ML18046A151

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Forwards Updated Inservice Insp Program to 1977 Edition of Section Xi,Asme Code W/Addenda Through Summer 1978. Includes Info Confirming Adequacy of Current Tech Specs & Addenda to Relief Request Statements Re Code Applicability
ML18046A151
Person / Time
Site: Palisades Entergy icon.png
Issue date: 11/12/1980
From: Hoffman D
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To: Crutchfield D
Office of Nuclear Reactor Regulation
References
NUDOCS 8011180411
Download: ML18046A151 (21)
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I consumers Power company General Offices: 212 West Michigan Avenue, Jackson, Michigan 49201 * (517) 788-0650

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November 12, 1980 Director, Nuclear Reactor Regulation Att Mr Dennis M Crutchfield, Chief Operating Reactors Branch No 5 US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - INSERVICE INSPECTION PROGRAM UPDATE SECTION XI, 77S78 ADDENDA The attached documents constitute the update Inservice Inspection Program for the Palisades Plant to the 1977 Edition of Section XI, ASME Code with Addenda through Summer 1978.

- Attachment 1 provides the update of the Inservice Inspection Program for the Palisades Plant as allowed by 10 CFR Part 50.

- Attachment 2 explains that the present Palisades Plant Technical Speci-fications are adequate and no changes are necessary relative to the requirements of 10 CFR 50.55a(g)(5)(ii).

Attachment 3 provides requests relief from the provisions of the 1974 ASME B&PV Code Section XI with Addenda through Summer 1975 and 1977 Edition with Addenda through 1978. It should be noted that 5 of the 7 relief requests were previously reviewed and approved by NRG letter dated October 15, 1979 and need not be reviewed; the 5 previous requests are included for the purpose of completeness. The new relief requests are identified by a bar in the right-hand margin.

- Attachment 4 is the Addenda to relief requests basis statements con-cerning Consumers Power Company's code applicability statements.

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- Attachment 5 provides the intervals for the ISI Program for the .s Palisades Plant.

Since the updated ISI Program and our Technical Specifications are in agree-1l'fo ment, this basic program can and will be implemented without prior NRG oc1180-0099a-42

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Palisades Plant November 12, 1980 Director, Nuclear Reactor Regulation 2 approval. Your approval is only required for the relief requ_ests (Attach-ment 3) and the code cases (Attachment 4) to be utilized.

David P Hoffman Nuclear Licensing Administrator CC Director, Region III, USNRC NRC Resident Inspector-Palisades Attachments 1, 2, 3, 4, 5 ocl180-009 9 a-42

. I ATTACHMENT 1 .

INSERVICE INSPECTION PROGRAM UPDATE - CODE USE.

APPLICABLE EDITIONS & ADDENDA OF ASME BOILER & PRESSURE VESSEL CODE SECTION XI Pursuant to Paragraph .50.55a(g) of 10 CFR Part 50, the in-service examination requirements applicable to nondestructive examination and system pressure testing at the Consumers Power Company, Palisades Plant, are based upon the rules set forth in the 1977 Edition of Section XI of the ASME Boiler and Pressure Vessel Code, including Addenda through Summer, 1978.

As required by 10 CFR 50.55a(b)(2)(iv)(A), Consumers Power Company will

.examine the Class 2 portions of the Residual Heat Removal, Emergency Core Cooling, and Containment Heat Removal Systems with the extent of Examination determined in accordance with IWC-1220, IWC-2411, and Table IWC-2520 (Category C-F and C-G) from the 1974 Edition of Section XI with Addenda through Summer 1975. The Examination Requirements, Examination Method, and Acceptance Standards for the Residual Heat Removal, ECCS, and Containment Heat Removal Systems shall be determined by the 1977 Edition of Section XI with Addenda through Summer, 1978.

As pennitted by 10 CFR 50.55a(b)(2)(ii) and 10 CFR 50.55a(b)(2)(iv)(B),

Consumers Power Comapny elects to determine the Extent of Examination (i.e. selection of welds for examination) by the requirements of Table IWB-2500 and Table IWB-2600 (Category B-J) for Class 1 piping and IWC-1220, IWC-2lill, and Table IWC-2520 (Category C-F and C-G) for Class 2 piping from the 1974 Edition of Section XI with Addenda through Summer 1975.

