ML20137X554
| ML20137X554 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 04/10/1997 |
| From: | Wozniak D COMMONWEALTH EDISON CO. |
| To: | NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BYRON-97-0087, BYRON-97-87, NUDOCS 9704220077 | |
| Download: ML20137X554 (4) | |
Text
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g Commonwealth Ediwn Company Ilyron Gener.ating Station 4 650 Nonh German Church Hoad flyron. IL 610ln979i Tcl H15-2M5441 April 10,1997 LTR:
BYRON-97-0087 FILE: 2.01.0700 Office of Nuclear Reactor Regulation 1
U.S. Nuclear Regulatory Commission Washington, DC 20555-001 ATTENTION: Document Control Desk
SUBJECT:
Response to Request for Additional Information concerning S:cond Interval Relief Request 12R 13 Byron Nuclear Power Station Unit (s) I and 2 Facility Operating License (s) NPF-37 and/or NPF-66 NRC Docket No(s). 50-454 and/or 50-455 i
REFERENCES:
1.
February 23, 1996 letter from fa. Lesniak (Comed) to NRC submitting the Byron Station Second 10-Year Inservice I ispection Program.
2.
January 30,1997 letter from G. Dick (NRC) to I. Johnson (Comed) requesting additional information regarding the Byron Station Second 10-year Inservice Inspection Program.
In Reference 1, Commonwealth Edison Company (Comed) submitted the Second 10-year Inservice Inspection (ISI) Program for Byron Station. The submittal included relief requests associated with the program. In Reference 2, NRC requested additional information regarding Relief Request 12R-13, which was submitted in Reference 1. The response to the two questions are included as Attachment 1.
In response to the first question, Relief Request 12R-13 has been revised and is also attached.
If there are any additional questions, please contac' Marcia Lesniak, Nuclear Licensing Administrator, at (630) 663-6484.
Sincerely,
?
David B. Wozniak Site Engineering Manager Byron Nuclear Power Station i
DBW/LZ/ld
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Attachments cc:
A. B. Beach, NRC Regional Administrator - F U001dd S.'D. Burgess, Senior Resident inspector - Bpon
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Office of Nuclear Safety -IDNS
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Relief Request 12R-13 RAI questions and responses 1)
The requirements of OSfa-1988, Part 4, Section 2, per IWF-5200 pertain to preservice (pre-operational) examination ofsnubbers. In ReliefRequest 12R-13, the licensee
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states that similar requirements are includedin the technicalspecifications (TS). Please identify the TS locationfor these requirements and describe their similarity with Part 4, Section 2 requirements or modyy the relief request accordingly.
RESPONSE
The intent of this relief request is to request relief from the ASME Section XI requirements for inservice visual examination of snubbers. The references to preservice examination per IWF-5200(a) and (c) have been deleted from the relief request text in Relief Request 12R-13 Revision 1.
2)
IWF-5400 requirements defer to OAfa-1988, Part 4, and IWF-4000for repair and IWF-7000for the replacement ofsnubbers. The Byron relief request states that the repair 1
and replacement requirements ofIWF-4000 and 7000 will be met and snubber repair and replacement will be performedper the TSs in lieu of OSfa-1988, Part 4, requirements. Please identify the TS location (s) that defines these requirements and describe how they replace the OSfu-1988, Part 4, requirements.
RESPONSE
The intent of this relief request is to request relief from the ASME Section XI requirements for inservice visual examination of snubbers. Byron Station performs repair and replacement activities per IWF-5400 requirements which defer to OMa-1988, Part 4, and IWF-4000 for repair $md IWF-7000 for the replacement of snubbers.
Revision I to Relief Request 12R-13, revises the last paragraph of the " Basis for Relief" to remove the oversight requesting relief from ASME Section XI repair and replacement.
This paragraph was intended and subsequently revised, to indicate the request for relief for visual examination requirements of ASME Section XI.
