ML18044A202

Safety Evaluation Supporting Amend 53 to License DPR-20

ML18044A202
Person / Time
Site:	Palisades
Issue date:	10/15/1979
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML18044A203	List: ML18044A202 ML19254F188 ML19254F191
References
NUDOCS 7911070294
Download: ML18044A202 (13)

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20655

,.9 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 53 TO PROVISIONAL OPERATING LICENSE NO. DPR-20

• CONSUMERS POWER COMPANY l. 0 -*-* H~TRODUCl-ION DOCKET NO. 50-255 PALISADES PLANT On May 5, 1976, the Commission sent a generic letter to Consumers Power Company (the licensee) advising than that the inservice inspection and testing requirements for ASME Code Class 1, 2 and 3 components* for nuclear power plants delineated in 10 CFR Part 50.55a were changed by a revision to the regulations published on February 27, 1976.

The revised regu~ations require inservice inspection and testing to be perfonned in accordance with the examination and testing requirements set forth in Section XI of the ASME Boiler and Pressure Vessel Code and Addenda thereto.

To avoid potential conflicts between the ASME Code requirements and the Technical Specifications presently in effect for the Palisades Plant, *we-also.advised the licensee that he should apply to the CO!Mlission for amendment of *the Technical Specifications.

Sample 1 anguage for sue h Technica 1 Spec if icati.ons changes was provided as an enclosure to o.ur letter of May 5, 1976.

By letter dated June 13, 1978, the licensee r~quested a change to the Technical Specifications (Appendix A) appended to Provisional Operating License No. DPR-20 for the Palisades Plant *. The proposed amendment and revised Technical Specifications would del.ete the present inspection and testing requirenents fn S~ctions 4.3 and 4. 9 of the Technical Speci-fications and substitute therefore - language based on the enclosure with our letter of May 5, 1976.

The proposed Technical Specifications would require all inspection and testing to be perfonned in accordance with the ASME Code except where specific written relief has been granted by the NRC pursuant to 10 CFR 50, Section 50.55a(g){6)(i).

Our letter of May 5, 1976, also advised the i'icensee that if he detennines that confonnance.with certain ASME Section XI inservice inspection and testing requirements is.impractical, he should subnit information to the Commission to support his determination in accordance with 50,55a(g}{5)(iii} and (iv).

By letters dated January 4, 1977 and January 13, 1978, we provided additional guidance in preparing inservice

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inspection and testing program descr1ptio_ns and-assoeiated re.1 ief requests.

In response to our letters, the *1 icensee sutm1tted a proposed Inserv1ce Inspectton and Testing Program by letters dated March 1, 1977, May 3, 1977, October 7, 1977, January 13, 1978, June 13, 1978 and March 6, 1979, The June 13, 1978 letter superseded the previous sutmittals. These sutmittals also included requests*for relief from examining certain components where the licensee deter-mined that it was impossible or impractical to examine or test the specific component because of design,,geometry or materials of construction.

This Safety Evaluation only encompasses the inservice inspection and pump testing portion of the proposed technical specification change and request for relief. A separate evaluat:ion.on---the valve testing portion of the application will be issued* at a later date.

EVALUATION

!.1 Technical Specifications The changes proposed by the licensee to the Technical Specifications are basea on the sample Technical Specifications*~nclosed with our letter of May 5, 1976.

The revised Technical Spe~ifications require all inspections and pump testing to be perfonned in accordance with

• the ASME Boiler and Pressur~ Vessel Code and are ?Cceptable.

?.2 Requests for Relief As required by 10 CFR 50.55a(g), the licensee has updated the Inservice Inspection Program for the Palisades Plant to the requirements of the 1974 Edition through Summer 1975 Addenda of Section XI of the ASME Boiler and Pressure Vessel Code (B&PV Code).

Based on infonnation contained in the suOOiittal dated June 13, 1978, and the revised sul::xnitta1 dated March 6, 1979, the licensee detennined that certain requirenents of the Code cannot be implenented at the facility because of component or systen design, geometry, or materials of construction.

Requested reliefs from those requirenents have been reviewed and

• evaluated by the staff; and our detenninations to grant or deny the requests, pursuant to 10 CFR 50.55a(g)(6)(i), are documented below.

~.2.1 Class 1 Components A.

Request relief from perfonning examinations to Category B-F Code requ irenents of nozzle to safe end, welds on the<_reactor pressure vessel and steam generator nozzle to pipe welds.

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--- Code Requirement Volumet~ic and surface examinationsof 100 percent of Category E-F welds dur"ing Each.inspection interval

{10 years).

