ASME BPV XI NUCLEAR INSERVICE INSPECTION INTERPRETATIONS SESSION HANDOUT 1. RECORD # PG 3. Page 1

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1 ASME BPV XI NUCLEAR INSERVICE INSPECTION INTERPRETATIONS SESSION HANDOUT 1. RECORD # PG 3 Page 1

2 INTERPRETATION SESSION - BPV XI Operating Guidelines / Conduct of Business 1. Open Forum. All are encouraged to participate. 2. Consideration of the inquiry will benefit from all user s experience relative to the topic. 3. Inquiries may be submitted by any member of the industry/public through C&S Connect or via to the Standards Committee Staff Secretary. (BPV XI Kim Verderber) 4. Submission and formatting instructions are contained in Section XI Code. (For older editions, it s in an Appendix. For newer editions, it s up front after the Forward.) 5. Two types of Interpretation. Both in the format of a Yes/No question. a. Requirement Point to current words in the Code to provide basis for interpretation. b. Intent Help define what the Code means. Needs an accompanying Code Change to clarify the intent. New Code requirements cannot be written thru an interpretation. 6. Neither type can be consulting (i.e., how to apply the Code), but rather they simply interpret the current Code requirements. 7. All must have an appropriate Subject and Code Edition Applicability. Approval (in accordance with BPV XI Operating Procedures) Requirement Interpretations Signed by a 6-Person Special Committee specific to each individual interpretation - Standards Committee Chair, Two Vice Chairs, and ASME Staff Secretary. - Two other subject matter experts. (Generally, the responsible SubGroup and Working Group Chairs.) - No more than 1/2 of the approvers (3 individuals) can be from any one Interest Group. - If unanimous consensus cannot be achieved, the item goes to Standards Committee for Letter Ballot. Intent Interpretations Standards Committee Vote through Letter Ballot - Presentation at the Interpretation Session for background and discussion. - Background, Basis, Type, Applicability considered/confirmed. - Final Question(s) and Reply(s) then go to Standards Committee the following day to be discussed and balloted under Agenda Item 8. Page 2

3 Inquiry Record Additional Background Information from the Inquirer note from Kevin Rhyne to Inquirer Chul-kyun Jeon: I do not know how processes with the Korean regulator work, but I was surprised to see that you were asking a question about the 1992 Edition with the 1994 Addenda of the ASME Section XI Code. In the United States, nuclear plant owners are required by the regulator to update their ISI Plans on a 10-year frequency, to the most recent ASME Section XI Code that has been reviewed and approved for use by the regulator. For instance, my utility owns 11 nuclear units, and all of their ISI Plans are currently based on the 2007 Edition through the 2008 Addenda of the ASME Section XI Code, which at the time was the latest code approved by the regulator when we began development of the units next 10-year ISI Plans. Can you provide more information on why you are asking about the 1992E/1994A Code rather than a more current Code year? What are the ISI Plan years covered by your 1992E/1994A Code? Paragraph IWA-2441(e) also states that the case must be approved for use in accordance with paragraphs IWA- 2441(a) through IWA-2441(d). So the following additional questions seek information that is needed to answer your question about use of paragraph IWA-2441(e): 1. Was paragraph IWA-2441(a) met? 2. Was paragraph IWA-2441(b) met? 3. Was paragraph IWA-2441(c) met? 4. Is paragraph IWA-2441(d) applicable to your case, that is, are you using a subsequently issued code case? 5. Please provide any other information regarding these paragraphs that you think may help our understanding and consideration of your inquiry. Can you share what code case (or code cases) you wish to use through paragraph IWA-2441(e)? note from Inquirer Chul-kyun Jeon to Kevin Rhyne (responses highlighted in yellow): Q. Can you provide more information on why you are asking about the 1992E/1994A Code rather than a more current Code year? A. ASME 1992E/1994A was Code for construction of plant. Q. What are the ISI Plan years covered by your 1992E/1994A Code? A. Present ISI plan years are covered by ASME 2001E/2002A Code. Q 1. Was paragraph IWA-2441(a) met? A 1. Yes, Code Case 2142 (Sec. IX Code Case) was stated on Final Safety Analysis Report. Page 1 of 2 Page 3

4 Q2. Was paragraph IWA-2441(b) met? A2. Yes Q3. Was paragraph IWA-2441(c) met? A3. Yes Q4. Is paragraph IWA-2441(d) applicable to your case, that is, are you using a subsequently issued code case? A4. No Q5. Please provide any other information regarding these paragraphs that you think may help our understanding and consideration of your inquiry. A.5 See below (Rhyne provided response). Q. Can you share what code case (or code cases) you wish to use through paragraph IWA-2441(e)? A. Based on IWA-2441(e), Code Case was used for maintain electric heater for pressurizer. However, regulation authority adopted IWA-2441(f). Regulation authority's opinion was as follows. 1. Approved by authority Code Case was Code Case was revised code case, not superseded code case. 3. Plant should submit relief request to use code case What I would like to know are that. 1. Do plant need to submit relief request or not to use each superseded code case? 2. Is Code Case superseded or revised code case? Page 2 of 2 Page 4

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