ML18066A315
| ML18066A315 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/06/1998 |
| From: | Haskell N CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9810130249 | |
| Download: ML18066A315 (4) | |
Text
A CMS Energy Company Palisades Nuclear Plant Tel: 616 764 2276 27780 Blue Star Memorial Highway Fax: 616 764 2490 October 6, 1998 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Covert. Ml 49043 Nathan L. Has/ls/I Director, Licensing DOCKET 50-255 - LICENSE DPR PALISADES PLANT INSERVICE INSPECTION PROGRAM - RELIEF REQUEST NO. RR-12 During a NRC Inspection of the Palisades lnservice Inspection Program performed during the 1998 refueling outage, the inspector determined that a relief request may be needed to accept the ultrasonic examinations being done on welds where access is not available from both sides of the weld. Consumers Energy agreed to submit a relief request to cover this issue. This relief request is contained in the attachment to this letter and is identified as relief request number RR-12.
While the required examinations are impractical and therefore NRC approval is not required prior to use, Consumers Energy requests approval by April 9, 1999, in order to support our planning for the 1999 refueling outage.
SUMMARY
OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.
athan L. Haskell irector, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Attachment
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ATTACHMENT CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 INSERVICE INSPECTION PROGRAM - RELIEF REQUEST NO. RR-12 2 Pages
RE_LIEF REQUEST NUMBER RR-12 COMPONENT IDENTIFICATION Code Class Code Reference Examination Category Item Numbers Component Description CODE REQUIREMENT 1and2 IWB-2500, Table IWB-2500-1 IWC-2500, Table IWC-2500-1 B-J, C-F-1, and C-F-2 89.11, C5.11, C5.21, C5.51, and C5.61 Pressure Retaining Welds in Piping - Similar Metal Table IWB-2500-1 and IWC-2500-1 require a surface and volumetric examination of 100% of the weld length as identified below:
A.
B-J/89.11 B.
C-F-1/C5.11 C.
C-F-1/C5.21 D.
C-F-2/C5.51 E.
C-F-2/C5.61 BASIS FOR RELIEF Nominal pipe size 4 inch or larger circumferential welds.
Austenitic or high alloy piping welds ~ 3/a inch nominal wall thickness for piping > 4 inch nominal pipe size.
Austenitic or high alloy piping welds> 1/5 inch nominal wall thickness for piping ~ 2 inch and ~ 4 inch nominal pipe size.
Carbon or low alloy piping we.Ids ~ 3/a inch nominal wall thickness for piping > 4 inch nominal pipe size.
__ Carbon or low alloy piping welds> 1/5 inch nominal wall thickness for piping ~ 2-inch and ~ 4 inch nominal pipe size.
The code required examinations from both sides of the welds are considered to be impractical due to the configuration of the welds at structural discontinuities. The code required examinations are distributed among terminal ends and structural discontinuities. These structural discontinuities include pipe welded joints to valve bodies, pump casings, flanges, etc., where access is limited to one side.
The code required volumetric examinations are performed utilizing the pulse-echo ultrasonic examination technique. The angle beam examination of these configurations 1
RELIEF REQUEST NUMBER RR-12 will not allow access from both sides of the welds. The transverse scans per Appendix Ill, Article 4430, are not limited, however.
In accordance with ASME Section XI, 1989 Edition, Appendix Ill, Article 111-4100, an ultrasonic examination is applicable to welds where access can be achieved from at least one surface adjacent to the weld seam. Appendix Ill, Article 4420 requires that the examination volume be examined from two sides of the weld, where practicable, or from one side of the weld as a minimum when examining for reflectors parallel to the weld seam. In some austenitic welds at Palisades the examination volume is limited to access from only one side of the weld seam. To perform these required ultrasonic examinations Palisades utilizes ASME Section XI, Appendix VIII, qualified personnel and procedures in accordance with the Electric Power Research Institute (EPRI)
Performance Demonstration Initiative (POI) Program. Recent results from this program indicate that examination from a single side may not detect some types of reflectors on the far side of the weld in austenitic materials.
Due to these recent EPRI results and a NRC field inspection which was performed at Palisades during the 1998 refueling outage (NRC Inspection Report 50-255/98006
_(DRS)) it is requested that relief be granted with the proposed alternatives.
PROPOSED ALTERNATIVE EXAMINATIONS Where the component configuration will not allow an ultrasonic angle beam examination of austenitic material from the axial direction from both sides of the weld, the following will be performed:
A 100% of the required volume will be examined in one axial direction by ultrasonic examination using personnel and procedures qualified through the EPRI POI Program for single sided access relating to the material type to be examined.
- 8.
100% of the required volume of the transverse scans will be performed in both directions as required by Appendix Ill, Article 4430._
C.
The code required surface examination will be performed.
D.
Welds where this relief request has been implemented will be identified on the NIS-1 report which will be submitted at the completion of each lnservice Inspection outage.
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