Additionally Revision I to 12R-13, revises the " Proposed Alternate Provisions" section to remove the oversight requesting relief from ASME Section XI repair and replacement.
I Revision I to 12R-13, also revises the " Proposed Alternate Provisions" section to remove j
the reference to visual examination (VT-3) of component support steel connected to snubber structural attachments. This is a good pr'actice to verify the integrity of the entire support component assembly, however, it is not intended as a proposed alternative to visual examinations in this relief request.
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t BYRON STATION UNITS 1&2 SECOND INTERVAL I5I PROGRAM PLAN-NRC SUBMrITAL RELIEF REQUEST 12R-13 Revision 1 (Page 1 of 2)
COMPONENT IDENTIFICATION Code Classes:
1,2 and 3
References:
IWF-5000 Examination Categories:
Not Applicable Item Numbers:
Not Applicable
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Description:==
Alternate Rules to IWF-5000 Inservice Inspection Requirements CODE REOUIREMENTS Inservice Inspection of snubbers shall be performed as follows:
Inservice examination per IWF-5300(a) in accordance with the first addenda to ASME/ ANSI OM-1987 Edition, Part 4, published in 1988 (OMa-1988 Part 4).
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BASIS FOR RELIFF i
Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested on the basis that the proposed alternatives provide an acceptable level of quality and safety, Byron Station Technical Specifications (TS) include comprehensive programs for visual examination l
and functional testing of all safety related hydraulic and mechanical snubbers. The program scope encompasses all Code Class 1,2, and 3 snubbers. Byron Station TS 4.0.5 also includes requirements i
for visual examination of Code Class 1,2, and 3 saubbers per ASME Section XI and ASME/ ANSI OMa-1988, Part 4. Because 10 CFR 50.55a does not currently address snubber functional testing, the
- snubber functional testing requirements of Section XI, IWF-5000 are not imposed on Byron Station per TS 4.0.5.
Because all safety related snubbers at Byron Station are also Code Class, the overlap of the visual examination programs per Technical Specifications and ASME Section XI for the Code Class snubbers presents'an unnecessary redundancy. Since the visual examination in both programs is rigorous, the imposition of only one program is necessary to assure an acceptable level of quality and. safety.
The TS snubber visual examination program and the program presented in OMa-1988, Part 4 per IWF-l 5300(a) are similar in content. Both programs include parallel criteria for visual examination, examination frequency, examination sample size, examination failure evaluation, examination corrective action and examination documentation.
It is Byron Station's position that the snubber visual examinations required per Technical Specifications meets the intent of the program required by OMa-1988, Part 4. No plant safety benefits will be l
realized by imposing both programs on the Code Class snubbers at Byron Station.
Based on the preceding information, Byron Station requet.ts relief from the ASME Section XI requirements for visual examination of Code Class snubbers.
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BYRON STATION UNITS 1&2 SECOND INTERVAL ISI PROGRAM PLAN NRC SUBMITTAL RELIEF REQUEST 12R-13 Revision 1 (Page 2 of 2)
PROPOSED ALTERNATE PROVISIONS Byron Station will perform visuil examinations of Code Class snubbers in accordance with TS 4.7.8 in lieu of the requirements of ASME/ ANSI OMa-1988, Part 4. The visual examination l
performed per the Technical Specifications will include the snubber structural attachment to the foundation or supporting structure up to and including the fasteners for connecting the snubbers to the pipe attachment or component attachment. Personnel performing the snubber visual examinations will be qualified to perform Visual, VT-3 examinations per IWA-2300.
I As required by IWF-5300(c), the examination of snubber intregal and nonintregal attachments will be performed in accordance with Subsection IWF.
If any part of the boundary included in the Technical Specification visual inspection cannot be verified to be functional due to insulation interference, the insulation will be removed to satisfy the Technical Specification requirements.
PERIOD FOR WHICil RELIEF IS REQUESTED Relief is requested for the second inspection interval.
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