ML060200095
| ML060200095 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/01/2006 |
| From: | Padovan L Plant Licensing Branch III-2 |
| To: | Harden P Nuclear Management Co |
| padovan L, NRR/DORL, 415-1423 | |
| References | |
| TAC MC8603, TAC MC8604 | |
| Download: ML060200095 (6) | |
Text
February 1, 2006 Mr. Paul A. Harden Site Vice President Nuclear Management Company, LLC Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530
SUBJECT:
PALISADES PLANT REQUEST FOR ADDITIONAL INFORMATION RELATED TO REQUEST FOR RELIEF FROM ASME SECTION XI CODE REQUIREMENTS FOR REPAIR OF REACTOR PRESSURE VESSEL HEAD PENETRATIONS (TAC NOS. MC8603 and MC8604)
Dear Mr. Harden:
Your letter of October 11, 2005, requested relief from certain sections of the 1989 Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, in the event a reactor vessel head penetration nozzle was in need of a repair at the Palisades Nuclear Plant.
We are reviewing your request, and find that we need additional information as shown in the enclosed request for additional information (RAI). We discussed this RAI with Ms. Amy Hazelhoff of your organization on January 19, 2006, and she agreed to respond by February 20, 2006. Please contact me at (301) 415-1423 if you have questions.
Sincerely,
/RA/
L. Mark Padovan, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-255
Enclosure:
RAI cc w/encl: See next page
February 1, 2006 Mr. Paul A. Harden Site Vice President Nuclear Management Company, LLC Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530
SUBJECT:
PALISADES PLANT REQUEST FOR ADDITIONAL INFORMATION RELATED TO REQUEST FOR RELIEF FROM ASME SECTION XI CODE REQUIREMENTS FOR REPAIR OF REACTOR PRESSURE VESSEL HEAD PENETRATIONS (TAC NOS. MC8603 and MC8604)
Dear Mr. Harden:
Your letter of October 11, 2005, requested relief from certain sections of the 1989 Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, in the event a reactor vessel head penetration nozzle was in need of a repair at the Palisades Nuclear Plant.
We are reviewing your request, and find that we need additional information as shown in the enclosed request for additional information (RAI). We discussed this RAI with Ms. Amy Hazelhoff of your organization on January 19, 2006, and she agreed to respond by February 20, 2006. Please contact me at (301) 415-1423 if you have questions.
Sincerely,
/RA/
L. Mark Padovan, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-255
Enclosure:
RAI cc w/encl: See next page DISTRIBUTION PUBLIC LPLIII-1 R/F RidsNrrPMMPadovan RidsNrrLATHarris RidsNrrDorlLple RidsRgn3MailCenter RidsOgcRp RidsAcrsAcnwMailCenter JTsao RidsNrrDorlDpr RDavis ADAMS Accession Number: ML060200095 OFFICE NRR/LPL3-1/PM NRR/LPL3-1/LA NRR/LPL3-1/BC (A)
NAME LPadovan THarris TKobetz DATE 1/26/06 1/26/06 2/1/06 OFFICIAL RECORD COPY
Palisades Plant cc:
Robert A. Fenech, Senior Vice President Nuclear, Fossil, and Hydro Operations Consumers Energy Company 1945 Parnall Rd.
Jackson, MI 49201 Arunas T. Udrys, Esquire Consumers Energy Company 1 Energy Plaza Jackson, MI 49201 Regional Administrator, Region III U.S. Nuclear Regulatory Commission Suite 210 2443 Warrenville Road Lisle, IL 60532-4351 Supervisor Covert Township P. O. Box 35 Covert, MI 49043 Office of the Governor P. O. Box 30013 Lansing, MI 48909 U.S. Nuclear Regulatory Commission Resident Inspector's Office Palisades Plant 27782 Blue Star Memorial Highway Covert, MI 49043 Michigan Department of Environmental Quality Waste and Hazardous Materials Division Hazardous Waste and Radiological Protection Section Nuclear Facilities Unit Constitution Hall, Lower-Level North 525 West Allegan Street P.O. Box 30241 Lansing, MI 48909-7741 Michigan Department of Attorney General Special Litigation Division 525 West Ottawa St.
Sixth Floor, G. Mennen Williams Building Lansing, MI 48913 Michael B. Sellman President and Chief Executive Officer Nuclear Management Company, LLC 700 First Street Hudson, MI 54016 Jonathan Rogoff, Esquire Vice President, Counsel & Secretary Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Douglas E. Cooper Senior Vice President - Group Operations Palisades Nuclear Plant Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Covert, MI 49043 Stephen T. Wawro, Director of Nuclear Assets Consumers Energy Company Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Laurie A. Lahti, Manager Regulatory Affairs Nuclear Management Company, LLC Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 November 2005
ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION (RAI)
RELATED TO REQUEST FOR RELIEF FROM AMERICAN SOCIETY OF MECHANICAL ENGINEERS (ASME) SECTION XI CODE REQUIREMENTS FOR REPAIR OF REACTOR PRESSURE VESSEL HEAD PENETRATIONS PALISADES NUCLEAR PLANT DOCKET NO. 50-255 Nuclear Management Companys (NMCs) letter of October 11, 2005, requested relief from certain sections of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME) Code,Section XI, in the event a reactor vessel (RV) head penetration nozzle was in need of a repair at the Palisades Nuclear Plant. To complete its review of the submittal, the staff requests the following additional information.
