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{{Adams
#REDIRECT [[L-MT-11-056, 10CFR50.55a Requests Associated with the Fifth Lnservice Inspection Ten-Year Interval]]
| number = ML112720147
| issue date = 09/28/2011
| title = 10CFR50.55a Requests Associated with the Fifth Lnservice Inspection Ten-Year Interval
| author name = O'Connor T J
| author affiliation = Northern States Power Co, Xcel Energy
| addressee name =
| addressee affiliation = NRC/NRR, NRC/Document Control Desk
| docket = 05000263
| license number = DPR-022
| contact person =
| case reference number = L-MT-11-056
| document type = Codes and Standards, Letter
| page count = 15
}}
 
=Text=
{{#Wiki_filter:@ Xcel EnergyB September 28, 201 1 Monticello Nuclear Generating Plant 2807 W County Rd 75 Monticello, MN 55362 L-MT-11-056 10 CFR 50.55a(g)
U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Monticello Nuclear Generating Plant Docket 50-263 Renewed License No. DPR-22
 
==Subject:==
1 OCFR50.55a Requests Associated with the Fifth lnservice Inspection Ten- Year Interval Pursuant to 10 CFR 50.55a, "Codes and standards," paragraphs (a)(3)(i) and (g)(4)(iv), the Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy, hereby requests NRC authorization or approval of the enclosed 10CFR50.55a requests associated with the Fifth lnservice lnspection (ISI) Interval for Monticello Nuclear Generating Plant (MNGP). The fifth interval of the MNGP, IS1 program will comply with the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI, 2007 Edition with the 2008 Addenda.
The latest edition and addenda of the code incorporated by reference in 1 OCFR50.55a(b)(2) of the regulation is the 2007 Edition with the 2008 Addenda. Proposed Alternative No. RR-002 requests authorization to implement ASME Code Case N-702 to perform Class 1 nozzle-to-vessel weld and nozzle inner radii examinations on the Reactor Vessel. Proposed Alternative No. RR-007 requests approval to utilize the 2007 Edition with 2008 Addenda of ASME Section XI for the performance of repairlreplacement activities of items within the scope of the IWE program. The bases for these 10CFR50.55a requests are provided in Enclosures I and 2 respectively.
10CFR50.55a requests similar or identical to RR-002, and RR-007 have previously been approved for use at MNGP. NSPM requests authorization or approval of these 10CFR50.55a requests by September 1, 2012, to support implementation of the fifth ten-year IS1 interval. These 10CFR50.55a requests are proposed for the duration of the IS1 fifth ten-year interval.
Document Control Desk Page 2 This letter makes no new commitments and no revisions to existing commitments.
If you have any questions or require additional information, please contact Mr.
Randy Rippy at 61 2-330-691
: 1. ~onticev ~uclear Generating Plant Northern States Power Company-Minnesota Enclosures (2) cc: Administrator, Region Ill, USNRC Project Manager, Monticello Nuclear Generating Plant, USNRC Resident Inspector, Monticello Nuclear Generating Plant, USNRC ENCLOSURE I 10 CFR 50.55a Request No. RR-002 Proposed Alternative In Accordance With 10 CFR 50.55a(a)(3)(i) Which Provides an Acceptable Level of Quality and Safety Alternative to the Requirements of Examination Category B-D I .O ASME Code Component(s)
Affected Code Class: 1 Component Numbers:
N2, N3, N5, N6, & N8 Nozzles with associated Inner Radius Sections (See Attachment 1 for complete list of nozzle identifications) Examination Category:
B-D Item Number(s):
B3.90 & B3.100
 
== Description:==
Alternative to ASME Section XI, Table IWB-2500-1, Examination Category B-D, with the use of Code Case N-702 (for components described above) 2.0 Applicable ASME Code Edition and Addenda The Monticello Nuclear Generating Plant (MNGP) will start the Fifth 10-year lnservice lnspection (ISI) Program Interval on September 1, 2012 and is required to follow the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI, "Rules for lnservice lnspection of Nuclear Power Plant Components," (ASME Section XI), 2007 Edition with the 2008 Addenda. 3.0 Applicable Code Requirement Table IWB-2500-1, "Examination Category B-D, Full Penetration Welded Nozzles in Vessels" Class 1 nozzle-to-vessel weld and nozzle inner radii examination requirements are given in ltem Numbers B3.90 "Nozzle-to-Vessel Welds" and B3.100 "Nozzle Inside Radius Section." The required method of examination is volumetric.
