ML023260262

CRD Welds Should Be Included in ISI Program

ML023260262
Person / Time
Site:	Quad Cities
Issue date:	11/20/2002
From:	Lyon C Exelon Generation Co
To:	David Jones, Ring M, Karla Stoedter Division Reactor Projects III
References
Download: ML023260262 (3)

Text

I Car Lyon - Quad Cities CR0 Welds Pa 11I Paae From: Carl Lyon To: Donald Jones; Karla Stoedter; Mark Ring Date: 11/20/02 12:28PM

Subject:

Quad Cities CRD Welds During a conference call on 11/6, the staff informed Exelon that it had reviewed the information provided by the licensee and concluded that Section Xl, Table IWB-2500-1, Category B-O, Item B14.10 (Reactor Vessel - Welds in CRD Housing), applies to the Quad Cities CRD housing welds. Therefore, the welds should be included in the ISI program.

Subsequent to the conference call, the licensee said that in the process of preparing a request for Code interpretation of the issue, their contractor had given them a copy of an NRC letter and SE to Hatch, dated 9/29/86, with an attached TER prepared by SAIC. The NRC letter responded to a request for relief from inspection of the CRD welds by informing Hatch that relief was not required, because the welds were exempt in accordance with IWB-1220. Exelon asked why Quad Cities should not also be exempt, since the staff position on Quad Cities appeared to be a "new or different staff position from a previously applicable position."

Following a cursory search of NUDOCS, I showed to EMCB staff a copy of an NRC letter and SE to Grand Gulf, dated 7/22/86, with an attached TER prepared by SAIC, granting relief, not exemption, from inspection of the CRD welds. I also reviewed ISI documentation from a number of BWRs and noted that every one, including 9 with RCIC, included the CRD housing welds in their IS[ program.

Review of past relief requests show some inconsistency by the staff in the application of ISI requirements in the late 1980s. If the Hatch request were made today, however, it would be evaluated for relief by the staff. It would not be viewed as a requirement from which exemption was granted by IWB-1220.

Notwithstanding the inconsistency between the responses to Hatch and Grand Gulf in 1986, for whatever reason it occurred, the staff's conclusion that the CRD welds should be included in the Quad Cities ISI program is unchanged. The IWB-1220 exemption does not apply to the CRD housing welds. The licensee may, however, apply for relief from the requirements of the Code.

Several options are available to Exelon, such as:

(1) include the CRD welds in their ISI program and inspect them in accordance with Code requirements, (2) submit a relief request to the NRC, which the staff will review in accordance with the normal licensing action process, or (3) submit a request to the Code committee for interpretation of the requirement.

The last option may be the best in order to get a definitive answer; however, the staff is not obligated to accept the Code committee's position.

CC: Keith Wichman; Lakshminaras Raghavan; Lawrence Rossbach; Michael Kurth; Terence Chan

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Quad Cities CRD Welds Creation Date: 11/20/02 12:28PM From: Carl Lyon Created By: CFL@nrc.gov Recipients Action Date & Time nrc.gov chpo.CHDO Delivered 11/20/02 12:29PM DEJ (Donald Jones) Opened 11/20/02 01:10PM KKB (Karla Stoedter) Opened 11/20/02 01:08PM MAR (Mark Ring) Opened 11/20/02 04:47PM MFK CC (Michael Kurth) Opened 11/20/02 01:14PM nrc.gov owf2_po.OWFNDO Delivered 11/20/02 12:28PM KRW CC (Keith Wichman) Opened 11/20/02 01:55PM TLC CC (Terence Chan) Opened 11/20/02 01:09PM nrc.gov owf4_po.OWFNDO Delivered 11/20/02 12:28PM LWR CC (Lawrence Rossbach)

LXR1 CC (Lakshminaras Raghavan) Opened 11/20/02 01:10PM Post Office Delivered Route ch-po.CHDO 11/20/02 12:29PM nrc.gov owf2_po.OWFNDO 11/20/02 12:28PM nrc.gov owf4_po.OWFNDO 11/20/02 12:28PM nrc.gov Files Size Date & Time MESSAGE 3573 11/20/02 12:28PM Options Auto Delete: No Expiration Date: None Notify Recipients: Yes Priority: Standard Reply Requested: No Return Notification: None Concealed

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