ML20137B161

Forwards RAI Re First ten-year Inservice Insp Program for Plant.Copy of Response to Be Sent to Inel in Order to Expedite Review Process

ML20137B161
Person / Time
Site:	Braidwood
Issue date:	03/19/1997
From:	Dick G NRC (Affiliation Not Assigned)
To:	Johnson I COMMONWEALTH EDISON CO.
References
TAC-M97134, TAC-M97135, NUDOCS 9703210190
Download: ML20137B161 (7)

Text

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6 1 March:19, 1997 Ms. Irene M. 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 FIRST 10-YEAR INSERVICE INSPECTION PROGRAM - BRAIDWOOD STATION (TAC NOS. M97134 AND M97135)

Dear Ms. Johnson:

On October 8, 1996, Commonwealth Edison Company (Comed) submitted its first 10-year Inservice Inspection (ISI) Program and associated relief requests for Braidwood Station, Units 1 and 2. Subsequent to the submittal, Comed requested expedited review for Relief Request NR-29 and it is being addressed separately.

During our review of the remainder of the October 8,1996 submittal, we have identified the need for additional information as discussed in the enclosed Request for Additional information (RAI). Please provide your response to the -

RAI so that we may continue to review your submittal.

In order to expedite the review process, please send a copy of the RAI response to our contractor, Idaho National Engineering Laboratory (INEL), at the following address:

Mr. Michael T. Anderson INEL Research Center 2151 North Boulevard PO Box 1625 Idaho Falls, Idaho 83415-2209 Sincerely, g ORIGINAL SIGNED BY:

George F. Dick, Jr., Project Manager Project Directorate III-2 Division of Reactor Projects - III/IV Office of Nuclear Reactor Regulation Docket Nos. STN 50-456, STN 50-457

Enclosure:

RAI 6

cc: See next page DISTRIBUTION: :__ __ -- PUpt.f t PDlit 2 r/f J. Roe E. Adensam R. Capra G. Dick j R. Lanksbury S. Bailey R. Assa C. Moore OGC M. Holmberg T. McLellan ACRS {

DOCUMENT NAME:G:\CMNTJR\ BRAID \BR97134.RAI To receive a copy of this document, indicate in the box: "C" = Copy without enclosures *E* = Copy with enclosures *N" = No copy 0FFICE PM:PDIII-2 l LA:P1LIlII-2 lG_. PD:PDIII-2 lC NAME GDICK Chl0URET RCAPRA 9 ,

DATE 03/ /97 03/('/ /97 03//9/97 9703210190 970319 FICIAL RECORD COPY PDR AnnCK 05000456 Ep PDR

, March 19, 1997 Ms. Irene M. 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 FIRST 10-YEAR INSERVICE INSPECTION PROGRAM - BRAIDWOOD STATION (TAC NOS. M97134 AND M97135)

Dear Ms. Johnson:

On October 8,1996, Commonwealth Edison Company (Comed) submitted its first 10-year Inservice Inspection (ISI) Program and associated relief requests for Braidwood Station, Units 1 and 2. Subsequent to the submittal, Comed requested expedited review for Relief Request NR-29 and it is being addressed separately.

During our review of the remainder of the October 8,1996 submittal, we have identified the need for additional information as discussed in the enclosed Request for Additional information (RAI). Please provide your response to the .

RAI so that we may continue to review your submittal.

In order to expedite the review process, please send a copy of the RAI response to our contractor, Idaho National Engineering Laboratory (INEL), at the following address:

l Mr. Michael T. Anderson l INEL Research Center  !

2151 North Boulevard i PO Box 1625 l Idaho Falls, Idaho 83415-2209 l'

Sincerely, ORIGINAL SIGNED BY:

1 George F. Dick, Jr., Project Manager Project Directorate III-2 Division of Reactor Projects - III/IV Office of Nuclear Reactor Regulation Docket Nos. STN 50-456, STN 50-457

Enclosure:

RAI ,

)

cc: See next page ,

DISTRIBUTION: Docket PUBLIC PDIll-2 r/f J. Roe E. Adensam R. Capre G. Dick R. Lanksbury S. Bailey R. Assa C. Moore OGC M. Holderg T. McLetIan ACRS DOCUMENT NAME:G:\CMNTJR\ BRAID \BR97134.RAI Ta receive a copy of this document,3rdcate le the box: 'C" = Copy without enclosures *E* = Copy with enclosures "N" = No copy j l0FFICE PM:PDIII-2 l LA:fRIllI-2 lG_. PD:PDIII-2 l C. l lNAME GDICK Chid 6 RET RCAPRA & l 03/ /97

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lDATE 03/('[/97 03//9/97 OFFICIAL RECORD COPY ,

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4 * , , , * ,o March 19, 1997 Ms. Irene M. Johnson, Acting Manager Nuclear Regulatory Services Commonwealth Edison Company Executive Towers West III 1400 Opus Place, Suite 500 Downers Grove, IL 60515 4

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SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING FIRST 10-YEAR INSERVICE INSPECTION PROGRAM - BRAIDWOOD STATION (TAC NOS. M97134 AND M97135)

Dear Ms. Johnson:

On October 8, 1996, Commonwealth Edison Company (Comed) submitted its first 10-year Inservice Inspection (ISI) Program and associated relief requests for Braidwood Station, Units 1 and 2. Subsequent to the submittal, Comed

, requested expedited review for Relief Request NR-29 and it is being addressed separately.

