ML20206P851

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-254/98-21 & 50-265/98-21.Corrective Actions Will Be Examined During Future Insp

ML20206P851
Person / Time
Site:	Quad Cities
Issue date:	05/11/1999
From:	Reynolds S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Kingsley O COMMONWEALTH EDISON CO.
References
50-254-98-21, 50-265-98-21, NUDOCS 9905190001
Download: ML20206P851 (2)

See also: IR 05000254/1998021

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DY 11, 1999

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Mr. Oliver D. Kingsley

President, Nuclear Generation Group

Commonwealth Edison Company

ATTN: Regulatory Services

Executive Towers West lli

1400 Opus Place, Suite 500

Downers Grove,IL 60515

SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-254/98021(DRS);

(50 264/98021(DRS))

Dear Mr. Kingsley: l

This will acknowledge receipt of your letter dated April 9,1999, in response to our letter

dated March 5,1999, transmitting a Notice of Violation associated with the above mentioned

inspection report at the Quad Cities Nuclear Power Station. The violation pertained to the ASME

Code weld examinations performed c'uring the Quau Cities Unit 1 and Unit 2 Second Ten Year

Inservice inspection Intervals. We have reviewed your corrective actions and have

no further questions at this time. These corrective actions will be examined during future

inspections, j

Sincerely,

Original /s/ Steven A. Reynolds

Steven A. Reynolds, Deputy Director

Division of Reactor Safety

Docket Nos. 50-254; 50-265  ;  !

License Nos. DPR-29; DPR-30 / {

Enclosure: Ltr did 4/9/99 J. Dimmette, Comed to  !

USNRC

See Attached Distribution

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DOCUMENT NAME: G:DRS\QUA05100.r/pd .

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O. Kingsley -2-

cc w/o encl: D. Helwig, Senior Vice President

H. Stanley, PWR Vice President I

C. Crane, BWR Vice President .

R. Krich, Vice President, Regu!atory Services l

DCD - Licensing

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J. Dimmette, Jr., Site Vice President l

G. Bames, Acting Quad Cities Station Manager

C. Peterson, Regulatory Affairs Manager i

cc w/ encl: M. Aguilar, Assistant Attorney General

State Liaison Officer, State of Illinois

State Liaison Officer, State of Iowa

Chairman, Illinois Commerce Commission

W. Leech, Manager of Nuclear l

MidAmerican Energy Company '

Distribution:

SAR (E-Mail) i

} RPC (E-Mail)

Project Mgr., NRR w/o enci '

J. Caldwell, Rill w/o enci

B. Clayton, Rlll w/o encI

SRI Quad Cities w/o encl

DRP w/o enci

DRS w/o enci

Rill PRR w/o encl

PUBLIC IE-01 w/enci

Docket File w/o enci

GREENS w/o encl

IEO (E-Mail)

DOCDESK (E-Mail)

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l SVP-99-063

April 9,1999

l U. S. Nuclear Regulatory Commission

ATTN

Document Control Desk

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Washington, DC 20555

Quad Cities Nuclear. Power Station, Units 1 and 2

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Facility Operating License Nos. DPR-29 and DPR-30

NRC Docket Nos. 50-254 and 50-265

Subject: Reply to a Notice of Violation ,

NRC Inspection Report Nos. 50-254/98021 and 50-265/98021 l

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References: (1) Letter f rom S.A. Reynolds (USNRC) to O.D. Kingsley (Comed), j

dated March 5,1999, 'NRC Inspection Report 50- l

. 254/98021(DRS); 50-265/98021(DRS) and Notice of Violation" l

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(2) Letter from J. P. Dimmette, Jr. (Comed), SVP-99-019, to

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USNRC, dated February 11,1999, "lSI improvement Plan"

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Enclosed is the Commonwealth Edison (Comed) Company reply to a Notice of

Violation (NOV) as requested in the Referenced (1) Inspection Report.

The inspection Report cited one Severity Level IV violation. The violation cited that the

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licensee had failed to identify to the NRC those welds where complete examination

coverage was determined to be impractical along with the basis for that determination

for the Second Ten Year Inservice Inspection (ISI) Program Interval which ended in

1993.

Our response to the NOV is provided in the attachment to this letter.

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APR 2 6 1999

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April 9,1999

U.S. Nuclear Regulatory Commission l

Page 2

This letter contains the following commitments with regard to the NOV.

