ML20097J049

Forwards Response to Questions Re 10-yr Inservice Insp & Testing Program.Addl Relief Requests & Rev 1 to Inservice Insp & Testing Program,Quad Cities Nuclear Power Station Units 1 & 2 Also Encl

ML20097J049
Person / Time
Site:	Quad Cities
Issue date:	09/07/1984
From:	Rybak B COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20097J052	List: ML20097J049 ML20097J059
References
9143N, NUDOCS 8409210095
Download: ML20097J049 (10)

Text

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/ 'N Commonwealth Edison A .[ '

) One First National Plaza, Chicago. Ilknots

} T ) Address Reply to: Post Office Box 767 N / Chicago Illinois 60690 September 7, 1984

-Mr. Harold R. Denton, Director-Office of Nuclear Reactor Regulation U.S.~ Nuclear Regulatory Commission Washington, DC ~20555 Sub ject: Quad Cities Station Units 1 & 2 Second Ten Year Inservice Inspection Program

~ Request for Additional Information NRC Docket No. 50-254 & 50-265

Reference:

T.J. Rausch letter to H.R. Denton dated February 17, 1983.

Dear Mr. Denton:

-- In accordance with the provisions of 10CFR 50.55 a Commonwealth Edison submitted, per the' referenced letter our second

=10-year Inservice Inspection and Testing (ISI.& IST) Program. We have-since received informal questions and are docketing our response in Attachment A to this letter. Attachment B includes two additional relief requests. Finally we are enclosing six (6) copies

.of our Summer 1975 Addenda ISI program for reference.

.'After all questions are resolved on the ISI/IST program we will submit an final amended program which will incorporate any changes resulting from your review.

If any questions arise on this matter, please contact this office.- One (1) signed original and forty (40) copies of this letter-and Attachment A & B are enclosed.

Very truly yours,

s. M B. Rybak Nuclear Licensing Administrator

-bs cc: R. Bevan - NRR NRC Resident Inspector -Quad Cities 9143N 8409210095 840907 hok9 PDR ADOCK 05000254 P O 3

ATTACHMENT A RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION 4

S 9143N

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION INSERVICE INSPECTION PROGRAM

References:

Request For Additional Information Inservice Inspection Program, dated April 10, 1984.

1. Quad-Cities Station is submitting two additional relief requests. They are relief request CR.ll and CR-12. Please see attached sheets for

. additional information.

2. Copies of Quad-Cities' revised "1975" program will be supplied by Nuclear Licensing Department.

'3. Relief Requests CR-1 and CR-2: Beltline Shell Welds and Bottom Head Welds in Reactor Vessel, Category B-A, Items Bl.ll, Bl.12, Bl.21, Bl.22 (Item Bl.ll) There are no accessible circumferential welds in the upper shell area, therefore no increased examination is feasible.

(Item Bl.12) One longitudiual beltline region shell weld has the length of 11'1", hence, 11'1" of accessible longitudinal shell weld in the upper shell area will be examined in order to achieve an examination sample equivalent to the category B-A weld for which relief is requested.

(Item Bl.21, Bl.22) Augmented examinations may not be necessary because Section XI of ASME Code,1980 Edition through Winter 1980 Addenda, only requires examination of accessible welds.

4. Relief Request CR-3 Piping Welds, Categroy B-J, Item B9.ll As permitted by 10 CFR 50.55a., Quad-Cities Station will continue to use table IWB-2500, Category B-J of Section XI,1974 edition including Summer 1975 addenda to determine the extent of examination for Code Class 1 pipe welds in lieu of the extent of examination specified in the 1980 Code in requiring the same sample to be reexamined. In other words, different 25%

sample will be inspected each inspection interval, therefore, Quad-Cities Station feels that this relief request is needed.

5.- Relief Request CR-4 and CR-5: Penetration'and Branch Connection Welds, Category B-J, Item B9.11 (Refer to explanation given in response to question 4 above, concerning the necessity of the relief requests.)

The first pressure boundary weld outside the containment on each of these process pipes will be volumetrically examined, where practical, over 100%

of its length during each inspection interval (CR-4). Surface examination of the saddle fillet welds will be performed in lieu of the Code required examination (CR-5) . The examinations required by IWB-5000 will also be conducted.