During our review of the remainder of the October 8, 1996 submittal, we have identified the need for additional information as discussed in the enclosed Request for Additional information (RAI). Please provide your response to the RAI so that we may continue to review your submittal.

In order to expedite the review process, please send a copy of the RAI response to our contractor, Idaho National Engineering Laboratory (INEL), at the following address:

Mr. Michael T. Anderson INEL Research Center 2151 North Boulevard PO Box 1625 Idaho Falls, Idaho 83415-2209 Sincerely, c

Geor F. Dick, Jr., Project Manager Project Directorate III-2 Division of Reactor Projects - III/IV Office of Nuclear Reactor Regulation Docket Nos. STN 50-456, STN 50-457

Enclosure:

RAI cc: See next page

_.--___.m.. _. _ .._ _ _ __ _ . _ .. _ .-.. _ _ . _ _ .... _ . _ . . _ __ _ . _ __ _ __. _ ._ _ _. -

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I.' Johnson Braidwood Station Commonwealth Edison Company Unit Nos. I and 2 cc 1

Michael Miller, Esquire Mr. Ron Stephens I Sidley and Austin Illinois Emergency Services 1 One First National Plaza and Disaster Agency ,

- Chicago, Illinois 60603 110 East Adams Street I Springfield,' Illinois 62706 Regional Administrator .

U.S. NRC, Region III Chairman l 801 Warrenville Road Will County Board of Supervisors l . Lisle, Illinois 60532-4351 Will County Board Courthouse l l .

Joliet, Illinois 60434 l

! Illinois Department of l Nuclear Safety Ms. Lorraine Creek )

Office of Nuclear Facility Safety Rt. 1, Box 182  !

1035 Outer Park Drive Manteno, Illinois 60950 l l Springfield, Illinois 62704 i Attorney General ,

Document Control Desk-Licensing 500 South Second Street l Commonwealth Edison Company Springfield, Illinois 62701 1400 Opus Place, Suite 400 Downers Grove, Illinois 60515 George L. Edgar Morgan, Lewis and Bocnius Mr. William P. Poirier 1800 M Street, N.W.

Westinghouse Electric Corporation Washington, DC 20036 Energy Systems Business Unit Post Office Box 355, Bay 236 West Commonwealth Edison Company Pittsburgh, Pennsylvania 15230 Braidwood Station Manager Rt. 1, Box 84 Joseph Gallo Braceville, Illinois 60407 Gallo & Ross 1250 Eye St., N.W., Suite 302 EIS Review Coordinator Washington, DC 20005 U.S. Environmental Protection Agency 77 W. Jackson Blvd.

Ms. Bridget Little Rorem Chicago, Illinois 60604-3590 Appleseed Coordinator 117 North Linden Street Mr. H. G. Stanley Essex, Illinois 60935 Site Vice President Braidwood Station Howard A. Learner Commonwealth Edison Company Environmental Law and Policy RR #1, Box 84 Center of the Midwest Braceville, IL 60407

, 203 North LaSalle Street

l. Suite 1390 i Chicago, Illinois 60601 i.

! U.S. Nuclear Regulatory Commission

! Braidwood Resident Inspectors Office

} Rural Route #1, Box 79 l Braceville, Illinois 60407 l

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• REQUEST FOR ADDITIONAL INFORMATION 1 l

FIRST 10-YEAR INSERVICE INSPECTION INTERVAL l

l COMMONWEALTH EDIS0N COMPANY BRAIDWOOD STATION. UNITS 1 AND 2 DOCKET NOS. STN 50-456 AND STN 50-457 1.. BACKGROUND Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) requires that components (including supports) that are classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) Class 1, 2 and 3, meet the requirements, except design and access provisions and preservice examination requirements, set forth in ASME Code Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, to the extent practical within the limitations of design, geometry, and materials of construction of the components. This section of the regulations' also requires that inservice examinations of components and system pressure tests conducted during successive 120-month inspection intervals comply with lthe requirements in the latest edition and addenda of l the Code incorporated by reference in Title 10 of the Code of Federal '

Regulations (CFR) at 10 CFR 50.55a(b) on the date 12 months prior to the start ,

of the 120-month interval, subject to the limitations and modifications listed i therein. The components (including supports) may meet requirements set forth 1 in subsequent editions and addenda of the Code that are incorporated by )

reference in 10 CFR 50.5Sa(b) subject to the limitations and modifications j listed therein. Commonwealth Edison Company (Comed, the licensee) has l prepared the Braidwood Nuclear Power Station, Units 1 and 2, First 10-Year Interval Inservice Inspection Program Plan, Revision 4, to meet the .

requirements of the 1983 Edition through the Summer 1983 Addenda of Section XI of the ASME Code.

