ML18043A538

Forwards Inservice Insp Program Proposed Request for Relief from Provisions of 1974 ASME Code,Section XI W/Addenda Through Summer 1975 & Suppl Info on Code Update & Code Implementation. Requests NRC Review Before June 1979

ML18043A538
Person / Time
Site:	Palisades
Issue date:	03/06/1979
From:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Ziemann D Office of Nuclear Reactor Regulation
References
NUDOCS 7903130284
Download: ML18043A538 (10)

Text

consumers

• Power company General Offices: 212 West Michigan Avenue, Jackson, Michigan 49201

• Area Code 517 788-0550 March 6, 1979 Director, Nuclear Reactor Regulation Att Mr Dennis L Ziemann, Chief Operating Reactors Branch No 2 US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - ISI RELIEF REQUESTS Consumers Power Company has reviewed its Inservice Inspection Program. update

• • submittal of June 13, 1978, and has determined that additional changes are required prior to the 1979 refueling outage. These changes constitute re-visions to Attachments II and IV of our June 13, 1978 submittal*. It is requested that you complete your review of these changes prior to June 1979*

Attachments:

1. Proposed Request for Relief from Provisions of 1974 ASME B&PV Code,Section XI with Addenda through Summer 1975.

2. Supplemental Information on Code Update and Code Implementation .

. David P Hoffman (Signed)

David P Hoffman Assistant Nuclear Licensing Administrator cc JGKeppler, USNRC

• ATTACBMENT 1 Proposed Request for Relief From Provisions of 1974 ASME B&PV Code,Section XI With Addenda Through Summer 1975

RELIEF REQUESTS PALISADES NUCLEAR POWER PLANT AilEA OF SEC XI SAFETY RELIEF CA'l'EGORY COMPONE.'N'l' FUNCTION CLASS RELIEF REgUESTED TESTING SUBSTITU'l'ED IMPLEMENT AT ION Bl.11 B-G-2 CRDM Bolting Primary 1 Nonperipheral CRDM Bolting a. Vessel Hydros a. Tech Specs Pressure Inaccessible .for VT b. Bl.11 Testing b. 110-Year Plan Boundary Bl.13 B-I-1 Closure Head Primary 1 Deletion of Category B-I-1 a. Vessel Hydros a. 'rech Specs Cladding Pressure b. Bl.15 & Bl.17 Testing b.c. l10-Year Plan Boundary c. Bl.l, Bl.2 & Bl.4 Testing Bl.111 B-I-1 Reactor Primary 1 Deletion of Category B-I-1 a. Vessel Hydros a. Tech Specs Vessel Pressure b. Bl.15 & Bl.17 Testing b.c. 40-Year Plan Cladding Boundary c. Bl.l, Bl.2 & Bl.4 Testing I*"

B2.9 B-I-2 Pressurizer Primary 1 Deletion of Category B-I-2 a. Vessel Hydros a.b. 110-Year Plan Cladding Pressure b. B2.l, B2.2 Testing Boundary B3.8 B-I-2 Steam Generator Primary 1 Deletion of Category B-I-2 a. Vessel Hydros a.b. 110-Year Plan Cladding Pressure b. B3.l, B3.2 Testing Boundary IWA-5210 All Class 1, 2, Pressure 1,2,3 Change Holding Time Require- None - Examinations 110-Yeur Plan

& 3 Components Boundaries ments for Hydros & Leak

. Tests for Noninsulated Components Performed as Scheduled e

• NOTES ON RELIEF REQUESTS

1. Item Bl.11 (Pressure Retaining Bolting)

BASIS STATEMENT Nonperipheral CRDM bolting is not accessible for VT examination.

REFERENCE CE Drawing 2966-SE-2443.

REMARKS CRDM bolting is not generally accessible for VT examination due to the configuration of the CRDMs. The peripheral CRDM bolting is accessible.

All nonperipheral CRDM is not accessible for VT examination.

IMPLEr"1ENTAT ION Peripheral CRDM pressure retaining bolting will be VT examined.

• 2. Item Bl.13, B-I-1 (Closure Head Cladding)

BASIS STATEMENT Category B-I-1 examinations were deleted from the ASME Code,Section XI, in the 74s76 addenda.

REMARKS The integrity of the cladding will be monitored through the conduct of Category B-A, B-B, B-D, B-N-1 and B-N-3 examinations.

IMPLEMENTATION Category B-I-1 examinations have been deleted from the Palisades 40-Year Plan.

3. Item Bl.14, B-I-1 (Reactor Vessel Cladding)

BASIS STATEMENT See Bl.13 above.

REMARKS See Bl.13 above .

IMPLEMENTATION See Bl.13 above.

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• 4. Item B2.9, B-I-2 (Pressurizer Cladding)

BASIS STATEMENT Category B-I-2 examinations were deleted from the ASME B&PV Code,Section XI, in the 74s76 addenda.

REMARKS The integrity of the cladding will be monitored through the conduct of Category B-B and B-D examinations.

IMPLEMENTATION Category B-I-2 examinations have been deleted from the Palisades 40-Year Plan.

5. Item B3.8, B-I-2 (Steam Generator Cladding)

BASIS STATEMENT See B2.9 above.

