ML20202F069

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Forwards SE of Third 10 Yr Internal Insp Program Plan Requests for Relief CR-13,rev 1 & CR-23.Util Proposed Alternative Contained in Request for Relief CR-13,rev 1,re Removing Only Insulation Classified as Removable,Denied
ML20202F069
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 12/02/1997
From: Capra R
NRC (Affiliation Not Assigned)
To: Johnson I
COMMONWEALTH EDISON CO.
Shared Package
ML20202F074 List:
References
TAC-M94924, TAC-M94925, NUDOCS 9712090002
Download: ML20202F069 (3)


Text

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December 2, 1997

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Ms. trene Johnson, Acting Manager 5*

Nuclear Regulatory Services Commonwealth Edison Company Executive Towers West lit 1400 Opus Place, Suite 500 Downers Grove,IL 60515 3

SUBJECT:

EVALUATION OF THE THIRD 10 YEAR INTERVAL INSPECTION PROGRAM PLAN REQUEST 8 FOR RELIEF NOS. CR 13, REVIPION 1, AND CR 23 ZION NUCLEAR POWER STATION, UNIT 81 AND 2 (TAC NOS M94924 AND M94925)

Dear Ms. Johnson:

The staff, with technical assistenw from its contractor, the Idaho National Engineering and Environmental Laboratory (INEEL) has reviewed and evaluated the information provided by Commonwealth Edison Company (Comed), in Hs letter dated March 1,1996, regarding Request for Relief Nos. CR 13, Revision 1, and CR 23 from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code),Section XI, requirements for the

/

Zion Nuclear Power Station, Units 1 and 2. Comed provided additional information in its "A97010, Requests Authorization for Alternative to One Time Augmented Insp of RPV Shell Welds Set Forth in 10CFR50.55a(g)(6)(ii) (A)(2) Per [[CFR" contains a listed "[" character as part of the property label and has therefore been classified as invalid.(5).Authorization to Use Partial Insp Coverage Requested|letter dated August 13,1997]]. The staff found Comets request for talief, CR 13, Revision 1, I

unacceptable and its evaluation and conclusions are contained in the enclosure. The results of i

our review of Relief Request CR 23 will be reported separately.

The RAI to which Comed responded in its "A97010, Requests Authorization for Alternative to One Time Augmented Insp of RPV Shell Welds Set Forth in 10CFR50.55a(g)(6)(ii) (A)(2) Per [[CFR" contains a listed "[" character as part of the property label and has therefore been classified as invalid.(5).Authorization to Use Partial Insp Coverage Requested|letter dated August 13,1997]], was issued by the staff on May 23,1996. The staff cor,siders a response time of almost fifteen months unacceptably long. In addition, if request for relief CR 13, Revision 1, had been approved, the Class 2 bolted a

connections without removable insulation would have been in-service for the remainder of the operating life of the units without an in service inspection with their insulation removed.

i Therefore, the staff does not consider this to have been a conservative engineering proposal.

Sinceroty, ORIGINAL SIGNED M G. DICK FOR:

Robert A. Capra, Director l

Project Directorate lil 2

- Division of Reactor Projects - Ill/IV i

Office of Nuclear Reactor Regulation

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Docket Nos. 50-295 and 50-304

Enclosure:

As stated j

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sI oc w/ encl: See next pa9e DISTRBUTION. Docket Fee PU8t.lc pdm-2 r#

EAdoneem RCapre CSNreid CMoore -

OGC,015018 ACRS, T2E26 MGenowey, RW DOCUMENT NAME: GACMNTJR\\ ZION \\Zl94924.LTR

'See previous concurrence Ts receive a oopy of this document, indicate in the box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No~ copy OFFICE PM:PD3 2 8/ L%DS 2 ECG8 OGC C:P D 3 2 /) 4 i

BCAPRA)fk NAME CSHIRAKl

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NUCLEAR RE2ULATCRY C2MMISSION R

