ML18065A372
| ML18065A372 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/20/1995 |
| From: | Gamberoni M NRC (Affiliation Not Assigned) |
| To: | Smedley R PALISADES GENERATING CO. |
| References | |
| TAC-M93628, NUDOCS 9512280314 | |
| Download: ML18065A372 (7) | |
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December 20, 1995 Mr. Ric Manager hard W. Smedley Licensing Pali sad 27780 B
- Covert, SUBJECT Dear Mr Based o es Plant lue Star Memorial Highway MI 49043 PALISADES PLANT - REQUEST FOR ADDITIONAL INFORMATION - INSERVICE INSPECTION PROGRAM (TAC NO. M93628)
. Smedley:
Program n our review of Palisades' Third IO-Year Interval Inservice Inspection Plan and associated requests for relief, we require additional informa 1995, s 60 days request This re subject Docket Enclosu Request cc w/en See nex DISTRIB Docket PUBLIC JRoe tion and clarification of information provided in the September 6, ubmittal.
Please provide a response to the enclosed questions within of the date of this letter. If you have any questions regarding this
, please contact me at 415-3024.
quirement affects nine or fewer respondents and, therefore, is not to the Office of Management and Budget review under P.L.96-511.
No. 50-255 re:
for Additional Information cl:
t page UTION File WKropp, RIII TMcLell an PD31 RDG Sincerely, Original signed by Marsha K. Gamberoni, Project Manager Project Directorate 111-1 Division of Reactor Projects - III/IV Office of Nuclear Reactor Regulation EAdensa m (e)
OGC ACRS DOCUMENT NAM To receive a copy oft OFFICE LA :PD31 NAME CJ amerson DATE 12/t;;/95 OFFICIAL RECORD COPY
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Richard W. Smedley Manager Licensing Palisades Plant 27780 Blue Star Memorial Highway Covert, MI 49043 December 20, 1995
SUBJECT:
PALISADES PLANT - REQUEST FOR ADDITIONAL INFORMATION - INSERVICE INSPECTION PROGRAM (TAC NO. M93628)
Dear Mr. Smedley:
Based on our review of Palisades' Third 10-Year Interval Inservice Inspection Program Plan and associated requests for relief, we require additional information and clarification of information provided in the September 6, 1995, submittal.
Please provide a response to the enclosed questions within 60 days of the date of this letter.* If you have any questions regarding this request, please contact me at 415-3024.
This requirement affects nine or fewer respondents and, therefore, is not subject to the Office of Management and Budget review under P.L.96-511.
Docket No. 50-255
Enclosure:
Request for Additional Information cc w/encl:
See next page Sincerely, Marsha K. Gamberoni, Project Manager Project Directorate llI-1 Division of Reactor Projects - III/IV Office of Nuclear Reactor Regulation
(_
Mr. Richard W. Smedley Consumers Power Company cc:
Mr. Thomas J. Palmisano Plant General Manager Palisades Plant 27780 Blue Star Memorial Highway Covert, Michigan 49043 Mr. Robert A. Fenech Vice President, Nuclear Operations Palisades Plant 27780 Blue Star Memorial Highway Covert, Michigan 49043 M. I. Miller, Esquire Sidley & Austin 54th Floor One First National Plaza Chicago, Illinois 60603 Mr. Thomas A. McNish Vice President & 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 Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Jerry Sarno Township Supervisor Covert Township 36197 M-140 Highway Covert, Michigan 49043 Office of the Governor Room 1 - Capitol Building Lansing, Michigan 48913 U.S. Nuclear Regulatory Commission Resident Inspector's Office Palisades Plant 27782 Blue Star Memorial Highway Covert, Michigan 49043 Palisades Plant Nuclear Facilities and Environmental Monitoring Section Office Division of Radiological Health Department of Public Health 3423 N. Logan Street P. O. Box 30195 Lansing, Michigan 48909 Gerald Charnoff, Esquire Shaw, Pittman, Potts and Trowbridge 2300 N Street, N. W.
Washington DC 20037 Michigan Department of Attorney General Special Litigation Division
- 530 Law Building P.O. Box 30212 Lansing, Michigan 48909 September 1995
CONSUMERS POWER COMPANY PALISADES PLANT
- REQUEST FOR ADDITIONAL INFORMATION I.
