ML20216F022

Safety Evaluation Accepting Request Re Temporary Use of Current Procedure for Containment Repair & Replacement Activities at Plant

ML20216F022
Person / Time
Site:	Quad Cities
Issue date:	03/06/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20216F001	List: ML20216E997 ML20216F022
References
NUDOCS 9803180224
Download: ML20216F022 (4)

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UNITED STATES s NUCLEAR REGULATORY COMMISSION WAsMINGToN, D.C. 30086 4001 EVALUATION OF RELIEF REQUEST FROM THE IMPLEMENTATION OF 10 CFR 50.55a REQUIREMENTS RELATED TO THE REPAIR AND REPl.ACEMENT ACTMTIES FOR CONTAINMENT COMMONWEMItiEQl 1 QN.GQMEBNY QUAD CITIES NUCLEAR POWER STATION. UNITS i AND 2 DOCKET NOS 50-254 AND 50-265

1.0 INTRODUCTION

By Federal Register notica dated August 8,1996, the Nuclear legulatory Commission amended its regulations (rule) to incorporate by reference the 1992 Edition with the 1992 Addenda of d Subsections IWE and IWL of Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code). Subsections IWE and IWL 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 ISl p!ans 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 has to be in accordance with the respective requirements of subsection lWE (lWL is not applicable to Quad Cities). However, a licensee can submit a request for relief for the date of implementation of its containment repair and replacement (R/R) activities with r perjustification. The provision for granting relief is incorporated in the ragulation.

Pursuant to 10 CFR 50.55a(s)(3)(ii), Commonwealth Edison Company (Comed, the licensee) submitted relief request CR-19 requesting NRC to grant relief from the immediate implementation of the requirement cf the ASME Code,Section XI,1992 Edition with the 1992 Addenda, Articles IWA-4000 and IW5-4000 of subsections IWA and IWE related to the containment R/R activities (Reference M The relief wss requested until December 31,1997. This evaluetion addresses the merits of the telief requests for Quad Cities, Units 1 and 2.

2.0 EVALUATION The relief requests are based on tha licensee's justification that immediate compliance w".h the ,

requirements of the rule for R/R activities would result in unusual difficulty without a 1 compensating increase in the level of safety and quality. In Reference 1, the licensee provides a number of reasons, such as reclassification of components to Class MC (from the original 1965 classification as Class B) classification criteria, revisions to existing precedures fu R/R activities to incorporate the requirements of subsections IWE and IWA, 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. i 9903190224 980306 a PDR ADOCK 05000254

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2-Reference 1, however, did not provide any assurance regarding the adequacy of the presortt containment R/R program. In response to the staffs request for additicaal information, the licensee clarified and provided a 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 September 9,1997 (Reference 2). Until September 9,1997, all R/R conducted on Class MC components and their integral supports will be performed in accordance with the existing Quad Cities Station site specific requiremets, and the Comed quality assurance (QA) program. The Comed QA program is govemed by the quality assurance criteria of Appendix B of 10 CFR Part 50. The staff considers the attemative prcgram for R/R activities reasonable and acceptable during the period of relief.

The staff considers the attemat!/e 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 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. The licensee willimplement the requirements of the amended rule for the containment R/R activities F. tarting September 9,1997.

3.0 CONCLUSION

Based on the review of the information provided in relief requert /,CR-19) and the response to the staffs request for additional information, the staff finds the temporary use of the current procedure for containmsnt 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 immediste compliance with the requirements of the amended rule for containment repair and rerbcement activities during the period September 9,1996, through September 8,1997, would r?> ult in hardship or unusual difficulty without a compensating increase in the level of quality and refety. Accordingly, the request for relief dated February 18,1997, as revised 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).

Principle Contributor: H. Ashar Date: March 6, 1998

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4.0 REFERENCES

1. Letter from E. S. Kraft (Comed) to NRC, " Quad Cities Nuclear Power Station Units 1 and 2, Third Ten Year Interval inspection Plan, Relief Request CR-19, Revision 0," dated 3 February 18,1997.

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

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