ML18064A676
| ML18064A676 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/30/1995 |
| From: | Haas K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9504060065 | |
| Download: ML18064A676 (6) | |
Text
..
~,.
consumers Power KurtM. Haas Plant Safety and Licensing Director POWERING MICHIGAN'S PllOlillE55 Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 March 30, 1995 Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, DC 20555 I
DOCKET 5.0-255 - LICENSE DPR PALISADES PLANT ALTERNATE CODE REQUIREMENTS FOR SECOND INTERVAL ISi VALVE INSPECTIONS We will complete the examinations and testing required by our second interval Inservice Inspection (ISi) program during the 1995 refueling outage which is scheduled to begin in late May of this year.
Our second interval ISi program is based on the ASME Code,Section XI 1983 Edition, Summer 1983 Addendum.
This Code (category B-M-2, Item Number 812.50) requires that valves greater than 4 11 nominal pip.e size be grouped by similar function and design, and that the internal surface of at least one valve in each group be examined during each interval.
The general process for meeting thi.s visual inspection requirement is to coordinate the valve internal surface inspection with the disassembly of one of the valves in each group when it is scheduled for maintenance or repair.
Using this process, a minimum of one valve in each of our valve groupings, with the exception of one, has met the valve internal surface inspection requirements for the second interval. Our interpretation is that the 1983 Code would require us to schedule one of the val~es from the grouping that has not been* inspe~ted, for disassembly during the refueling outage to complete the internal surface inspection requirement.
10 CFR 50.55a(g)(4)(iv) allows that inservice examinations of components may meet the requirements set forth in subsequent additions and addenda of the Code that the NRC has approved in 10 CFR-50.55a(b), is long as all related requirements of the respective editions or addenda are met.
10 CFR 50.55a(b) now states that Section XI of the ASME Code including Addenda through the.1988 Addenda and Editions through the 1989 Edition have been approved for use. The 1989 Edition of Section XI of the Code has been revised to require the internal surface inspection of one valve in each grouping onlv when a valve is disassembled for maintenance, repair or volumetric evaluation.
1 r~~9;;:-so~4~.
0:::.6::-:0:-:0:-:6:-:s~.-9-5
-:-0~3-3~0--!-,
"\\
PDR ADOCK. 05000255 1
- P I'
A CMS' ENERGY COMPANY
~DR f\\0~11 I
2 The purpose of this letter is to request NRC approval to apply the 1989 Edition of Section XI of the ASME Code, as it applies to visual in~pection of valves, so that we will not have to schedule a disassembly of one of the valves for the sole purpose of performing a visual inspection of the valves' internal surfaces.
We believe that compliance with the valve disassembly and internal surface visual inspection requirements of the second interval Code of Record for one valve, would result in hardship without a compensating increase in the level of quality and safety. contains the justi.fication for use of the later Code Edition.
SUMMARY
OF COMMITMENTS This letter contains no new commitments.
Kurt M Haas Plant Safety and Licensing Director CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment
-. 0 ATTACHMENT 1 Consumers Power Company Pa 1 i sades Pl ant Docket 50-255 ALTERNATE CODE REQUIREMENTS FOR SECOND INTERVAL ISi VALVE INSPECTIONS 3 Pages
JUSTIFICATION FOR USE OF ALTERNATE CODE REQUIREMENTS FOR SECOND INTERVAL ISi VALVE INSPECTIONS Component Identification Code Class Code Reference Examination Category Item Number Component Description Component Function Code Requirement 1
IW8-2500 Table IW8-2500-1 8-M-2 812.50 12" Velan Gate Valves; M0-3015 and M0-3016 M0-3015 and M0-3016 isolate the primary coolant system from shutdown cooling The ASME Code,Section XI 1983 Edition Summer 1983 Addenda, Table IWB-2500-1 Category B-M-2, Item Number 812.50 requires a visual (VT-3) examination of the internal surfaces for valves exceeding 4 inch nominal pipe size. This examination is limited to at least one valve within each group of valves that are of the same construction, design, manufacturing method and that perform a similar function in the system. This examination is required each ten year inspection interval and may deferred to the end of the interval.