B~sis For Regu~sting Relief The transition pieces between the carbon steel nozzles and the carbon steel piping are also carbon steel and thus not dissimilar metal safe-ends.

The examination Category 8-J which applies to piping also applied to these welds ra*ther than Category B-F.

Evaluation As defined by the applicable code, these welds are not Category B-F and would therefore qualify for examination under 8-J category.* However, they are "safe-ends" and subjected to the higher stress levels associated

"'ith :::-:*ri:inal ends. 2nd 1*:al1 thicl:ness tr2nsitions.

It is the staff's position that these welds should be included and inspected to Category B-J requirements with the restriction that the

~nspection be expanded to include 100 percent.of each welr durinq.this i~sp~ction interval.

Howeve~ this examination could be included in the 25 percent examination requirements of Category 8-J welds.

B. *Request relief fran examina"t.ion-of~the-*reactor vesse.l cladding.

(Item 81.14, Examination Category 8-I-l)

Code Requirement Visual examination performed during each inspection interval shall cover 100 percent of the patch areas.

The areas shall include at least six patches (each 36 square inches) evenly distributed in

. accessible sections of the vessel shell.

Basis For Requesting Relief

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The areas to be visually inspected are inaccessible.~hen the core barrel. is in place.

Since this examination can onlj. be performed

'from the inside surface of the reactor vessel shell*; the reouired examination can only be perfofmed when the 2ore barrel is r~moved.

Evaluation

. The inaccessibility of the internal surface of the reactor vessel makes the required visual inspection of the surface areas impractical for the licensee to perform with the core barrel in.place~ A surface examination of the closure head*cladding. Item 81.l~~*is possible during the inspection interval and the licensee has committed* to do a supplementary examination*during the interval which includes a remote visual examination of the vessel interior (Item 81.15, closure head cladding {Item Bl. 13)~ and if possible clad surface

~nspection of outlet nozzles in place of th~ inspection required under this examination category.

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Request relief fran volumetri~ examination,of inaccessible welds which are identified below:

I.tern 84.5 Category 8-J PCS-42-RCL-1Hl-2LD~ -3LU, ~3, -3LD

• PSC-42-RCL-2Hl-2LD, -3LU, -3, -3LD Code Requirements Volumetric examination ~f 25 percent of circumferential weld during each* inspection interval.

Basis For Reouestinq Relief These welds are inaccessible, as determined by a visua1 ex~r.-,inction by the licensee, for volumetric or *surface examination because they

• are buried inside the reactor shield.

Evaluation Access to volumetrically and/or surface examine these welds are not possible.* All welds identified above as being inaccessible shall be visually inspected by observing the general area after a four-hour hold at the pressure test requirements stated in Section.XI IWA/IWB-5000.. This examination, and other vol~metric inspections required by Section XI of-similar welds on the Class I piping v.*hich can be _perf armed, wi 11 pro vi de assurance that no degradation has

• occurred and that the piping pressure boundary will remain structurally acceptable during the inspection interval.

This relief does not appiy in the event paragraph IWR-2430 of Section XI is applicable.

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Request relief to delay the volumetric examination of the reactor vessel to flange, head to flange and inlet and outlet nozzle welds until the. end of, the 10-year inspection interval.

Code Requirement Volumetric examination of 100 percent of each weld during the inspection interval.. The examination must be divided and inspected at 1/3 intervals during the 10-year -interval.

Basis* For Req~esting Relief Deferment to the end of 10-year interval will allow all mechanized examinations to ~e performed during the same outage ~hen the core barrel is removed. *The core barrel is scheduled to be removed only at the end of each interval;

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Evaluation One-third of the reactor vessel to flange weld was inspected during the first inspection period..

As stated in a later code addenda (Winter 1975) this inspection can be performed at the end of *the inspection interval.

To allow auto~ati~ scanning and recording of this weld and to be consistent with the later code addenda, the balance (two-thirds) of this weld must be perfonned at the end of the inspection interval.

The reactor pressure vessel closure head to flanqe weld is accessible*

for examination.

Therefore, the weld must be examined in accordance----..

with the frequency in lWB-2410.

The inlet and outlet nozzles are not accessible for autcxnatic ultrasonic examinations until the core barrel is removed at the end of the 10-year inspection interval. The two outlet nozzles were examined during the first inspection interval to the extent required by Code Case 1647 and no unacceptable flaws were found.

The inlet nozzles are inaccessible to examine in accordance with Code Case 1647.

If the. core barrel is* removed from the reactor vessel for other

• reasons, 100 percent of the volume shown in Figure IWB-3512.l(a) of one outlet and one inlet nozzle shall be examined volumetrically.

