Text

Requests Relief Associated with Containment Examinations at Hope Creek & Salem Generating Stations.Attachment 1 Includes Proposed Alternatives & Supporting Justification for Relief Requests
	ML18107A556
Person / Time
Site:	Salem, Hope Creek
Issue date:	10/07/1999
From:	Salamon G; Public Service Enterprise Group
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	LR-N990409, NUDOCS 9910210078
	Download: ML18107A556 (84)
	v • d • e

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Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit OCT 7. *:.:.1999)

LR-N~90409 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

ISi RELIEF REQUESTS FOR CONTAINMENT EXAMINATIONS HOPE CREEK AND SALEM GENERATING STATION FACILITY OPERATING LICENSES DPR-70, DPR-75, AND NPF-57 DOCKET NOS. 50-272, 50-311, AND 50-354 Pursuant to 10CFR50.55a(a)(3), Public Service Electric and Gas Company (PSE&G) requests relief associated with containment examinations at the Hope Creek and Salem Generating Stations. Specifically, PSE&G requests relief from the requirements of Subsection IWE and IWL of the 1992 Edition and Addenda of the ASME Code. As an alternative, PSE&G proposes to use Subsection IWE and IWL of the 1998 Edition of the Code.

I Attachment 1 to this letter includes the proposed alternatives and supporting justification for the relief requests as well as the basis for concluding that the proposed alternatives provide an acceptable level of quality and safety.

Accordingly, the proposed alternative satisfies the requirements of 10CFR50.55a(a)(3)(i). Attachment 2 includes a comparison of the 1992 Edition/Addenda with the 1998 Edition for IWE while Attachment 3 includes the comparison for IWL.

The containment examinations must be performed during the upcoming ninth refueling outage at Hope Creek (scheduled to begin in April 2000). Since Hope Creek would realize immediate benefits from the proposed Relief Request RR-E1 during the upcoming refueling outage, PSE&G is requesting that the NRC approve this relief request by March 15, 2000.

Changes similar to the changes proposed in this letter were approved by the NRC for Comanche Peak Steam Electric Station, Units 1 and 2, in a safety evaluation report, dated July 23, 1999 (TAC NOS. MA2038 and 2039).

9910210078 991007 PDR ADOCK 05000272 Q ** PDR The power is in your hands.

95*2168 REV. 6/94

LR-N990409 Document Control Desk Should you have any questions regarding this request, please contact Mr. C. E.

Manges, Jr. at 609-339-3234.

G. Salamon Manager - Licensing Attachment C Mr. H.J. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. R. Ennis Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 8B1 11555 Rockville Pike Rockville, MD 20852 Mr. P. Milano Licensing Project Manager - Salem U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 8B1 11555 Rockville Pike Rockville, MD 20852 USN RC Senior Resident Inspector - Hope Creek (X24)

USN RC Senior Resident Inspector - Salem (X24)

Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P. 0. Box 415 Trenton, NJ 08625

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ATTACHMENT 1 TO LR-990409 RELIEF REQUESTS RR-E1 AND RR-L 1

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RELIEF REQUEST RR-E1 NRC Approved (Yes or No): Date _ __

Component

Description:

Metallic containment shell and penetration liners and their integral attachments ASME Code Class:

MC ASME Examination Requirement:

1992 Edition, 1992 Addenda of Subsection IWE, "Requirements for Class MC and Metallic Liners of Class CC Components of Light-Water Cooled Power Plants", of Section XI, Division 1, of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code).

Basis for Relief:

In the Federal Register, dated August 8, 1996 (61 FR 41303), the NRC amended its regulations to incorporate, by reference, the ASME Code Section XI, 1992 Edition and Addenda of Subsection IWE for expedited examination of containments. Considerable comments were provided by the industry to this rule change, and the NRC staff took appropriate action to provide exceptions to allow licensees a flexible implementation schedule and relaxation in specific areas to meet these requirements. Based on the effective date of the rule change of September 9, 1996, licensees have until September 9, 2001 to have a Containment ISi program in place and to complete the first period inspection requirements contained in Section XI.

ASME has made extensive changes to the Subsection IWE contained in the 1992 Edition and Addenda concerning the examination requirements for containments.

These changes were based on industry concerns and comment and are now published in the 1998 Edition of the ASME Code Section XI. Publication of the 1998 Edition by the ASME, with NRC participation, provides the basis for the approval of these new 1998 Edition requirements that have been determined by the ASME consensus process to provide an acceptable level of quality and safety.

RELIEF REQUEST RR-E1 The proposed alternative is to utilize the current ASME approved 1998 Edition of

Subsection IWE of Section XI in its entirety as augmented by the additional requirements contained in the "Alternative Examinations" section below. Utilizing the 1998 Edition of IWE in its entirety incorporates other exceptions to the 1992 addenda stated in NRC rulemaking and provides more cohesiveness than could be achieved by requesting relief on several individual subjects separately. The examination requirements of the 1998 Edition of the Code were developed in accordance with the ASME Code committee process with input from interested parties, other utilities, manufacturers, engineering organizations, Authorized Nuclear Inspection Agencies, EPRI and the NRC. The updating of requirements by this consensus process is intended to ensure the continued safe operation of nuclear power plants and specifically, in this case, ensures the continued leak-tight and structural integrity of metallic containment components. Therefore, the overall level of plant quality and safety will not be adversely affected by utilizing the requirements of the 1998 Edition of IWE.

PSE&G has determined that the use of the 1998 Edition requirements as augmented by the additional requirements contained in the "Alternative Examinations" section below in lieu of the 1992 Edition and Addenda requirements for our Containment ISi program represents an equivalent level of quality and safety. A line by line comparison was made of the 1998 Edition to the 1992 Edition and Addenda. The 1998 Edition provides an equivalent, and in some cases an increased, level of quality and safety to our

proposed containment inspection program.

Salem Generating Station Unit 1 is in its 2nd Interval, 3rd Period, Salem Generating Station Unit 2 is in its 2nd Interval, 2nd Period, and Hope Creek Generating Station Unit 1 is in its 2nd Interval, 151 Period. Based on schedules and the requirement of the new rulemaking for full implementation by September 9, 2001, a containment ISi examination program must be established immediately. Implementing this relief request at the present time would reduce the overall impact to resources (PSE&G's and the NRC's) compared to incorporating the mandated edition and addenda of IWE in conjunction with the initial establishment of a containment ISi program followed by updating to a later edition and or addenda or to a series of Code Cases at a later date (e.g., upon either formal NRC endorsement or during the next ten year ISi plan issuance).

Alternative Examinations:

The 1998 Edition of Subsection IWE provides the alternate examinations of this relief request. The requirements of the 1998 Edition of the Code are augmented by the requirements described below .

RELIEF REQUEST RR-E1 The PSE&G program governing containment visual examinations and personnel qualifications includes the following:

1. "General Visual Examiriation" criteria are developed from VT-3 procedures that are used to examine ASME Class 1, 2, and 3 components.

2. Pressure retaining bolting recording criteria are developed from the VT-1 procedure used for Class 1 bolting.

3. Moisture barriers are examined for tears, cracks or damage that permits moisture to intrude.

4. Detailed Visual exam criteria are developed similar to VT-1 and VT-3 procedures.

5. The containment visual examination procedure qualification requirement for lighting and illumination are similar to, and developed from, the procedures used for VT-1 and VT-3 examinations of ASME Class 1, 2, and 3 components.

6. In applications where remote visual examination systems are to be used, those systems will be demonstrated to have a resolution capability at least equivalent to that attainable by direct visual examination.