Since the 12" Velan Gate valves, M0-3015 and M0-3016 are of the same design, construction and perform similar functions, they are defined under our program as a grouping of valves.
M0-3015 and M0-3016 are the only two valves in this grouping.
Neither of these valves have so far been disassembled for maintenance or repair during this inspection interval and are not scheduled for maintenance or repair during the 1995 refueling outage which is the last outage scheduled for the second ISi inspection interval.
Our interpretation is that under the second interval Code of Record we would be required to plan to disassemble one of the valves to complete a visual inspection of the valve internal surfaces.
Alternate Code Requirements Palisades is seeking approval from the NRC to upgrade from Section XI 1983 Edition Summer 1983 Addenda to Section XI 1989 Edition for Category B-M-2, Item Number 812.50 for this grouping of valves only, as allowed by 10 CFR 50.55a(g)(iv).
10 CFR 50.55a(g)(iv) allows that inservice examination of components may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations listed in paragraph (b) and subject to commission approval provided that all related requirements of the respective editions or addenda are met.
Section XI 1989 Edition is the approved edition of the code as identified in 10 CFR 50.55a(b)(2).
The 1989 Edition of Section XI, Category 8-M-2, Item Number 812.50, Footnote (2) states "Examination is required.Q!l]_y when a pump or valve is disassembled
for maintenance, repair, or volumetric examination.
Examination of the internal pressure boundary shall be performed to the extent practicable.
Examination is required only once during the inspection interval."
It is our interpretation that allowing us to upgrade to this portion of the 1989 Code will give us the latitude not to schedule either M0-3015 or M0-3016 for disassembly solely to complete the valve internal surface inspection.
Justification All other valve groups and pump internal examination requirements were met during the second interval using Section XI 1983 Edition Summer 1983 Addenda.
Palisades will be using the Section 1989 Edition only for valves M0-3015 and M0-3016.
We have reviewed the 1989 Edition of Section XI and find that there are no other related sections of the Code that need to be considered for implementation when using the later edition valve internal visual inspection requirements.
We also have reviewed section 10 CFR 50.55a(b) and find no limitations or modifications subject to the use of this valve internal visual inspection requirement.
2 These Velan gate valves were constructed under ASTM specification Al82 and the body material is Stainless Steel Grade F316.
The F316 material is made of 16Cr-12Ni-2Mo with a 30 KSI Yield Strength and a 75 KSI Tensile Strength.
This material is suited for the expected service conditions and will not degrade in service. Both M0-3015 and M0-3016 were disassembled during the first inspection interval and no indications were identified.
We have no evidence to suggest that the condition of these valves has degraded since those inspections.
These valves can only be disassembled during a full core off-load with shutdown cooling stopped and the primary coolant system drained.
While the reactor will be defueled during a portion of the 1995 refueling outage, inspection of one of the two valves is still not warranted in light of the impact on the outage schedule and the radiation dose that would be accumulated.
Since these two valves isolate the shutdown cooling system from the primary coolant system and primary coolant system leakage rate is monitored very closely, any leakage through these valves to the shutdown cooling system would be readily identified.
The valve body welds on M0-3016 will be ultrasonically inspected from the exterior surface during the upcoming refueling outage. This examination will require removal of insulation from the valve body and will identify any internal defects in the weld and heat affected zone and will allow a visual inspection of the external surfaces.
11 3
These valves are part of our motor-operated valve program and are scheduled to have their motors replaced during the next refueling which will be followed by Votes static diagnostic testing. This testing will provide assurance that the valve stem and disc are intact and the valve is fully functional.
Based on the above, we believe that disassembling either M0-3015 or M0-3016 for the sole purpose of performing a visual valve internal surface examination would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Following the 1995 refueling outage we will be beginning the third of our ten year ISI inspection intervals. Our third interval testing and inspection program, per 10CFR50.55a requirements, will be completed in accordance with the 1989 Edition of the Code.
The 1989 Code, Category B-M-2 Item Number 812.50, requires the internal valve surface inspection of one valve in each group, onlv when a valve is disassembled for maintenance, repair or volumetric examination. Therefore ~uring the third ISI inspection interval we will only be performing the valve internal surface visual inspection for those valves that are scheduled for maintenance or repair.