Consumers Power Company elects, per 10 CFR 50.55a(g)(4)(iv), to adopt Subsection IWF, requirements for Classes 1, 2 and 3 Component Supports included in the Winter, 1978 Addenda to the 1977 Edition of the Section XI ASME Code. This Subsection IWF provides improved inspection guidance not contained in the earlier code Edition and Addenda issues.

In order to permit. effective implementation of the commitment to sub-section IWF, the Winter, 1978 Addenda to the Section XI ASME Code modified certain other portions of the 1977 Code with Addenda thru Summer 1978. These changes are described in Table I and these changes will be implemented for inspections.

,, n, TABLE I Winter 1978 Requirements Which Supercede Summer 1978 Requirements to Permit the

  • Application of Subsection IWF IWA-llOO{a), to include Footnote #7 Scope IWA-1300 Components Subject to Inspection IWA-2110(h) Definition of a Component IWA-2120(c) Duties of the Inspector IWA-2200 Examination Methods IWA-2400(e) Inspection Intervals for Component Supports IWA- 3100 ( a) Evaluation IWA-4110 R.epair Procedures Scope IWA-7530 Replacements Pressure Inspection IWB-1100 Scope IWB-1210 Examination Requirements Tahle IWB-2500-1 Integral Attachments for Vessels Examination Category B-H Table TIIB-2500-1 Integral Attachments for Piping, Pumps Examination Category B-K-1 Pumps and Valves Table IWB-2500-1 Component Supports for Piping, Pump Examination Category B-K-2 and Valves
  • Figure IWB-2500-13 Integral Attachment Weld Figure IWB-2500-14 Support Circumferential Weld Joint Figure IWB-2500-15 Integral Attachment Table IWB-3410-1 Acceptance Standard IWB-3516 Standards for examination.Categories B-H Integral Attachments for-Vessels and B-K-1,. Integral Attachments for Piping Valves and Pumps IWB-3522. Standard for Examination Category B-K-2, Support Components for Piping, Valves and Preps IWC-1100 Scope IWC-1210 Examination Requirements IWC-1220(c) Components Exempt for Ex::miination Table IWC-2500-1 Integral Attachments for Vessel, Piping, Examination Categories Pump::> and Valves C-C and C-E

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2 Figure IWC-2520-5 Integrally Welded Attachments IWD-1100 Scope IWD-121.0 Examination Requirements Table IWD-2500-1 Test and Examination Categories

ATTACHMENT 2 STATEMENT OF CONTINUED ADEQUACY PALISADES PLANT TECHNICAL SPECIFICATIONS INSERVICE INSPECTION PROGRAM The Palisades Nuclear Plant Technical Specifications (Sections 4.3, 4.4, 4.12 and 4.16) have been reviewed with respect to the Inservice Inspection Program Update. The Technical Specifications are adequate relative_ to the Updated Inservice Inspection program and no change in Technical Specifications is deemed necessary relative to the requirements of 10CFR50, paragraph 55a(g)(5)(ii).

  • ATTACHMENT 3 REQUESTS FOR RELIEF FROM THE PROVISIONS OF SECTION XI

The following table delineates those areas of the 1974 AS:ME B&PV Code Section XI with Addenda through Summer 1975 and 1977 Edition with Addenda through Summer 1978 which cannot be implemented at the Palisades Nuclear Plant.

The areas requiring relief are identified by the Item numbers listed in Table IWB-2500-1 and IWC-2500-1 of the Summer 1978 Addenda.

The notes following the table provide information concerning the basis for each relief request and concerning the implementation of the reference code.

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RELIEF REQUEST PALISADES NUCLEAR PLANT Area of Sect XI Safety Relief Cate son: Comeonent Function Class Relief Reguested Testing Substituted I~lementation Bl.21 B- A Vessel Closure Head Primary Pressure 1 Inaccessible for a. Vessel Hydros a.b. Tech Specs Boundary Volumetric Exam b. Vessel Coupons c. 40*Year Plan

c. Bl.10,Bl.20 Bl.30,Bl.40 testing Bl.21 B- A Vessel Bottom Head Primary Pressure 1 Meridional & Circum a. Vessel Hydros a.b. Tech Specs Bl.22 Boundary Seam Welds Generally Inaccessible for Volumetric Exam b.

c.