All nozzles with full penetration welds to the vessel shell (or head) and integrally cast nozzles require examination each interval.
All of the nozzle assemblies identified in Attachment 1 have full penetration welds to the vessel shell or head. Page 1 of 11 L-MT-I 1-056 Enclosure I 4.0 Reason for Request Attachment 1 provides a complete listing of the Reactor Pressure Vessel (RPV) Nozzles that are subject to this request for alternative examination. The proposed alternative provides an acceptable level of quality and safety, while also permitting a significant reduction in required examination scope and related impacts throughout the fifth 10-Year IS1 Program Interval.
5.0 Proposed Alternative and Basis for Use Proposed Alternative:
Pursuant to 10 CFR 50.55a(a)(3)(i), an alternative is requested from performing the required examinations on 100% of the nozzle assemblies identified in Table 5-1 below (See Attachment 1 for a detailed list of RPV Nozzles included in this alternative). As an alternative for examination of welds and inner radii on all the nozzle assemblies identified in Table 5-1, Northern States Power - Minnesota (NSPM) proposes to examine a minimum of 25% of the MNGP nozzle-to-vessel welds and inside radius sections, including at least one nozzle from each system and nominal pipe size, in accordance with ASME Code Case N-702. For the nozzle assemblies identified in Table 5-1, this would mean that examination would be required for three of the Recirculation lnlet (N2) nozzles and one from each of the other nozzle groups, as identified below. Table 5-1 ASME Code Case N-702 stipulates that a VT-1 examination may be used in lieu of the volumetric examination for the inner radii (i.e., Item No. B3.100, "Nozzle Inside Radius Section"). However, NSPM is only requesting to perform volumetric examination of the applicable nozzle inner radius sections. NSPM is not requesting use of the VT-I examination provisions included in the code case - in lieu of performing volumetric examinations. The NSPM is not currently using ASME Code Case N-648-1 for the identified components for enhanced magnification visual examination and has no plans of using ASME Code Case N-648-1 on those components in the future.
Nozzle Assembly Group Recirculation Inlet (N2) Main Steam (N3) Core Spray (N5) Closure Head (N6)
Jet Pump Instrumentation (N8) Page 2 of 11 Nozzles Per Group 10 4 2 2 2 Minimum Number to be Examined 3 1 1 1 1 L-MT-11-056 Enclosure 1 Examination of the nozzle inside radius will continue to be performed using a volumetric method meeting the requirements of Examination Category B-Dl except that the quantity of nozzles examined are reduced as described in this alternative. Basis for Use:
Electric Power Research Institute (EPRI) Technical Report 1003557, "BWRVIP-108: Boiling Water Reactor Vessel and lnternals Project Technical Basis for the Reduction of Inspection Requirements for the Boiling Water Reactor Nozzle-to-Vessel Shell Welds and Nozzle Blend Radii," (Reference
: 2) provides the basis for ASME Code Case N-702. The evaluation found that failure probabilities at the nozzle blend radius region and nozzle-to-vessel shell weld due to a Low Temperature Overpressure event are very low (i.e., <I x 10" for 40 years) with or without inservice inspection.
The report concludes that inspection of 25% of each nozzle type is technically justified.
