ML20134K738

Forwards RAI Re First 10 Yr ISI Program for Plant,Units 1 & 2

ML20134K738
Person / Time
Site:	Braidwood
Issue date:	02/11/1997
From:	Dick G NRC (Affiliation Not Assigned)
To:	Johnson I COMMONWEALTH EDISON CO.
References
TAC-M97134, TAC-M97135, NUDOCS 9702140213
Download: ML20134K738 (4)

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b February 11, 1997 l

-. Ms.IreneM. Johnson,Acti ' Manager-Nuclear Regulatory Services. 1 IE i f

Commonwealth Edison Company Executive Towers West III .t ' "/;. , N 'a ,

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SUBJECT:

• REQUEST FOR ADDITIONAliINFORMATION REGARDING FIRST 10 YEAR i INSERVICE INSPECTION PROGRAM - BRAIDWOOD STATION (TAC NOS. M97134 AND M97135),

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Dear Ms. Johnson:

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On October 8, ~ 1996,, Commonwealth Edison Company (Comed) submitted Revision 4 <

of its*first'10 year Inservice Inspection-Program and associated relief requests for Braidwood Station, Units 1 and 2. Subsequent to the submittal }

Comed requested expedited review for Relief Request NR-29. During our review  !

of-relief request NR-29, we have. identified the need for further information l as discussed in,the enclosed request for additional information (RAI). Please  !

provide your response to the RAI so that we may continue to review your l submittal. l In addition, in order to expedite the review process, please send a copy of-the RAI response to our contractor, Idaho ~ National Engineering Laboratory i (INEL), at the following address:

Mr. Michael T. Anderson INEL Research Center 2151 North Boulevard P.O. Box 1625 Idaho Falls, Idaho 83415-2209 Sincerely, Ge/s/orge F. Dick, Jr., Project Manager Project Directorate III-2 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation i Docket Nos. STN 50-456 and STN 50-457

Enclosure:

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1. Johnson Braidwood Station Commonwealth Edison Company Unit Nos. I and 2 cc:

Michael Miller, Esquire Mr. Ron Stephens Sidley and Austin Illinois Emergency Services One First National Plaza and Disaster Agency Chicago, Illinois 60603 110 East Adams Street Springfield, Illinois 62706 Regional Admir.istrator U.S. NRC, Region III Chairman 801 Warrenville Road Will County Board of Supervisors Lisle, Illinois 60532-4351 Will County Board Courthouse Joliet, Illinois 60434 Illinois Department of Nuclear Safety Ms. Lorraine Creek Office of Nuclear Facility Safety Rt. 1, Box 182 1035 Outer Park Drive Manteno, Illinois 60950 Springfield, Illinois 62704 Attorney General Document Control Desk-Licensing 500 South Second Street Commonwealth Edison Company Springfield, Illinois 62701 l 1400 Opus Place, Suite 400 j Downers Grove, Illinois 60515 George L. Edgar Morgan, Lewis and Bochius Mr. William P. Poirier 1800 M Street, N.W.

Westinghouse Electric Corporation Washington, DC 20036 Energy Systems Business Unit Post Office Box 355, Bay 236 West Commonwealth Edison Company ,

Pittsburgh, Pennsylvania 15230 Braidwood Station Manager i Rt. 1, Box 84 i Joseph Gallo Braceville, Illinois 60407 Gallo & Ross 1250 Eye St., N.W., Suite 302 EIS Review Coordinator Washington, DC 20005 U.S. Environmental Protection Agency l 77 W. Jackson Blvd.