Vessel Coupons Bl.10,Bl.20,

c. 40-Year Plan 9,

Bl.30,Bl.40 testing B5.10 B-F v*essel Safe Primary Pressure 1 Not a Dissimile.r Welds Covered ns 11()-'fcnr Plnn End Welds Boundary Metal Weld B9.ll B-J B5.30 B-F Steam Generator *Primary Pressure l Not a Dissimilar Welds Covered as 40-Year Plan Safe End Welds Boundary Metal Weld B9.ll B-J B7.10 B-G-2 CRDM Bolting Primary Pressure l Nonperipheral CRDM a. Vessel Hydros a. Tech Specs Boundary Bolting Inaccessible b. Bl.ll Testing b. 40-Year Plan

  • for VT-1 B9.11 B-J PCS-42-RCL-1Hl-2LD, Primary Pressure l Inaccessible for UT a. Hydros a. Tech Specs B9.12 3LU, 3, 3LD Boundary b. Remaining B-J b. 40-Year Plan PCS-42-RCL-2Hl-2LD, .Welds in System 3LU, 3, 3LD B9.11 B-J PCS-42-RCL-111-1,2 Primary Pressure l Inaccessible for a. Hydro a. Tech Specs B9.12 PCS-42-RCL-211-1,2 Boundary surface Exam b. Remaining B-J bt.c 40-Year Plan PCS-30-RCL-lA-15, 15LD-l, 15LD-2, 16LU-l 16LU-2, 16 c.

Welds 100% UT of pipe thickness

'pcs-30-RCL-2A-14

  • on remainder. of System.

C5.ll C-F ESS-24-SIS-SH2-201 Pressure Boundary 2 Inaccessible for UT a. Hydro a.b. 40-Year Plan 202, 203, 204 b. C5.10, C5.~0 testing on remainder of System.

Area-of Sect XI Safety Relief Category Component Function Class Relief Requested Testing Substituted Implementa"tion B5.20 B-F Piping Welds Primary Pressure 1 *utilization of Hole Type None-Examinations 40-Year Plan B5.40 Boundary UT reflectors for thick Performed as B5.50 piping. scheduled B9.ll B-J Piping Welds Primary Pressure 1 Utilization of Hole Type None-Examinions 40-Year Plk B9.12 Boundary UT reflectors for thick Performed as piping. scheduled c5.21 C-F Piping Welds Pressure Boundary 2 Utilization of Hold Type None-Examinations liO-Year Plan C5.22 UT renectors for thick Performed as piping. scheduled

Notes on Relief Requests RR-1 Item Bl.21, Bl.22 (Long, Cir and Meridional Welds in Rx Vessel Heads)

BASIS STATEMENT The dollar plates weld in the closure head is inaccessible for volumetric examination due to control rod guide tube constraints.

Meridional welds in the closure head are partially accessible for volumetric examination.

An attempt will be made to volumetrically inspect the meridional and* circumferential seam welds in the bottom head during the next refueling outage in which mechanized inspection is performed on the Rx vessel.

REMARKS See CE Dwg E-232-139-1.

IMPLEMENTATION & RELIEF REQUESTED Meridional welds in the bottom heads and.circumferential welds in the bottom head may be accessible for volumetric examinations. The dollar plate weld in the closure head is ex~!'.IlPt .-fro!Il;1volumetric examination and shall be visually examined during the system.pressure test.

RR-2 Item B5.10, B7.10 (Nozzle to Safe End Welds)

BASIS STATEMENT 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 nozzle to safe end welds are .therefore classed as B9.ll, B-J welds rather than B5.10 or B7.10, B-F welds.

REMARKS See CE Dwg E-232-119-11.

IMPLEMENTATION & RELIEF REQUESTED These welds should be included and inspected to Category B-J requirements with the rest~iction that the inspection be expanded to include 100% of each weld during each inspection interval.

However, this examination could be included in the 25% examination requirements of Category B-J welds.

