ML20129A334

Requests Addl Info & Amount of Time Required to Formally Respond in Response to Re Remaining Relief Requests

ML20129A334
Person / Time
Site:	Byron
Issue date:	10/16/1996
From:	Dick G NRC (Affiliation Not Assigned)
To:	Johnson I COMMONWEALTH EDISON CO.
References
TAC-M94830, TAC-M94831, NUDOCS 9610220113
Download: ML20129A334 (5)

Text

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October 16, 1996 Ms. Irene Johnson, Acting Manager Nuclear Regulatory Services Commonwealth Edison Company Executive Towers West III 1400 Opus Place, Suite 500 Downers Grove, IL 60515

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING SECOND TEN-YEAR INSERVICE INSPECTION PROGRAM - BYRON STATION, UNITS 1 AND 2 (TAC NOS. M94830 AND M94831)

Dear Ms. Johnson:

On February 23, 1996, ictimonwealth Edison Company (Comed) submitted its second ten-year Inservice Insg etion Program and associated relief requests. In its submittal, Comed requested expedited review for Relief Requests 12R-ll and 12R-12. Relief Request 12R-11 was subsequently withdrawn by Comed on June 12, 1996; we authorized Relief Request 12R-12 on July 22, 1996.

On June 13, 1996, we issued a Request for Additional Information (RAI) concerning the remaining relief requests. Comed provided its response on August 12, 1996. During the continuation of our review of the initial submittal and Comed's August 12, 1996 submittal, we have identified the need for further information, as discussed in the enclosed RAI, before we can complete our review. Please contact me with your estimate of the time required to provide a formal response.

Sincerely, Original signed by:

George F. Dick, Jr., Project Manager Project Directorate III-2 Division of Reactcr Projects - III/IV Office of Nuclear Reactor Regulation Docket Nos. STN 50-454, STN 50-455

Enclosure:

RAI pfOl'f y cc w/ encl: see next page Distribution:

(Docket? File PDIII-2 r/f x. -

J. Roe, JWR E. Adensam, EGA1 R. Capra C. Moore NQQN)PUBLIC G. Dick ACRS, T2E26 T. McLennan R. Lanksbury, RIII OGC, 015B18 DOCUMENT NAME: BYRON \BY94830.LTR NRC FILE CENTER COPY To receive e espy of this document, indioete in the boa: *C" = Copy without enclosures *E* = Copy with enclosures "N" = No copy 0FFICE PM:PDIIj-3 f:

i CALP4III-2 & D:PDIII-2 l 9 l .

NAME GDICK h di CMOORT RCAPRA F ~ l 10//6 /96 j DATE 10//6 /96 10Ah/96

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l 9610220113 961016 'FICIAL RECORD COPY PDR ADOCK 05000 M 4 i G Pbn  ; j

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I. Johnson Byron Station Commonwealth Edison Company Unit Nos. I and 2 cc:

Michael I. Miller, Esquire Chairman, Ogle County Board Sidley and Austin Post Office Box 357 One First National Plaza Oregon, Illinois 61061 Chicago, Illinois 60603 Mrs. Phillip B. Johnson Regional Administrator, Region III 1907 Stratford Lane U.S. Nuclear Regulatory Comission Rockford, Illinois 61107 801 Warrenville Road Lisle, Illinois 60532-4351 Attorney General l

500 South Second Street Illinois Department of Springfield, Illinois 62701 Nuclear Safety Office of Nuclear Facility Safety EIS Review Coordinator 1035 Outer Park Drive U.S. Environmental Protection Agency Springfield, Illinois 62704 77 W. Jackson Blvd. ,

Chicago, Illinois 60604-3590 l l Document Control Desk-Licensing l Comonwealth Edison Company Commonwealth Edison Company l l

1400 Opus Place, Suite 400 Byron Station Manager l '

Downers Grove, Illinois 60515 4450 North German Church Road Byron, Illinois 61010 Mr. William P. Poirier, Director Westinghouse Electric Corporation Kenneth Graesser, Site Vice President Energy Systems Business Unit Byron Station Post Office Box 355, Bay 236 West Commonwealth Edison Station Pittsburgh, Pennsylvania 15230 4450 N. German Church Road Byron, Illinois 61010 Joseph Gallo Gallo & Ross 1250 Eye St., N.W.