Effective September 8, 1992, regulations were issued regarding the augmented examination of reactor vessels.
As a result of these regulations, all licensees must augment their reactor vessel examinations by implementing once, as part of the inservice inspection (ISi) interval in effect on September 8, 1992, the examination requirements for reactor vessel shell welds specified in Item 81.10 of Examination Category 8-A.
In addition, all previously granted reliefs for Item 81.10, Examination Category 8-A for the interval in effect on September 8, 1992 are revoked by the new regulation.
For licensees with fewer than 40 months remaining in the interval on the effective date, deferral of the augmented examination is *permissible with the conditions stated in the regulations.
Please provide the staff with a technical discussion describing how the regulation will be or has been implemented for the reactor pressure vessel (RPV) shell welds at the Palisades Plant.
Include a description of the approach and any specialized techniques or equipment that will be or have been used to complete the required augmented examination.
If the one-time augmented examination has already been performed, verify that at least 90 percent of each RPV shell weld (Items 81.11 and 81.12) has been examined.
- 2.
The copies of the color-coded piping and instrument drawings (P&IDs) contained in the September 6, 1995, submittal are difficult to read or illegible. Provide the staff with the P&IDs used to define the ASME Code Class 1, Class 2, and Class 3 boundaries for the systems in the Third Ten-Year Inspection Interval Inservice Inspection Plan for the Palisades Plant.
- 3.
Provide the staff with an itemized listing of the components subject to examination during the third 10-year interval. The requested listing, along with the isometric/component drawings and the requested P&IDs, will enable the staff to determine if the extent of ISi examinations meets the applicable code requirements.
- 4.
Paragraph 10 CFR 50.55a(b)(2)(iv) requires the examination of ASME Code Class 2 piping welds in the residual heat removal (RHR), emergency core cooling (ECC), and containment heat removal (CHR) systems. These systems or portions of these systems should not be completely exempted from inservice volumetric examination based on the Section XI selection criteria (e.g., piping wall thickness). The staff has previously determined that a 7.5 percent augmented volumetric sample constitutes an acceptable resolution at similar plants and that the safety significance of these systems warrants the volumetric examination. It is noted that 1304 Examination Category C-F-1 welds are excluded from examination based on wall thickness. Define the systems or portions of the RHR, ECC, and CHR systems at the Palisades Plant that have been excluded based on wall thickness. Also include the nominal thickness of each line. Considering
- the technical prudence of performing volumetric examination on a portion of the welds in these systems, identify the welds that will be scheduled for examination during the third inspection interval, or provide a discussion justifying the exclusion of these systems.
- 5.
In Basis Statement D, "Additional Examinations, n it states, in part:
0 lf weld processing discontinuities (i.e., porosity, slag, i.ncomplete fusion or penetration) are detected during any inspection that exceed the allowable indication standards of Section XI IWB-3000 they shall be subject to Palisades ISi evaluation but.no expansion of exanination scope will be required.
The additional examinations as required by Section XI IWB-IWC-IWF-2400, Subsection 2430 will only be performed if service induced discontinuities are detected.
0 The intent of the code-required sample expansion is to assess the extent of generic degradation in similar components.
Section XI does not differe~tiate between service-induced and fabrication flaws; therefore, gener.ically classifying indications revealed during inservice inspection as fabrication flaws is not in accordance with the code.
Indications suspected of being fabrication flaws should be addressed on a case-by-case basis based on documentation from previous inspections (Le.,.
fabricatiion radiographs or preservice inspection records). Considering that Palisades is in the third interval, pre-existing condit.ii<D'rrs~ should*
already be documented as the result of previous examinations.
Does the licensee.expect to find "new" fabrication flaws?
Provide a discussion regarding the evaluation process used to determine the origin of indications found during inservice inspection.
- 6.
In Basis Statement G, "Containment Penetrations," it states that all containment penetrations have been optionally upgraded to ASME Class I or 2.
It also states that containment penetrations not part of an ASME Class 1, 2, or 3 system will only be tested under the Pal isatd'es Appendix J Program.
This statement appears to exclude the optionally classified containment penetrations from the examination requirements of Class 1, 2, and 3. Components classified as Class 1 and 2 are subject to the examination requirements of the code and cannot be omitted: w.ithout specific relief in accordance with the regulations.