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6. Relief Request CR-8 RHR Hx Nozzla-to-Shell Welds, Category C-B Item C2.10 or C2.20 A. The RHR Heat exchanger shell is 1. inch thick, therefore, both surface and volumetric examinations are imposed on-these nozzle-to-shell welds by the Code.

Relief from volumetric exam is added to CR-8. See attached revised relief request CR-8 for cdditional information.

B. Alternative surface examinations imposed in the SER have been incorporated into the station's procedure which lists all components to be examined and method of examination for the current inspection interval.

7. Exemption of Class 2 welds in RHR, ECCS, and Containment Heat Removal Systems.

' Class 2 welds in RHR and ECC systems will be examined except for those components exempted from examination by Code allowed exemptions as specified in IWC.1220 (a) ,(b) , and (c) .

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ATTACHMENT B ADDITIONAL RELIEF REQUEST 9143N

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RELIEF REQUEST NO. CR-8 I. IDENTIFICATION OF COMPONENTS AND IMPRACTICAL CODE REQUIREMENTS There are two 18" diameter nozzles in the Class-2 portion of each of the two RER System heat exchangers that are fabricated with reinforcement saddles. These. saddles are fillet welded over the actual pressure retaining nossle to shell weld. The configuration is shown on Figure 5.

Section XI of the ASNB Boiler and Pressure vessel Code, 1980 Edition through the Winter 1980 Addenda requires surface and volumetric examinations of two of these four nozzle-to-shell welds in the inspection inteval. This requirement is impractical due to -

, inaccessibility.

II. BASIS FOR RELIEF .

The fabrication of these nossle-to-shell welds precludes any type of volumetric or surface examination. The design does, however, provide

!? additional. strength at the joint and results in lower stresses at the internal weld. Integrity of these joints will be monitored by periodic system pressure and hydrostatic tests.

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III. ALTERNATE FR0 VISIONS

~An alternative surface examination of the reinforcing ring welds will be performed and a visual examination for evidence of leakage will be

. conducted in accordance with the Subsection INC-5000 requirements.

Station's procedure will be revised to insure the performance of the alternative examinations.

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RELIEF REQUEST NO. CR-ll I. IDENTIFICATION OF COMPONENTS AND IMPRACTICAL CODE REQUIREMENT Section XI of the 1980 Edition of the ASME Code including the Winter 1980 Addenda specifies that a volumetric inspection of all full penetration nossle inside radii sections (code category B-D, item 53.100) each ten-year interval.

The design of the Standby Liquid Control (SBLC) Nozzle as shown on 4

Figure 6 provides an inner radius geometry which is not conducive to ultrasonic inspection.

Relief is requested from this SBLC inner radius inspection due to the nossle inside radius geometry.

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II. BASIS FOR RELIEF The design of the SBLC nozzle piece does not lend itself to ultraconic

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! which the boron injection piping is fillet welded and consequently provides a geometry which will result in a meaningless ultrascnic

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III. ALTERNATE PROVISION l

l No alternate or augmented examinations are feasible a this time.

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1 RELIEF REQUEST NO. CR-12 I. IDENTIFICATION OF COMPONENTS AND IMPRACTICAL CODE REQUIREMENTS Each Quad-Cities Unit has an ISI class 2 HPCI Turbine in the HPCI System.

The ASME Boiler and Pressure Vessel Code,Section XI 1980 Edition through the Winter 1980 Addenda requires a hydrostatic test once every inspection interval on all ISI class 2 pressure boundaries.

Relief is requested from this Code requirements in order to avoid damaging the turbine's labyrinth seals.

II. BASIS FOR RELIEF The labyrinth seals used in the HPCI turbine are designed to prevent steam from leaking out of the turbine casing. The fragile design of the seals is not intended to retain water under pressure. Therefore, performing a hydrostatic test on the turbine. casing will permanently damage the turbine seals.

III. ALTERNATE PROVISIONS A system functional test will be conducted in lieu of the hydrostatic

, test.

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