ML20141F375

Forwards RAI to Complete Review of Licensee Submittal Re First 10-yr ISI Interval Program Relief Request NR-20, Related to Ultrasonic Exam of Rv Welds for Plant,Units 1 & 2

ML20141F375
Person / Time
Site:	Byron
Issue date:	06/30/1997
From:	Dick G NRC (Affiliation Not Assigned)
To:	Johnson I COMMONWEALTH EDISON CO.
References
TAC-M96425, TAC-M96426, NUDOCS 9707020318
Download: ML20141F375 (5)

Text

_ _ _ . _ _ _ . _. _ . _ _ . _ - _ . . _ _ . _ ___ .

June 30, 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 l INSPECTION PROGRAM RELIEF REQUEST NR BYRON STATION, UNITS 1 1 AND 2 (TAC NOS. M96425 AND M96426) l l

Dear Ms. Johnson:

i On July 15, 1996, Commonwealth Edison Company (Comed) submitted Byron Station First 10-Year Interval Inspection Program Relief Request NR-20, related to the ultrasonic examination of reactor vessel welds for Byron Station, Units 1 and

. 2. During the course of our review, we have identified the need for further information as discussed in the enclosed request for additional information (RAI). Please indicate when we may expect a response to the RAI so that we may schedule the completion of our review of your submittal.

In order to expedite the review process, 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 P.O. Box 1625 Idaho Falls, Idaho 83415-2209 Sincerely,

/s/

George F. Dick, Jr., Senior Project Manager Projeci, Dl rectorate III-2 Division of Reactor Projects - III/IV Office of Nuclear Reactor Regulation k Docket Nos. STN 50-454, STN 50-455 V'

Enclosure:

RAI cc w\ enc 1: See next page kh b {

Distribution:

Docket File PUBLIC PDIII-2 R/F E. Adensam, EGA1 J. Roe, JWR R. Capra S. Bailey G. Dick C. Moore OGC, 05G18 R. Assa R. Lanksbury, RIII ACRS, T2E26 T. McLellan DOCUMENT NAME: BYRON \BY96425.RAI Ta receive a copy of this doctamt, Ipdicate in the boa: "C" = Copy without enclosures "E" = Copy with enclosures "II" = No copy 0FFICE PM:PDIII-(2 fl E LA,:llDJ II-2 l V./ D:PDIII-2 l& l l NAME G. Dick 1/4 k '

C/MMre R. Capra R

• DATE 06/.27/97 06 $ /97 06/30/97 0FFICIAL RECORD COPY 9707020318 970630 PDR ADOCK 05000454 G PDR

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

Michael I. Miller, Esquire Chairman, Ogle County Board l Sidley and Austin Post Office Box 357 One First National Plaza Oregon, Illinois 61061 Chicago, Illinois 60603 Mrs. Phillip B. Johnson l Regional Administrator, Region III 1907 Stratford Lane U.S. Nuclear Regulatory Commission Rockford, Illinois 61107 801 Warrenville Road Lisle, Illinois 60532-4351 Attorney General 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 Document Control Desk-Licensing Commonwealth Edison Company Commonwealth Edison Company 1400 Opus Place, Suite 400 Byron Station Manager 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 Howard A. Learner Environmental law and Policy Center of the Midwest 203 North LaSalle Street Suite 1390 Chicago, Illinois 60601 U.S. Nuclear Regulatory Commission Byron Resident Inspectors Office 4448 North German Church Road Byron, Illinois 61010-9750 Ms. Lorraine Creek Rt. 1, Box 182 Manteno, Illinois 60950

d

, RE0 VEST FOR ADDITIONAL INFORMATION FIRST 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF RE00EST NR-20 COMMONWEALTH EDISON COMPANY BYRON STATION. UNITS 1 AND 2 DOCKET NOS. STN 50-454. STN 50-455 SCOPE / STATUS OF REVIEW 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, Class 2, and Class 3 meet the requirements,'except design and access provisions and preservice examination requirements, set forth in the ASME Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, to the extent practical within the limitations of design, geometry, ana materials of construction of the components. This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during a 120-month inspection interval comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 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 therein. The components (including supports) may meet requirements set forth in subsequent editions and addenda of the Code that are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein and subject to Nuclear Regulatory Commission (NRC) approval.

The staff has reviewed the available information provided by the licensee in the July 15, 1996, submittal. The applicable edition of the Code for the Byron Nuclear Station, Units 1 and 2, first 10-year ISI interval is the 1983 Edition, through Summer 1983 Addenda of ASME,Section XI.

BACKGROUND In accordance with 10 CFR 50.55a(g)(6)(ii)(A), all licensees must implement once, as part of the inservice inspection interval in effect on September 8, 1992, an augmented volumetric examination of the reactor pressure vessel (RPV) welds specified in Item Bl.10 of Examination Category B-A of the 1989 Edition  ;

of the ASME Code,Section XI. Examination Category 8-A, Items B1.11 and Bl.12 require volumetric examination of essentially 100 percent of the RPV  ;

circumferential and longitudinal shell welds, as defined by Figures IWB-2500-1 and -2, respectively. Essentially 100 percent, as defined by 10 CFR 50.55a(g)(6)(ii)(A)(2), is greater than 90 percert of the examination volume of each weld.