However, l 00 percent must be completed by the end of tne ten-year interval. *

, It is *our judgment that the.examinations we recommend and the inspection of the outlet nozzles to Code Case 1647 will provide an adequate level of assurance that the reactor pressure* vessel w_il l remain structurally sound throughout this period.

On this basis, relief may be granted.

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Request relief from volumetric examination of the circumferential weld in the reactor pressure vessel closure head.

(Item Bl. 2)

Code Reguire~ent Volumetric examination of five percent of the length of each circumferential head weld.

Basis For Requesting Relief The circumferential weld in the closure head is inaccessible for examination due to" control 'rod guide tube constraints *

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. *.e Evaluation The weld is located within the cluster of control rod guide tubes which penetrate the reactor.pressure vessel head. *The weld is the dollar plate to peel segment and volumetric examination of this weld is impractical to perfonn.

Therefore, relief may be granted

. from the requirement for volumetric and visual examinations during the system pressure test.:

F.

Request relief from visual inspection of nonperiphera.l control rod drive bolting.

(Item Bl.11, Examination Category B-G-2)

Vi~ual examinations perfor~ed during each inspection interval shall cover 100%.of the bolts, studs, and nuts.

Bolting may-be examined either in place under tension, when the connection is disassembled, or when the bolting is removed.

LICENSEE BASIS FOR REQUESTING RELIEF Nonperipheral CROM bolting is not accessible for visual examination.

Peri-pheral CROM ~olting_~ill be visually examined.

EVALUATION The iriaccessibility of the inner control rods bolting hinders the visual examination required by the Code when the control rod assemblies are in place.

However, the code requirement allows the* examination to be performed either in place, when disassembled, or when the bolting is removed.

Visual examin-ation of the peripheral control rod bolting in place will provide a significant sample to gain assurance of the structural condition of the inner control rod bolting.

The staff concludes that this request may be granted if the inner control rod assemblies are not disassembled or the bolting removed during this inspection period.

If the inner assemblies are disassembled or the bolting removed, visual examination as*required by the Code shall b~ performed.

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Request relief from examination of the reactor pressure vessel and closure head tladding.

(Item Bl.13, Examination Category B~I-1)

CODE REQUiREMENT The.examination, visual and ~urface or voiumetric, sha11 include at least six patches (each 36 sq. in.) evenly distributed in the vessel and in the closure head.

The examinations performed during each inspection interval shall cover 100% of the p'tch areas.

7 LICENSEE BASIS FOR REQUESTING RELIEF Category B~I-l examinations wer~ del~~ed from the ASME Cod~ Section XI, in the 74576 Addenda.

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

EVALUATION The licensee has not demonstrated that the Code requirement is impractical to implement at his faciltiy as required by 10 CFR 50.55a(g). The lnservice Inspection Program is based upcin the requireme-nts of the 1974 Edition through Summer 197 5 Addenda of _Sef! ion_ XL_Q_f_ the ASME Code.

Del et ion of the examination requirements from a-later Addend~ of the Code which has not been endorsed by the NRC is not adequate to justify not performing the *requir~d visual examination.

The staff *c6ncludes that relief from the requirement may not be granted.

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Request relief from examination of the pressurizer and steam generator cladding.

(Item 82.9 and 83.8, Ex~mination Category B-1~2)

CODE REQUIREMENT Visual examination shall include one patch (36 sq. in.) near each manway in the primary side *of--the ve2sel.

The examination of the patches may be per-

. formed at or near the end of the inspection interval.

LICENSEE BASIS FOR REQUESTING RELIEF Category B-I-2 examinations were deleted from the ASME B&PV Code,Section XI, iri the 74576 Addenda.

Th~ integrity. of the cladding will be monit6~ed

• through the conduct of Category B-B and B-D examinations.

EVALUATION The licensee has" not demonstrated the Code requirement to be impractical for implementation at the facility. The Inservice Inspection Program for the facility is based upon the requirements of the 1974 Edition through Summer 1975 Addenda of Section XI of the ASME Code.

Deletion of the examination requirements from a later Addenda of the Code which has not been endorsed by the NRC is not an adequate justification for not performing the visual examination required. Therefore, the staff concludes that this request for re 1 i ef may not be granted.

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.. 2.2.2 Class 2 Ccmponents A.

Request relief from volumetric examination of inaccessible welds which are identified below:

ESS-24-SIS-SHl-201

-ESS-24-SIS-SHl-202, -203, -204 ESS-24-SIS-SH2-201 ESS-24-SIS-SH2-202, -203, -204 ESS-14-SCS-2Hl-209 ESS-8-CSS-SLA-224 ESS-8-CSS-SLB-224 ESS-6-SIS-lHP-21~

ESS-6-SIS-SHP-219 R~S-6-CWR-SL4-201 ESS-12-SIS-lLP-232 SFP-3-CPL-DLI-207 SFP-6-CPL-S~l-207 Code Requirement Volumetric examination shall cover 100 percent of the welds during a 40-year period.

