ML20137Q958

Forwards RAI Re First 10-yr ISI Program & Associated Relief Requests for Plant,Units 1 & 2

ML20137Q958
Person / Time
Site:	Braidwood
Issue date:	03/17/1997
From:	Dick G NRC (Affiliation Not Assigned)
To:	Johnson I COMMONWEALTH EDISON CO.
References
TAC-M97134, TAC-M97135, NUDOCS 9704110185
Download: ML20137Q958 (6)

Text

fDE-March 1 17, l'997

LMs. Irene M.- Johnson,! Acting Manager Nuclear Regulatory Services

, Commonwealth Edison Company.

Executive Towers West III 1400 Opus P1 ace, Suite 500 Downers Grove,:IL 60515

SUBJECT:

REQUEST FOR ADDITIONAL;INFORMATION REGARDING THE FIRST 10-YEAR-INSERVICE' INSPECTION PROGRAM .BRAIDWOOD STATION (TAC.NOS. M97134

~AND M97135)

Dear Ms. Johnson:

On October 8, 1996, Commonwealth Edis Company (Comed) submitted its first 10-year, Inservice Inspection (ISI)-pr ai$gingstociatedreliefrequestsfor

Braidwood Station, Units l' and 2.- Subsequent t'a tM*3(>bmittal, Comed i st NR-29.

requested expedited review for ReliggWHENT Rn -

i' A Request for Additional Information (RAI) _was issued on February.11,1997.

Comed provided.its response on February 25, 1997, and a followup conference L call was held on March 11, 1997. A review of Comed's February 25, 1997,

.  : submittal has revealed the need for further information regarding Relief Request NR-29 as discussed in the enclosed RAI. Please provide your response l' to the questions so.that we may continue our review of your submittal.

In addition, in order to expedite the review process, please send a copy of i 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 -

i- PO Box 1625

. Idaho Falls, Idaho 83415-2209 i Sincerely, ORIGINAL SIGNED BY

NRC HLE CEN1B CMProject ceo,,e ,. Oica, o ,., g,oject Directorate III-2

,,,,,e, i

Division of Reactor Projects - III/IV D[th r Office of Nuclear Reactor Regulation Docket Nos. STN 50-456, STN 50-457f.

. DISTRIBUTION:  ; Docket Filet g

PUBLIC 2 PDIII-2 r/f

Enclosure:

. RAI J. Roe, JWR R. Capra

+

E. Adensam, EGA1 C. Moore R. Lanksbury, RIII G. Dick cc w/ encl: -see next page; T. McLellan, 07H15 OGC,- 015B18 f-9704110185 97031 J. Strosnider G. Bagchi y? PDR ADOCK 05000456 M.; Holmberg, RIII ACRS, T2E26 P PDR & D. Naujock, 07D4 Ta receive a copy of this document, indicate in the box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy 0FFICE- PM:PDII?2n E LA:lGIII-2-l O ECGB -

EMCB / D:PDIII-2 l C

. NAME '

GDICK h M Ch004 GBAGCHI * -

JSTROSfD8ER RCAPRA Ra .-

DATE 03/H/97 03/%/97- 03/13/97' 0 7 /97 03/n /97 j' 300UMENT l4AME: : BR97134.LTR. ;0FFICIAL RECORD COPY E*fConcurrence b'y memorandum. dated 3/13/97

. . . - . . . - .a. J' . - . . . - -.

March 17, 1997-j g;s, 'Ms'. Irene M.' Johnson, Acting Manager-Nuclear Regulatory Services 4;,

,, Commonwealth Edison Company

• • Executive Towers West III

-1400 Opus Place,< Suite 500 Downers Grove, IL: 60515-

SUBJECT:

REQUEST FOR ADDI110NAL INFORMATION REGARDING THE FIRST 10-YEAR INSERVICE INSPECTION PROGRAM - BRAIDWOOD STATION (TAC NOS. M97134 ANDM97135) i

Dear Ms. Jo'hnson:

On 0ctober 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.

= A Request for Additional Information (RAI) was issued on February 11, 1997.

Comed provided its response on February 25, 1997, and a followup conference call was held on March 11, 1997. A review of Comed's February 25, 1997, I submittal has revealed the need for further information regarding Relief )

Request NR-29 as discussed in the enclosed RAI. Please provide your response ,

-to the questions so that we may continue our review of your submittal. i In addition, in; order to expedite the review process, please send a copy of  :

the RAI response _ to our contractor, Idaho National Engineering Laboratory l

-(INEL), at the following address: 1 Mr. Michael T. Anderson INEL Research Center 2151 North Boulevard PO Box 1625 .

Idaho Falls, Idaho 83415-2209 Sincerely, ORIGINAL SIGNED BY:

! George F. Dick, Jr., Project Manager ,

L Project Directorate III-2 Division of Reactor Projects - III/IV

Office of Nuclear Reactor Regulation

! Docket Nos. STN 50-456, STN 50-457 DISTRIBUTION: Docket File

! PUBLIC PDIII-2 r/f

Enclosure:

RAI J. Roe, JWR R. Capra E. Adensam, EGA1 C. Moore R. Lanksbury, RIII G. Dick

-cc w/ enc 1: see next page T. McLellan, 07H15 OGC, 015B18

!' J. Strosnider G. Bagchi M. Holmberg, RIII ACRS, T2E26 D. Naujock, 07D4 Ta teosive a espy of this document, inecate in the boa: 'C' = Copy without enclosures *E' = Copy with enclosures *N* = No copy L OFFICE PM:PDII7 h E LA:1311-2 -C- ECGB EMCB- / D:PDIII-2 C,

, NAME GDICK h &A Clip 0M GBAGCHI* JSTROSHI8 Ell RCAPRA Ra,.- .