This EPRI report was approved by the NRC in a safety evaluation (SE) dated December 19, 2007 (Reference 3). Section 5.0, "Plant Specific Applicability," of the SE indicates that each licensee who plans to request relief from ASME Code, Section XI requirements for RPV nozzle-to-vessel shell welds and nozzle inner radius sections may reference the BWRIP-108 report as the technical basis for the use of ASME Code Case N-702 as an alternative. The NRC SE further states that each licensee should demonstrate the plant specific applicability criteria from the BWRVIP-108 report to its units in the relief request by showing that all the following general and nozzle-specific criteria are satisfied (i.e., as described in Attachment 2):
(1) The maximum RPV heatup/cooldown rate is limited to less than 115&deg;F per hour. MNGP Technical Specification (TS) 3.4.9, "RCS Pressure and Temperature (PPT) Limits, provides a limiting condition for operation (LCO). The heatup/cooldown rate is referenced in the MNGP operating procedures, where applicable, for events such as scrams and start-ups. The maximum heatup/cooldown rate of 100&deg;F per hour is specified within the MNGP Updated Safety Analysis Report in Table 4.1-1, "Reactor Coolant System Data." For Recirculation Inlet Nozzles (see Attachment 2 for MNGP calculated results):
(2) (pr/t)/CRPV<l. 15 where:
p = RPV normal operating pressure r = RPV inner radius Page 3 of 11 L-MT-11-056 Enclosure 1 t = RPV wall thickness and CRpV = 19332 (i.e., 1000 psi x 11 0 inch / 5.69 inch, based on the BWRIP-108 recirculation inlet nozzle
/ RPV finite element method (FEM) model) (3) [p(r: + ri2) / (r: - b2)] / CNOzZLE < 1 .I 5 where: p = RPV normal operating pressure r, = nozzle outer radius ri = nozzle inner radius and CNoZZLE = 1637 [i.e., 1000 psi x (1 3.988' + 6.8752) / (1 3.9882 - 6.8752)], based on the BWRVIP-108 recirculation inlet nozzle
/ RPV FEM model] For Recirculation Outlet Nozzles: (see Attachment 2 for MNGP calculated results):
(4) (pr/t)/CRpv<
I .I 5 where: p = RPV normal operating pressure r = RPV inner radius t = RPV wall thickness and CRpV = 161 71 (i.e., 1000 psi x 11 3.2 inch / 7.0 inch), based on the BWRIP- 108 recirculation outlet nozzle
/ RPV finite element method (FEM) model) (5) [p(r: + b2) / (r: - ri2)] 1 CNOZZLE < 1.15 where: p = RPV normal operating pressure r, = nozzle outer radius b = nozzle inner radius and CNoZZLE = 1977 [i.e., 1000 psi x (22.312 + 12.78~) 1 (22.312 - 12.78~)], based on the BWRVIP-108 recirculation outlet nozzle
/ RPV FEM model] Note that as stated in the NRC SE, only the recirculation inlet and outlet nozzles need to be checked because the conditional probabilities of failure, P(F/E)s, for the other nozzles are an order of magnitude lower. Based on the information contained in Attachment 2, the nozzles listed in Table 5-1 have been demonstrated to meet the general and nozzle-specific criteria in BWRVIP-108 and the NRC SE as described above. As calculated in Page 4 of 11 L-MT-11-056 Enclosure 1
~ttachment 2, the recirculation outlet or suction nozzles (N-I) do not meet the specified criteria and are excluded from this alternative. In addition to the recirculation outlet nozzles that are excluded based on the criteria in Attachment 2, Code Case N-702 specifically excludes feedwater nozzles (N4) and control-rod drive return line (N10) nozzle from the alternative examination requirements.
Therefore, ASME Code Case N-702 is applicable to specific nozzle assemblies as described in this alternative. Use of ASME Code Case N-702 provides an acceptable level of quality and safety in accordance with 10 CFR 50.55a(a)(3)(i) for the RPV nozzle-to-vessel shell full penetration welds and nozzle inner radii sections listed in Table 5-1. 6.0 Duration of Proposed Alternative The proposed alternative will be used for the entire fifth interval of the MNGP lnsewice lnspection Program scheduled to begin on September 1, 2012. 7.0 Precedents The NRC authorized use of this alternative for MNGP during the Fourth 10-Year lnsewice lnspection Interval by letter dated November 24, 2010 (Reference I). The NRC has authorized similar requests for Clinton Power Station, Unit 1 (Reference 4), Dresden Nuclear Power Station, Units 2 and 3 (Reference 5), Columbia Generating Station (Reference 6), Limerick Generating Station, Units 1 and 2 (Reference 7), and Vermont Yankee Nuclear Power Station (Reference
: 8) to adopt Code Case N-702 reduced percentage requirements for nozzle-to-vessel welds and inner radius examinations as an alternative to ASME Section XI, Table IWB-2500-1 criteria.
8.0 References
: 1. NRC Letter, "Monticello Nuclear Generation Plant - Approval of Alternative to Nozzle-to-Vessel Weld and lnner Radius Examinations (TAC No.
ME3527)," dated November 24,201 0 (ADAMS Accession No. ML103190311).
