ML18046B310
| ML18046B310 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/22/1982 |
| From: | Wambach T Office of Nuclear Reactor Regulation |
| To: | Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| TASK-03-03.C, TASK-3-3.C, TASK-RR LSO5-82-02-092, LSO5-82-2-92, NUDOCS 8203010344 | |
| Download: ML18046B310 (12) | |
Text
(
.(
'UNITED STATES.
NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 Docket No. 50-255 LS05 02-092 Mr., David J. VandeWa1le Nuclear Licensing Administrator Consumers Power Company 1945 W. Parnal l Road Jackson, Michigan 49201
Dear Mr. VandeWalle:
February 22, 1 982
SUBJECT:
PALISADES - SEP TOPIC III-3.C, INSERVICE' INSPECTION OF WATER CONTROL STRUCTURES Consumers Power Company letter (R.A. Vincent to D.M. Crutchfield) dated December 21, 1981, transmitted for our review you safety assessment re-port (SAR) on SEP Topic III-3.C, 11 Inservice Inspection of Water Control Structures 11 *. Enclosed is our evaluation of thfs topic.
Our conclusion
~egarding this topic assessment is briefly summarized below:
- 1)
Consumers Power Company has.identified appropriate cooling water system structures that requfre inspection in accordance with the regulatory positions of Regulatory Guide 1.127.
However; the licen-see has not identified any flood control structures covered by Reg-ulatory Guide 1.127..
It is the staff 1s position that the submarine-type fl oodproof doors and bulkheads that protect the pl ant from the effects of a probable maximum surge are water control structures that requ~re inspection in accordance with Regulatory Gui~e 1.127.
- 2). At present~ the licensee does not have a formal insp,ection program
- for water-control structures. Although occasional inspections of the 1ntake crib, the pipeline, and the concrete intake structure have been performed by the licensee, no formal technical reports ap"'."
pear to have been written to document the results of these inspec~
tions, as recommended by Regulatory Guide 1.127.
Therefore, the licensee should. develop a formal in~pection program to be accomp-lished by or under the supervision of qu~lified engineers.
In thi~
connection, a checklist should fie developed for each structure.
The inspection schedule should be based upon the type and present:
condition of the structures, the potential for distress, anc!: their maintenance needs.
A technical report should be prepared to present the resu)ts of each general*inspection.
_A
,III. ~)
Sl:-""1 Ff.dA.
- Jv
.. ' :s 1/1 t;j.J.
8203010344 820222 PDR ADOCK 05000255 G
PDR SEPB
!(yf)./.1 SEP
\\
OFFICE~.............. \\..(.,.,...................... ****
suRNAME ~ Rf.~JJ..~P..1.......... ~.~~r.in~rrn.....
DATE... U!l..!.§.?........ ;.... ?.t.111.§.?.......
~
I NRC FORM 318 (10*80) NRCM 0240 fj1d. 6~~~,,{~)
OFFICIAL RECORD COPY o '~ o
- O* o o' o 'I'*",*, 0 o *D
- .~.....
USGPO: 1981-335-960.
(
(
2 -
- 3)
The licensee should perfor~ special inspections immediately after the occurrence of ~ignif1cant unusual events {such as earthquake, flooding, ice, etc~) and prepare technical reports to present the
. res<s of such inspections.
In light of the above variance with accepted practice, Consumers Power Company should inform NRC within 30 days of the actions.they will take to incorporate our recommendations.
Enclosure:
As stated cc w/erwl osure:
See next page
- ..... *.1 L_ -~ ~
~.~l:O:SE\\it::z:l Sincerely, Thomas V. Wambach, Project Manager Operating Reactors Branch No. 5 Division of Licensing
-*~ - I I
- \\"-:-:.*
Mr. David J. VandeWalle cc M.* I. Miller, Esquire Isham, Lincoln & Beale Suite 4200
- One First National Plaza Chicago, Illinois 60670 e*.
