ML18047A671

Forwards Request for Relief from Section XI of ASME Boiler & Pressure Vessel Code Requirements.Request Suppls 780613 Relief Request.Encl Will Be Incorporated Into 40-yr Master Inservice Insp Plan

ML18047A671
Person / Time
Site:	Palisades
Issue date:	11/16/1982
From:	Johnson B CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Crutchfield D Office of Nuclear Reactor Regulation
References
NUDOCS 8211220006
Download: ML18047A671 (15)

Text

consumers Power company General Offices: 1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-0550 November 16, 1982 Dennis M Crutchfield, Chief Operating Reactor Branch No 5 Nuclear Reactor Regulation US Nuclear Regulatory Commisssion Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - REQUEST FOR RELIEF FROM SPECIFIC ASME B & PV CODE REQUIREMENTS Pursuant to 10 CFR 50.55a(g) and Palisades Technical Specification 4.3.c relief requests from certain provisions of Section XI of ASME B & PV Code are being submitted for NRC review and approval. This relief request is in addition to a relief request by letter dated June 13, 1978.

The specific areas where relief is requested and the basis for that request are presented in Attachment 1 to this letter. These requests have been reviewed and approved by plant management and the PRC and will be incorporated into the Palisades Nuclear Plant 40-year Master Inservice Inspection Plan upon approval by the NRC.

Brian D Johnson Staff Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades fllJrA

/loV7 8211220006 821116 PDR ADOCK 05000255 G PDR OC1182-0012A-NL02

ATTACHMENT 1 PROPOSED REQUEST FOR RELIEF FROM THE PROVISIONS OF ASHE B & PV CODE SECTION XI PURSUANT TO 10 CFR 50.55a(g)

OC1182-0012A-NL02

( PALISADES NUCLEAR PLANT INSERVICE INSPECTION Review and Approval For Proposed Requests for Relief from the Provisions of ASME B&PV Code,Section XI, Pursuant to 10CFR50 50.55a

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Initiated by (NPS (ISI Coordinator) echiliCa1~v~NPS) ~~D te Administrative Review Date (Tech Supt)

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~ Plant R~ew Committee Date (QA-05#)

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Date Note: The attached document is to be incorporated into the Palisades Nuclear

• Plant 40-Year Master Inservice Inspection Plan upon review/approval.

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J. . .o, 1982 RELi EF REQUEST PALISADES NUCLEAR PLANT Area of Sec XI. Safety Re I i er Category Component Function Class Relief Requested Testing Substituted Implementation I B1.21 B-A Vessel Closure Head Primary Pressure Boundary 1 Longitudinal Meridional and Circum Welds in Rx Vessel Heads Inacces-sible for Volumetric a.

b.

c.

Vessel Hydros Vessel Coupons B1.10, 81.20, B1.30, B1.40 a.b. Tech Specs

c. 40-Year Plan Exam Testing Vessel Bottom Head Primary Pressure 1 Meri d i ona I & C 1*rcum a. Vessel Hydros a.b. Tech Specs B1.21 B-A b. Vessel Coupons c: 40-Year Plan Boundary Seam Welds Generally

.e B1.22 c. B1 . 10, B1

• 20

• Inaccessible for Volumetric Exam B1.30, B1.40 Testing I B5.10 B-F Vessel Safe End Welds (Nozzle Safe End)

Primary Pressure Boundary 1 Not a Dissimilar Metal Weld Welds Covered as 89.11 8-J 40-Yea r PI an Not a Dissimilar Metal Welds Covered as 40-Yea r PI an I B5.30 B-F Steam Generator Safe End Welds (Nozzle Safe End)

Primary Pressure Boundary 1

Weld B9.11 B-J B7.10 B-G-2 CROM Bolting Primary Pressure 1 Nonperipheral CROM a. Vessel Hydros a. Tech Specs Boundary Bolting Inaccessible b. 81.11 Testing b. 40-Year Plan for VT-1 PCS-42-RCL-1H1-2LD, Primary Pressure 1 Inaccessible for UT a. Hydros a. Tech Specs B9.11 B-J b. Remaining B-J b. 40-Year Plan B9.12 3LU, 3, 3LO Boundary PCS-42-RCL-2H1-2LO, We Ids In System 3LU, 3, 3LO

a. Hydro a. Tech Specs I B9.11 B9~ 12 B-J PCS-42-RCL-1H-1,2 PCS-42-RCL-2H-1,2 PCS-30-RCL-1A-15, 15L0-1, 15LD-2, Primary Pressure Bounds ry 1 Inaccessible for surface Exam (Volumetric Exam To Be Done From ID) b.

c.