: 2. BWRVIP to NRC letter submitting EPRI report, "BWR Vessel and lnternals Project, Technical Basis for the Reduction of lnspection Requirements for the Boiling Water Reactor Nozzle-to-Vessel Shell Welds and Nozzle lnner Radius
' (BWRIPV-108)," dated November 25, 2002, as supplemented by letters dated July 25,2006, September 13,2007, and November 21,2007. Page 5 of 11 L-MT-11-056 Enclosure 1
: 3. NRC letter to BWRVIP Chairman (R. Libra), "BWRVIP Safety Evaluation of Proprietary EPRl Report, "BWR Vessel and lnternals Project, Technical Basis for the Reduction of lnspection Requirements for the Boiling Water Reactor Nozzle-to-Vessel Shell Welds and Nozzle lnner Radius (BWRIP-108)," dated December 19, 2007 (ADAMS Accession No. ML073600374).
: 4. NRC letter, "Clinton Power Station, Unit No. 1 - Proposed Alternative to 10 CFR 50.55a Examination Requirements for Reactor Pressure Vessel Weld Inspections (TAC No. ME0218)," dated August 24, 2009 (ADAMS Accession No. ML092300394)
: 5. NRC Letter, "Dresden Nuclear Power Station, Units 2 and 3 -Alternative to Nozzle-to-Vessel Weld and lnner Radius Examinations (TAC Nos.ME0882 and ME0883), dated November 3,2009 (ADAMS Accession No. M L092940436)
: 6. NRC letter, "Columbia Generating Station - Request for Relief No. 31SI-09 for the Third 10-Year lnservice lnspection Program Interval (TAC No. MD9850)," dated April 8, 2009 (ADAMS Accession No. ML090790588)
: 7. NRC letter, "Limerick Generating Station, Units 1 and 2 - Proposed Alternative Request RR-13R-14, Nozzle-to-Vessel Weld and lnner Radii Examinations (TAC Nos.
ME3306 and ME3307), dated September 9, 2010 (ADAMS Accession No.
MLI 02390467)
: 8. NRC letter, "Relief Request VY-ISI-014, Alternative Examination Requirements for Nozzle-to-Vessel Weld and lnner Radius using ASME Code Case N-702 -Vermont Yankee Nuclear Power Station (TAC No. ME2909), dated October 1,2010 (ADAMS Accession No.
MLI 02600249)
Page 6 of 11 L-MT-I 1-056 Enclosure 1 Attachment 1 - ASME Components Affected Page 7 of 11 Nozzle ID Nozzle-to-vessel (NV) Inner Radius (IR) N2A (NV) N2A (IR) N2B (NV) N2B (IR) N2C (NV) N2C (IR) N2D (NV) N2D (IR) N2E (NV) N2E (IR) N2F (NV) N2F (IR) N2G (NV) Cateaor Numbe: B-D B- D B-D B-D B- D B-D B- D B-D B- D B-D B-D B-D B- D item ~~~b~~ B3.90 B3.100 B3.90 B3.100 B3.90 B3.100 83.90 B3.100 B3.90 B3.100 B3.90 B3.100 B3.90 Svstem Recirculation (Inlet) Recirculation (Inlet) Recirculation (Inlet) Recirculation (Inlet) Recirculation (Inlet) Recirculation (Inlet) Recirculation (Inlet) Recirculation (Inlet) Recirculation (Inlet) Recirculation (Inlet) Recirculation (Inlet) Recirculation (Inlet) Recirculation (Inlet) Nominal Pipe (Inches) 12 12 12 12 12 12 12 12 12 12 12 12 12 Exam Year (Appendix VIII I PDI) 2009 2009 2007 2007 NIA (1) NIA (1) 2005 2005 2005 2005 NIA (1) NIA (1) 2007 L-MT-11-056 Enclosure 1 Attachment 1 - ASME Components Affected Nozzle ID Nozzle-to-vessel (NV) Inner Radius (IR) Svstem Cateqor Numbey N2G (IR) item Number Nominal Plpe Size (Inches) N2J (NV) N2J (IR) Exam Year (Appendix VIII 1 PDI) B-D N2K (NV) N2K (IR) N3A (NV) N 3A (I R) N3B (NV) N3B (IR) N3C (NV) N3D (IR) B-D B-D N3C (IR) N3D (NV) I B-D / B3.100 I Main Steam 1 18 / NIA (I) I B3.100 pp NIA (1) NIA (1) N2H (NV) B-D 12 B-D B-D B-D B-D B-D B-D B-D N2H (IR) B3.90 B3.100 B-D B-D Page 8 of 11 Recirculation (Inlet) B3.90 83.100 B3.90 B3.100 B3.90 83.100 B3.90 N5A (NV) N 5A (I R) B-D Recirculation (Inlet) Recirculation (Inlet) B3.100 B3.90 12 Recirculation (Inlet) Recirculation (Inlet) Main Steam Main Steam Main Steam Main Steam Main Steam B-D B-D 2007 B3.100 12 12 Main Steam Main Steam 2005 2005 12 12 18 18 18 18 18 B3.90 B3.100 Recirculation (In let) NIA (1) NIA (1) 2005 2005 NIA (1) NIA (1) 2009 18 18 12 2009 NIA (1) Core Spray Core Spray 8 ' 8 NlA(1) NIA (1)