REMARKS

• See B2.9 above.

IMPLEMENTATION See B2.9 above.

6. IWA-5210 (System HydTostatic and Leak Tests)

BASIS STATEMENT Application of 4-hours' holding time for hydrostatic and leak testing is not necessary for noninsulated systems.

REMARKS IWA-5213,Section XI, 77W77 Edition, recognized that 4-hours' holding time was not necessary for noninsulated components. The 77W77 Edition requires no holding time for leak tests and a 10-minute holding time for hydro tests on noninsulated components.

IMPLEMENTATION IWA-5213 a & d will be applied to the Palisades Plant .

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• ATTACHMENT 2 Supplemental Information on Code Update and Code Implementation

SUPPLEMENTAL INFORMATION ON CODE UPDATE AND CODE INFORMATION SEC XI SEC XI SAFETY ITEM NO CATEGORY COMPONENT FUNCTION CLASS CO:MMENT B3.2 B-D Regenerative Heat Primary Pressure 1 No Inner Radius Exists Exchanger Boundary IWB/IWC-2430 All Class 1 & Pressure Boundaries 1,2 Modification of Additional Class 2 Components Examination Requirements of Section XI to Conform to Current and Past Practices at Palisades Plant

• SUPPLEMENTAL INFORMATION ON CODE UPDATE Al~D CODE IMPLEMENTATION

1. Item B3.2, B-D (Nozzle Inner Radius)

BASIS STATEMENT The crossover (interconnecting) nozzles of the regenerative heat exchanger are fabricated by welding square-ended 2-1/2" Schedule 160 pipe nipples into the heat exchanger's shell. The portion of the pipe nipple corre-sponding to a nozzle inner radius section has a radius of essentially zero and, therefore, cannot be UT inspected.

REFERENCE Atlas Industrial Manufacturing Co Drawing D-1733-3.

REMARKS The prestart hydro and the remainder of Category B-D testing will provide

• adequate monitoring of the regenerative heat exchanger's integrity .

IMPLEMENTATION No relief requested, none required - Inner Radius Section does not exist.

2. IWB-2430, IWC-2430 (Additional Examinations)

BASIS STATEMENT Performance of additional nondestructive testing subsequent to identifica-tion, characterization and evaluation of indications exceeding allowable standards is intended to identify generic defects.

REMARKS Section XI requires the examination of an equal number of components from the same category. Identification of generic defects, eg, specific mate-rial, welder, welding process, weld rods, heat treatment, etc, based on additional NDT examinations performed solely on components of the same Section XI category may at times be too restrictive and at times too unrestrictive as per the following examples:

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• a. (1)

( 2)

Indication NDT Method Bent Hanger VT (B4.10/B~K-2)

( 3) Cause Heavy structural material in area was moved during maintenance.

Structural material inadvertently contacted the hanger.

(4) Section XI Required Action Examine additional hangers (B-K-2).

(Location of additional hangers not specified.)

(5) CP Co Recommended Action Conduct VT examinations on hangers and other equipment in immediate area (same room and in same vicinity where structural material was moved).

b. (1) Indication Linear indications adjacent to socket weld (B4.8/B-J).

( 2) NDT Method PT (3) Cause Surface deformation due to previous temporary clamping of pipe with vice grips.

(4) Section XI Required Action Examine additional B-J welds without regard to service condition, possible cause and without'regard to NDT method (ie, UT or PT).

(5) CP Co Recommended Action a. Verify that minimum wall has not been intruded upon.

b. Perform prestart-up leak test.

c. Perform no additional testing as this indication is nongeneric in nature.

c. (1) Indication Linear indication of socket weld on 2 11 drain line (B4. 8/B-J) .

( 2) NDT Method PT (3) Cause Unknown (4) Section SI Required Action Examine additional B-J welds without regard to service condition and with-out regard to NDT method ( ie, UT or PT) .

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• (5) CP Co Recommended Action Examine additional socket welds on 2 11 drain lines using same NDT method (and same Section XI Item Number).

Number of *examinations to be conducted will equal number of B4.8/B-J examina-tions conducted this outage on drain lines of comparable size.

Defects determined to be generic in nature at the Palisades Plant will be traced/evaluated without respect to category restrictions in order. to adeQuately identify the entire scope of the specific occurrence.

IMPLEMENTATION Application of IWB/IWC-2430 at the Palisades Plant will be as follows:

a. Indications which are not related to process or fabrication o_:r _service conditions.

(1) Conduct additional examinations using the same NDT method which detected the defect.

(2) The number of examinations to be performed and the components to be examined (irrespective of category) will be determined by the nature of the original defect and its postulated cause.

(3) All engineering evaluations and additional examination reports will be included in the ISI Final Report.

b. Indications which are related to process or fabrication or service condition.

(1) Additional examinations will be conducted on and restricted to components of the same size, function and Section XI item number and using the same NDE method as encountered on the exam area revealing the indication(s).

(2) The number of examinations performed will be determined by the nature of the defect and its causes. If cause is unknown, a number equal to the number of components originally scheduled with the same size, function and Section XI item number will be examined.

No relief requested, none required. The above statement of implementation reflects the current and past practices for the Palisades Plant .

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