ML20135C327

Forwards Relief Request CR-19,rev 0 to Third Ten Yr Interval Insp Plan

ML20135C327
Person / Time
Site:	Quad Cities
Issue date:	02/18/1997
From:	Kraft E COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ESK-97-047, ESK-97-47, NUDOCS 9703030495
Download: ML20135C327 (4)

Text

, ,.. Commonweahh lihvin Company Quad Citics Generating Station 22?l0 2(eth Avenue North

, , Ornhn a.11. 612 s2-9740 Tel M19M 122 41 ESK-97-047 Febmary 18,1997 United States Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk

Subject:

Quad Cities Nuclear Power Station Units 1 and 2, Third Ten Year Interval Inspection Plan l Relief Request CR-19, Resision 0 NRC Docket No. 50-254 and 50-265 This letter transmits Relief Request CR-19, Revision 0, to the subject Inservice Inspection (ISI) Plan.

Reliefis requested from immediate compliance with the repair and replacement requirements of Subsection IWE (IWL is not applicable to Quad Cities) of ASME Boiler and Pressure Vessel Code Section XI 1992 Edition with the 1992 Addenda. A copy of the proposed Relief Request is provided as an attachment to this letter.

If there are any questi ons concerning this matter or need for further clarification, please s

contact Mr. Charles Peterson, Regulatory Affairs Manager, at (309) 654-2241, extension 3609.

Respectfully,

b. 8, 1 .

E. S. Krafl, Site Vice President Quad Cities Station  ;

Attachment:

Relief Request CR-19, Revision 0 cc: A. B. Beach, Regional Administrator, Region III .

)b '

R. M. Pulsifer, Project Manager, NRR C. G. Miller, Senior Resident Inspector, Quad Cities D. C. Tubbs, MidAmerican Energy Company R.1 Singer, MidAmerican Energy Company F. A. Spangenburg, Regulatory Affairs Manager, Dresden Office of Nuclear Facility Safety, IDNS DCD License (both electronic and hard copies)

Hanf rd Steam Bouu, Chicago ofrice 03011O ESK Letter File 9703030495 970218 PDR ADOCK 05000254 IEEE H MJtBIR

'*~ ' ' '

O PDR u

ATTACHMENT A (Page 1 of 3)

RELIEF REQUEST NUMBER: CR- 19 COMPONENT IDENTIFICATION Code Class: MC

References:

IWE-4000 IWA-4000 Examination Category: E-A, E-B, E-C, E-D, E-F, E-G, and E-P ltem Numbers: All Class MC components listed in Table IWE-2500-1

Description:

ASME Section XI Repair and Replacement Procedures For IWE Components Units: I and 2 Component Numbers: All Class MC Components Subject to Repair and l Replacement Rules ofIWA-4000 CODE REOUIREMENT:

l l

10CFR50.55a(g)(4)(v) requires Class MC and CC pressure retaining components and their integral attachments to meet the applicable ASME Section XI repair and replacement requirements. Class CC (Subsection IWL) does not apply to Quad Cities Units I or 2.

Anicle IWE-4000 refers to Anicle IWA-4000 for Repair Procedures.

BASIS FOR RELIEF Reliefis requested from immediate compliance with the repair and replacement requirements of Subsection IWE (IWL is not applicable to Quad Cities) Pursuant to 10CFR50.55a(a)(3)(ii),

reliefis requested on the basis that the immediate compliance with the aforementioned requirements would result in unusual difficulty without a compensating increase in the level of quality and safety.

A revision to 10CFR50.55a was published on August 8,1996, which endorses Subsections IWE and IWL of the ASME Boiler and Pressure Vessel Code Section XI,1992 Edition with the 1992 Addenda. This revision requires the completion of an expedited examination by September 9, 2001. However, in a letter to the Nuclear Energy Institute (NEI) dated November 6,1996, the NRC staff clarities that all repair and replacement activities within the scope of Subsections IWE and IWL which are conducted after September 9,1996 must be conducted in accordance with the applicable rules of Subsections IWE and IWL of ASME Section XI,1992 Edition and 1992 Addenda.

Immediate compliance with the repair and replacement rules of ASME Section XI,1992 Edition and 1992 Addenda, for IWE components is impractical because substantial time and resources must be expanded for the following major efforts:

a* ,

I ATTACHMENT A (Page 2 of 3)

RELIEF REQUEST NUMBER: CR - 19 l 1.

CONTAINMENT STRUCTURE COMPONENT CLASSIFICATION: The containment structures at Quad Cities Station were constructed to the rules of ASME Section III,1965 Edition, Quality Group B. In order to comply with 10 CFR 50.55.a(g)(4)(v), it will be

{

l necessary to identify and reclassify all containment components to Class MC classification criteria. This effon will include the retrieval and review of all applicable fabrication and installation documentation, the development of a basis document to identify the correct classification boundaries, and the eventual development of an Inservice Inspection Program l to govern all IWE-related activities at Quad Cities Station. l i

2. PROCEDURE REVISIONS: The requirements ofIWE must be incorporated into applicable i station procedures. The current Inservice Inspection Program, (which includes the repair and replacement program), for Quad Cities Station is currently based on the rules of ASME Section XI,1989 Edition and only addresses the inservice inspection requirements for Class 1,2, and 3 pressure retaining components and component supports. Therefore, various procedures that control Code repair and replacement activities must be revised to incorporate the unique requirements of Subsection IWE.

3. EXAMINER TRAINING AND CERTIFICATION: The unique examiner qualification required by Subsection IWE must be incorporated into the existing Commonwealth Edison (Comed) training and certification program. The existing Comed training and certification program only addresses the cenification requirements for Class 1,2, and 3 pressure retaining components and component supports. The Comed training and certification program must be revised to incorporate the unique requirements of Subsection IWE.

Since the containment structures at Quad Cities Station weie constructed to the rules of ASME Section III, Quality Group B, all repair and replacement activities conducted on these components have been subjected to Comed Quality Assurance (QA) Program, which implements the requirements of 10CFR50, Appendix B. The Comed QA Program requires repair and replacement activities to be conducted in accordance with the original design specifications using approved procedures. This approach assures applicable design bases are maintained. In addition, the containment structure integrity is verified by periodic pressure tests in accordance with 10 CFR 50, Appendix J. The application of the requirements of Subsection IWE-4000 imposes added administrative burden (such as the requirement for a repair / replacement plan and NIS-2 form) that does not provide a compensating increase in the level of quality or safety.

PROPOSED ALTERNATIVE PROVISI  ;

Until December 31,1997, repair and replacement activities conducted on Class MC containment  :

structure components at Quad Cities Station will be performed in accordance with the existing Comed QA program requirements. Compliance with ASME Section XI,1992 Edition and 1992 Addenda, Subsections IWE-4000 will begin on January 1,1998.

)

I l

1 . -

i a

ATTACHMENT A (Page 3 of 3)

RELIEF REQUEST NUMBER: CR- 19 I APPLICABLE TIME PERIOD Reliefis requested f t" the third ten-year interval of the Inservice Inspection Program for Quad

, Cities Units I and 2 .,til December 31,1997.

i j

4 1

4 9

l I 4

4

.  ?

r i

i  ?

} f f

t f

(

l t

.I d

i l

1

, . -