Containment visual examination procedures will be demonstrated to the authorized nuclear inspector for capability to detect flaws and degradation levels defined within the procedure, and

The containment visual examination program is developed from the guidelines of SNT-TC-1A and ANSl/ANST CP-189. Certified personnel will have "demonstrated skill, demonstrated knowledge, documented training, and documented experience required to properly perform the duties of a specific job."

The PSE&G Program for examination of paints or coatings requires that procedures exist to ensure the following:

1. In areas important to containment integrity, coating deficiencies identified on the containment liner are brought to the attention of the IWE Responsible Individual; and

2. Base metal conditions that could challenge the structural integrity of the containment are examined by properly qualified personnel.

The PSE&G Program requires that the ultrasonic examinations required by IWE 3511.3 apply to Class CC components as well as to Class MC components.

Anticipated Impact on the Overall Level of Plant Quality and Safety:

None

RELIEF REQUEST RR-L 1 NRC Approved (Yes or No): Date _ __

Component

Description:

Reinforced concrete and post-tensioning systems of Class CC components.

ASME Code Class:

cc ASME Examination Requirement:

1992 Edition, 1992 Addenda of Subsection IWL, "Requirements for Class CC Concrete Components of Light-Water Cooled Power Plants", of Section XI, Division 1, of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code).

Basis for Relief:

In the Federal Register, dated August 8, 1996 (61 FR 41303), the NRG amended its regulations to incorporate by reference the ASME Code Section XI, 1992 Edition and Addenda of Subsection IWL for expedited examination of containments. Considerable comments were provided by the industry to this rule change and the NRG staff took appropriate action to provide exceptions to allow licensees a flexible implementation schedule and relaxation in specific areas to meet these requirements. Based on the effective date of the rule change of September 9, 1996, licensees have until September 9, 2001 to have a Containment ISi program in place and to complete the first period inspection requirements contained in Section XI.

ASME has made extensive changes to the Subsection IWL contained in the 1992 Edition and Addenda concerning the examination requirements for containments.

These changes were based on industry concerns and comments and are now~

published in the 1998 Edition of the ASME Code Section XI. The 1998 Edition provides the Responsible Engineer, adds a requirement to train personnel, and establishes the examination categories of general and detailed visual. The 1998 Edition also provides additional inspections of tendon end caps, as well as guidelines to inspect for leakage of corrosion protection medium. Publication of the 1998 Edition by the ASME, with NRG participation, provides the basis for the approval of these new 1998 Edition requirements that have been determined by the ASME consensus process to provide an acceptable level of quality and safety.

RELIEF REQUEST RR-L 1

The proposed alternative is to utilize the current ASME approved 1998 Edition of Subsection IWL of Section XI in its entirety as augmented by the additional requirements contained in the "Alternative Examinations" section below. Utilizing the 1998 Edition of IWL in its entirety incorporates other exceptions to the 1992 addenda stated in NRC rulemaking and provides more cohesiveness than could be achieved by requesting relief on several individual subjects separately. The examination requirements of the 1998 Edition of the Code were developed in accordance with the ASME Code committee process with input from interested parties, other utilities, manufacturers, engineering organizations, Authorized Nuclear Inspection Agencies, EPRI and the NRC. The updating of requirements by this consensus process is intended to ensure the continued safe operation of nuclear power plants and specifically, in this case, ensures the continued leak-tight and structural integrity of concrete containment components. Therefore, the overall level of plant quality and safety will not be adversely affected by utilizing the requirements of the 1998 Edition of IWL.

PSE&G has determined that the use of the 1998 Edition requirements as augmented by the additional requirements contained in the "Alternative Examinations" section below in lieu of the 1992 Edition and Addenda requirements for our Containment ISi program represents an equivalent level of quality and safety. A line by line comparison has been made of the 1998 Edition to the 1992 Edition and Addenda. The 1998 Edition provides an equivalent, and in some cases an increased, level of quality and safety to our proposed containment inspection program.

Salem 'Generating Station Unit 1 is in its 2nd Interval, 3rd Period, Salem Generating Station Unit 2 is in its 2nd Interval, 2nd Period, and Hope Creek Generating Station Unit 1 is in its 2nd Interval, 151 Period. Based on schedules and the requirement of the new rulemaking for full implementation by September 9, 2001, a containment ISi examination program must be established immediately. Implementing this relief request at the present time would reduce the overall impact to resources (PSE&G's and the NRC's) compared to incorporating the mandated edition and addenda of IWL in conjunction with the initial establishment of a containment ISi program followed by updating to a later edition and or addenda or to a series of Code Cases at a later date (e.g., upon either formal NRC endorsement or during the next ten year ISi plan issuance).

Alternative Examinations:

The 1998 Edition of Subsection IWL provides the alternate examinations of this relief request. The requirements of the 1998 Edition of the Code are augmented by the requirements described below .

RELIEF REQUEST RR-L 1 The PSE&G program governing containment visual examinations and personnel qualifications includes the following:

1. General and Detailed Visual Examinations are developed to identify areas of concrete deterioration and distress as defined in ACI 201.1 and are equivalent to the VT-3C and VT-1C examinations in terms of assessing the condition and potential for deterioration within the containment system.

2. In applications where remote visual examination systems are to be used, those systems will be demonstrated to have a resolution capability at least equivalent to that attainable by direct visual examination.

Containment visual examination procedures will be demonstrated to the authorized nuclear inspector for capability to detect flaws and degradation levels defined within the procedure, and

The containment visual examination program is developed from the guidelines of SNT-TC-1A and ANSl/ANST CP-189. Certified personnel will have "demonstrated skill, demonstrated knowledge, documented training, and documented experience required to properly perform the duties of a specific job."

The PSE&G Program requires a detailed inspection on suspect areas (Item L 1.12) .

Anticipated Impact on the Overall Level of Plant Quality and Safety:

None

ATTACHMENT 2 TO LR-990409 IWE COMPARISON

IWE COMPARISON Para- Changes between IWE1992 Significance of change and or basis for use Edition/1992 Addenda and the as an alternative examination Graph 1998 Edition IWE- No change None 1000 1100 ASME Section XI generic Non significant wording change from repair, replacement and or modification terms to repair/replacement activities.

1200 No change None 1210 No change None 1220 Changed "containment" to Non significant "containment system"

. 1230 No change None 1231 Removed Item 3) - "single The single welded butt joints were removed as a welded butt joints from the weld separately listed examination item and is now side" - as a specific item required included within the item for the pressure to remain accessible for the life retaining boundary as discussed in the changes of the plant. to Table IWE-2500-1 below. Examination of pressure retaining welds arid pressure retaining dissimilar metal welds are optional as specified in 10CFR50.55a(b)(2)(x)(C).

Changed wording from "80% of The exclusions from 80% incorporate an the surface area" to "80% of the existing Table IWE 2500-1 note and clarify that pressure retaining boundary" areas made inaccessible during construction and stated exclusions from that are also excluded.

80%.

Reworded paragraph b). Change to b) is for clarity and is non significant.

1232 ASME XI generic change from Non significant repair and or replacement to repair/replacement activities.

IWE COMPARISON Para- Changes between IWE1992 Significance of change and or basis for use Edition/1992 Addenda and the as an alternative examination Graph 1998 Edition 1232 Deleted paragraph (a)(3) Welded joints were removed as a separately addressing inaccessible welded listed examination items and are now included (cont.)

joints. within the item for the pressure retaining boundary as discussed in the changes to Table IWE-2500-1 below. Examination of pressure retaining welds and pressure retaining dissimilar metal welds are optional as specified in 10CFR50.55a(b)(2)(x)(C).