Remaining B-J Welds 100% UT of Pipe b.c. 40-Year Plan

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16LU-1, 16LU-2, 16 Thickness

• PCS-30-RCL-1B-13, 13LD-1, 13L0-2, 14LU-1, 14LU-2, 15 PCS-30-RCL-2A-14, 14L0-1, 15LU-1, 15LU-2, 16 PCS-30-RCL-2B-14, 14L0-1, 14LD-2, 15LU-1, 15LU-2, 16 Reactor Coo I ant Primary Pressure 1 Inaccessible & Not a. Hydros a. 40-Year Plan B12. 10 B-L-1 Pump Casing Welds Bounds ry lnspectable With Volumetric Technique rp0682-0111a-46-155

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' J(. .o, 1982 Area ..

of . Sec XI Safety Rel lef Categor~ Com12onent Function Class Relief Reguested Testing substituted lm12lementatlon I B12,20 B-L-2 Reactor Coolant Pump Casing Internal Surfaces Primary Pressure Boundary 1 Inaccessible a. Hydros . a. 40-Year Plan C5.11 C*F ESS-24-SIS*SH1-201, Pressure Boundary 2 Inaccessible for UT a. Hydro a.b. 40-Year Plan 202, 203, 204 b. C5.10, C5.20 Testing on Re*

mainder of System C5.11 C*F ESS-24*SIS-SH2-201, Pressure Boundary 2 Inaccessible for UT a. Hydro a.b. 40-Year Plan 202, 203, 204 b. *cs. 10, CS.20 Testing on Re*

mainder of System e

85.20 B*F Piping Welds Primary Pressure 1 Util lzation of Hole None - Examinations 40-Year Plan

. 85.40 Boundary Type UT Reflectors for Performed as 85.50 Thick Piping Scheduled 89.11 B-J Piping Welds* Primary Pressure 1 Utll ization of Hole None - Examinations 40-Year Plan 89.12 Boundary Type UT Reflectors for Performed as Thick Piping Scheduled C5.21 C-F Piping Welds Pressure 2 Utilization of Hole None - Examinations 40-Vear Plan C5.22 Boundary Type UT Reflectors for Performed as Thick Piping Scheduled rp0682*0111a*46-155

• e .June 10, 1982

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

BASIS STATEMENT The dollar plate 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.

IMPLE!'lENTATION & 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 ~xempt from volumetric examination and shall be visually examined during the system pressure test.

RR-2 Items B5.10, B5.30 (Nozzle to Safe End Welds)

I BASIS STATEl'lENT 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 I welds rather than B5.10 or B5.30, B-F welds.

See CE Dwg E-232-119-11.

IMPLE!'lENTATION & RELIEF REQUESTED These welds should be included and inspected to Category.B-J requirements with the restriction 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.

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June 10, 1982

(.. RR-3 Item B7.10 (Pressure Retaining Bolting)

BASIS STATEMENT N~nperipheral CRDM bolting is not accessible for VT-1 examination.

REFERENCE CE Dwg 2966-SE~2554.

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

All nonperipheral CRDM bolting is not accessible for VT examination.

IMPLEMENTATION & RELIEF REQUESTED Peripheral CRD:H pressure retaining bolting will be VT-1 examined.

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

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

BASIS STATEMENT Piping welds adjacent to the reactor vessel are buried in the cement and 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-1, 2 PCS-42-RCL-2H-1, 2 PCS-30-RCL-lA-15, 15LD-1, 15LD-2, 16LU-1, 16LU-2, 16 PCS-30-RCL-lB-13, 13LD-1, 13LD-3, 14LU-1, 14LU-2, *14 PCS-30-RCL-2A-14, 14LD-1, 14LD-2, 15LU-1, 15LU-2, 15 PCS".'30-RCL-2B-14, 14LD-1, 14LD-2, 15LU-1, 15LU-2, 15 IMPLE~1ENTATION & RELIEF REQUEST All welds identified above shall be examined from the ID volumetrlcal-ly. The weld will be 100~ examined (in lieu of the bottom 1/3 required by Section XI, 77578, Figure IWB-2500-8). The. surface exam will not be performed due to inaccessibility.

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• June 10, 1982 RR-S Items BS.20, BS.40, BS.SO, B9.11, B9.12, B9.31, CS.21, CS.22 (Pressure Retaining Piping - Volumetric Examination)

BASIS STATEMENT ASME B&PV Code,Section XI, 1977 Edition with Addenda through 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 examina-tion techniques and calibration block design in accordance with IWA-2240 (Alternative Examinations). Consumers Power Company elects to utilize hold 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 examinatio~s of piping welds in accordance with Article S,Section V, ASME Codes. The requirements of Article 5,Section V 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 statements 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 code applicability statements be substituted in lieu thereof.

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

BASIS STATEMENT Welds PCS-42-RCL-1Hl-2LD, 3LU, 3, 310 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.

• rp0682-0lllc-46-1SS

• e June 10, 1982 The application of IWB-2430 at.the Palisades Plant for the above listed welds will be as follows:

The application of IWB-2430 will be in accordance with the information submitted in CP Co letter to D L 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 Pa'lisades 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 int.erest 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.

CP Co 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 C5.11 (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 CP Co letter to D L 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 pursuant to finding the original rp0682-0lllc-46-155

• .e June 10, 1982

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defec.t) results in the remainder of the line/component (with the same Section XI item number) being examined.

