ML20197B753

SER Accepting License Request for Relief from Immediate Implementation of Amended Requirements of 10CFR50.55a for Plant,Units 1 & 2

ML20197B753
Person / Time
Site:	Braidwood
Issue date:	03/04/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20197B752	List: ML20197B746 ML20197B753
References
NUDOCS 9803110404
Download: ML20197B753 (3)

Text

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EVALUATION OF RELIEF REQUEST FROM THE IMPLEMENTATION OF 10 CFR 50.55a REQUIREMENTS RELATED TO THE REPAIR AND REPLACEMENT ACTMTIES FOR CONTAINMENT COMMONWEALTH EDISON COMPANY BRAIDWOOD STATION. UNITS 1 AND 2 DOCKET NOS. STN 50 566 AND STN 50-457 1,0 INTRODUCTION By Federal Megister notice dated August 8,1996, the Nuclear Regulatory Commission amended its reguistions (rule) to incorporate by reference the 1992 Edition with the 1992 Addenda of Subsections IWE and IWL of Section XI of the American Society of Mechanical Engineers (ASME) Boiler avl Pressure Vessel Code (Code). Subsections IWE and lWL provide the requirements for inservice inspection _ (ISI) of Class concrete containments (CC), and Class metallic containments (MC) of the light water cooled power plants. The effective date for the amended rule was September 9,1996, and it requires the licensees to incorporate the new-requirements into their 181 plans and to complete the first containment inspection within five years, that is, by September 9,2001. Since the amended rule became effective on September 9, 1996, any repair or replacement activity to be performed for the containments after that date is '

required to be in accordance with the respective requirements of Subsections IWE and IWL.

However, a licensee can submit a request for relief for the date of implementation of its containmeist repair and replacement (R/R) activities with proper justification. The provision for granting relief is incorporated in the regulation.

This evaluation addresses the merits of the relief request proposed by the licensee,

. Commonwealth Edison Company (Comed), for Braidwood Station Units 1 and 2.

2.0 EVALUATION Comed requested the relief on the basis that immediate compliance with the requirements of the rule for R/R activities would result in unusual difficulty without a compensating increase in the level of safety and quality, in Reference 1, the licensee provided a number of reasons, such as reclassification of components to Class CC and MC classification criteria, revisions to existing procedures for R/R activities to incorporate the requirements of Subsections IWE and IWL, and incorporation of appropriate examiner training and qualification requirements in the Comed procedures to demonstrate the impracticality of meeting the requirements of the rule for R/R activities.

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2-However, Reference 1 did not provide any assurance regarding the adequacy of the present containment R/R program. In responss to the staffs request for additionalinformation, Comed clarified and provided a summary description of the allemative that is used for the containment R/R activities and revised the relief request dates from December 31,1997, to September 9, 1997 (Reference 2). Comed stated that antil September 9,1997, all R/R conducted on Class CC and Class MC components and their integral supports will be performed in accordance with the existing Braidwood Administrative Procedure,' Action / Work Request Processing Procedure" for nuclear safety related components. These activities will be govemed by the Comed Quality Assurance (QA) Manual. The Comed QA program complies with the QA requirements of 10 CFR Part 50, Appendix B, ASME Section li' NCA-4000, and ANSI /ASME NQA 1. Also, the inspection and R/R activities related to the containment post tensioning tendons for both units are govemed by the Breldwood Station Technical Specifications.

The staff considers the attemative program for R/R activities reasonable and acceptable during the period of relief. Also, the staff concludes that immediate compliance with the requirements of the amended rule during the pe.iod September 9,1996, through September 8,1997, would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. The licensee willimplement the requirements of tho amended rule for the containment R/R activities starting September 9,1997.

3.0 CONCLUSION

Based on the review of the information provided in relief request NR 32 and the response to the staffs request for additionalinformation, the staff finds the temporary use of the current procedure for containment repair and replacement activities instead of the requirements of the amended 10 CFR 50.55a rule to be reasonable and acceptable. Also, the staff concludes that immediate compliance with the requirements of the amended rule for containment repair and replacement activities during the period September 9,1996, through September 8,1997, would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the request for relief dated April 10,1997, as supplemented on September 11,1997, to delay implementation of the rule for repair and replacement activities until September 8,1997, is acceptable for authorization pursuant to 10 CFR 50.55a(a)(3)(ii).

Piinciple Contributor: H. Ashar Dste: March 4, 1998

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4.0 REFERENCES

1. Letter from John Hosmer (Comed) to NRC, " Relief Requests from ASM2 Section XI, 1992 Edition with the 1992 Addenda, Article IWE-4000," dated April 10,1997,

2. Letter from John Host.)er (Comed) to NRC," Response to Request for Additional Information," dated September 11,1997,

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