ML20212H185

SE Approving Temporary Use of Current Procedure for Containment Repair & Replacement Activities Instead of Requirements in Amended 10CFR50.55a Rule

ML20212H185
Person / Time
Site:	Byron
Issue date:	03/06/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20212H182	List: ML20212H176 ML20212H185
References
NUDOCS 9803180071
Download: ML20212H185 (3)

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j UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20556 0001 0

...e.4 EVALUATION OF RELIEF REQUEST FROM THE IMPLEMENTATION OF 10 CFR 50.55a REQUIREMENTS RELATED TO THE REPAIR AND REPLACEM ACTIVITIES FOR CONTAINMENT COMMONWEALTH ED' SON COMPANY BYRON NUCLEAR POWER STATION. UNITS 1 AND_2 DOCKET NOS. STN 50-454 AND STN 50-455

1.0 INTRODUCTION

By FederalRegisternotice dated August 8,1996, the Nuclear Regulatory Commission amended its rsgulations (rule) to incorporfe by reference the 1992 Edition with the 1992 Addenda of Subsections IWE and (WL of Sedion XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code). Subsections IWE and IWL provide the rzquirements for inservice inspection (ISI) of Class Concrete Containments (CC), and Class Mattilic Containments (MC) of the light-water cooled power plants. The effective date for the cmanded rule was September 9,1996, and it requires the licensees to incorporate the new rsquirements into their ISI plans and to complete the first containment inspection within five yarrs, 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 has licensee can submit a request for relief for the date ofimplemen cnd raplacement incorporated (R/R) activitios with proper justification. The provision for grantmg reliefis in the regulation.

Pursu nt to 10 CFR 50.55a(a)(3)(ii), Commonwealth Edison Company (Comed, the licensee) imp 12 mentation of the requirements of the ASME Code,Section X Add 2nda, Articles IWA-4000, IWE-4000, and IWL-4000 of subsections IWA, lWE, and lWL, rslIttd to the Dec:mber containment R/R activities (Reference 1). The relief was requested until 31,1997.

Station, Units 1 and 2.This evaluation addresses the merits of the relief requests for Byron 2.0 EVALUATION Th3 relief requests are based on the licensee's justification that immediate cornpliance with the requirements of the rule for R/R activities would result in unusual difficulty without a numbsr of reasons, such as reclassification of components to Class C i criteria, revisions to visting procedures for R/R act.Vities to incorporate the requirements of Substetions IWF and IWL, and incorporation of appropriate examiner training and qualification 9803180071 J306

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n requirements in'the Comed procedures to demonstrate the impracticality of meeting the rcquirzments of the rule for R/R activities Rif:rsnee 1, however, did not provide any assurance regarding the adequacy of the present cont:inment R/R program. In response to the staff's request for additionalinformation, the licensza clarified and provided to summary description of the attemative that is used for the containment R/R activities, and revised the relief request dates from December 31,1997, to S:pt mber 9,1997 (Reference 2). Until September 9,1997, all R/R conducted on Class CC and Cl:ss MC components and their integral supports will be performed in accordance with the existing Byron Administrative Procedure, " Action / Work Request Processing Procedure" for nuciscr safety related components. These activities will be govemed by the Comed Quality Assurcnce (QA) Manual. The Comed QA program complies with the QA requirements of 10 CFR Part 50, Appendix B; ASME Section til NCA-4000; and ANSI /ASME NOA-1. Also, the insptction and R/R activities related to the containment post-tensioning tendons for both units era govsmed by the Byron Station Technical Specification. The staff considers the attemative program for R/R activities reasonable and acceptable during the period of relief.

Tha st:ff considers the attemative program for R/R activities reasonst4e and acceptable during ths p2riod of relief. Also, the staff concludes that immediate compliance with the requirements of tha cmsnded rule during the period September 9,1996, through September 8,1997, would result in hIrdship or unusual difficulty without a compensating increase in the level of quality and asisty. The licensee willimplement the requirements of the amended rule for the containment R/R cctivities starting September 9,1997, 3.0 C_ONCLUSION B:std on the review of the information provided in the relief requests (12R-19 and NR-21) and tha rasponse to the staff's request for additional information, the staff finris the temporary use of thn current procedure for containment repair and replacement activities instead of tne rcquirements of the arnended 10 CFR 50.55a rule to be reasonable and acceptable. Also, the stsff concludes that immediate compliance with the requirements of the amended rule for contzinment repair and replacement activities during the period September 9,1996, through Szptsmber 8,1997, would result in hardship or unusual difficulty without a compensating incrcess in the level of quality and safety. Accordingly, the requests for relief dated April 10, 1997 (cs revised on September 11,1997), to delay implementation of the rule for repair and rapl: cement activities until September 8,1997, are acceptable for authorization pursuant to 10 CFR 50.55a(a)(3)(ii).

Principio Contributor: H.Ashar D:ta: March 6, 1998

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<. e i 4.0 REFEREtCfft

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

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

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