CP Co will implement IWC-2430 on these inaccessible welds only after the first 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.

RR-8 Item B12.10 (Pump Casing Welds)

BASIS STATEMENT The Palisades Plant has four (4) reactor coolant pumps which are welded to the 30-inch recirculation loop. These pumps function during normal reactor operation to provide forced recirculation through the core.

The ASME Code,Section XI, 77S78 Addenda requires that the casing welds on one pump be volumetrically examined and dye penetrant examined each inspection interval. The inspection of these pumps is considered to be impractical based on the following rationale:

1. Approximately 1,000 man-hours and over 100 manrem would be required to perform the examination. The man-hour *estimate is based only on onsite outage work performed by maintenance, operations and NDT personnel. The estimate does not include engineering time or pre-outage job planning. The manrem estimate is* based on an expected dose rate of 30-40 Rem/hr. Additionally, man-hours will be ex-pended by Radiation Protection personnel providing direct coverage ..

The time required to perform the inspection would be at least two weeks of critical path time. All work-would have to be performed under full face mask or "supplied air" conditions.

2. The pump casing is fabricated from cast stainless steel (ASTII A351, Grade ~FSM). The material is essentially a cast Type 316 stainless steel. This material is widely used in the nuclear industry and no industry failures of this type material have been. noted. The presence of delta ferrite (typically 15% or more) impacts increased resistance to intergranular stress corrosion cracking (IGSCC). The delta ferrite also improves re~ista?ce to pitting corrosion.

3. The coarse grain structure inherent in large.thick casting pre-cludes the use of Ultrasonic Testing (UT).

4. The design configuration of the pump corresponds to a Type E pump illustrated in Figure NB-3442.5-1 (1977 Edition, AS~IE B&PV Code,Section III). The presence of the diffuser vanes precludes Radio-graphic Testing (RT). The vanes prevent placement of th~ RT film rp0682-0lllc-46-155

. . .e J'une 10, 1982 cassettes inside the pump (as also does the radiation field in terms of film exposure and personnel radiation exposure) . . Place-ment of the film on the outside of the pump is feasible but there is no radiographic source suitable for placement inside the pump.

Standard radiation sources, eg, Co-60 are too weak to penetrate the thick casting and the background radiation from the inside surface of the pump would serve to uniformly fog the film (ie, a bad signal to noise ratio).

It is further requested that no dye penetrant examination be required during,plant iife due to as-cast surface texture of the pump.

RR-9 Item B12.20 (Pump Casing)

BASIS STATEMENT The same basis applies to this relief request as applied to RR-8 above.

REf'IARKS This request for relief appiies to the following pumps:

P-SOA P-SOB P-SOC P-SOD ItIPLEMENTATION AND RELIEF REQUESTS It is requested that relief be granted to not examine the pump casing due to the radiation exposure, the coarse su~face texture which precludes meaningful examination and since the pump is not expected to be disassembled for other reasons (see RR-8). The pump interior _will be inspected to the extent practical (in recognition ~f the vanes therein) should the pump be disassembled*for any other reason. As an alternate test, it is proposed that the pump be hydrostatically tested per Section XI (see RR-8).

rp0682-0lllc-46-155

.e June 10, 1982 ADDENDA TO RELIEF REQUESTS BASIS STATEMEt-.TTS CONCERNING CP CO CODE APPLICABILITY STATE~IENTS r..**

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rp06S2-0llle-46-155_

- i June 10, 1982

( CODE USE FOR THIRD PERIOD FIRST INSERVICE INSPECTION INTERVAL Consumers 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 11 Article 5 of ASME Section V ritic piping and with addenda through dissimilar metal Summer 1978 welds Austenitic and .1" to .4" Appendix III with Supple-Ferritic piping and ment 7 of ASHE Section XI dissimilar metal with addenda through welds Summer 1978 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:

l. 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 thickDess 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 trans-fer (attenuation compensation) be accomplished between the production material and the basic calibration block and a correction made for

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the difference. In accordance with Code Interpretation V-78-01 and rp0682-0llle-46-l55

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e. June 10 J 1982

( Code Case 1698 (N-92), the transfer method will not be used. Attenu-ation 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 obs~rved difference before or during the Ultrasonic Examination.

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

III-2300 Written Procedure Requirements III-2400 General Exmination Requirements III-3100 Instrument Calibration (To Include Supplement 5 and 6)

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

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rp0682-0llle-46-155

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• *June 10, 1982 CODE USE FOR THIRD PERIOD

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FIRST 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 Para-graph III-3410.

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D. Calibration Reflectors

1. Thickness: .10" to .40" Calibration reflectors shall conform to the requirements of Paragraph III-3430,Section XI.

2. Thickness: Greater than .4" to 6 11 Calibration reflectors shall be holes and shall conform to the requirements of Paragraph T-533 (a), Article 5,Section V, 77S78 ASME B&PV Code.

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rp0682-0llle-46-155