Mr. Paul A. Perry, Secretary Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire
. Consumers Power Company
.212 West Mich~gan Avenue Jackson, Mi~higan
~9201 Myron M. Cherry, Esquire Suite 4501 One IBM Plaza Chicago, Illinois 60611 Ms*~ Mary P. Sinclair Great Lakes Energy Alliance 5711 Summerset Drive Mtdland, Michigan 48640
- alamazoo Public Library 315 South Rose Street Kalama'zoo, Michigan 49006 Township Supervisor I
Covert Townshi Route 1, Box 10 Van Buren County,. Michigan 49043.
Office of the Governor (2)
Room l - Capitol Building Lansing, Michjgan 48913 William J. Scanlon, Esquire 2034 Pauline Boulevard Ann Arbor, Michigan 48103 Palisades* Pl ant ATTN:
Mr. Robert Montross Pl ant Manager*
Covert, Michig~n 49043 U. s: Environmental Protection Agency Federal Activities Branch Region V Office ATTN:
Regional Radiation Representative 230 South Dearborn Street Chicago, Illinois 60604 Charles.Bechhoefer, Esq., Chairman Atomic Safety and Licensing Board.
Panel
- U. s. Nuclear Regulatory Commission Washington, D. c.
20555 Dr. George C. Anderson Department of Oceanography University of Washington.
Se_attl e, Washington 981.95 Dr. M. Stanley Livingston 1005 Calle Largo Santa Fe; New Mexico 87501 Resident Inspector c/o U. S. NRC Palisades Plant Route 2, P. 6. Box 155 Covert, Michigan 49043 James G. Keppier, Regional Administrator Nuclear Regulatory Commission, Region Ill Office of Inspection and Enforcement 799 Roosevelt Road.
Glen Ellyn, Illinois 60137
I.
INTRODUCTION Systematic Evaluation Program Topic Assessment Topic:
III-3.C - Inservice Inspection of Water Control Structures Plant* Name:
Palisades Nuclear Plant Docket Number:
50-255 The purpose of this report is to evaluate the assumptions, conclusions, and completeness of documentati?n in the assessment report suM!itted to NRC by Consumers Power Comapny (CPCo), for Systematic Evaluation Program (SEP)
Topic III-3.C (Inservice Inspection of Water Control Structures) for the Palisades Nuclear Power Statiori.
The SEP was established to evaluate the safety of 11 of*the older nuclear power plants.
An important element of the evaluation is to judge the plants by current licensing criteria with respect to 137 selected topics, several o_f which relate to hydrologic assessments of the site.
In January, 1981 the NRC agreed to the SEP Owners Group's proposed re-directio~ of the SEP whereby eac~ licensee would select any 60% of the SEP topics and submit evaluati-ons of. these topics for review by the NRC staff.
Evaluations of topics not selected by a licensee were the NRC's responsibility.
One of the topics *so selected by the licensee is Topic III-3.C for which it submitted its assessment report on December 21, 1981 (ref. l). The adequacy of the licensee's assessment of Topic III-3.C is reviewed in this report.
II.
REVIEW CRITERIA The applicable rules and basic acceptance criteria pertinent to the review of this topic are:
e**
..,/ 1.
10 CFR Part SO, Appendix A (a) General Design-Criterion 11Quality Standards and Records.
11 This c*ri teri on requires that structure~, systems, and components important to
. safety shall be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions to be performed. It also requires that appropriate records of the design; fabrication, erection, and testing of structures, systems and components important to safety shall be maintained by or under the control of the nuclear power plant licensee through-out the life of the plant.
{b) General Design Cri'terion 2 - "Design Bases for Protection ~gainst Natura 1 Phenomena.
11 This criterion re qui res that safety-related portfons of the system shall be designed to withstand the effects of earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety functions.
(c) Gen~ral Design Criterion 44 -
11 Cooling Water.
11
- This criterion requires. that a syst6'll shall be provided with the safety function of trans-.
ferring the combined heat load from structures, systems, and components important to safety to an ultimate heat sink under nonnal operating and accidental conditions.
- 2.
1 O CFR Part 100, Appendix A, 11Seismic* and Geologic Siting Criteria for Nuclear Power Plants" These criteria describe the nature of the investigation required to obtain the geologic and seismic data necessary to determine site suitability and identify geologic and seismic factors required to be taken into account in the sitin~ and design of nuclear power plants.
r'
-.3 -
- 3.