Ba~is For Requesting Reli~f These welds are inaccessible for volumetric or surface examination because of ~ither being encased iri the steel plate missile shield or.in the contain~ent penetration structure. _

Evaluation.

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Volumetric or surface examination of these welds is restricted by not having access to the outside surface due.to the interference fran*steel plate or concrete. All welds identified above as beinq inaccessible shall be visually inspected for leakage by observing the general area after a four-hour hold at the pressure test requirenents as stated in IWC-5000.

This examination, and other volumetric inspections required by Section XI of similar systens,

• will provide assurance that no degradation has occurred and the

. piping pressure boundary will rena in structurally acceptable durinq the inspection interval. Therefore, relief may be granted.

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This rel 1ef, however, does not apply in the event paragraph IWC-2430 of Section XI is applicnble *

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Request relief fran volumetric examination of welds covered by pipe hanger strapping which are identified below:

ESS-14-CSS-lPB-210,* -211 ESS-lO-CSS-lPB-224, -225 ESS-14-CSS-lPC-213 ESS-14-SDC-LPD-213 Code Requirement Volumetric examination shall cover 100 percent of the welds during a 40-year period.

Basis For Requesting Relief The welds are covered by pipe hanger strapping and inaccessible for

• volumetric examination.

Evaluation The requirenent to volumetrically examine these welds once during a 40-year period is not considered impractical.

Therefore, these pipe hanger straps* must be renoved at sane point in the 40-year period and the w~lds be volumetrically examined.

On this basis, the requested relief 1s denied.

2.2.3 General - All Classes A.

Request to use 100 percent of the referen~e level as the evaluation crfterion for indications detected during ultrasonic examination of piping welds.

Code Reouirement Oltra~Jnic.ex~mination shall be conducted in accordance with the provisions of Appendix I.

Where Appendix I is not applicable, the provisions of Article 5 gf Section V shall apply.

Basis For Requesting Relief Evaluation of indications at 20% of th~ reference level increases the number of indications which*have to be evaluated by a very significant amount.

To evaluate and record the numerous indications would require examination personnel to stay longer periods of time in radiation areas.

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The 100% reference 1 evel.evaluation is judged sufficiently reliable for detection of defects warranting evaluation.

As an interim measure, relief *may be granted from the 20% reference level evaluation criterion provided the following are incorporated in the ultrasonic examination procedure:

l) All indications at or above 50% DAC shall be recorded.

2) All indicati9ns 100% DAC or greater shall be recorded and evaluated in accordance with the rules of Sectio-n xr. -------

3) Indications 20% DAC or greater which are interpreted by a Level 2 or Level 3 examiner to be a crack must be identified and evaluated to the rules of Section XI.

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Request relief fran the holding time requirement for system hydrostatic __

• and leak tests.

~IWA-5210)

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CODE REQUIREMENT The pressure-retai-ning ~omponents

• sha 11 be visually examined while the system is under the hydrostatic-test pressure and temperature.

The test pressure and temperature shall be maintained for at least four hours pr'ior to the performance of th~ examinations.

LICENSEE SASIS FOR REQUESTING RELIEF Application of four-hours holding time for hydrostatic an~ leak testing is..

not necessary for noninsulated systems.

IWA-5213,Section XI, 77W77 Edition requires no holding time for leak tests and a 10-minute holding time for

• hydro tests on noninsulated components. -

EVALUATION The four-hour holding time requir~d by the 1974-Ed1tion of Section XI during hydrostatic tests is intended for applicatio~ to sy~tems where the base material_and weld deposits are covered by insulation. The purpose of the holding time is to allow pressure boundar~ leakage.to become evident at the insulation s~rface. Where the base material and ~eld are visible, the intent of the nolding time i's meaningless and delet~on ~f this requirement will.not decrease the effectiveness o! the examinat~on.

The staff concludes that ~his request may be granted with the following conditions:

l) -When performing a system pressure test the entire system must be visible."directly. This includes the welds and all base materials.

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When the areas are exposed, the pressure and temperature required by the Code for the hydrostatic and leak test shall be maintained for a minimum time of ten (10) minutes and for such additional time as may be necessary to conduct the examinations. *

3) Following a repair, the repaired area must be accessible for a direct visual examination.

2.2.4 Pumps A.

Request relief from measurement of bearing temperature of the service water, charging, and concentrated boric acid pumps.