1240 No change None 1241 Added stiffeners and, by Clarifies the intent of the Code that areas reference to IWE-2420, flaws identified in IWE 2420(b) require an augmented accepted by evaluation as areas exam in the next period.

requiring augmented examination.

1242 Changed (c) to (b) Non significant 2000 No change None 2100 Added new Subarticle 2100- The containment examinations are completely "General"-to provide reference to defined within the jurisdiction of IWE, and thus IWA-2000 with exceptions from reference to IWA 2210, and IWA 2300 are not IWA-2210, 2300, 2500, and applicable. However, to ensure that industry-2600. wide consistency is maintained with respect to containment visual examinations and personnel qualifications, the PSE&G program governing these areas is described in the "Alternative Examinations" section of Relief Request RR-E1.

The exceptions to IWA 2500, and IWA 2600 are to weld base exams, which do not apply to IWE.

The examinations of IWE in the 1998 Edition coupled with the described PSE&G program governing containment visual examinations and personnel qualifications provide an equivalent level of quality an safety as defined in IWA of the 1992 Edition.

2200 Deleted paragraph c), which The deletion of an allowance for an alternative provided allowances for the use examination ensures that proper preservice of shop or field examinations in examinations are performed and documented.

lieu of on site preservice examinations.

IWE COMPARISON

Para- Changes between IWE1992 Significance of change and or basis for use Edition/1992 Addenda and the as an alternative examination Graph 1998 Edition 2200 Deleted paragraph g), which The deletion of the requirement to document the required the condition of new condition of "new" non pressure retaining (cont.)

coating to be documented in the coatings in the preservice examination record preservice examination record. provides for more efficient program implementation without affecting component integrity. See the discussion under Paragraph 2500 below for additional discussion on PSE&G's coating program.

ASME XI generic change from Non significant.

repair and or replacement to repair/replacement activities.

2300 Added new Subarticle 2300 - The philosophy of IWE to be an engineering "Visual Examination, Personnel inspection under the direction of the Qualification and Responsible Responsible Individual is contained in this new Individual" subarticle. The most significant change is the definition of the roles and responsibilities of the Responsible Individual. This individual will be accountable for the entire inspection program, which will meet or exceed the level of quality and safety defined in the 1992 Edition. The specific paragraphs added will be discussed below. Also, see discussion under IWE 2100 above.

2310 Added new paragraph 2310 - The VT-3 and VT-1 inspections of IWA have Visual Examinations - which a) been replaced by Owner (Responsible states that the owner shall define Individual) defined general and detailed visual requirements for visual exams, respectively. As identified in IWE 2100 examination of containment above, to ensure that industry-wide consistency surfaces; b) and c) defines is maintained with respect to containment visual general and detailed visual examinations and personnel qualifications, the examinations; and d) and e) PSE&G program governing these areas is provides the requirements for the described in the "Alternative Examinations" conditions of areas affected by section of Relief Request RR-E1. The definition repair/replacement activities, of critical examination items and acceptable painted or coated areas, non conditions has not changed, such that any coated areas, pressure retaining conditions adversely affecting quality or safety materials and moisture barriers . are not impacted by this change.

IWE COMPARISON Para- Changes between IWE1992 Significance of change and or basis for use Edition/1992 Addenda and the as an alternative examination Graph 1998 Edition 2310 The general and detailed visual examinations are equivalent to the VT-3 and VT-1 exams in (cont.)

terms of assessing the general condition and potential for deterioration within the containment system.

Visual criteria will be developed from VT-3 procedures that are used to examine ASME Class 1, 2, and 3 components.

10CFR50.55a(b)(x)(B) mandates qualification of the remote examination procedure for Subsection IWE. The lighting and resolution qualification requirements will be developed and similar to the procedures used for Code Class 1,2 and 3 components.

Pressure retaining bolting recording criteria will be developed from the VT-1 procedure used for Class 1 bolting.

Moisture barriers will be examined for tears, cracks or damage that permits moisture to intrude.

Detailed Visual exam criteria will be developed similar to VT-1 and VT-3 procedures The use of owner defined inspection types allows for the involvement of qualified engineering personnel with backgrounds in programs such as the Maintenance Rule, containment coatings, and Appendix J. This provides for a containment inspection program that is performed by individuals with knowledge in containment degradation mechanisms.

The code provides some specific examples of unacceptable conditions when performing "detailed" exams. These types of conditions were previously stated in IWE 3000.

IWE COMPARISON Para- Changes between IWE1992 Significance of change and or basis for use Edition/1992 Addenda and the as an alternative examination Graph 1998 Edition 2310 The overall impact of the changes in IWE 2310 coupled with the PSE&G program governing (cont.)

containment visual examinations and personnel qualifications is a inspection program that is consistent with other containment monitoring programs, and thus provides an equivalent level of quality and safety as the 1992 Edition.

2320 Added new paragraph 2320 - The qualifications along with the roles and "Responsible Individual" - which responsibilities of the Responsible Individual are a) states the qualification clearly delineated within this subarticle. This requirements of the responsible section clearly states the expectations for the individual and Responsible Individual, and brings accountability for the entire program to an individual knowledgeable in containment and their degradation mechanisms. This individual b) defines the responsibilities of will develop the inspection plans, train the responsible individual for the personnel, direct or perform inspections, and development of plans and finally evaluate the results. The cohesiveness procedures; instruction, training of the inspection program has been improved by and approval of visual the addition of this subarticle. This, along with examination personnel; the containment visual examinations and performance or direction of personnel qualifications program described in visual examinations; evaluation the "Alternative Examinations" section of Relief of results and documenting Request RR-E1, results in an increase of the results. level of quality and thus no adverse impact on safety.

2330 Added new paragraph 2330 - Adding requirements for the owner to define "Personnel Qualification" - which personnel qualification requirements is a) states that the owner is consistent with the philosophy that the responsible for defining the Responsible Individual must qualify the qualification requirements for inspection personnel. The code recognizes that personnel performing visual the qualifications may differ depending on the examinations and provides rules containment type and even the inspection that were previously contained in period in question.

the acceptance criteria of IWE-3510.1.

IWE COMPARISON

Para- Changes between IWE1992 Significance of change and or basis for use Edition/1992 Addenda and the as an alternative examination Graph 1998 Edition 2330 The Containment Visual Examination Personnel will be certified with the PSE&G program and (cont.)

will satisfy the requirements of SNT-TC-1A and ANSl/ANST CP-189. Certified personnel will have "demonstrated skill, demonstrated knowledge, document training and documented experience required to properly perform the duties of a specific job." This change is consistent with the other changes discussed above and serves to improve the level of quality and thus has no adverse impact on safety.

2400 No change None 2410 No change None 2411 Deleted a subparagraph The deleted subparagraph eliminates discussing decreasing and duplication with IWA-2400.

extending inspection periods.

2412 Deleted a subparagraph The deleted subparagraph eliminates discussing decreasing and duplication with IWA-2400. The added extending inspection periods. requirements for the scheduling of added welds Added a subparagraph detailing or components ensure that a representative requirements for the scheduling sampling of examinations is maintained. There of added welds or components. are no plans to add items to the IWE inspection program. If items were added to IWE program, the methodology would be essentially the same as that for adding items to the ASME Code Class 1,2 or 3 ISi program.

2420 Removed repaired areas as Repaired areas that are likely to experience areas requiring reexaminations accelerated degradation and aging are already during the next successive subject to augmented examinations per IWE-inspection period, and changed 1241. Some repairs may be located in non (c) to require that areas that augmented areas and may be necessary to remain essentially unchanged for correct physical damage caused by construction the next inspection period no or craft activities.

longer require augmented The evaluation that determines that flaws or examinations. The 1992 Edition areas of degradation remain unchanged is required three consecutive sufficient to conclude that there are no active examinations to reach this corrosion mechanisms present.

conclusion.