WASHINGTON, D.C. 306H 4001 o

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December 2, 1997 Ms. Irene Atomn, Acting Manager Nuclear RegtMosy Services CommonweattiGdison Company Executive Towere Wut 111 1400 Opus Place, Sun 500 Downers Grove,IL 60515

SUBJECT:

EVALUATION OF THE THIRD 10 YEAR INTERVAL INSPECTION PROGRAM PLAN REQUESTS FOR RELIEF NOS. CR 13, REVISION i, AND CR 23 - ZION

-NUCLEAR POWER GTATION, UNITS 1 AND 2 (TAC NOS. M94924 AND M94925)

Dear Ms..lohnsen:

The staff, with technical assistance from its contractor, the Idaho National Engineering and Environmental Laboratory (INEEL) has ravkwed and eyeluated the information provided by Commonwealth Edison Company (Comed). in its lotter dated March 1,1996, regarding Request for Relief Nos. CR-13. Revision 1, and CRO from tra American Society of Mechanical Engineers (ASME) Boller and Pressure VMSci Code (Code),Section XI, requirements for the Zion Nuclear Power Station, Units 1 and 2. Cor#d provided additional information in its "A97010, Requests Authorization for Alternative to One Time Augmented Insp of RPV Shell Welds Set Forth in 10CFR50.55a(g)(6)(ii) (A)(2) Per [[CFR" contains a listed "[" character as part of the property label and has therefore been classified as invalid.(5).Authorization to Use Partial Insp Coverage Requested|letter dated August 13,1997]]. The staff found Comti#s mquest for relief, CR-13, Revision 1, unacceptable cid its evaluation and conclusions are containe.1ia the enclosure. The results of oer review of Relief Request CR 23 will be reported separately.

The RAI to which Comed responded in its "A97010, Requests Authorization for Alternative to One Time Augmented Insp of RPV Shell Welds Set Forth in 10CFR50.55a(g)(6)(ii) (A)(2) Per [[CFR" contains a listed "[" character as part of the property label and has therefore been classified as invalid.(5).Authorization to Use Partial Insp Coverage Requested|letter dated August 13,1997]], was issued by the staff on May 23,1996. The staff considers a response time of almost 9 teen months umcceptably long in addition, if request for relief CR-13, Revision 1, had been approved, the Class 2 bolted connections without removable insulation would have been in-service for the rema!nder of the operating life of the units without an !n service inspection with their insulation reiToved.

Therefore, the staff does not consider this to have been a conservative engineering proposa!.

Sincerely, Robert A. Capra, Director Project Directorate lil 2 Division of Reactor Projects -lil/lV Office of Nuclear Reactor Regulation Docket Nos. 50 295 and 50-304

Enclosure:

As stated cc w/ encl: See next page t

g.

l. Johnson Zion Nuclear Power Station Commonweshh Edison Company Unit Nos.1 and 2 cc:

Michael I. Miller, Esquire Document Control Desk Licensing Sidley and Austin Commonwealth Edison Company One First National Plaza 1400 Opus Place, Suite 400 Chicago,lilinois 60603 Downers Grove, Illinois 60515 W. Cecil Lue Hing Director of Research and Developrnent Metropolitan Sanitary District of Greater Chicago 100 East Erie Street Chicago, Illinois 60611 Phillip Steptoe, Esquire Sidley and Austin One First National Plaza Chicago, Illinois 60603 Mayor of Zion Zion, Illinois 30099 Commonwealth Edison Company Site Vice President - Zion 101 Ghiloh Blvd.

Zion, Illinois 60099 2797 lilinois Department of Nuclear Safety Office of Nuclear Facility Safety 1035 Outer Park Drive Springfield, Illinois 62704 U.S. Nuclear Regulatory Commission Zion Resident inspectors Office 105 Shiloh Blvd.

Zion, Illinois 60099 Regional Administrator U.S. NRC, Region til 801 Warrenville Road Oslo, Illinois 60532-4351 Comrnonwealth Edison Company Zion Gtation Manager 101 Shiloh Blvd.

Zion, Illinois 60099-2797 l

l

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