= We will submit the relief request (s) for those ASME Section XI weld examinations .

performed to date during the Third ISI Program interval where the coverage

achieved was less than or equal to 90%. Specifically, this includes the first period

of the Third ISI Program interval and twa refueling outages that have been

completed in the second period of the Third ISI Program Interval. The review of

examinations completed and.the evaluation of percent coverage achieved is in i

progress. The relief request (s) will be prepared and submitted no later than J

October 30,1999. i

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= For those welds for which a relief request has not yet been submitted for the

current Third ISI Program Interval, we will submit a general relief request in

accordance with 10 CFR 50.55a that will cover those welds for which an

examination of greater than 90 percent of the weld volume was not achieved during l

the Second ISI Program Interval. This general relief will only be needed until the

end of the Third ISI Program Interval, at which time the complete population of

welds will have been examined and appropriate specific relief requests will have

been submitted. This general relief request will be submitted by May 14,1999.

As agreed to by teleconference between Mr. Steven Dort (Comed) and

Mr. Christopher Miller (U.S. NRC) held on April 5,1999, the submittal date for this letter

was extended from April 5,1999, to April 9,1999.

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Should you have any questions conceming this letter, please contact Mr. Wally Beck,

Acting Regulatory Assurance Manager, at (309) 654-2241, extension 3100.

Res ully,

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I P. Dimmette, Jr.

Site Vice President

Quad Cities Nuclear Power Station

Attachment: Reply to a Notice of Violation ,

cc: Regional Administrator- NRC Region lil

NRC Senior Resident inspector - Quad Cities Nuclear Power Station

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Attachment

Reply to a Notice of Violation

SVP 99-063

(Page 1 of 4)

NOTICE OF VIOLATION -

Quad Cities Technical Specification 4.0.E requires that the ' inservice inspection of

ASME Code Class 1, Class 2, and Class 3 components ...shall be performed in

accordance with Section XI of the ASME Boiler and Pressure Vessel Code and

applicable Addenda as required by 10 CFR 50, Section 50.55a (g).'

10 CFR 50.55a (g)(5)(lv) requires, "Where an examination requirement by the code or

addenda is determined to be impractical by the licensee and is not included in the

revised inservice inspection program as permitted by paragraph (g)(4) of this section, the

basis for this determination must be demonstrated to the satisfaction of the Commission

not later than 12 months after the expiration of the initial 120-month period of operation

and each subsequent 120-month period of operation during which the examination is

determined to be impractical.'

Contrary to the above, as of December 18,1998, the licenseg had not included in a

revised inservice inspection (ISI) program nor demonstrated to the satisfaction of the l

NRC, the basis for their determination that the code required examination was

impractical for the Unit 2 Reactor Pressure Vessel (RPV) nozzle weld N8B, the Unit 1

RPV nozzle weld N1 A, and the recirculation system tee to valve weld 02BS-F6.

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This is a Severity Level IV Violation (Supplement 1). (50-254(265)/98021-01)

REASON FOR THE VIOLATION

The violation was caused by our misinterpretation of the applicability of

10 CFR 50.55a(g) that requires that relief be obtained for ISI Program Non-Destructive

Examinations (NDEs) that accomplish less than essentially 100 percent coverage. The

timeliness of response to this issue was inadequate because required procedural

changes were not implemented until 12 months after identification of the issue.

For the Second Ten Year ISI Program Interval,1983-1993, our interpretation of the

requirements resulted in the conclusion that relief was not required because the

examinations were performed to the extent practical within the constraints of design,

geometry and fabrication. Specifically, Quad Cities Nuclear Power Station, Unit 2 RPV

Nozzle-to-Shell weld N8B generally has an Outside Diameter (OD) radius on the nozzle

which precludes Ultrasonic Testing (UT) angle beam and straight beam scanning from

the nozzle side of the weld. Due to the geometric condition, scanning is limited to the

RPV shell side of the weld. Also, Interferences were encountered that limit the extent of

scanning from the shell side of the weld.

This misinterpretation is the same as that cited in NRC Information Notice (lN) 98-42,

" Implementation of 10 CFR 50.55 a(g) Inservice inspection Requirements."

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Attachment

Reply to a Notice of Violation

SVP 99-063

(Page 2 of 4)

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED

Corrective actions taken as a result of the root cause analysis include the following.

• Site ISI procedure, QCAP 0410-06, " Inservice inspection Plan implementation for

Third Ten Year Inspection interval," was revised to require the ISI Coordinator to

record all welds whose UT results did not meet the requirements of the applicable

section of the approved ISI Program and to ensure that a relief request is submitted

to the NRC at or before the end of.the ISI 10 year interval. This was completed in  ;

September,1998. Subsequently, a common corporate procedure, NSP-ER-3016, )

" Implementing Procedure for Conduct of Inservice inspection Activities," was

implemented that supercedes the site specific procedure, and assigns specific

responsibilities for assuring that relief requests are submitted as required.

