68-2211 Sh 50-54 Random areas o rsurface corrosson and locahzed peng Torus Submerged Secton F E-C E411 VT-1 RFO18 WA 68-2211 Sh 50-54 Random areas of surface corrosen and locaRzed peng Torus Submerged Sectron G F-C E411 VT-1 RF018 MA 68-2211 Sh 50-54 Random areas of surface corrosson and iocahzed peng (

Torus Submerged Secton H E-C E411 V'-1 RFO18 N/A 68-2211 Sh 50-54 Random areas of staface corrosen and locahzed peng Vrssble Surfaces E-C E411 VT-1 NA NA No a eas adenhfed for augmerwed exams at thrs trne.  !

Surface Areas E-C E4.12 UT MA N/A No areas identified for augmented exams at thrs tee.  ;

Number of Sections in Category E-C = 11 CRD Hatch (X-6) E-D E510 VT-3 NA RC-02 68-2211 Sh 13 i Elec2rtcal Penetraton Seats E-D E5.10 Exempt N/A CT05  ;, e for wsualexamna%n y

, Electtcal Pseeb= E-D E510 VT-3 MA CT-05 117C3346  !

Bottom Manway (X-3) E-D E5.20 VT-3 WA MA 68-2211 Sh 21 Inaccessde Sealwelded closed i Equipmerd Hatch (X1-A) E-D E520 VT-3 MA RC-02 68 2211 Sh 13 Equipment Hatch (X1-B) E-D E5.20 VT-3 N/A RC-02 68-2211 Sh 13 Hea6 Manway (X-4) E-D E520 VT-3 KA RC-02 68-2211 Sh 21 Personnel Asrtock (X-2) E-D E520 VT-3 N/A RC42 68-2211 Sh 100 i Torus Manway (X-200A) E-D E5.20 VT-3 4A RC-02 68-2211 Sh 70 i TcJus Manway (X-2008) ED E5.20 VT-3 N/A RC-02 68-2211 Sh 70 Mositure Bamer E-D ES 30 Exeiipt M;A RC-02 No intemal moisture bemer present j Number of Sections in Category E-D = 11 Drywell Flange Botting E-G E810 VT-1 RF019 MA 68-2211 Sh 11 76 Nuts, Bolts, ard Spbencal Washer Sets  ;

Eqttpment Hatch (X1-A) Flange Bothng E-G E8.10 VT-1 RF019 N/A 68-2211 Sh 13 17 Diameter Testable FlangWth 8 Sets of 1-1/4" Eyebolts and Nuts Equipment Hatch (X1-8) Flange Boling E-G E810 VT-1 RF022 N/A 68-2211 Sh 13 17 Diameter Testable Flange with 8 Sets of 1-1/4" Eyebolts and Nuts i Head Manway (X-4) Flange Boltng E-G EB10 VT-1 RFO24 WA 68-2211 Sh 21 24" RF Testable Flange with 24 Sets of 1-1/8" Nuts and Bolts Stabehzer Assembly (StP-1) Flange Boltog E-G E810 VT-1 RFO19 WA 63-2211 Sh 16 16 Bolts per Flange Stabdtzer Assembly (SIP-2) Flange Boltmg E-G E8.10 VT-1 RF020 N/A 68-2211 Sh 16 16 Bolts per Finnge Stabdizer Assembty (SIP-3) Flange Bo!tmg E-G E810 VT-1 RF020 EA 68-2211 Sh 16 16 Bolts per Flange .

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Cooper Sumn Sst wwve C. :_ .a inapecten Program Cr t COMPONENT EXAMINATION SCHEDULE w

Cositesiment Section Code. Code Enam Mettiod Scletide Rehet Draweig Number Remarks Cat. Item Date Resquest Statzieer Assembly (SIP-4) Flange Borbng E-G E810 VT-1 RF022 NA 68-2211 Sh 16 16 Bolts per Frge StatWeer Assernbly (StP-5) Flange Bolung - E-G E8to VT-1 RFO22 NA B2211 Sh 16 16 Pctts per Finnge I