Suite 302 Washington, DC 20005 l

Howard A. Learner Environmental law and Policy Center of the Midwest 203 No. d LaSalle Street Suite 1390 Chicag'o, Illinois 60601 l

U.S. Nuclear Regulatory Commission l Byron Resident Inspectors Office i

l 4448 North German Church Road

Byron, Illinois 61010-9750 Ms. Lorraine Creek

! Rt. 1, Box 182

Manteno, Illinois 60950 i

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REQUEST FOR ADDITIONAL INFORMATION SECOND TEN-YEAR INSERVICE INSPECTION INTERVAL COMONWEALTH EDISON COMPANY BYRON STATION. UNITS 1 AND 2 DOCKET NOS. STN 50-454 AND STN 50-455

1) Unapproval Code cases: In accordance with 10 CFR 50.55a(c)(3), 10 CFR 50.55a(d)(2), and 10 CFR 50.55a(e)(2), American Society of Mechanical Engineers (ASME) Bailer and Pressure Vessel Code (Code) cases may be used as alternatives to Code requirements. Code cases that the NRC has approved for use are listed in Regulatory Guide (RG) 1.10, Inservice Inspectfon Code Case Acceptablifty, with any additional conditions deemed necessary by the NRC. Code cases agl referenced in RG 1.147 may be adopted only if authorized by the NRC on a case-by-case basis. In some cases, use of unapproved Code cases may be acceptable for use when certain conditions are included. To ensure consistent implementation, licensees proposing the use of currently unapproved Code case (s), must commit to such conditions, if applicable.

In Relief 12R-10, the licensee has proposed to implement the al':ernatives contained in ASME Code Case N-522, Pressure Testing of Containment Penetratfon Piping. This Code case may be considered acceptable for use with the following conditions:

a) The leak test is performed at the peak calculated containment design pressure; ant i b) a test procedure is used that provides for detection and location of through-wi11 leakages in the pipe segments that are being tested.

In Request for Relicef I2R-17, the use of Code Case N-509, Alternate Rules for the Selection and Examination of Class 1, 2, and 3 Integrally Weided Attachments, is proposed. This Code case may be considered acceptable for use provided that a minimum of~10 percent of the total number of integral attachments in all Class 1, 2, and 3 systems are examined.

To find the proposed alternatives to the Code requirements acceptable for use, incorporation of the above conditions into the applicable request for relief is necessary. Confirm that the conditions stated above will be met.

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2) In Request for Relief I2R-03 relief is requested from performing the

. Code-required volumetric examination of the pressurizer surge nozzle-to-vessel weld and inside radius section. This request was evaluated and authorized for the first 10-year interval provided that the ENCLOSURE

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. Code-required examination was performed if the insulation was removed for any reason. To find this proposed alternative to the Code requirements acceptable for use for the second 10-year interval, incorporation of the above condition into the request for relief is necessary. Confirm that the condition stated above will be met.

3) Request for Relief I2R-05: In lieu of performing the 100 percent volumetric examination as required by the Code, the licensee requested to perform a "best effort" ultrasonic examination on the residual heat removal heat exchanger nozzle-to-shell welds. In the staff's Request for Additional Information dated June 13, 1996, the licensee was requested to provide an estimate of the Code-required volume that could be examined with the best-effort ultrasonic examination. This information was not provided in the August 12, 1996, response. Provide an estimate of the coverage that can be achieved with the best effort ultrasonic examination.

As a result of indications found in the subject welds during the first 10-year interval, the licensee submitted a request for relief (December 12,1995) from the successive examination requirements of the Code. This request, which was subsequently evaluated in the staff's Safety Evaluation dated February 29, 1996, included the performance of a surface examination once each period as the proposed alternative. Will the welds included in 12R-05 continue to receive surface examinations during the second 10-year interval?  ;

4) In Request for Relief 12R-01, relief is requested from two separate i requirements for reactor vessel shell Weld RPVC-WR29 due to physical l' obstructions that limit the volumetric examination to less than 90 percent of the required volume - (1) the period volumetric l examination required by Section XI for the second 10-year interval, i and (2) the augmented volumetric examination required by 10 CFR l 50.55a(g)(6)(ii) that should have been performed during the first i 10-year interval.  ;

Regarding the augmented exami e tion, the regulations state that licensees that can not completely satisfy the examination requirements of 10 CFR 50.55a(g)(6)(ii)(A), mus+. submit information supporting that determination and must propose an alternative that would provide an ,

acceptable level of quality and safety. This alternative may be used j when authorized by the NRC staff. In accordance with 10 CFR 1 50.55a(a)(3), alternatives to the requirements of 10 CFR 50.55a(g)(6)(ii)(A) may be used when authorized by the NRC staff if the licensee demonstrates that either (i) the proposed alternative provides l an acceptable level of quality and safety, or (ii) that the examination l requirements would result in a hardship without a compensating increase

in quality and safety.

Request for Relief 12R-01 can not be evaluated for the Section XI

requirements in the second 10-year interval until the augmented i

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. Request for Relief I2R-01 can not be evaluated for the Section XI requirements in the second 10-year int:rval until the augmented volumetric examination requirements of the regulations are satisfied for the first interval. To satisfy the regulations, the licensee should provide a separate submittal containing the required proposed alternative. The staff will evaluate the proposed alternative to verify that examination coverage has been maximized from both the vessel interior and exterior. To help the staff complete the evaluation and close out this issue, provide a technical discussion describing how

] examination coverage was maximized (including the possibility of, or the burden associated with, performing an examination from the vessel exterior). Once the augmented volumetric examination requirements are satisfied for the first interval, the limited Code examinations for the second interval can be addressed by revising and resubmitting Request

for Relief 12R-01.

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