L-MT-11-056 Enclosure 1 Attachment 1 - ASME Components Affected (1) - This nozzle was last examined prior to implementation of Appendix Vlll I PDI Exam Year (Appendix VIIIIPDI) 2005 2005 2007 2007 2009 2009 2005 2005 2009 2009 Nozzle ID Nozzle-to-Vessel (NV) Inner Radius (IR) N5B (NV) N5B (IR) N6A (NV) N6A (IR) N6B (NV) N6B (IR) N8A (NV) N8A (I R) N8B (NV) N8B (IR) Cateqor B-D B-D B- D B-D B- D B-D B-D B- D B-D B-D item Number B3.90 B3. I00 B3.90 B3.100 B3.90 B3.100 B3.90 B3.1 O0 B3.90 B3.100 Svstem Core Spray Core Spray Closure Head Spare Closure Head Spare Closure head Spare Closure Head Spare Jet Pump lnstrumentation Jet Pump lnstrumentation Jet Pump lnstrumentation Jet Pump lnstrumentation Nominal Pipe size (Inches) 8 8 6 6 6 6 4 4 4 4 L-MT-11-056 Enclosure 1 Attachment 2 Verification of Plant Specific Nozzle Applicability to Apply Code Case N-702 to the MNGP in Accordance with BWRVIP-108 (Criteria
: 1) Maximum RPV heatuplcooldown rate limited to less than 115&deg;F per hour The Monticello Updated Safety Analysis Report indicates a maximum heatuplcooldown rate of 100&deg;F per hour. This heatuplcooldown rate is referenced in the MNGP operating procedures, where applicable, such as scrams and start-ups.
MNGP Technical Specification 3.4.9, "RCS Pressure and Temperature (PPT) Limits," provides a limiting condition of operation (LCO). Values for Monticello Recirculation lnlet and Outlet Nozzles: Monticello specific values:
p = RPV normal operating pressure
= I025 psig r = RPV inner radius
= 102.5 inches t = RPV wall thickness
= 5.0625 inches ro = Recirculation'inlet nozzle outer radius
= 14.1875 inches ri = Recirculation inlet nozzle inner radius
= 7.0625 inches ro = Recirculation outlet nozzle outer radius
= 24.375 inches ri = Recirculation outlet nozzle inner radius = 13.0625 inches BWRVIP-108 Constants:
CRpV (Recirculation lnlet Nozzles)
= 19332 CNoZZLE (Recirculation lnlet Nozzles)
= 1637 CRpV (Recirculation Outlet Nozzles)
= 16171 CNOZZLE (Recirculation Outlet Nozzles) = 1977 For the Recirculation lnlet Nozzles (N2): (Criteria
: 2) (prlt) 1 CRpV < 1.15 [(I025 x 102.5) I 5.06251 1 19332 = 1.07351 < 1 .I 5 (Criteria
: 3) [p(r; + ri2) I (r: - ri2)] 1 CNOZZLE < 1 .I 5 [I 025(14.1 8752 + 7.0625~) I (14.1 8752 - 7.0625~)] 1 1637 = 1.03870 < 1.15 Page 10of 11 1-MT-11-056 Enclosure 1 Attachment 2 Verification of Plant Specific Nozzle Applicability to Apply Code Case N-702 to the MNGP in Accordance with BWRVIP-108 For Recirculation Outlet Nozzles (NI): (Criteria
: 4) (prlt) I CRpV < 1.15 [(I 025 x 102.5) I 5.06251 I 16171 = 1.28335 > 1 .I 5 (does not pass) (Criteria
: 5) [p(r: + b2) / (r: - b2)] 1 CNOZZLE < 1.15 [1025(24.375~
+ 13.0625~)
1 (24.3752 - 13.0625*)]
1 1977 = 0.93623 < 1.15 Page I1 of 11 ENCLOSURE 2 1 OCFR50.55a REQUEST RR-007 Request in Accordance with 10 CFR 50.55a(g)(4)(iv) For RepairIReplacement Activities I. ASME Code Compo-nents Affected Class MC components in the ASME Section XI IWE Program at Monticello Nuclear Generating Plant (MNGP) subject to RepairIReplacement activities.