ENCLOSURE

i lM'* . l The Code of Federal Regulations (CFR) provides that a licensee may propose an i alternative to CFR or Code requirements in accordance with 10 CFR

_50.55a(a)(3)(1) or 10 CFR 50.55a(a)(3)(ii). -Under 10 CFR 50.55a(a)(3)(1), the

' proposed alternative must be shown to provide an acceptable level of quality and safety, i.e., essentially be equivalent to the original requirement in

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 1-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 j l provide access for examination, and development of sophisticated tooling that '

{ would result in only minimal increases in examination coverage.

i A licensee may also submit a request for relief from ASME requireraents. Ic accordance with 10 CFR 50.55a(g)(5)(iii), if a licensee determines that conformance eith certain Code requirements is impractical for its facility, the licensee s5all notify the Commission and submit, as specified in 150.4, information to rupport that determination. When a licensee determines that an  :

inservice inspec'. ion requirement is impractical, e.g., component design or 1 configuration lin,its the examination and the system would have to be i redesigned or a cc.mponent replaced to enable the inspection, the licensee should cite 10 CFR 50.55a(g)(5)(iii). The NRC may, giving due consideration to the burden placted on the licensee, impose an alternative examination requirement. I ADDITIONAL INFORQ TION RE00ESTED Per the licensees's letter dated July 15, 1996, Request for Relief No. NR-20  !

was submitted in accordance with 10 CFR 50.55a(a)(3)(ii) for welds that were examined to the " extent practical" due to component configuration. However, this relief should have been submitted as three separate requests:

1) For the Category B-A, Item Bl.11 - Reactor Vessel Circumferential Shell i Welds, it appears that the licensee should have identified this request '

as an alternative pursuant to the augmented reactor vessel examination requirements of 10 CFR 50.55a(g){6)(ii)(A); '

It appears that the licensee did not meet the augmented reactor vessel volumetric examination requirements of 10 CFR 50.55a(g)(6)(ii)(A) of essentially 100 percent of the ASME Code Item B1.11 - Reactor Vesse?

Circumferential Shell Weld; therefore, the licensee must propose an .

alternative. Consequently, the licensee should: 1) state the correct 10 CFR 50.55a paragraph in which an alternative is requested; 2) propose an alternative exam; 3) justification for using an alternative i' examination (e.g., exams from the 00, if any, stresses on the vessel, equipment used, etc.); 4) identification list of welds and coverage for all the Category B-A, Item Bl.10 welds (e.g., circumferential and longitudinal welds); and 5) history of the reactor vessel weld inspections and results.

1

iI '

i 1

! I 4

' 2) For the Category B-A, Item Bl.21.- Reactor vessel Lower Head I Circumferential Welds, it appears that the licensee should have j identified this request as an ASME Code,Section XI, relief request

or alternative from/to the Code requirements  ;

b' It appears that the licensee is requesting an alternative pursuant to 10 CFR 50.55a(a)(3)(ii) for the Category B-A, Item Bl.21 - Reactor Vessel Lower Head Circunferential Welds and the Category B-A, Item B1.30 - Reactor Vessel Shell-to-Flange Welds however, this 1s not evident; therefore, information is required for the subject welds regarding the 10 CFR 50.55a requirement since the licensee is requesting' relief or alternative from/to the Code requirement.

1 The licensee is. requested to: 1) provide the correct 10 CFR 50.55a paragraph in which the relief / alternative is requested; 2) provide its bases why the Code requirement is impractical (10 CFR 50.55a(g)(6)(i))

or compliance would result in hardship without compensating increase in safety (10 CFR 50.55a(a)(3)(ii)); and 3) provide why its proposed alternative provides reasonable assurance of operational readiness, and in the case of 10 CFR 50.55a(g)(6)(i) discuss the burden on the licensee if the Code requirements were imposed.

3) For the Category B-A, Item Bl.30 - Reactor Vessel Shell-to-Flange Welds; it appears that the licensee should have identified this request as an ASME Code,Section XI, relief request or alternative from/to the Code requirements.

It appears that the licensee is requesting an' alternative pursuant to 10 CFR 50.55a(a)(3)(ii) for the Category B-A, Item Bl.21 - Reactor Vessel Lower Head Circumferential Welds and the Category B-A, Item B1.30 - Reactor Vessel Shell-to-Flange Welds; however, this 1s not evident; therefore, information is required for the subject welds regarding the 10 CFR 50.55a requirement since the licensee is requesting relief or alternative from/to the Code requirement.

The licensee is requested to: 1) provide the correct 10 CFR 50.55a paragraph in which the relief / alternative is requested; 2) provide its bases why the Code requirement is impractical (10 CFR 50.55a(g)(6)(i))

or compliance would result in hardship without compensating increase in safety (10 CFR 50.55a(a)(3)(ii)); and 3) provide why its proposed alternative provides reasonable assurance of operational readiness, and in the case of 10 CFR 50.55a(g)(6)(1) discuss the burden on the licensee if the Code requirements were imp'ased, t

,