IWE COMPARISON

Para- Changes between IWE1992 Significance of change and or basis for use Edition/1992 Addenda and the as an alternative examination Graph 1998 Edition 2420 The requirements for reexamination of augmented examination areas has been revised (cont.)

to be consistent with Class 1 and 2 such that only one additional examination is required during the next inspection period before the item can be removed from an Owner's augmented examination program. Areas may be subject to augmented examination during successive ISi intervals if an Owner determines that conditions that could cause degradations in these areas still exist. The ability to designate an area as augmented during successive examinations ensures that the area is monitored for as long as necessary.

These changes do not adversely affect the level of quality or safety within the containment inspection program.

2430 Deleted the paragraph - The changes to Table IWE 2500-1 eliminate Additional Examinations - which several examination categories. The categories discussed adding examination that remain all require 100% examination.

items of the same category if Therefore no items are available for additional flaws or areas of degradation are examinations.

identified during an examination.

2500 Reworded the existing The reworded subparagraphs add clarity and subparagraphs consistent with provide consistency within IWE.

the previous paragraph changes and with Table IWE-2500-1 changes.

Deleted the requirement to The code jurisdiction is the pressure boundary, examine paint or coatings prior and not the non pressure retaining coatings.

to removal. Eliminating this requirement does not adversely impact the level of quality or the safety of the containment inspection program. The PSE&G coating program that is in place has the Coatings Program Engineer and IWE Responsible Engineer reporting to the same person.

IWE COMPARISON

Para- Changes between IWE1992 Significance of change and or basis for use Edition/1992 Addenda and the as an alternative examination Graph 1998 Edition Procedures are in place that require notification to the IWE Responsible Individual for coating deficiencies or containment integrity issues.

Prior to final disposition of the coating deficiency by the Coatings Program Engineer, the IWE Responsible Engineer has the opportunity to establish visual examination hold points for any point in the coating removal and reapplication process. These procedural requirements ensure that base metal conditions that could challenge the structural integrity of the containment are identified and appropriate action taken prior to recoating the plant containment liner.

Replaced the requirement for The new Table IWE 2500-2 provides more one foot square grids in detailed requirements for thickness thickness measurements with a measurement and is discussed below.

reference to Table IWE 2500-2.

Added a reference to IWE-5000 The added reference to IWE-5000 provides for pressure tests. direction for the performance of pressure test.

2600 Deleted a sentence discussing The removal of this sentence addressing "new" compatibility of paint and coating non pressure retaining paint and coatings systems and a requirement to provides for more efficient containment ISi examine new paint. Program implementation without adversely affecting component integrity. The compatibility of paint and coating systems with the existing system, and the examination of newly applied coatings, is covered in the PSE&G nuclear coatings Program.

The code jurisdiction is the pressure boundary, and not the non pressure retaining coatings.

Eliminating this requirement does not adversely

impact the level of quality or the safety of the

IWE COMPARISON

Para- Changes between IWE1992 Significance of change and or basis for use Edition/1992 Addenda and the as an alternative examination Graph 1998 Edition 2600 containment inspection program. PSEG Coating program in place has the Coatings (cont.) Program engineer and IWE Responsible engineer under the same person.

Procedures are in place that requires notification to the IWE Responsible individual for coating deficiencies or containment integrity issues.

3000 No change None 3100 Removed the word Non significant nondestructive from the heading.

3110 No change None 3111 Replaced the reference to Table Table IWE-3410-1 and paragraphs IWE-3115 IWE-3410-1 with a reference to have been deleted and are discussed below.

subarticle IWE-3500. Removed IWE-3500 adequately captures all of the reference to paragraph IWE- information previously contained in the deleted 3115 . table and paragraph.

3112 Replaced the reference to Table Non significant IWE-3410-1 with a reference to subarticle IWE-3500. ASME XI generic change from repair and or replacement to repair/replacement activities.

3114 Replaced the reference to Table Non significant IWE-3410-1 with a reference to subarticle IWE-3500. ASME XI generic change from repair and or replacement to repair/replacement activities.

3115 Deleted subparagraph, which Non significant - there were no submittal or addressed repair programs and retention requirements changed by the deletion evaluations being subject to of the subparagraph.

review by authorities.

3120 Removed the word Non significant nondestructive from the heading .

IWE COMPARISON Para- Changes between IWE1992 Significance of change and or basis for use Edition/1992 Addenda and the as an alternative examination Graph 1998 Edition 3121 Removed the word The removal of nondestructive is non-nondestructive and deleted significant. The referenced subparagraphs did references to IWE-3124 and not actually apply to the acceptance of flaws for IWE-3125 for the acceptance of continued service.

flaws for continued service.

3122 Replaced the references to Non significant - the changes are for clarity and Table IWE-2500-1 and IWE- to reconcile paragraphed numbering. There 3000 with a reference to was no submittal or retention requirements Subarticle IWE-3500. ASME XI changed by the deletion of the sentence generic change from repair and addressing evaluation reviews.

or replacement to repair/

See IWE 3125 discussed below.

replacement activities.

Reworded several sentences.

Deleted sentence, which addressed evaluations being subject to review by authorities.

3124 Replaced the reference to Table Non significant IWE-3410-1 with a reference to Subarticle IWE-3500. ASME XI generic change from repair and or replacement to repair/replacement activities.

3125 Deleted subparagraph, which No submittal or retention requirements changed addressed repair programs and by the deletion of the subparagraph.

reexamination results being NRG Rulemaking (Page 41312 of Federal subject to review by authorities.

Register dated August 8, 1996, Volume 61, Number 154, Rule and Regulations) states in part, "Licensees do not have to submit to the NRG staff for approval of their containment inservice inspection program which was developed to satisfy the requirements of Subsection IWE and IWL with specified modifications and a limitation. PSE&G will maintain required documentation on site for review or audit.

3130 No change None

IWE COMPARISON

Para- Changes between IWE1992 Significance of change and or basis for use Edition/1992 Addenda and the as an alternative examination Graph 1998 Edition 3200 Added a statement to the end of The added statement clarifies requirements and the paragraph that states eliminates potential duplication or contradiction supplemental surface or of requirements in stating that the engineering volumetric examinations are evaluation requirements of IWE-3122 determine required when specified by the what and when supplemental examinations are engineering evaluation. required.

3400 No change None 3410 Replaced the reference to Table Non significant IWE-3410-1 with a reference to Subarticle IWE-3500.

3430 No change None 3500 No change None 3510 Reconciled acceptance Previously, examination requirements were standards with the IWE-2300 contained in the acceptance standards of changes discussed above and IWE-3500. This section has been restructured the Table IWE-2500-1 changes by the addition of IWE-2300 as discussed discussed below by: above.

Adding the requirement that the This change directly corresponds to the addition owner shall define acceptance of IWE-231 O(a) discussed above. See criteria for visual examination of discussion under IWE 2100, and 2310 above for containment surfaces; additional discussion and justification.

Removing the wording for This change directly corresponds to the addition responsible individual and for of IWE-2320 discussed above.

personnel qualifications; Combining 3510.2 and 3510.3 These changes directly correspond to the and removing specific VT-1 and addition of IWE-2310(e)( 1) and (2) discussed VT-3 examination attribute above.

wording; and

IWE COMPARISON Para- Changes between IWE1992 Significance of change and or basis for use Edition/1992 Addenda and the as an alternative examination Graph 1998 Edition 3510 Incorporating IWE-3511, 3513, These changes correspond to the changes in 3514, and 3515 with changes the examination categories of Table IWE-2500-(cont.)

into IWE-3510. 1 as discussed below and to the removal of examination requirements from the acceptance standards paragraphs per the addition of IWE-2310 (e)(3) and (4) as discussed above.