Code Requirement Bearing temperatures shall be measured during at least one inservice test each year.

Basis for.Requestin~ Relief The design of these pumps does not permit direct bearing temperature measurements.

Evaluation Th~ design of the concentrated boric acid pumps would permit indirect measurement of bearing temperatures by measuring the surface. contact temperatures of the bearing housings which the lic~nsee has com~itted to do.

Since there are no installed oil coolers, these me2sure~ents are considered to be closely related. to oil temperatures which are, in turn, correlative to bearing temperatures.

Th~*design of the charging pumps does not permit accurate ~~asurernent of the bearing housings because of oil coolers installed for these pumps.

The service water pumps are submerged in water and not accessible for any measurements.*

The licensee has*corrmitted to vibration amplitude measurements on a monthly basis.

Because of the frequency of measurement of this parameter and the Code requirement to compare this parameter to reference values, we have determined that the vibration amplitude measurement is a suitable indicator of bearing degradation and bearing degradation will !;le detected sooner by vibration amplitude measurements taken monthly than by yearly bearing temperature measurements.

On this basis, relief from measurement of bearinq temperature may be granted.

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B. Request relief ~r001 measuring the* suction pressure of pumps listed below:

As ME Pi.il'.P CLASS P7A, 8, c, Service h'a ter Pumps 3

PE.Cl., B, Auxil icry Feedwater Pumps 3

p:,2A, B, c, Co:-:ponent Cooling Pumps 3

P54, A, B, C,.Containment Spray Pumps -

2 P::SA~ B *' C,. Charging Pumps 2

p:,f,.~, B, Boric.l.:-i d--?umps----*- --*

2 P66A, B; c, HP Safety Injection Pumps -

2 P67A, B, LP. Safety Injection Pumps r--

2 Code Reouire~ent Measure inlet pressure monthly.

Basis For Reouesting Relief There is no instrumentation for measuring this parameter.

Evaluation Although a direct measurement of suction pressure is not being performed, the licensee has included in his program a me~ns to. detect changes in inlet pressure

• This will be accomplished by taking the difference between each ~ump suction and its a~sociated expansion tank pressure and calculating inlet pressure.

The differential pressure will be calculated by taking this pressure calculation and the difference from the dischc.rge pressure.

It is the staff's. position that this technique will detect any changes associated with pump suctions which is the intent of the requirenents stated in ASME Section XI.

On this basis, the relief from measurenent of inlet pressure may be granted.

C.

Request relief fr001 examination requirenents of ASME Section XI for the following items designated to be inspected in Section XI.

Code Item E2.5, 82.6, 82.7 S3. Li, ::.:. 5'

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51;. 2, St;. 3, b~. 4 BS. 6

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e:5 is ;c.r ;::~=-~:t ~ 1:::: Eel ief Component Pressurizer Bolting St~am Generator Bolting Piping Bolting Valve Seam \\..'elds Valve Bolting IL2re are nci "i.::'iis in the facility which fall into these categories.

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'* Evaluation There are no such itens in the facility. Therefore, relief is not required.

2.2.5 Summary - Inservice Inspection and Pump Testing 3.0 4.0 The licensee has sutxnitted infonnation to support his determinations that certain ASME Section XI Code (1974 Edition through Surroner 1975) require-men'!:s are impractical to implenent at the Palisade_s Plant.

We have evaluated the licensee's bases for his detenninations and find that relief from specific Code requirements requested may be granted* for the reasons given in the evaluation.

Based on the foregoing, we find that the relief requested is authorized by law, will not endanger life or property or the common defense and security and is in the public interest considering the burden on the licensee that could result if the relief were not granted.

We conclude that the revised Inservice Inspection and Pump Testing Program meets the requirements of 10 CFR 50.55a(g).

ENVIRONMENTAL CONS.IDERATION We have determined that this amendment and granting of the relief do not authorize a change in effluent types or _total amounts nor an increase in power level and *will not result in an,Y significant environmental impact.

Having made this determination, we have

_ further concluded that the amendment and relief involve actions which are insignificant from the standpoint of environmental impact and, pursuant to 10 CFR ~51.5(d)(4), that an environmental impact statenent, or negative declaration and environmental impact appraisal need not be prepared in connection with the issuance of these actions.

CONCLUSION We have concluded, based-on the considerations discussed above, that:

(1) because the amendment does not involve a significant increase in the probability or consequences of accidents previously considered and does not involve a significant decrease in a safety margin, the amendment does not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the publ1c will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in ~ompliance with the Commission's regulations and the* issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the i:x.i bl ic.

Date: October 15, 1979

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