Statdeer Assemtfy (SIP-6) Flange BotMg E-G EB10 VT-1 RF022 WA 68-2211 Sh 16 16 Bolts per Flange Statzleer Assembly (StP-7) Flange Bolung E4 .ES10 VT-1 RFO24 NA J 662211 Sh 16 16 Bolts per Flange hh*w Assembly (S.P-8) Flange Bortmg E-G EP.10 VT-1 RF024 KA 68-2211 Sh 16 16 Bolts per Flange ,

Torm Manway (X-200A) Flange Boltng - E-G E8to VT-1 RFOM NA 68-2211 Sh 70 4T RF Testable Fearge wet 44 Sets of SW Nuts and Bolts 'l Torus Marmey (X-2038) Flange Boitry E-G E810 VT-1 P"O22 MA ' 60-2211 Sh 70 47 RF Testab4e Flange wet 44 Sees of SF Nuts and Bolts Drywe5 Flange Bolbng - E-G EB 20 Torque Test NA RC45 68-2211 Sh 11 Requred miess drsasse%ied and reessembled dunng the mtervat

. Equipment Hatch (X1-A) Flange softng E-G E8 20 Torque Test NA RC-05 68-2211 Sh 13 Regianrj unless drsassentwed and reessembled dunng the rile' val Equpment Hatch (X1-B) Flange Bothng E-G E820 . Torque Test MA RC-05 68-2211 Sh 13 Requrred uniess drsassembled and reessembled dunng the reerval. ,

Head Manway(X-4) Flange Bofbng E-G E820 Torque Test NA RC-05 68-2211 Sh 21 Regi.ared unless drsassembled and reessembled dunng the riterval  !

f Stabduer Assembey (SfP-1) Flange BoFrg E-G E820 Torque Test MA RC-05 68-2211 Sh 16 Requred Stabstzer Assembly (S!P-2) Flange Borbng E-G E8 20 Torque Test RA RC-05 68-2211 Sh 16 Requred '

Stabdizer Assembly (SIP-3) Flange Bottng E-G EB20 Torque Test MA RC45 68-2211 Sh 16 Requred l Satuleer Assemb!y (SIP-4) Flange Bortng E-G E8 20 Torque Test RA RC-05 68-2211 Sh 16 Requred i Statxhzer Assembly (SIP-5) Flange Bolung E-G E8 20 Torque Test KA RC-05 68-2211 Sh 16 Requred -

Statalizer Assembly (SIP 4) Flange Bothng E-G E8 20 Torque Test N/A RC-05 68-2211 Sh *6 Requered Statwijzer Assembly (SIP-7) Flange Bortng E-G E8.20 Torque Test WA RC-05 68-2211 Sh 16 Requred Statwkzer Assembly (SIP-8) Flange Bo#tng E-G E8.20 Torque Ted - MA RC-05 68-2211 Sh 16 Requred f Torus Manway(X-200A) Flange Boltog E-G E820 Torque Test KA RC-05 68-2211 Sh 70 Requred unless drsasser'ibled arwd reessembled dunng the interval j Torus Manway (X-2008) Flange Bolung E-G E820 . Torque Test TA RC-05 68-2211 Sh 70 Requred tTiless dh.and reassembled dunng the interval  ;

Number of Sections in Category E-G = 28 -

Contamment Vessel Pressure Test E-P' E910 Type A RFO18 N/A RA Conducted b accordance with 10CFR50 Appenda J f

Penetration Beaows Pressure Tests E-P E920 Type B Each MA NA Conducted n accordance who 10CFR50 Appendtz J Arlock Pressure Tests FP E9 30 Type B Each WA NA Conducted in accordance wet 10CFRSO Appendru J [

Seals and Gaskets Pressure Tests t. -P E9 40 Type B Each N/A KA Conducted in accordance w'th 10CFRSO Appenda J .i Number of Sections in Category E-P = 4 [

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. - ContairunentInslu;tionPingnun 10,0 INDEX OF AilllRlWIATIONS Ahlsretlationi Description MC Metal Containment l'C l'rimary Coataintnent Pl!NT Penetration SIP Stabillier inspection Port I

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(10-1) Revision 0

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