By the incorporation of 3515 the The resulting acceptance standards for bolting acceptance standards for bolting provide for more practical containment ISi were changed from referencing program implementation without adversely material specs and torque or affecting containment leak tight or structural tension limits to conditions integrity.

affecting leak tight or structural integrity.

3511 Deleted subparagraph, which Examination category E-B has been addressed examination category incorporated into examination category E-A per E-B. the changes to Table IWE-2500-1 discussed below.

3512 Renumbered subparagraph to The subparagraph was renumbered based on IWE-3511. Reconciled the deletion of previous IWE-3511 as discussed acceptance standards with the above. Previously, examination requirements IWE-2300 changes discussed. were contained in the acceptance standards of above and the Table IWE-2500- IWE-3500. This section has been restructured 1 changes discussed below by the addition of IWE-2300 as discussed above.

Added the requirement that the This change directly corresponds to the addition owner shall define acceptance of IWE-2310 (a) discussed above. See criteria for visual examination of discussion under IWE-2300 and IWE-231 O containment surfaces above for justification.

Combined 3512.2 and 3512.3 These changes directly correspond to the with changes into 3511.2 and addition of IWE-2310 (e)(1) and (2) discussed removed specific VT-1 above and eliminate potential duplication or examination attribute wording contradiction of requirements.

IWE COMPARISON

Para- Changes between IWE1992 Significance of change and or basis for use Graph Edition/1992 Addenda and the as an alternative examination 1998 Edition 3512 Reworded ultrasonic This change is for clarity. The 1998 code examination subparagraph. specifically states MC and not CC. Metallic liner (cont.)

inspections will be done as required by IWE-3200. NRC Rulemaking (61FR41312, dated 8/8/96) states that metallic shell and penetration liners which are pressure retaining components and their integral attachments must meet the inservice inspection, repair and replacement requirements applicable to components which are classified as ASME Code MC.

3513 Deleted subparagraphs Examination categories E-D, E-F and E-G have IWE-3513, 3514 and 3515, been incorporated into examination category 3514 which addressed examination E-A per the changes to Table IWE-2500-1 3515 categories E-D, E-F, and E-G discussed below.

respectively.

4000 No change None 4100 No change None 5000 No change None 5200 No change None 5210 No change None 5220 ASME XI generic change from Non significant repair and or replacement to repair/replacement activities.

5221 ASME XI generic change from Non significant - the requirement to meet the repair and or replacement to requirements of the Appendix J paragraph repair/replacement activities. referenced is not affected by removing the Removed the quotation of 10 quoted App J paragraph.

CFR 50 Appendix J paragraph IV.A.

5222 ASME XI generic change from Non significant, DN25 is a standard repair and or replacement to measurement identification.

repair/replacement activities. (b) changed repair to weld (c) added (DN25)

IWE COMPARISON

Para- Changes between IWE1992 Significance of change and or basis for use Edition/1992 Addenda and the as an alternative examination Graph 1998 Edition 5240 Replaced a reference to IWA The types of examinations performed in the 5240 with requirements to containment program are all contained in IWE perform detailed visual 2300. The requirements of IWA 5240 to detect examination of evidence of leakage will be satisfied through the repair/replacement areas during use of the detailed visual examination of IWE pressure tests. 2300. This change does not alter or impact the level of quality or safety of the containment inspection program.

5250 Changed Corrective Measures to Non significant Corrective Action in the heading.

ASME XI generic change from repair and or replacement to repair/replacement activities.

IWE-4000 now IWA-4000 7000 No change None

7100 Table 2411-1 Table No change No change Replaced the separate entries None None Non significant - The previous requirements for 2412-1 for 1st and successive intervals the 1st and successive intervals were identical.

with one entry for all intervals. Therefor combining the entries does not affect Added note: first period any requirements.

completion percentage for any Ensures allocations of exams are done through exam category exceeds 34%, at out the 10-year interval. No change in PSE&G's least 16% of required exams

philosophy.

shall be performed in the second period.

Table Revised all examination 2500-1 categories.

Exam Cat.

E-A

IWE COMPARISON Para- Changes between IWE1992 Significance of change and or basis for use Edition/1992 Addenda and the as an alternative examination Graph 1998 Edition Table Item E1 .1 O: Added Note 1 to Added for clarification. NRC rulemaking 2500-1 examine all accessible interior removes the emphasis from specific weld based and exterior surfaces of class examinations.

Exam MC components, parts, and Cat.

appurtenances, and metallic E-A shell and penetration liners of (cont.) Class CC components. A list of items is listed to consider for examination.

Item E1 .11: Revised frequency Removing the requirement to coordinate of examination from "prior to examinations with Type A tests, and requiring a each Type A test" to "100% general visual during every inspection period is during each period". more restrictive. This change corresponds with the rule as stated in 10CFR50.55a.

Item E1 .12: Re-designated item Replacing the accessible surface area from "accessible surface areas" designation (which is included in Item E1 .11) to "wetted surfaces of with wetted surface areas (which were submerged areas". Replaced previously included in Item E1 .12, Footnote 4) examination method VT-3 with does not eliminate or reduce any required general visual. examination areas. The conditions of distress, which would be detected by a VT-3 exam, are the same conditions that will be detected by a general visual exam, as defined in IWE 2300.

The requirement to perform a detailed exam on any suspect area has not changed. The new requirement to perform general visual exams every inspection period increases the total number of potential examinations on the containment surface in the interval. The PSE&G program governing containment visual examinations is described in the "Alternative Examinations" section of Relief Request RR-E1 to ensure that industry-wide consistency is maintained with respect to containment visual examinations. The overall impact of this change is to increase the level of quality and does not adversely affect the safety of the containment

inspection program.

IWE COMPARISON Para- Changes between IWE1992 Significance of change and or basis for use Edition/1992 Addenda and the as an alternative examination Graph 1998 Edition Table Item E1 .20: Added BWR to item See the above for a description of the 2500-1 description. Replaced equivalency of the general visual to the VT-3, examination method VT-3 with and the increased frequency of exams. This Exam general visual. change has no impact on the level of quality or Cat.

the safety of the containment inspection E-A program.

(cont.)

E1 .30 Added item for moisture Moisture barriers were previously included in barriers with a general VT Examination Category E-D with a VT-3 required required each period. each interval. Examining moisture barriers more frequently will assure reliable detection of conditions adverse to containment integrity.

All Item No.'s were replaced with Non significant - Previously some examination reference to IWE-3510 for requirements were contained in IWE-3500.

examination requirements with They now exist in IWE-2300 as discussed above.

IWE-2310 .

Notes were revised to Welds and bolting were previously included in specifically include welds and Examination Categories E-B, E-F and E-G.

bolting as part of the pressure Including these items in the examination retaining boundary requiring category for the containment pressure retaining examination. boundary provides for more efficient program implementation. This change will not alter the level of quality or adversely affect the safety of the containment inspection program.

Table This examination category, Pressure retaining welds are now included in 2500-1 which addressed pressure Examination Category E-A as addressed above.

retaining welds, was deleted. Examination of pressure retaining welds are Exam optional (See 10CFR50.55a(b)(2)(x)(C)). The Cat. PSE&G program governing containment visual E-B examinations is described in the "Alternative Examinations" section of Relief Request RR-E1 to ensure that industry-wide consistency is maintained.