The staff has reviewed the information submitted by the licensee in a letter dated October 8,1996, containing Revision 4 to the first 10-year inservice inspection (ISI) program. Revision 4 includes editorial corrections, incorporates approved relief requests, and submits seven new requests.

2. STAFF RE0 VESTS I

The staff has concluded that additional information and/or clarification is required to complete the evaluation of Revision 4 to the first 10-year ISI Program Plan. Relief Request NR-29 is being evaluated separately. Therefore, the licensee does not need to address Relief Request NR-29 in response to this RAI.

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l 3. SPECIFIC INFORMATION RE0VIRED 3.1 The staff has determined that licensees must state the specific paragraph l of the regiations under which each proposed alternative or request for

! relief is submitted. The licensee should review the current submittal and ENCLOSURE

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provide the required references to ensure that each proposed. alternative or request for relief is evaluated in accordance with the appropriate criteria, as discussed below.

A licensee may propose an alternative to CFR or Code requirements in )

accordance with 10 CFR 50.55a(a)(3)(i) or 10 CFR 50.55a(a)(3)(ii). When i submitting a proposed alternative, the licensee must specify the appropriate regulatory basis. Under 10 CFR 50.55a(a)(3)(i), the proposed )

alternative must be shown to provide an acceptable level of quality and i

safety, i.e., essentially be equivalent to the original requirement in I l

terms of quality and safety. Under 10 CFR 50.55a(a)(3)(ii), the licensee '

! must show that compliance with the original requirement results in a hardship or unusual difficulty without a compensating increase in the level of quality and safety. Examples of hardship and/or unusual difficulty include, but are not limited to, excessive radiation exposure, disassembly of components solely to provide access for examinations, and development of sophisticated tooling that would result in only minimal increases in examination coverage, i i

i l In accordance with 10 CFR 50.55a(g)(5)(iii), a licensee may submit a l l request for relief from ASME Code requirements. If a licensee determines i that conformance with certain ASME Code requirements is impractical for

its facility, the licensee shall notify the Commission and submit, as l specified in 950.4, information to support that determination. When a licensee determines that an inservice inspection requirement is impractical, e.g., the system would have to be redesigned or a component l would have to be replaced to enable inspection, the licensee should cite l this part of CFR to support the criteria for evaluation. The NRC may, giving due consideration to the burden placed on the licensee, impose an alternative examination requirement.

3.2 Based on the review of Relief Requests NR-27, NR-28, and NR-31, that are associated with the reactor pressure vessel examinations, it appears that the Code volumetric coverages are based on those obtained on similar examination areas at the Byron Station. Requests for relief should be .

based on actual examination coverages on a plant specific basis. The Code requires that all examinations be performed to the extent practical. This may require a combination of manual and automated examinations.

It should be noted that because the licensee has not submitted plant specific information, these requests are considered unacceptable for review. As such, the licensee may want to consider the withdrawal of the current submittals and resubmit following the actual examinations.

Describe the action the licensee proposes to take regarding this j -observation.

[ 3.3 Provide the staff with the status of the augmented reactor pressure vessel i examinations required by 10 CFR 50.55a(g)(6)(ii)(A), effective i September 8, 1992 (Note: plants with greater than 40 months remaining in

} the interval on the effective date of the rule were required to perform i

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the augmented examination in that interval) and provide a technical discussion describing how the regulation was/will be implemented at Braidwood Station, Uni.ts 1 and 2. Include ~in the discussion a description of the approach and any specialized techniques or equipment that was/will be used to complete the required augmented examination. It should be l noted that requests for relief associated with the reactor pressure vessel examinations required by Section XI, Examination Category b ' Item Bl.10, l cannot be evaluated until the augmented reactor pressure t ~> ret requirements listed in 10 CFR 50.55a(g)(6)(ii)(A), are satisfied.

3.4 For Request for Relief NR-30, the licensee has proposed to satisfy the Code pressure test for Class 2 piping at containment penetrations in conjunction with Appendix J 1eakage tests. When implementing the alternatives to Code requirements contained in Code Case N-522, Pressure l Testing of Containment Penetration Piping, the NRC staff finds this

, alternative to Code requirements acceptable only if the licensee commits l to performing the pressure test at peak design pressure and implements a l procedure for the detection and location of through-wall flaws. Describe the action the licensee proposes to take regarding these conditions for acceptance.

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