: 2. Applicable Code Edition and Addenda lnservice inspection (ISI) related activities such as pressure testing, and non- destructive examination (NDE) for Class MC Components (IWE) are currently performed at MNGP in accordance with the 2001 Edition with the 2003 Addenda of ASME Section XI for the second 2" IWE Interval scheduled to end September 8, 201 8. RepairIReplacement activities for Class MC Components (IWE) are performed in accordance with the 2001 Edition of ASME Section XI with no Addenda, as authorized under 4th Interval IS1 Relief Request No. 7. 3. Proposed Subsequent Code Edition and Addenda (or Portion) A. Background ASME Section XI lnservice Inspection activities at MNGP are currently being updated in accordance with the 10-year update requirements of 10 CFR 50.55a(g)(4)(ii) to the 2007 Edition with the 2008 Addenda with a scheduled implementation date of September 1, 2012. The MNGP IWE Plan is currently in the 2" period of its 2" 10-Year Interval, and it is not scheduled to be updated until September 9, 201 8. The MNGP IS1 program and the IWE program interval start and end dates are not aligned. The MNGP new IS1 interval begins on September I, 2012 and is being updated to the 2007 Edition with the 2008 Addenda of ASME Section XI, whereas the IWE program will continue to meet the 2001 Edition with the 2003 Addenda through September 8,2018. The one ASME Section XI program that is common to both IS1 and IWE is the RepairIReplacement (RIR) program. If the MNGP RIR program for both IS1 and IWE are not aligned to the same edition and addenda of Section XI, two separate program documents with implementing procedures will be required.
Page 1 of 2 L-MT-11-056 Enclosure 2 B. Proposed Use of Subsequent Code Edition and Addenda Pursuant to 10 CFR 50.55a(g)(4)(iv) and following the guidance of RIS-2004-16, MNGP requests permission to utilize the 2007 Edition12008 Addenda of ASME Section XI for the performance of repairlreplacement activities of items within the scope of the IWE program. It is important to note that this request does not apply to the selection, planning, scheduling or pressure testing of IWE examinations and tests as defined in IWE-2500 or IWE-5000.
IWE examinations and tests at MNGP will continue to be selected, planned, and scheduled in accordance with its present Code of Record as described in Section 2.0, above.
In implementing this proposal, MNGP will also comply with all NRC conditions specified in 10 CFR 50.55a that are applicable to IWA-4000.
: 4. Related Requirements MNGP is requesting permission to use the 2007 Edition12008 Addenda of ASME Section XI for the performance of repairlreplacement activities of items within the scope of the IWE program. In making this request, MNGP will comply with all related requirements in ASME Section XI as described below: MNGP will utilize the appropriate portions of "Articles" (e.g. IWA-1000, IWA-2000, etc) from each "Subsection" (e.g. IWA, IWB, etc.) of the 2007 Edition12008 Addenda that are required for the performance of repairlreplacement activities. MNGP will also use all "Mandatory Appendices" of the 2007 Edition12008 Addenda that are referenced by IWA-4000. With regard to the performance of IWE examinations and tests, MNGP will continue to select, plan, and schedule these IWE inspection activities, as specified in IWA-2500 and IWE-2500 in accordance with its current code of record for the 2" Interval IWE Program. To ensure that all related requirements are met, MNGP will also continue to comply with applicable portions of IWA-2000 and all provisions of IWE-1000 and 2000 from its current code of record for the 2" Interval IWE Program. IWA-4550 requires Class MC items subjected to repairlreplacement activities to be tested in accordance with IWE-5000. However, due to the conditions of 10 CFR50,55a(b)(2)(ix)(J) on the 2007 Edition with the 2008 Addenda of ASME Section XI, the pressure testing of repairlreplacements of IWE items will continue to be in accordance with the current Code of Record (2001 Edition with 2003 Addenda) for which no additional regulatory conditions apply. 5. Duration of Proposed Request The duration of this request will be for the entire fifth interval of the MNGP lnservice Inspection Program scheduled to begin on September 1, 2012. Page 2 of 2}}

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