ML18054B365
| ML18054B365 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/12/1990 |
| From: | De Agazio A Office of Nuclear Reactor Regulation |
| To: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| PAL-90-003, PAL-90-3, TAC-72622, NUDOCS 9001190064 | |
| Download: ML18054B365 (9) | |
Text
January 12, 1990 Docket No. 50-255 Serial No. PAL 90-003 Mr. Kenneth \\'!. Berry Director, Nuclear Licensing Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201
Dear Mr. Berry:
DISTRIBUTION DOCKET FILE NRC & LOCAL PDRs PD31 GRAY FILE JZWOLINSKI AMJl.SCIANTONIO ADEAGAZIO GJOHNSON BWBROWN OGC EJORDP.N ACRS(lO)
PSHUTTLEWORTH
SUBJECT:
PALISADES SECOND TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM REQUEST FOR ADDITIONAL INFORMATION (TAC NO. 72622)
The NRC staff, with assistance from Idaho National Engineering Laboratory, is reviewing and evaluating the second ten-year interval Inservice Inspection (ISI) program for the Palisades Plant. Additional information, as detailed in the enclosure, is needed for completion of our review and evaluation.
In order to meet our review schedule, we request that the information is provided not later than February 16, 1990.
VJe also request that copies of transmittals regarding the Palisades second ten-year interval ISI program be forwarded to Boyd W. Brown, Idaho National Engineering Laboratory, P.O. Box 1625, Idaho Falls, Idaho 83415-2209 in order to expedite the review.
The reporting and/or recordkeeping requirements of this letter affect fewer than ten respondents; therefore, OMB clearance under PL 96-511 is not required.
cc:
See next page PM/PD31~
ADEAGAZIO lf5/90
(.M'OtPD31:DRSP JrMOMA 1/( /90 Sincerely, Original signed by Albert De Agazio, Project Manager Project Directorate III-1 Division of Reactor Projects - III, IV, V & Special Projects Office of Nuclear Reactor Regulation PALISADES ISI TAC 72622
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 Docket No. 50-255 Serial No. PAL 90-003 Mr. Kenneth W. Berry Director, Nuclear Licensing Consumers Power Company..
1945 West Parnall Road Jackson, Michigan 49201
Dear Mr. Berry:
January 12, 1990
SUBJECT:
PALISADES SECOND TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM REQUEST FOR ADDITIONAL INFORMATION (TAC NO. 72622)
The NRC staff, with assistance from Idaho National.Engineering Laboratory, is reviewing and evaluating the second ten-year interval Inservice Inspection (ISi) program for the Palisades Plant. Additional inforffiation, as detailed in the enclosure, is needed for completion of our review and evaluation.
In order to meet our review schedule, we request that the information is provided not later than February 16, 1990.
We also request that copies of transmittals rEgarding the Palisades second ten-year interval ISi program be forwarded to Boyd U. Brown, Idaho National Engineering Laboratory, P.O. Box 1625, Idaho Falls, Idaho 83415-2209 in order to expedite the review.
The reporting and/or recordkeeping requirements of this letter affect fewer than ten respondents; therefore, OMB clearance under PL 96-511 is not required.
cc:
See next page Sincerely,
~JLf7~*
Albert De Ag:~;(c~-Manager Project Directorate 111-1 Division of Reactor Projects - III, IV, V & Special Projects Office of Nuclear Reactor Regulation
Mr. Kenneth W. Berry Consumers Power Company cc:
M. I. Miller, Esquire Sidley & Austin 54th Floor One First National Plaza Chicago, Illinois 60603 Mr. Thomas A. McNish, Secretary Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consumers Power.Company 212 West Michigan Avenue Jackson, Michigan 49201 Regional Administrator, Region III U.S. Nuclear Regulatory Co1T1nission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Jerry Sarno Township Supervisor Covert Township 36197 M-140 Highway Covert, Michigan 49043 Office of the Governor Room 1 - Capitol Building Lansing, Michigan 48913 Mr. Gerald B. Slade Plant General Manager Palisades Plant 27780 Blue Star Memorial Hwy.
Covert, Michigan 49043 Resident Inspector c/o U.S. Nuclear Regulatory Corrmission Palisades Plant 27782 Blue Star Memorial Hwy.