- Regulatory Guides The following Regulatory Guides provide infonnation, recommendations, and guidance and in general describe a basis acceptable to the staff that may be used ~o implement the requirements of the above described criteria.
(a) Regulatory Guide 1.127, "Inspection of Water-Control Structures Associated with Nuclear Power Plants 11 (ref. 2). This guide describes procedures for developing an appropriate inservice inspection and survei1lance program for dams, slopes, canals, and other water-control structures associated with emergency cooling water systems or flood protection of nuclear power plants in complying with 10 CFR, Part 50.
(b) Regulatory Guide 1.132, 11Site Investigations for Foundat:ions of Nuclear Power Plants 11 (ref. 3). This guide describes programs of site investi-gations related to geotechnical engineering aspects that would nonnally meet the needs for evaluating the safety of the site from the standpoint of the perfonnance of foundation and earthworks under anticipated loading conditions includi~g earthquakes in complyi~g with 10 CFR, Part 100,. Appendix A.
It provides general guidance and recommendations for developing site-specific investigation*
progr?ms as well as specific guidance for conducting subsurface investigations, the spacing and d~pth *of borings, and sampling.
III.
RELATED SAFETY TOPICS AND INTERFACES The settlement of structures and buried equillllent are reviewed under
~'
Topic II-4.F.
Other interface topics include II-4.E, "Dam-Integrity; II-3.C, 11 Safety-Related Water Supply (Ultimate Heat Sink);" III-6, "Seismic Design~
Considerations"; XVI, "Technical Specifications"; III-3.A, "Effects _of*High Water Level on Structures"; and IX-3, 11 Station*service and Cooling Water Systems".
e*.
- '4 -
IV.
REVIEW GUIDELINES In general, the method* for complying with specific requirements of the rules and regulatory positions described in Regulatory Guide 1.127 is used in
- evaluating inservice inspection programs for water-control structures. Pertinent elements of the licensee's program are evaluated and compared to current safety criteria and the significance of any differences is evaluated.
V. *TOPIC EVAL.UATION Safety-Related Water Control Structures Identification The 1 icensee has identified three safety related water control structures p.nd components requiring i*nspection in accordance with Regulatory Guide* 1.121*.
They are:
- 1) th~ intake crib, 2) the intake pipeline, and 3) the intake structure. Engineering drawings that provide the techhical data pertaining to these structures and construction photographs are available at the site. The NRC staff and its consultant concur with the licen~ee's id~ntification of appropriate cooling water system structures and components.
Specific in-..
spection features of these structures are described later in this section.
The licensee has not identified any flood control structures at the site.
The NRC staff coni~ltant has, howe~er, identified submarine-type flood doors and bulk heads as safety related flood protection structures at the site.
Some of these components are shown in Bechtel Company's Drawing C-327 showing architectural exterior elevations. Since these floodproof doors are being rel ie.d upon to protect the plant from the effects of a probable maximum surge (PMS) of Lake M1chigan, all of these doors should be identified, considered flood protection structures, and should be included in the licensee's flood protection inspection program.
- 5. -
Details of Structures and Components to be Inspected The following elements of the previously identified structures *were identified by the licensee (ref. 1) as appropriate inspection items:
A~ Cooling Water System Structures Element Intake Crib Structure Intake Bell Mounded Structure of Riprap and Cernent-Filled Sacks 11-Ft-Diameter Intake Pipe and Bifurcation Concrete Intake Structure Traveling Screens Stop Logs B.
Flood Protection Structures Feature(s) to be Observed Integrity of steel grill structure None identified None identified Sediment buildup Functionabil i ty Functionability Functionability Frequency None identified (two inspections have been documented during the 'course of 1 O years of operation)
None identified None* identified None identified Non-formal Non-formal Non-formal No flood protection structure details were identified by' the licensee. It is the staff position however that the following elements would be included in the formal inspection program for water control structures:
Element For Flood Doors
- Waterproof Gaskets Mechanical Locking/
Latching Device Canel usi on e*.
- *6 -
Feature.(s) to be Observed Visual inspection for era.eking, leaking, deterioration, absence Capability of operation A.