IWE COMPARISON , . . Para- Changes between IWE1992 Significance of change and or basis for use Edition/1992 Addenda and the as an alternative examination Graph 1998 Edition Table Item E4.11: Replaced The conditions of distress or deterioration, that 2500-1 examination method VT-1 with would be detected by a VT-1, are the same detailed visual. conditions that will be detected by a detailed Exam visual exam, as defined in IWE 2300. The Cat. PSE&G program governing containment visual E-C examinations is described in the "Alternative Examinations" section of Relief Request RR-E1 to ensure that industry-wide consistency is maintained.

E4.12 Added grid line . The added wording clarifies inspection intersections to description of requirements and ensures repeatability in the parts examined. Changed location of subsequent thickness measurement examination method from points.

volumetric to ultrasonic thickness.

All Item No.'s: Added Previously no references existed for examination requirement examination requirements. These requirements paragraph number references. have been added to IWE 2310 and 2500 as Updated acceptance standard discussed above. Adding new references and references. updating paragraph numbers ensure proper requirements are applied to examinations.

Notes: Changed Note 2 from Three inspection periods cover a ten year requiring augmented interval. Performing augmented examinations examination until an area for at least two periods while continuing general remains unchanged for three visual examinations each period provides for consecutive inspection periods more efficient program implementation without to the next inspection period. adversely affecting component integrity. See Deleted Note 3, which discussed discussion in 2420 above. Deletion of Note 3 is inspection deferrals. non significant.

Extent and Frequency of Non significant Examination 2500 (c) is changed to (b)

IWE COMPARISON Para- Changes between IWE1992 Significance of change and or basis for use Edition/1992 Addenda and the as an alternative examination Graph 1998 Edition Table Deleted examination category Moisture barriers have been included in 2500-1 which addressed seals, gaskets Examination Category E-A as addressed above.

and moisture barriers. The PSE&G program governing containment Exam visual examinations is described in the Cat. "Alternative Examinations" section of Relief E-D Request RR-E1 to ensure that industry-wide consistency is maintained with respect to containment visual examinations. Seals and gaskets previously required examination once per an interval with an affective acceptance criteria of leak tightness. Leak tight integrity is verified during each 10CFR50 Appendix J leak test.

Table Deleted this examination Dissimilar metal welds are now included in 2500-1 category which addressed Examination Category E-A as addressed above.

dissimilar metal welds. Examination of pressure retaining dissimilar Exam metal welds are optional as specified in Cat. 10CFR50.55a(b)(2)(x)(C). The PSE&G E-F program governing containment visual examinations is described in the "Alternative Examinations" section of Relief Request RR-E1 to ensure that industry-wide consistency is maintained.

Table E-G Deleted examination Pressure retaining bolting is now included in 2500-1 category which addressed Examination Category E-A as addressed above.

pressure retaining bolting. Pressure retaining bolting has been removed as Exam a separate examination. Bolting is under Cat. Examination Category E-A and is done in place E-G and not disassembled. Local pressure tests of bolted and gasketed joints performed in accordance with 10CFR50, Appendix J demonstrate leak-tight integrity. Examination of bolting in place is consistent with the requirements for ASME Code Class 1, 2 and 3 bolting. The PSE&G program governing containment visual examinations is described in the "Alternative Examinations" section of Relief Request RR-E1 to ensure that industry-wide consistency is maintained .

IWE COMPARISON

Para- Changes between IWE1992 Significance of change and or basis for use Edition/1992 Addenda and the as an alternative examination Graph 1998 Edition Table E-P Deleted examination Appendix J testing is mandated by plant 2500-1 category which addressed Technical Specifications. Removing this 10CFR50 App J testing for all duplicate requirement from IWE does not Exam pressure retaining components. adversely affect component integrity.

Cat.

E-P

Added new Table 2500 The new requirements provide for consistency Ultrasonic Thickness and repeatability in obtaining thickness Measurements For Augmented measurements and thus assure the reliable Examinations - which details detection of conditions adverse to containment girding and thickness integrity.

measurement requirements.

Table Deleted table. Non significant: the contents of the previous table are adequately addressed in IWE-3500.

3410-1 Figure Changed Figure IWE-2500-2 in Non significant IWE 1992 to Figure IWE-2500-1 in 2500-2 1998

ATTACHMENT 3 TO LR-990409 IWL COMPARISON

IWL COMPARISON Para- Changes between IWL 1992 Ed. Significance of change and or basis for

'92 Ad. and the 1998 Ed. use as an alternative examination Graph IWL- No change None 1000 1100 ASME Section XI generic Non significant wording change from repair, replacement and or modification terms to repair/replacement activities 1200 No change None 1210 No change None 1220 No change None 2000 No change None 2100 Changed "Inspection" to Non significant "General" in heading.

(a) Provided reference to IWA- The containment examinations are 2000 with exceptions from IWA- completely defined within the jurisdiction of 2210 and 2300 for visual IWL, and thus reference to IWA 2210, and examinations and for IWA 2300 are not applicable. However, to qualification of visual ensure that industry-wide consistency is examination personnel. maintained with respect to containment visual examinations and personnel qualifications, the PSE&G program governing these areas is described in the "Alternative Examinations" section of Relief Request RR-L 1. The examinations of IWL in the 1998 Edition provide an equivalent level of quality and safety as defined in IWA of the 1992 Edition. The examinations of IWE in the 1998 Edition coupled with the described PSE&G program governing containment visual examinations and personnel qualifications provide an equivalent level of quality an safety as defined in IWA of the 1992 Edition .

IWL COMP.ARISON Para- Changes between IWL 1992 Ed. Significance of change and or basis for

'92 Ad. and the 1998 Ed. use as an alternative examination Graph 2200 Delete reference to IWL 2500. The reference to IWL 2500 in the '92 Edition was incorrect, and this non significant change is associated with a subsequent inquiry.

2210 No change None No change None 2220 2230 ASME Section XI generic Non significant change from repair and or replacement to repair/replacement activities.

2300 No change; content changes in The philosophy of IWL to be an engineering IWL-2310 inspection under the direction of the Responsible Engineer is contained in this revised subarticle. This individual will be accountable for the entire inspection program, which will meet or exceed the level of quality a safety defined in the 1992 Edition. The specific changes to IWL-2310 and IWL-2320 will be discussed below.

2310 (a) Replaced VT-3C and VT-1C The VT-3C and VT-1 C inspections of IWA visual examination terminology have been replaced by Owner (Responsible with new general and detailed Engineer) defined general and detailed examination terms. visual exams, respectively. The PSE&G program governing containment visual examinations is described in the "Alternative Examinations" section of Relief Request RR-L 1 to ensure that industry-wide consistency is maintained with respect to containment visual examinations. The definition of critical examination items and acceptable conditions has not changed, such that any conditions adversely affecting quality or safety are not impacted by this change.

IWL COMPARISON

Para- Changes between IWL 1992 Ed. Significance of change and or basis for Graph '92 Ad. and the 1998 Ed.

use as an alternative examination 2310 (b) Eliminated reference to IWA- 10CFR50.55a(b)(2)(x)(B) mandates a 2210 for illumination levels, qualification of the remote examination (cont.)

examination distances and procedure for Subsection IWE. The lighting resolution requirements. and resolution qualification requirements for IWL will be developed similar to the procedures used for IWE.

General and Detailed Visual exams will be developed to identify areas of concrete deterioration and distress as defined in ACI 201.1.

The general and detailed visual examinations are equivalent to the VT-3C and VT-1 C exams in terms of assessing the condition and potential for deterioration within the containment system.

(c) Replaced reference to IWA- The use of owner defined inspection 2300 for concrete examination qualifications allows for the involvement of personnel qualification qualified engineering personnel with requirements with provisions for backgrounds in programs such as the the owner to define the Maintenance Rule, R.G. 1.135, and examination personnel Appendix J. This provides for a qualification requirements. containment inspection program that is performed by individuals with knowledge in containment degradation mechanisms.

