ML18052B025
| ML18052B025 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/26/1987 |
| From: | Kuemin J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8706010214 | |
| Download: ML18052B025 (2) | |
Text
consumers Power POWERINli
/llllCHlliAN'S PROliRESS General Offices:.1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-0550 May 26, 1987 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
INSERVICE INSPECTION - SECTION XI CODE UPDATE REQUIREMENT In reviewing the ASME Section XI Inservice Inspection program, it was identified that Palisades has deviated from the updating requirement.
This letter discusses the requirement, the deviation and commits to actions which will result in compliance with the requirement.
Requirement for "Code" Update 10CFR50.55a(g)(4)(ii) requires that inservice inspection programs be updated each ten year inspection interval to the latest edition and addenda of ASME Sect.ion XI, which is approved and incorporated by 10CFR50. 55a(b), 12 months prior to the start of the ten year interval.
"Code" updating is to be applied to each ten year inspection interval for the life of the plant.
Additionally, an inspection program may be optionally upgraded at any time, as long as the intended "Code" edition and addenda is incorporated by reference in 10CFRS0.55a(b) and the NRC approves the update (10CFRS0.55a(g)(4)(iv)).
Palisades Application of "Code" Update Requirement The 10CFRS0.55a(g) requirement for "Code" update was apparently misinterpret-ed, in the past, at Palisades, and we are not in full compliance with the updating requirement.
The requirement intends that a facility will update each ten years, in concert with its ten year inservice inspection intervals.
Contrary to this, the rule was interpreted as meaning a facility must stay on a particular "Code" edition and addenda for ten years following the last update~ whenever that was, and that "Code" updates did not have to coincide with the ten year inservice inspection intervals.
A "Code" update should have occurred following the 1983 refueling outage, coincident with the end of the first ten year inservice inspection interval.
However, the Palisades Inservice Inspection program was updated in May of 1977 and again in June of 1980, and it was thought that another update was not required until 1990 (ten years following previous update).
This has resulted in the "Code update" not coinciding with the ten year inservice inspection interval and, additionally, IC0587-1476A-NL02 87060102.14 870526 !
PDR ADOCK 05000255
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Nuclear Regulatory Commission Palisades Plant Inservice Inspection May 26, 1987 will cause Palisades to live to two different "Code" editions within the same inservice inspection interval.
2 Had Palisades updated in accordance with the requirements of 10CFR50.55a(g)(4)(ii) requirement, it wou"id currently be using the 1980 edition of Section XI of the code.
The current *Palisades Inservice Inspection Program incorporates the 1977 edition of the code, summer of 1978 addenda.
The 1978 winter addenda subsection IWF is used for supports.
The requirements of the two editions are essentially the same except the 1980 edition relaxes the inspection frequency for supports.
Therefore, although the misinter-pretation has resulted in Palisades using an inappropriate edition (1977 vs 1980) the later code edition requirement is being met by the present program.
Commitment A revision to the Palisades Inservice Inspection Program will be developed and submitted in early 1988 and pendi~g NRC approval become effective after the refueling outage. It has been determined impractical to update the inspection program prior to the 1988 refueling outage, as the *Plant would be using two different "Code" editions within one 3~ year inspection period.
Since the 1983 edition through the winter of 1984 addenda has been approved, this edition and addenda will be adopted into the updated program.
Palisades will again update the Inservice Inspection Program at the end of the current inspection interval in 1994.
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t/~c:mes L Kuemin Staff Licensing Engineer CC Administrator, Region III, NRC NRC Resident Inspector - Palisades IC0587-1476A-NL02