Covert, Michigan 49043 Palisades Plant Nuclear Facilities and Environmental Monitoring Section Office Division of Radiological Health P.O. Box 30035 Lansing, Michigan 48909
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- CONSUMERS POWER COMPANY PALISADES NUCLEAR PLANT DOCKET NUMBER 50-255
- Request for Additional Information - Second IO-Year Interval Inservice Inspection Program I. Scope/Status of Review Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) requires that components (including supports) classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1, Class 2, and Class 3 meet the requirements, except design and access provisions and preservice examination requirements, set forth in the ASME Code Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during successive 120-month inspection intervals comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The components (including supports) may meet requirements set forth in subsequent editions and addenda of this Code which are incorporated by reference in 10 CFR 50.5Sa(b) subject to the limitations and modifications listed therein.
Based on the start date of November 10, 1983 for the second 10-year interval, the applicable Code Section XI would be the 1980 Edition through Winter 1980 Addenda.
However, as allowed by the regulations, the lnservice Inspection (ISi) Program has been prepared by the Licensee to meet the requirements of the 1983 Edition, Summer 1983 Addenda of the ASME Code Section XI except that the extent of examination for Code Class 2 piping welds in Residual Heat Removal (RHR), Emergency Core Cooling (ECC), and Containment Heat l
Removal {CHR) systems has been determined by the I974 Edition through Summer I975 Addenda as required by IO CFR 50.55a{b).
As required by IO CFR 50.55a{g){5), if the Licensee determines that certain Code examination requirements are impractical and relief is requested, the Licensee shall submit information to the Nuclear Regulatory Commission {NRC) to support that determination.
The staff has reviewed the available information in the Palisades Nuclear Plant Second IO-Year Interval ISI Program, submitted December I9, I988, including the requests for relief from the ASME Code Section XI requirements which the Licensee has determined to be impractical.
- 2.
Additional Information/Clarification Required Based on the above review, the staff has concluded that the following information and/or clarification is required in order to complete the review of the ISI Program and relief requests:
A.
The tables in Section 6 of the ISi Program were reviewed.
Although the tables show the total number of welds to be examined, the specific piping welds to be examined during the second IO-year interval are not listed. Please provide the staff with an itemized listing of the welds/components subject to examination during the second IO-year interval.
B.
Please provide isometric and/or component drawings showing the welds, components, and supports which Section XI of the ASME Code requires to be examined during the second IO-year interval. The drawings, along with the requested weld listing, will enable the staff to determine if the correct welds have been selected for examination during the second 10-year interval.
C.
The Second IO-Year Interval ISi Program, submitted December 19, 1988, makes reference to Long-Term Inspection Plans for 2
Class 1, Class 2, and Class 3 components.
If these documents contain the information requested in items A and B above, please provide the Long-Term Plans for Class 1 and Class 2 components in lieu of the above requests.
10 CFR 50.55a(b)(2)(iv) requires that ASME Code Class 2 piping welds in the RHR, ECC, and CHR systems be examined; these systems should not be completely exempted from inservice volumetric examination based on the 1974 Edition through Summer 1975 Addenda (74S75)Section XI exclusion criteria contained in IWC-1220.
To satisfy the inspection requirements of General Design Criteria 36, 39, 42, and 45, the inservice inspection program must include volumetric examination of a representative sample of welds in the RHR, ECC, and CHR systems.
With regard to the exemptions addressed in paragraphs D., E., F., and G.
below, it is noted that later editions and addenda of Section XI of the ASME Code and ASME Code Case N-408, which has been implemented by some Licensees, require volumetric examination of Class 2 piping welds greater than or equal to 3/8-inch nominal wall thickness for piping greater than 4-inch nominal pipe size (NPS).
The staff has previously determined that a 7.5% augmented volumetric sample constitutes an acceptable resolution at similar plants.
D.
Table Al (page 21 of the ISI Program), "Pressure Temperature Exemptions IWC-1220(a)," states that "IWC-1220(a), 74S75 has been applied to all Class 2 piping." Verify that the pressure/temperature exclusion will not be used for the RHR, ECC, and CHR systems and that the ISi Program includes volumetric examinations of a representative sampling of welds in these systems.
The staff points out that later editions and addenda of the Code do not permit the pressure/temperature exclusion for these systems.
E.