Identify the subject penetrations and verify that either the code examination and testing requirements will be met for these components or include the penetrations in a request for relief from the applicable code requirements.
- 7.
The code requires the examination of all Class I nozzle-to-vessel welds (Examination Category 8-0). It is noted that only 38 of 42 Examination Category B-D welds are scheduled in the ISi Program for the third IO-year interval. It is understood that relief is requested for some of the affected areas, but complete relief has not been requested or justified.
Provide clarification regarding this omission.
- 8.
Section 6, Subsection E, "Midinterval Requirement Changes," states:
"10 CFR 50.SSa(g) requires periodic updates of ISi programs to the currently approved version of Section XI.
Implementation of these changes in the Plan in midinterval may require examinations of areas not previously subject to examination.
No attempt is made to 'catch up' those examinations."
In 10 CFR 50.55a(g)(4)(ii) it states that the inservice examination of components and system pressure tests conducted during the 120-month interval must comply with the requirements of the latest edition and addenda of the code incorporated by reference in the regulations 12 months prior to the start of the inspection interval. Subsequent editions and addenda incorporated by reference in the regulations may be used with approval by the NRC staff. The regulations are clear on this issue; updates of the program are generally not required mid-interval.
Updates are optional and are subject to NRC approval.
The intent of the paragraph quoted above is not clear.
Provide a discussion regarding this statement.
- 9.
Request for Relief RR-1:
The licensee requested relief to perform a mechanized ultrasonic (UT) examination of the full weld volume of Class 1 piping welds adjacent to the reactor vessel in lieu of the code-required surface examination of the outside diameter (OD) surface. This request was evaluated and granted in the previous interval with the condition that the licensee demonstrated its ability to detect crack-type OD defects in a laboratory test block.
In a letter dated July 13, 1990, the licensee committed to perform this demonstration.
Has the demonstration been performed? If so, provide the results and the dates of the associated documentation.
If the results have not been docketed, provide the staff with information sufficient to confirm that the proposed alternative has been adequately demonstrated.
There are 14 welds listed in this relief request but at least 26 listed in the program that reference this request and the use of mechanized UT.
Provide a clarification regarding the welds that should be included in this request.
- 10. Requests for Relief RR-2, RR-3, RR-4, RR-5 and RR-7:
For the subject relief requests, the information provided is insufficient to justify the impracticality of the code requirements and the drawings provided are either illegible or inadequate.
For each of the welds, components, or supports for which relief is requested, provide the staff with an estimate of the code-required weld volume that can and will be examined and a written description and/or drawing of the examination area and associated limitations.
- 11.
Request for Relief RR-6:
The licensee has requested relief from the volumetric examination of a number of pressurizer welds, including the upper and lower head meridional welds.
Eight meridional head welds (four per head) are listed in this request, but only two welds (one per head) are required to be examined by the code.
Provide a clarification for the welds for which relief is requested.
In addition, provide an estimate of the code-required volume that can and will be examined for each weld, and provide a technical description and/or drawing of the examination area and the associated limitations.
- 12.
Request for Relief RR-8:
The licensee has requested relief from examining reactor vessel closure head Weld 6-1188 to the extent required by the code.
Provide an estimate of the code-required volume that can and will be examined for the weld and a technical description and/or drawing of the examination area and the associated limitations.
Weld 6-1188 is not scheduled to be examined in the program plan (only 27 of 28 Examination Category 8-A welds are scheduled).
Is this an oversight?
Provide a clarification for this omission.
- 13.
Request for Relief RR-9:
The licensee has requested to defer the examination of the RPV nozzle-to-vessel welds until the third period of the third ISi interval. This request may be considered acceptable provided that there are more than 10 years between examinations (except where the length of a IO-year interval is adjusted in accordance with IWA-2430).
However, a mid-interval vessel anneal may alter this decision.
How is the vessel anneal expected to affect the third 10-year ISI Program? Will a complete examination of the RPV be performed following the vessel anneal procedure?
How will connected and adjacent components (i.e., safe-end welds, integral attachments, etc.) be affected?
- 14. Verify that there are no additional relief requests other than those included in the September 6, 1995, submittal. If additional relief requests are required, the licensee should submit them for staff review.
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