RR-3 Item B5.30 (Pressure Retaining Bolting}

BASIS STATEMENT Nonperipheral CRDM bolting is not accessible for VT-1 examination.

RR-3 (Cont'd)

REFERENCE CE Dwg 2966-SE-2554 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 bolting is not accessible for VT examination.

IMPLEMENTATION & RELIEF REQUESTED Peripheral CRDM pressure retaining bolting will be VT-1 examined.

However, if the inner CRDM assemblies are disassembled or the bolting removed, visual examination as required by the code shall be performed.

RR-4 Item B9.ll, B9.12 (Pressure Retaining Piping)

BASIS STATEMENT Piping welds adjacent to the reactor vessel and buried in the cement reactor vessel are inaccessible for OD examinations. The surface examination cannot be performed. The volumetric examination of these welds can be performed from the ID using a mechanized device.

REMARKS Welds subject to this relief request are:

PCS-42-RCL-lH-l, 2 PCS-42-RCL-2H-l, 2 PCS-30-RCL-lA-15, 15LD-l, 15LD-2, 16LU-l, 16LU-2, 16 PCS-30-RCL-lB-13, 13LD-l, 13LD-3, 14LU-l, 14LU-2, 14 PCS-30-RCL-2A-14, 14LD-l, 14LD-2, 15LU-l, 15LU-2, 15 PCS-30-RCL-2B-14, 14LD-l, 14LD-2, 15LU-l, 15LU-2, 15 IMPLEMENTATION & RELIEF REQUEST All welds identified above shall be examined from the ID volumetrically.

The weld will be 100% examined (in lieu of the bottom 1/3 required by Section XI, 77S78, Figure* IWB-2500-8). The surfac.e exam will not be performed due to inaccessibility.

RR-5 Items B5.20, B5.40, B5.50, B9.ll, B9.12, B9.31, C5.21, C5.22 (Pressure Retaining Piping - Volumetric Examination).

RR-5 (Cont'd)

BASIS.STATEMENT ASME B&PV Code,Section XI 1977 Edition with addenda thorugh Summer 1978, paragraph IWA-2232(b) requires the utilization of Appendix III,Section XI for ultrasonic examinations of piping. Appendix III, paragraph III-llOO(d) permits the utilization of alternative exam-ination techniques and calibration block design in accordance with IWA-2240 (Alternative Examinations). c'onsumers Power Company elects to utilize hole type reflectors. in lieu of notch type reflectors required by paragraph III-3430 for ultrasonic examinations performed on piping thicker than 0.400". In order to effect the change in reflector type,* consumers Power Company elects, per IWA-2232, to conduct ultrasonic examinations of piping welds in accordance with Article 5,Section V, ASME Codes. The requirements of Article 5, Section will be modified by the attached code applicability statements.

DISCUSSION

  • Utilization of hole type reflectors for material thicker than 0.400" in lieu of notch type reflectors will increase the sensitivity of the examination by a factor of two (2) over the standard 45° angle beam examination. Consumers Power Company will implement the two

.code applicability statement attached in order to affect this change in reflectors. The code applicability statements will enhance procedure and calibration control, and. control of calibration block procurement/fabrication.

IMPLEMENTATION & RELIEF REQUESTS It is requested that relief be granted from the provisions of IWA-2232 with respect to calibration block design and calibration procedures and that the provisions of the two (2) codes applicability statements be substituted in lieu thereof.

RR-6 Item B9.ll, B9.12 (Pressure Retaining Piping)

BASIS STATEMENT Welds PCS-42-RCL-1Hl-2LD, 3LU, 3, 3LD and PCS-42-RCL-2Hl-2LD, 3LU, 3, 3LD are located inside the cement reactor shield and are inaccessible for UT.

REMARKS The area between the last known weld (at the elbow entrance to the steam generator) and the reactor shield was visually examined; no welds were apparent in this region. Therefore, it is concluded that the welds are buried inside the reactor shield.