Ms. Bridget Little Rorem Chicago, Illinois 60604-3590 ,

Appleseed Coordinator l 117 North Linden Street Mr. H. G. Stanley Essex, Illinois 60935 Site Vice President Braidwood Station Howard A. Learner Commonwealth Edison Company Environmental Law and Policy RR #1, Box 84 Center of the Midwest Braceville, IL 60407 203 North LaSalle Street Suite 1390 Chicago, Illinois 60601 >

U.S. Nuclear Regulatory Commission Braidwood Resident Inspectors Office Rural Route #1, Box 79 Braceville, Illinois 60407

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REQUEST FOR ADDITIONAL INFORMAUM FIRST TEN YEAR INSERVICE INSPECTION INTERYAL COMONWEALTH EDISON COMPANY BRAIDWOOD STATION. UNITS 1 AND 2 DOCKET NOS. STN 50-456 AND STN 50-457 l i

BACKGROUND l

The NRC-is responsible for the review and disposition of licensees' requests J relatisjg to inservice inspection (ISI) requirements contained in the Code of Federal Regulations (CFR) 10 CFR 50.55a, and Section XI of the American Society of Mechanical Engineers' (ASME) Boiler and Pressure Vessel Code. When submitting such requests, licensees are required to provide both a regulatory basis (by citing the appropriate section of 10 CFR 50.55a) and a technical discussion supporting the request. This information is used in evaluating tiie request.

The Staff has determined that licensees must state the specific paragraph of the Regulations under which each proposed alternative or request for relief is submitted, as discussed below.

A licensee may propose an alternative to CFR or Code requirements in accordance with 10 CFR 50.55a(a)(3)(1) or 10 CFR 50.55a(a)(3)(ii). When submitting a proposed alternative, the licensee must specify the -

appropriate regulatory basis. Under 10 CFR 50.55a(a)(3)(1), the proposed alternative must be shown to provide an acceptable level of quality and safety, i.e., essentially be equivalent to the original requirement in terms of quality and safety. Under 10 CFR 50.55a(a)(3)(ii), the licensee must show that compliance with the original requirement results in a hardship or unusual difficulty without a compensating increase in the level of quality and safety. Examples of

l. hardship and/or unusual difficulty include, but are not limited to,

excessive radiation exposure, disassembly of components solely to

provide access for examinations, and development of sophisticated

! tooling that would result in only minimal increases in examination coverage.

i In accordance with 10 CFR 50.55a(g)(5)(iii), a licensee may submit a request for relief from ASME Code requirements. If a licensee determines that conformance with certain ASME Code requirements is i impractical for its facility, the licensee shall notify the Commission l and submit, as specified in 10 CFR 50.4, information to support that determination. When a licensee determines that an inservice inspection

! requirement is impractical, e.g., the system would have to be redesigned t

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[ or a component would have to be replaced to enable inspection, the licensee should cite this part of CFR to support the criteria for

evaluation. The NRC may, giving due consideration to the burden placed i

on the licensee, impose an alternative examination requirement.

i STAFF REQUESTS i The staff has reviewed the information submitted by the licensee in a letter

] dated October 8, 1996, containing Revision 4 to the first 10-year inservice i inspection program. Revision 4 includes editorial corrections, incorporates j approved relief requests, and submits seven new requests. As requested by the

licensee, the review of Relief Request NR-29 is being expedited. To support

! this review, further clarification is being requested for Relief Request NR-29 i only, at this time.

A. General Comment

! Based on the review of Relief Request NR-29, it appears that the licensee is requesting relief from Code volumetric examination technique and procedural requirements (i.e. ASME Section XI, ASME Section V, Article 4, and Regulatory Guide 1.150). As an alternative, the licensee proposes to implement a performance based procedure. It is generally agreed that qualification by demonstration would provide a basis to conclude that the flaw detection capabilities of a performance based pr.ocedure would be at least equal to that of past examinations.

However, the qualification of volumetric examination techniques in accordance with the Performance Demonstration Initiative (PDI), is I currently under review by the Staff. As such, performance based i qualifications do not preclude the requirement to satisfy the Code of record for a plant or other commitments that the licensee may have made.

B. Soecific Information Reouired

1. From the initial review of the subject relief, the staff cannot determine the specific part(s) of the Code or regulations for which relief is being requested. As such, please describe the differences between the requirements associated with the Code of record and commitments for the licensee's plant, and the performance based ultrasonic examination procedure being implemented to satisfy the subject examinations.

2. Provide the basis to conclude that the proposed alternative will meet or exceed current Code requirements.

3. Verify that scanning of welds will be performed from both sides of the weld on the same surface where feasible.

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