The Containment Visual Examination Personnel will be certified with our written practice. It will satisfy the requirements of SNT-TC-1A and ANSl/ANST CP-189.

Certified personnel will have demonstrated skill, demonstrated knowledge, document training and documented experience required to properly perform the duties of a specific job.

The Responsible Engineer has accountability for personnel qualification, and all the requirements are contained within IWL.

IWL COMPARISON Para- Changes between IWL1992 Ed. Significance of change and or basis for

'92 Ad. and the 1998 Ed. use as an alternative examination _,

Graph 2310 The overall impact of the changes in IWL-2310 results in an inspection program, (cont.)

which is consistent with other containment monitoring programs, and thus provides an equivalent level of quality and safety as the 1992 Edition.

2320 Changed wording slightly. Non significant - clarifies wording Made the ASME Section XI Non significant generic change from repair and or replacement to repair/replacement activities.

Added a responsibility for the The added pressure test responsibilities for Responsible Engineer to review the Responsible Engineer ensures proper certain pressure test procedures. performance of pressure testing activities.

2400 No change None 2410 Added to (c) condition, which This change insures that all surfaces that allows for deferral of concrete can be inspected are examined, but visual exams to the next recognizes the personnel safety of the scheduled plant outage for inspectors. This change increases the level inaccessible portions of concrete of quality and does not adversely affect the surface. safety of the Containment Inspection Program.

2420 No change None 2421 Changed wording for sites with Non significant - clarifies wording and more than one plant. Changed accommodates plant life extensions.

frequencies by adding "and every 10 years thereafter.

2500 No change None 2510 Changed heading. Non significant

IWL COMPARISON Para- Changes between IWL 1992 Ed. Significance of change and or basis for

'92 Ad. and the 1998 Ed. use as an alternative examination Graph 2510 Eliminated the reference to VT- The conclusion that this change to owner 3C and VT-1 C and refers to the defined inspection types has no adverse (cont.)

general and detailed visual impact on the level of quality or safety is exams of IWL-2310. reached in the IWL-2310 discussion.

Adds the requirement to (b) that Increases the level of quality and safety of the Responsible Engineer will the examinations.

designate areas as suspect and requiring additional examinations.

Adds the requirement (c) for a Increases the level of quality of the exams visual examination of all tendon associated with the tendon anchorage and anchorage areas and tendon end caps. This requirement is consistent end caps shall be examined for with the rule in 10CFR50.55a. This change specific conditions. does not apply to PSE&G.

Overall the changes made in this subarticle improve the level of quality and do not adversely affect the safety of the containment inspection plan described in the 1992 Ed.

2520 No change None 2521 No change None 2522 Changed the heading and added The added details ensure proper tendon a subparagraph to address examinations. However, these changes do tendon elongation. not apply to PSE&G.

2523 No change None 2524 Eliminated the VT-1 exam and This change is consistent with the changes replaced it with the detailed described in IWL-2310 above, and the visual exam described in IWL- change in IWE 2310, which eliminated the 2310 above. VT-1 exam and replaced with a detailed visual exam .

IWL COMP.ARISON

Para- Changes between IWL 1992 Ed. Significance of change and or basis for

'92 Ad. and the 1998 Ed. use as an alternative examination Graph 2524 This change does not affect the level of (cont.) quality or safety of the inspection program previously described in the 1992 Ed.

However these changes do not apply to PSE&G.

2525 Changed wording for sample Non significant analysis.

2526 Added a subparagraph The new paragraph provides the addressing replacement of Responsible Engineer some options from corrosion protection medium. . which to specify corrosion medium replacement. This change adds to the level of quality and does not adversely impact the safety of the inspection program described in the 1992 Ed.

However, these changes do not apply to PSE&G containments.

3000 No change None 3100 No change None 3110 No change None 3111 ASME Section XI generic Non significant change from repair and or replacement to repair/replacement activities.

3112 No change None 3113 ASME Section XI generic Non significant change from repair and or replacement to repair/replacement activities.

3120 No change None 3200 No change None 3210 Removed the word concrete Non significant from the heading

IWL COMPARISON Para- Changes between IWL1992 Ed. Significance of change and or basis for

'92 Ad. and the 1998 Ed. use as an alternative examination Graph 3211 Added tendon end and The acceptance criteria has expanded to anchorage areas to the scope of recognize that the surface area being the subparagraph and added examined per IW-2510 includes the corrosion protection medium concrete surrounding the tendon end leakage and end cap anchorage, and the tendon end caps. This deformation as acceptance increases the overall quality of the exam, criteria attributes. and is consistent with the rule in 10 CFR 50.55a. However, these changes do not apply to PSE&G containments.

ASME Section XI generic Non significant.

change from repair and or replacement to repair/replacement activities.

3212 No change None

3213 ASME Section XI generic change from repair and or replacement to repair/replacement activities.

Non significant 3220 No change None. However, these changes do not apply to PSE&G containments.

3221 Added acceptance criteria The additions to the acceptance criteria of attributes for unbonded post- IWL-3221 have provided further assurance tensioning systems in the that the Responsible Engineer will evaluate following areas: all potential conditions that could impact the post-tensioning system integrity. These 3221.1 (c) evaluates the enhancements to the 1998 Edition increase predicted force for the next the level of quality of the inspection scheduled exam meets the program and has no adverse impact on the minimum design prestress force.

safety of the inspection program described 3221.1 (d) compares the in the 1992 Edition. These additions are elongation with the last consistent with the requirements of the rule measurement and specifies that as stated in 10CFR 50.55a.

it can not vary by more than However, these changes do not apply to 10% .

PSE&G containments.

IWL COMl?ARISON

Para- Changes between IWL1992 Ed . Significance of change and or basis for Graph '92 Ad. and the 1998 Ed. use as an alternative examination 3221 3221.3(e) added evidence of (cont.) free water as an unacceptable condition.

3221.4 added criteria to compare the difference of the amount of corrosion protection medium removed with that replaced.

3222 No change None 3223 ASME Section XI generic Non significant change from repair and or replacement to repair/replacement activities.

3300 No change None 3310 Added applicability for other Non significant plants at the same site.

ASME Section XI generic Non significant change from repair and or replacement to repair/replacement activities.

3320 Deleted paragraph, which Non significant - there were no submittal or addressed engineering retention requirements changed by the evaluations being subject to deletion of the subparagraph.

review by authorities.

NRC Rulemaking (Page 41312 of Federal Register dated August 8, 1996, Volume 61, Number 154, Rules and Regulations) states in part, "Licensees do not have to submit to the NRC staff for approval of their containment inservice inspection program which was developed to satisfy the requirements of Subsection IWE and IWL with specified modifications and a limitation.

PSE&G will maintain required documentation on site for review and audit.

4000 ASME Section XI changes from Non significant - all related repair and repair and or replacement to replacement requirements have been

repair/replacement activities. consolidated into IWL-4000.

IWL COMPARISON Para- Changes between IWL 1992 Ed. Significance of change and or basis for

'92 Ad. and the 1998 Ed. use as an alternative examination Graph 4100 No change None 4110 Exempted grease cups and Non significant - the exempted items are installation screws from the non structural items and the exemption of scope. these items is consistent with the ASME position on other such items, i.e. seals, gaskets.

However these exemptions do not apply to PSE&G containments.

ASME Section XI generic Non significant change from repair and or replacement to repair/replacement activities.

4120 Removed (a), (b), (c). Non significant. Added for clarification Added "/replacements activities", Non significant

"/Replacement", and "Plan".