- 1. Enclosure 1, page 1. NMC said that an analysis of a non-abrasive water jet machining (non-AWJM) conditioned repair showed that a crack in the nozzle will not grow to 75 percent through-wall in 5.04 effective full power years (EFPY) for a repaired control rod drive (CRD) nozzle, and 5.13 EFPY for a repaired incore instrumentation nozzle. These periods are beyond the duration for the relief request, which will conclude on December 12, 2006. Therefore, NMC determined that AWJM conditioning was unnecessary in the repair process. Explain why AWJM conditioning is not needed if the periods for a 75 percent through-wall crack are beyond the duration of the relief request. Will NMC examine the nozzles periodically to assure that cracks will not develop, and the inspection frequency will be shorter than 5.04 and 5.13 EFPY?
- 2. Enclosure 2, page 1. NMC said that extensive radiological dose was received during the nozzle repair due to the chamfering process. Provide the dose measurement.
- 3. Enclosure 2, page 3, Item 4. NMC proposed to use the 2005 Addenda of ASME Section XI, 2004 Edition, where the code allows the ratio of the maximum applied stress intensity factor and the available fracture toughness based on crack initiation (KIC) for the corresponding crack tip temperature be less than /2 at a temperature of RTNDT [reference temperature].
The proposed criterion is not the same as the requirements in ASME Section XI, IWB-3613(a), which require that for conditions < 20 percent of design pressure, the ratio of the maximum applied stress intensity factor and the available fracture toughness based on crack arrest (KIa) for the corresponding crack tip temperature be < /2 at a temperature of RTNDT + 60 EF.
(a)
The Nuclear Regulatory Commission (NRC) has not accepted the 2004 Edition and 2005 Addenda in Title 10, Code of Federal Regulations, Part 50 (10 CFR 50.55a).
The NRC staff has not completed its review of the 2004 Edition of the Code as part of updating 10 CFR 50.55a. Therefore, NMC needs to reference documents other than the 2004 Edition and 2005 Addenda of ASME Section XI to support its technical basis in Item 4.
(b)
Show why the postulated flaw in the remnant J-groove weld could not meet the requirements in IWB-3613(a) of the 1989 edition of the ASME Code,Section XI, which is the code of record, to establish the basis for the relief.
(c)
Demonstrate that your proposed criterion provides sufficient safety margin such that the structural integrity of the RV head will not be compromised. Confirm that the proposed criterion applies only to the RV head, not to the nozzles.
- 4. Enclosure 2, page 4, 3rd paragraph. Discuss whether hydrostatic pressure was applied to the crack face, and whether a plastic zone correction factor was included in the flaw evaluation of the remnant J-groove weld.
- 5. Enclosure 3, page 3. Reference 7, AREVA Proprietary Document 32-5059512-00, Palisades CEDM [control element drive mechanism] and ICI [in-core instrumentation]
Nozzle IDTB [inner-diameter temper bead] Repair PWSCC [primary-water stress corrosion cracking] Life Evaluation, March 2005, contains flaw evaluations of non-AWJM to the nozzles. Provide Reference 7 to the NRC.
[control rod drive mechanism] J-groove weld and butter are acceptable for 27 years of operations.... In the 3rd paragraph, NMC said... the results showed that the postulated radial crack in the Alloy 182 J-groove weld and butter would be acceptable for 5 years of operation for an ICI nozzle....
(a)
Discuss why there is a large difference in periods of acceptability between the CRDM nozzle and ICI nozzle.
(b)
The NRC staff understands that in NMCs flaw evaluations, the remnant J-groove weld was assumed to be cracked in its entirety, and the tip of the initial crack was assumed to be located at the boundary between the weld and the RV head. The crack was assumed to propagate into the RV head, and the goal was to determine the structural integrity of the RV head. Therefore, it is not clear whether the acceptable periods of operation discussed in the above statement refer to the remnant J-groove welds or the RV head. Clarify the above statements.
- 7. NMCs RV head penetration nozzle relief request of August 2, 2004, said if the IDTB weld repair is not abrasive water jet machining (AWJM) remediated, the life expectancy relative to PWSCC is conservatively estimated at 1.3 effective full power years (EFPY) for a CRD nozzle and 1.5 EFPY for an ICI nozzle. If AWJM is used, the life expectancy relative to PWSCC is conservatively estimated at 53 EFPY for CRD and ICI nozzles. NMCs relief request of October 11, 2005, said the life expectancy of the non-AWJM conditioned IDTB weld repair relative to PWSCC is conservatively estimated at 5.04 effective full power years (EFPY) for a CRD nozzle and 5.13 EFPY for an ICI nozzle. Explain the change in the current method used to analyze the life expectancy of non-AWJM versus the method used in the previous relief request.
- 8. On Page 8 of 16 of Enclosure 1 to its October 11, 2005, submittal, NMC lists the differences between its alternative and the requirements of Code Case N-638, Similar and Dissimilar Metal Welding Using Ambient Temperature Machine GTAW [Gas Tungsten Arc Welding]
Temper Bead Technique. In paragraph d) on this page, NMC discusses its impact-property testing. NMC indicates that the RTNDT is 30 degrees F, but in the next sentence states that the RTNDT + 60 degrees F is 30 degrees F. Explain this inconsistency.
- 9. In the same paragraph d) as discussed above, NMC said that it did not meet the requirements of N-638 2.1 (j), but it conducted additional testing, as permitted by NB-4335.2, "Impact Tests of Heat Affected Zone," of the 1989 edition of the ASME Code,Section III Code, Division 1 - NB, because the mils lateral expansion results were not acceptable. Confirm that all requirements for impact testing of the heat affected zone as described in NB-4335.2 have been met.