ML20206P851
| 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:
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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,
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Sincerely,
Original /s/ Steven A. Reynolds
Steven A. Reynolds, Deputy Director
Division of Reactor Safety
Docket Nos. 50-254; 50-265
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D. Helwig, Senior Vice President
H. Stanley, PWR Vice President
C. Crane, BWR Vice President
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R. Krich, Vice President, Regu!atory Services
DCD - Licensing
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J. Dimmette, Jr., Site Vice President
G. Bames, Acting Quad Cities Station Manager
C. Peterson, Regulatory Affairs Manager
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
MidAmerican Energy Company
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Distribution:
SAR (E-Mail)
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Project Mgr., NRR w/o enci
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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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SVP-99-063
April 9,1999
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U. S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Washington, DC 20555
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Quad Cities Nuclear. Power Station, Units 1 and 2
Facility Operating License Nos. DPR-29 and DPR-30
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NRC Docket Nos. 50-254 and 50-265
Subject:
Reply to a Notice of Violation
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NRC Inspection Report Nos. 50-254/98021 and 50-265/98021
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References: (1)
Letter f rom S.A. Reynolds (USNRC) to O.D. Kingsley (Comed),
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dated March 5,1999, 'NRC Inspection Report 50-
254/98021(DRS); 50-265/98021(DRS) and Notice of Violation"
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(2)
Letter from J. P. Dimmette, Jr. (Comed), SVP-99-019, to
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
licensee had failed to identify to the NRC those welds where complete examination
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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
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U.S. Nuclear Regulatory Commission
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
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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
progress. The relief request (s) will be prepared and submitted no later than
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October 30,1999.
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For those welds for which a relief request has not yet been submitted for the
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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
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.
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
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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)
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
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,
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" 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,
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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
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examinations in either the Second or Third ISI Program Interval. To date,
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
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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.
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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
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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.
a needed until the end of the Third ISI Program interval, at
This general relief will onI3
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
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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