The application of IWB-2430 at the Palisades Plant for the above listed welds will be as follows:

RR-6 (Cont'd)

The application of IWB-2430 will be in accordance with the information submitted in CPCo letter to D 1 Ziemann, dated March 6, 1979, Attachment 2, Supplemental Information on Code Update and Code Implementation. It should be noted that the application of IWB-2430 at the Palisades Plant is a two-step process; ie, the first application of IWB-2430 generally adds the same number' of welds (same Section XI Item Number) on the component/line of interest as was originally scheduled. The second application of IWB~2430 (required by the detection of a defect in the examinations added pursuant to finding the original defect) results in the remainder of the line/component(with the same Section XI Item Number) being examined.

CPCo will implement IWB-2430 on these inaccessible welds only after the first set.of additional examinations has revealed defects.

IMPLEMENTATION & RELIEF REQUESTED The welds identified above shall be visually inspected by observing the general area after a four-hour hold at the pressure test requirements stated in Section VI, IWA/IWB-5000. This exemption does not apply in the event that Paragraph IWB-2430 of Section XI is applicable.

RR-7 Item C5.ll (Pressure Retaining Piping)

BASIS STATEMENT Welds encased in steel plate missile shield; welds inaccessible for NDT examination.

REMARKS Basis statement applicable to the following welds:

ESS-24-SIS-SHl-201, 202, 203, 204 ESS-24-SIS-SH2-201, 202, 203, 204 The application of IWC-2430 at the Palisades Plant for the above listed welds will be as follows:

The application of IWC-2430 will be in accordance with the information submitted in CPCo letter to D 1 Ziemann, dated March 6, 1979, Attachment 2, Supplemental Information on Code Update*and Code Implementation. It should be noted that the application of IWC-2430 at the Palisades Plant is a two-step process; ie, the first application of IWC-2430 generally adds.the same number of welds (same Section XI Item Number) on the component/line of interest as was originally scheduled. The second application of IWC-2430 (required by the detection of a defect in the examinations added p~suant to finding the original defect) results in the remainder of the line/component (with the same Section XI Item Number) being examined.

  • RR-7 (Cont'd)

CPCo will implement IWC-2430 on these inaccessible welds only after the

  • fir.st set of additional examinations has revealed defects.

IMPLEMENTATION & RELIEF REQUESTED All welds identified shall be examined visually for evidence of leakage by observing the general area after the four-hour hold at the pressure test requirements as stated in IWC-5000. This exemption does not apply in the event that Paragraph IWC-2430 of Section XI is applicable.

Addenda to Relief Requests. Basis Statements Concerning CPCo Code Applicability Statements

  • A.\

CODE USE FOR 3rd PERIOD 1st INSERVICE INSPECTION INTERVAL Co~sumers Power Company Code Applicability Statement No. 1

Subject:

Piping Examination I: The basic requirements for Ultrasonic Examination of piping shall be in accordance with the following:

Type of Material Nominal Thickness Applicable Code .

Austenitic and Fer- Greater than .4 to 6 Article 5 of ASME Section ritic piping and in. V with addenda through dissimilar metal Summer 1978 welds Austenitic and .i to .4 in. Appendix III with Supplement Ferritic piping and 7 of ASME Section XI with dissimilar metal addenda through Summer 1978 welds II. The following modifications.of the requirements of Article 5 Section V, and Appendix III,Section XI, 77S78 addenda are applicable.

A. The following code cases shall be utilized.

1) Code Case N-211 Recalibration of Ultrasonic Equipment upon Change of Personnel
2) Code Case N-234 Time Between Ultrasonic Calibration ChecksSection XI Division 1
3) Code Case N-235 Ultrasonic Calibration Checks per Section V,Section XI, Division 1 B. For examinations conducted in accordance with Article 5 of ASME Section V, the basic calibration block for production material thickness 1.0" or less shall be as follows: The basic calibration block shall have the same nominal thickness as the production material or no more than 25% less than the nominal production material thickness or closer in thickness to the production material than the 3/4-inch alternate thickness allowed by Article 5. This modification will assure a more accurate calibration than the basic calibration block design allowed by the code.

C. Subparagraph T-535.l(d) (1) and (2) of Article 5 requires that transfer (attenuation compensation) be accomplished between the production material and the basi.c calibration block and a correction niade for the difference.