Changed IWA-4140 to IWA-4150.

Deleted (b) repairs shall be Non significant - IWL-4200 still applies.

completed in accordance with the Repair Plan of IWL-4200.

4200 ASME XI generic change from Non significant repair and or replacement to repair/replacement activities.

Added a new paragraph 4210 to Non significant -this is a paragragh require Repair/Replacement numbering change from the '92 Ed.

Plans to be developed under the direction of a Responsible Engineer per IWL-2300.

4210 Changed paragraph number to Non significant 4220, removed the word repair from heading and changed referenced paragraph numbers consistent with the addition of a new paragraph 4210 above.

IVVL COMP.ARISON Para- Changes between IWL1992 Ed. Significance of change and or basis for

'92 Ad. and the 1998 Ed. use as an alternative examination Graph 4210 Changed wording consistent with Non significant the changes to IWL-2310 (cont.)

addressed above.

ASME Section XI generic Non significant change from repair and or replacement to repair/replacement activities.

Changed repair material to new Non significant material in several places.

4220 Changed paragraph number to Non significant 4230.

4230 Changed paragraph number to Non significant 4240 and clarified by removing the word repair.

ASME Section XI generic Non significant change from repair and or replacement to repair/

replacement activities.

Added detailed requirements for The 1998 Edition is more prescriptive in the contents of a repair/ terms of the details that are expected to be replacement plan. addressed in the repair/replacement plan developed by the Responsible Engineer.

This increases the level of quality of the plan developed under the 1998 Edition.

However, these changes do not apply to PSE&G containments.

4300 ASME Section XI generic Non significant change from repair and or replacement to repair/

replacement activities.

5000 No change None

IWL COMf?ARISON Para- Changes between IWL 1992 Ed. Significance of change and or basis for

'92 Ad. and the 1998 Ed. use as an alternative examination Graph 5100 ASME Section XI generic Non significant change from repair and or replacement to repair/

replacement activities.

5200 No change None 5210 ASME Section XI generic Non significant change from repair and or replacement to repair/replacement activities.

5220 No change None 5230 Changed wording by removing Non significant - the removed wording was some specific IWE related IWE specific and is contained in IWE-5000.

requirements while maintaining the reference to IWE-5000.

5240 Deleted paragraph that Non significant - the schedule of pressure addressed the scheduling of tests are contained in IWE-5000 as pressure tests. referenced in IWL-5230.

5250 Changed wording regarding the The clarified role of the Responsible role of the Responsible Engineer Engineer ensures proper pressure test in pressure test activities. procedures and examinations.

Replaced the VT-1 exam with a The acceptability of the change to an reference to IWL-2310 (b) for a owners defined detailed visual inspection is detailed visual. discussed in the IWL-2310 section.

ASME Section XI generic Non significant change from repair and or replacement to repair/replacement activities.

5260 Changed heading from Non significant Corrective Measures to Corrective Action .

IWL COMP.ARISON

Para- Changes between IWL 1992 Ed. Significance of change and or basis for Graph '92 Ad. and the 1998 Ed. use as an alternative examination 5260 ASME Section XI generic Non significant change from repair and or (cont.)

replacement to repair/replacement activities.

5300 ASME Section XI generic Non significant change from repair and or replacement to repair/replacement activities.

7000 Deleted Article including IWL- Non significant - all related repair and 7100, 7110, 7120 consistent with replacement requirements have been the IWL-4000 changes above. incorporated into IWL-4000.

Table Changed item L 1.11 from all The addition of accessible provides areas to all accessible areas. consistency with the requirements of the 2500-1 scope of IWL-1000, and does not alter the level of quality of the inspection plan described in the 1992 Edition.

Changed Item L 1.12 from Visual, This is a less stringent inspection. PSE&G VT-1C to general examination to will perform a detailed inspection on all suspect areas. suspect areas to be more consistent with the intent of the code.

Replaced the VT-3C, VT-1C, The acceptability of the change to an owners defined general and detailed visual and the VT-1 exams with general inspection is discussed in the IWL-2310 visual and detailed visual, section.

respectively, as described in the paragraph IWL-2310 changes above.

Table Changed inspection periods to Non significant - accommodates plant life 2521-1 state every 5th year in lieu of extensions for tendon examinations.

listing out each year and However, these requirements do no apply changed note 2 for having to to PSE&G containments.

meet acceptance criteria from "each of the earlier inspections" to "for the last 3 inspections".

IWL COMl?ARISON

Para- Changes between IWL1992 Ed. Significance of change and or basis for Graph '92 Ad. and the 1998 Ed. use as an alternative examination Table Added optional test methods for Non significant - additional test method 2525-1 corrosion protection medium options provides for more practical test analysis implementation. However, these requirements do not apply to PSE&G containments .

\.

ATTACHMENT 1 TO LR-990409 RELIEF REQUESTS RR-E1 AND RR-L 1

,, }.*

RELIEF REQUEST RR-E1 NRC Approved (Yes or No): Date _ __

Component

Description:

Metallic containment shell and penetration liners and their integral attachments ASME Code Class:

MC ASME Examination Requirement:

1992 Edition, 1992 Addenda of Subsection IWE, "Requirements for Class MC and Metallic Liners of Class CC Components of Light-Water Cooled Power Plants", of Section XI, Division 1, of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code).

Basis for Relief:

In the Federal Register, dated August 8, 1996 (61 FR 41303), the NRC amended its regulations to incorporate, by reference, the ASME Code Section XI, 1992 Edition and Addenda of Subsection IWE for expedited examination of containments. Considerable comments were provided by the industry to this rule change, and the NRC staff took appropriate action to provide exceptions to allow licensees a flexible implementation schedule and relaxation in specific areas to meet these requirements. Based on the effective date of the rule change of September 9, 1996, licensees have until September 9, 2001 to have a Containment ISi program in place and to complete the first period inspection requirements contained in Section XI.

ASME has made extensive changes to the Subsection IWE contained in the 1992 Edition and Addenda concerning the examination requirements for containments.

These changes were based on industry concerns and comment and are now published in the 1998 Edition of the ASME Code Section XI. Publication of the 1998 Edition by the ASME, with NRC participation, provides the basis for the approval of these new 1998 Edition requirements that have been determined by the ASME consensus process to provide an acceptable level of quality and safety.

RELIEF REQUEST RR-E1 The proposed alternative is to utilize the current ASME approved 1998 Edition of

Subsection IWE of Section XI in its entirety as augmented by the additional requirements contained in the "Alternative Examinations" section below. Utilizing the 1998 Edition of IWE in its entirety incorporates other exceptions to the 1992 addenda stated in NRC rulemaking and provides more cohesiveness than could be achieved by requesting relief on several individual subjects separately. The examination requirements of the 1998 Edition of the Code were developed in accordance with the ASME Code committee process with input from interested parties, other utilities, manufacturers, engineering organizations, Authorized Nuclear Inspection Agencies, EPRI and the NRC. The updating of requirements by this consensus process is intended to ensure the continued safe operation of nuclear power plants and specifically, in this case, ensures the continued leak-tight and structural integrity of metallic containment components. Therefore, the overall level of plant quality and safety will not be adversely affected by utilizing the requirements of the 1998 Edition of IWE.

PSE&G has determined that the use of the 1998 Edition requirements as augmented by the additional requirements contained in the "Alternative Examinations" section below in lieu of the 1992 Edition and Addenda requirements for our Containment ISi program represents an equivalent level of quality and safety. A line by line comparison was made of the 1998 Edition to the 1992 Edition and Addenda. The 1998 Edition provides an equivalent, and in some cases an increased, level of quality and safety to our

proposed containment inspection program.