DATE 03//3/97: 03/E /97 - 03/13/97 V /97 03/n /97 JOCUMENT-(AME: :BR97134.LTR OFFICIAL RECORD COPY

• Concurrence by memorandum dated 3/13/97-i

. / ?'%.,

o p*  % UNITED STATES 3

I s# j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30665 0001

• • • • • [ March 17, M.97 - ,

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 THE 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 l 10-year Inservice Inspection (ISI) program and associated relief requests for l Braidwood Station, Units I and 2. Subsequent to the submittal, Comed  !

requested expedited review for Relief Request NR-29.

A Request for Additional Information (RAI) was issued on February 11, 1997.

Comed provioed its response on February 25, 1997, and a followup conference call was held on March 11, 1997. A review of Comed's February 25, 1997, submittal has revealed the need for further information regarding Relief Request NR-29 as discussed in the enclosed RAI. Please provide your response to the questions so that we may continue our review of your submittal.

In addition, in order to expedite the review process, please send a copy of the RAI response to our contr' actor, Idaho National Engineering Laboratory (INEL), at the following addiess:

Mr. Michael T. Anderson INEL Research Center 2151 North Boulevard PO Box 1625 Idaho Falls, Idaho 83415-2209 Sincerely, Geo . 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 w/ enc 1: see next page

g ...

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

Michael Miller, Esquire Mr. Ron Stephens Sidley and Austin Illinois Emergency Services j One First National Plaza and Disaster Agency Chicago, Illinois 60603 110 East Adams Street Regional Administrator t U.S. NRC, Region III Chairman 801 Warrenville Road Will County Board of Supervisors Lisle, Illinois 60532-4351 Will County Board Courthouse Joliet, Illinois 60434 Illinois Department of Nuclear Safety Ms. Lorraine Creek

Office of Nuclear Facility Safety Rt. 1, Box 182

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

. Document Control Desk-Licensing 500 South Second Street i Commonwealth Edison Company Springfield, Illinois 62701 1

1400 Opus Place, Suite 400 Downers Grove, Illinois 60515 George L. Edgar

. Morgan, Lewis and Bochius ,

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 l Joseph Gallo Braceville, Illinois 60407 l 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 Suite 1390 Chicago, Illinois 60601 U.S. Nuclear Regulatory Commission Braidwood Resident Inspectors Office Rural Route #1, Box 79 Braceville, Illinois 60407

4

]

i l

REQUEST FOR ADDITIONAL INFORMATION  ;

FIRST 10-YEAR INSERVICE INSPECTION INTERVAL COMONWEALTH EDISON COMPANY BRAIDWOOD STATION. UNITS 1 AND 2 r

DQf8T NOS. STN 50-456. STN 50-457

1.0 BACKGROUND

The Nuclear Regulatory Commission (NRC) is responsible for the review and disposition of licensees' requests relating to inservice inspection (ISI) requirements contained in the Code of Federal Regulations (CFR) at 10 CFR +

50.55a, and Section XI of the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Ves:;e1 Code (Code). When submitting such requests, licensees are required to provide both a regulatory basis (by citing the l appropriate section of 10 CFR 50.55a) and a technical discussion suoporting the request. This information is used in evaluating the request.  ;

The staff has reviewed the information submitted by the licensee in a' letter ,

dated October 8, 1996, containing Relief Reque t NR-29. By letter dated  :

February 25, 1997, the licensee submitted addiinnal information in response to an NRC request of February 11, 1997. On Mar d 11, 1997, a conference call was held between the NRC, the licensee's ISI vendor (Framatome), Electric Power and Research Institute (EPRI), a Performance Demonstration Initiative  ;

(PDI) representative, the Idaho National Engineering and Environmental .

)

Laboratory (INEEL), and the licensee. Based on this conversation and the

- licensee response of February 25, 1997, it has been determined that further clarification is required to complete this evaluation.

2.0 ADDITIONAL INFORMATION RE0VIRED l

Th9 staff has concluded that additional information and/or clarification is j required to complete the evaluation of Relief Request NR-29.

t 2.1 It is the NRC staff's understanding that the PDI test specimens used for

vessel performance demonstration qualifications are designed for i examination from two sides.

Use of existing PDI test specimens for qualification of procedures and

personnel when performing one direction scans perpendicular and parallel to the weld may not provide adequate assurance of flaw detection. The l staff believes that certain adverse conditions that would challenge an

. examiner's skills when examinatiot.s are performed from one side only may L not be represented by the

PDI test specimens. For instance, certain actual field conditions such as off-normal flaw orientations at the weld 1

root, incomplete fusion, flaw geometries that may mask other flaws, and  ;

ENCLOSURE J

r - - - - - -

e-. . , u a - . .

9- .

, rough cladded surfaces that caus oeam redirection may result in flaws going undetected when scanning from one side only.

Provice a discussion that addresses the staff's concerns. Include a basis for concluding that one-sided examinations provide equivalent flaw detection as the Code-required two-sided examinations.

2.2 Verify that all Code requirements, except for those specifically described in the licensee's February 25, 1997, response, will be met.

2.3 Verify that the subject examinations will be performed by implementing the same essential variables as those used for the PDI qualification.

2.4 Is it the intent of the subject reactor pressure vessel examinations to satisfy the current interval Section XI requirements as well as the augmented reactor pressure vessel examinations required by 10 CFR 50.55a(g)(6)(ii)(A)?

1 a