In accordance with Code Interpretation V-78-01 and Code Case 1698 (N-92),

the transfer method will not be used. Attenuation measurements will be recorded and considered during analysis and evaluation of indications, however no attempt will be made by the examiner to compensate for any observed difference before or du~ing the Ultrasonic Examination.

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  • J II-D For examination conducted on welds, the following requirements from Appendix III,Section XI 77S78 shall be used in lieu of paragraph T-530,Section V, 77S78.

III~2300 Written Procedure Req~irements III-2400 General Examination Requirements III-3100 Instrument Calibration (to include Suppl. 5&6)

III-3210 System Calibration - General Requirements III-3300 Calibration Confirmation III-3500 Calibration Data Record III-4000 Examination II-E Data shall be recorded as per IWA-2232 (b)

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CODE USE FOR 3rd PERIOD 1st INSERVICE INSPECTION INTERVAL Consumers Power Company Code Applicability Statement No 2

Subject:

UT Piping Calibration Blocks I. All new piping ultrasonic calibration blocks will be procured, designed, and fabricated as follows.

A. Material Basic Calibration block material shall conform to the requirements of Paragraph III-3411,Section XI.

B. Radius of Curvature Basic calibration blocks shall conform to the radius of curvature required by paragraph III-3410,Section XI.

C. Thickness Basic Calibration blocks shall conform to the requirements of Paragraph III-3410.

D. Calibration Reflectors

1. Thickness: .10" to .40" Calibration reflectors shall, conform to the requirements of III-3430,Section XI.
2. Thickness: Greater than .4" to 6" Calibration reflectors shall be holes and shall conform to the requirements of Paragraph T-533 (a), Article 5,Section V, 77578 ASME B&PV Code.

ATTACHMENT 4

'CONSUMERS 'POWER *coMPANY

.-InserYice .Inspection Code Case Utilization Consumers Power Company elects per 10 CFR 50.55a(a)(2)(ii) and Footnote 6 to 10 CFR 50.. 55a to utilize the followi_ng ASME Code Cases as an integral part of the Inservice Inspection Programs for the Palisades Nuclear Power Plant.

CODE CASE N-98 Ultrasonic Examination - Calibration Block Tolerance CODE CASE N-211 Recalibration of Ultrasonic Equipment Upon ehange of Personnel CODE CASE N-234 Time Between Ultrasoni~ Calibration Checks CODE CASE N-235 Ultrasonic Calibration Checks per Section V CODE CASE N-278 Alternative Ultrasonic Calibration Block Configuration

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  • ATTACHMENT 5 PALISADES N.UCLEAR PLANT Interim Response Inservice Inspection Program Update The Palisades Plant Technical Specifications along with 10 CFR 50.55a(g)(4) allows periodic reviews/updates in the Inservice Inspection Programs for Power Reactors. The regulation currently allows the use of the 1974 edition with addenda through the summer of 1975. However, 10 CFR 50.55a(g)(4)(iv) allows for the use of subsequent editions of addenda referenced by 10 CFR 50.SS(b) and the approval by the Commission. Therefore, we are updating to the AS~1E Boiler and Pressure Code Section XI to the 1977 edition with addenda through the summer 1978 ..

The following information is submitted concerning the Palisades Plant ISI intervals:

1. Date of Commercial. Operation: December 31, 1971
2. End of First Inservice Inspection Period: October 31, 1976*
3. End of Second Inservice Inspection Period: February 29, 1980 (Scheduled)
4. Actual End Date of Second ISI Period: May 27, 1980
5. End of First ISI 10-Year Interval: June 30, 1983* (Scheduled)
6. Projected End of First ISI 10-Year Interval: September 30, 1983*"*
i. Projected Beginning of Second ISI 10-Year Interval: October 1, 1983
  • First ISI period extended by adding 18 months cumulative shutdown time between August 1973 and April 1975. Extension of 18 months within the ISI period also extended the ISI interval as permitted by Paragraph IS-241,Section XI, 1971 edition.
    • The second ISI period encompasses 9 months cumulative shutdown time between September 1979 and May 1980. The second ISI period was extended 3 months due to an extended outage as permitted by IWA-2400(c),Section XI, 77S78 Addenda. The third ISI period (from ~1ay 1980 to September 1983) is 40 months in duration.
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