Table A2 (page 22 of the ISi Program), "Class 2, Operational Exemptions IWC-1220(b)," shows that the Containment Spray system has 3
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been exempted from ISI examinations based on the fact that the Containment Spray system does not perform an emergency core cooling function.
This exemption includes 8-inch and IO-inch lines containing stagnant borated water.
As stated above, 10 CFR 50.55a(b)(2)(iv) requires that pipe welds in CHR systems (i.e., Containment Spray) be examined.
Confirm that the ISI Program will be revised to include a representative sample of welds in the Containment Spray system.
F.
Table A3 (page 23 of the ISi Program), "Class 2, ECCS Controlled Chemistry Exemptions IWC-1220(c)," describes the use of the chemistry control exemption at Palisades Nuclear Plant. The Licensee should not be using the control of water chemistry exemption of IWC-1220(c).
The control of water chemistry to minimize stress corrosion is not an acceptable basis for exempting components from examination because practical evaluation, review, and acceptance standards cannot be defined. Operating data indicate that "chemistry control" has not supported the exclusion; later editions and addenda of the Code have deleted the chemistry control exclusion. Therefore, examination should be included for any components for which exemption is selected by the Licensee under paragraph IWC-1220(c) of the 1974 Edition and Addenda of Section XI of the ASME Code.
Verify that the chemistry control exclusion will not be used and that the ISi program will be revised to include examinations for these components.
G.
The staff notes that the "Examination Category C-F" table (page 145 of the ISI Program) shows a total of 942 Engineered Safeguards System (ESS) welds which have not been exempted based on the exclusion criteria of IWC-1220.
This table also indicates that an additional 489 ESS welds have been exempted based on the exclusion criteria of IWC-1220 (some of which are discussed above).
Of the 942 welds which have not been exempted, 78 are scheduled to receive surface only examinations and only 5 are scheduled to receive volumetric examination. Volumetric examination of 5 ESS system welds is not considered a representative sample and, therefore, does 4
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not meet the intent of the Code and the Regulations.
Please clarify or explain how the volumetric examination of 5 welds in the ESS system over the IO-year ISI interval would be statistically representative and would provide a level of confidence that a generic problem would be identified.
H.
Plans for inservice examination of the Reactor Pressure Vessel welds should address the degree of compliance with NRC Regulatory Guide 1.150, "Ultrasonic Testing Of Reactor Vessel Welds During Preservice and Inservice Examinations." Discuss the near-surface examination and resolution with regard to finding service induced flaws and the use of electronic gating as related to the volume of material near the surface that is not being examined.
I. Relief Request RR-2:
Relief is requested from the ASME Code-required surface examin~tion of piping welds adjacent to the Reactor Pressure Vessel. These welds are buried in cement and are inaccessible for O.D. surface examinations.
The Licensee has proposed the use of ultrasonic techniques; from the I.D. surface, to examine the outside surface of the subject welds in lieu of the Code-required surface examination.
The Licensee reports that the welds will be 1003 examined in lieu of the bottom 1/3 as required by the Code for volumetric examination.
This proposal could be considered acceptable provided that the Licensee meets the following conditions:
(1) The remote volumetric examination includes the* entire weld volume and heat affected zone instead of only the inner.
one-third of the weld as required by the Code.
(2) The ultrasonic testing instrumentation and procedures are demonstrated to be capable of detecting O.D.
surface-connected defects in the circumferential orientation 5
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in a laboratory test block.
The defects should be cracks and not machined notches.
Provide a discussion of the above conditions and verify that they will be met.
J. Verify that there are no additional relief requests applicable for the second 10-year interval, other than RR-1 through RR-4 in Section 5 of the 151 Program for the second 10-year interval as submitted December 19, 1988.
Because requests for relief are not automatically granted for subsequent inspection intervals, the Licensee must make a complete submittal of all requests for relief for each 10-year inspection interval. This enables the staff to review the requests for relief against the updated Code requirements and the Licensee's use of new and improved examination techniques as they become available. If relief requests other than RR-1 through RR-4 are required, the Licensee should submit them for staff review.
The schedule for timely completion of this review requires that the Licensee provide, by the requested date, the above requested information and/or clarifications with regard to the Palisades Nuclear Plant Second 10-Year Interval ISI Program.
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