Cooling Water System Structure Inspection Frequency Semi-annually
- Annually (or in accordance with
- manufacturer's specifications)
- 1. It is recommended that annual inspections of the intake crib be undertaken in 1 ight of the** followi.ng:
(a) the structural failure of the previous intake crib at the Palisades Plant resulting from wind-induced ice floe-forces, (b) the intake crib protects the intake bell from extreme forces, and (c) the freezing of Lake Michigan is an annual event.
Further, additional inspections (cal~ed special inspections) should follow extreme events that challeng~ the Ultimate Heat Sink (UHS) supply, e.g., extreme wind:...induced fee floe movement.
- 2.
The intake crib structure, single 11-ft-diameter pipe, and twin 8-ft-diameter pipes should be inspected not only for siltatibn,* but also for structural integrity.
- 3.
The mounded structure below the intake bell should be inspected to ascertain movement or degradation, and an inspection frequency should be detern1ined based on those findings.
- 4.
For all elements, a forn1al inspection program should be developed which defines the inspection freguency.
B.
- Flood Prote~tion St~uctures The floodproof submarine-type doors used to protect the plant from the consequences of flooding should be included as inspection items in t~e licensee's fonna 1. inspection program for water control structures. The frequency of those inspections should take:-. *into account the intensity of use, type o~ use (i.e.,
equipment transport or personnel movement), and consequences of failure for each of the flood doors.
INSPECTION PROGRAM The licensee has stated that there is no formalized inspection program for water control structures incorporating the methodology identifi~d in Regulatory Guide 1.127 for the Palisades plant (ref. 1). The licensee has not stated that the preventive maintenance* program at Palisades is conducted or overseen by qualified engineering personnel.
Inspection Report Regulatory Guide 1.127 identifies the need to prepare insp*ection reports following the inspection of safety-related water control structures. These documents should be maintained on-si~e, for reference purpo~es. The licensee has stated that drawings of water control structures and construction photographs are available at the site. Photographs taken during underwater inspections are also available for use during future inspections. The licensee has stated that no fonnal inspection program for water control structures is under way at the Palisades plant.
Frequency of Inspection The licensee's non-fonnal inspections do not meet the intent of *the inspec~ion criteria identified in Regulatory Guide 1.127. The licensee should
A
..*.
- develop fonnal inspections to be conducted at a frequency which takes into consideration the consequences of failure of the structure and the *frequency of the initiating event (i.e., annuall.Y for ice-induced crib pressures). Special inspections should be perfonned immediately after the occurrence of an event which challenges the integrity of the safety-related water control structure.
Additional inspections (called special. inspections) *should follow extreme events which challenge the UHS supply.
For the UHS,.this implies that an inspection is* necessary following significant buildup of ice or*other debris.
CONCLUSIONS In order for the in~pection.program for water control structures at th~
Palisades plant to conform to the intent of Regulatory Guide l.127, the insp.ection program now under way should be forma1ized*detailing the quality.
and frequency of inspections of various structures and components.
Standard report forms should be prepared by competent and qualified inspectors and reviewed by qualified engineers.
Floodproof, submarine-type doors should be included in the licensee's formal inspection* program for water c.ontrol structures.
- . SpecJal inspections of the intake crib structure shoul~ be undertaken following the occurrence of wind-iriduced ice floe movement on Lake Michigan.
Following the initiation of these recommended changes, the inservice.
- inspection for water control structures under way at the Palisades plant may be considered acceptable in meeting the intent of Regulatory Guide 1.127.
~..,.. REFERENCES
- l. Letter dated Dec. 21, 1981 from R. A. Vincent (CPCo) to D. M. Crutchfield (NRC) on the subject:
11 Palisades Plant - SEP Topic III-3.C, Inservice-Inspection of Water Control Structures 11
- 2. *Regulatory Guide l.127, 11 Inspection of Water-Control Structures Associated with Nuclear Power Plants 11
, March 1978.
- 3.
Regulatory Guide 1.132, 11Site Investigation for Foundations of Nuclear Power Plants 11, March 1979*.
- 4.
Palisades Plant, Final Safety Analysis Report, Consumers Power Company, Docketed November 5, 1968.