• Comed Nondestructive Testing procedure, NDT-C-30, " Ultrasonic Examination of

Reactor Vessel Wr.las to NRC Reg Guide 1.150," was revised to require calculating

and recording the percent weld volume scanned and a determination of whether the

percent of weldvolume scanned meets ISl Program requirements. The purpose of

NDT-C-30 is to detect, locate and evaluate discontinuities within the weld and

adjacent base material utilizing UT techniques. To address the coverage, issues, J

Comed procedure, NDT-Z-1, " Method for Calculating ASME Section XI Examination

Coverage for Volumetric and Surf ace Examinations," was created and impleraented

in August,1998. The procedure requires that the ISI Coordinator be notified in

writing if any welds receive less than essentially 100% coverage (i.e., s 90% as

defined in Code Case N-460). Therefore, examinations that are less than the

required coverage will be documented, using a standardized approach, and a relief

request will be submitted for those limited exams.

The above corrective actions address ISI Programmatic relief request issues and

timeliness issues by enhancing the procedural controls for ISI relief request submittals.

On January 8,1999, an evaluation of the effect of this deficiency on operability of the

affected components and their respective systems was initiated. The evaluation

concluded that an operability concem does not exist based on the following

considerations.

. There were no reportable indications detected for the affected components during j

examinations in either the Second or Third ISI Program Interval. To date, l

examination of approximately 55% of the American Society of Mechanical Engineers

(ASME) Boiler and Pressure Vessel Code (B&PV), Section XI, " Inservice Inspection

and Testing," component population is complete for the Third ISI Program Interval.

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Attachment

Reply to a Notice of Violation l

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SVP 99-063

(Page 3 of 4)

• There are no outstanding generic, failure mechanisms associated with the Nozzle-to-

Shell welds. It should be noted that all the feedwater nozzles were modified during

earlier refueling outages to prevent thermal fatigue cracking addressed in NUREG

0619,'BWR Feedwater Nozzle and Control Rod Drive Retum Une Nozzle Cracking."

Specialized augmented examinations of the feedwater nozzles were completed

satisfactorily as scheduled.

• In general, the inside surface of the Nozzle-to-Shell weld, where flaws, if present,

would most likely initiate, are examined during the UT examlhation.

• In addition to the efforts described above, limited access exams received augmented

techniques to increase coverage and detectability of flaws during the recently

completed refueling outage Q1R15. Specifically, six Nozzle-to-Shell welds, one RPV

top head to flange weld and approximately 55 various piping weld configurations

were examined utilizing augmented techniques. No reportable indications were

detected. l

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To date, for the Third ISI Program Interval, we have completed five refueling outages

(Q1R13, Q1R14, Q1R15 for Unit 1 and Q2R13, Q2R14 for Unit 2). These inspections

represent approximately 55% of the total population required to be examined during the

interval. The components examined during the Third (31 Program Interval are essentially ,

the same components examined during the Second ISI Program Interval.

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CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS

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We will submit the relief request (s) for those ASME B&PV, Section XI weld examinations

performed to date during the Third ISI Program Interval where the coverage achieved

was less than or equal to 90% Specifically, this includes the first period of the Third ISI

Program Interval and two refueling outages that have been completed in the second

period of the Third ISI Program Interval. The review of examinations completed and the

evaluation of percent coverage achieved is in progress. The relief request (s) will be

prepared and submitted no later than October 30,1999.

For those welds for which a relief request has not yet been submitted for the current

Third ISI Program Interval, we will submit a general relief request in accordance with

10 CFR 50.55a that will covar thcce welds for which an examination of greater than 90

percent of the weld volum , u achieved during the Second ISI Program Interval.

This general relief will onI3 a needed until the end of the Third ISI Program interval, at

which time the complete population of welds will have been examined and appropriate

specific relief requests will have been submitted. This general relief request will be

submitted by May 14,1999.

All planned milestones of the ISI Program improvement Plan, detailed in Reference (2),

are completed or on schedule.

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Attachment l

Reply to a Notice of Violation

SVP 99-063

(Page 4 of 4)

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

Quad Cities Nuclear Power Station will be in full compliance on May 14,1999, at which

time a general relief request for the remaining Second ISI Program Interval welds will be

submitted.

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