ML18067A737
| ML18067A737 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/17/1997 |
| From: | Robert Schaaf NRC (Affiliation Not Assigned) |
| To: | Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| TAC-M98925, NUDOCS 9710290268 | |
| Download: ML18067A737 (4) | |
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Mr. Thomas C. Berdine Manager, Licensing Palisades Plant 27780,Blue Star Memorial Highway Gi;ivert.. Ml 49043 October 17, 1~9~
SUBJECT:
PALISADES PLANT - REQUEST FOR ADDITIONAL INFORMATION RELATED TO CONSUMERS ENERGY COMPANY'S INSERVICE INSPECTl.ON PROGRAM RELIEF REQUEST RR-4 (TAC NO. M98925)
Dear Mr~ Berdine:
- Based on our review of your June 3, 1997, submittal, we have determined that we need
- additional information to complete our review of the subject inservice inspection program relief request. Please provide a response to the enclosed questions within 30 days of receipt of this letter. In addition, to expedite the review process, please forward a copy of your response to the NRC's contractor, the Idaho National Engineering and Environmental Laboratory (INEEL), at the following address:
Michael T. Anderson INEEL Research Center 2151 North Boulevard P.O. Box 1625 Idaho Falls, Idaho 83415-2209 If you have any questions regarding this request, please contact me at (301) 415-1312.
Docket No. 50-255 Sincerely, ORIGINAL SIGNED..BY Robert G. Schaaf, Project Manager Project Directorate 111-1 Division of Reactor Projects - Ill/IV*
Office of Nuclear Reactor Regulation
Enclosure:
Request for Additional Information cc w/encl: See next page DISTRIBUTION Docket File
- PD31 Reading OGC GGrant, Riii PUBLIC EAdensam ACRS MJordan, Riii DOCUMENT NAME: PAL98925.RAI OFFICE PM:PD31 NAME DATE 9710290268 971017 PDR ADOCK 05000255 G
PDR LA:PD31 1111111111111111111111111111111111111111 :
- 9&1AB8*
Mr. Thomas C. Berdine Consumers Energy Company cc:
- Mr. Thomas J. Palmisano Site Vice President
- Palisades Plant 27780 Blue Star Memorial Highway Covert, Michigan 49043 Mr. Robert A. Fenech, Sr Vice Pres Nuclear, Fossil, and Hydro Operations Consumers Energy Company 212 West Michigan Avenue Jackson, Michigan 49201 M. I. Miller, Esquire Sidley & Austin 54th Floor One First National Plaza Chicago, Illinois 60603 Mr. Thomas A. McNish Vice President & Secretary Consumers Energy Company 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consumers Energy Company 212 West Michigan Avenue Jackson, Michigan 49201 Regional Administrator, Region Ill U.S. Nuclear Regulatory Commission 801 Warre_nville Road Lisle, Illinois 60532-4351 Jerry Samo Township Supervisor
~overt Township
- 36197 M-140 Highway Covert, Michigan 49043 Office of the Governor Room 1 - Capitol Building Lansing, Michigan 48913 Palisades Plant U.S. Nuclear Regulatory Commission Resident Inspector's Office
-Palisades Plant 27782 Blue Star Memorial Highway Covert, Michigan 49043 Drinking Water and Radiological Protection Division Michigan Department of Environmental Quality 3423 N. Martin Luther King Jr Blvd P. 0. Box 30630 CPH Mailroom Lansing, Michigan 48909-8130 Gerald Chamoff, Esquire Shaw, Pittman, Potts and Trowbridge 2300 N Street, N. W.
Washington DC 20037 Michigan Department of Attorney General Special Litigation Division 630 Law Building P.O. Box 30212 Lansing, Michigan 48909 July 1997
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REQUEST FOR ADDITIONAL INFORMATION REGARDING RELIEF REQUEST RR-4 PALISADES PLANT ISi PROGRAM SUBMITTAL DATED JUNE 3, 1997
- 1. 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) that are 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 a 120-month inspection interval 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 the Code that are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein and subject to Nuclear Regulatory Commission (NRC) approval.
By letter dated June 3, 1997, the licensee submitted two requests for relief from the requirements of the ASME Section XI Code. The available information provided by the licensee has been reviewed by the NRC staff.
- 2. Additional Information Required Based on the above review, the staff has concluded that the following information and/or clarification is required to complete the review of the June 3, 1997, submittal:
A.
Based on the initial review of the Request for Relief No. RR-4, the staff has concluded that either (a) the appropriate paragraph of the Regulations has not been cited, or (b) the regulatory basis has not been adequately supported. Request for Relief RR-4 was submitted pursuant to 10 CFR 50.55a(a)(3) for examinations performed to the extent practical. This request should be reviewed for the correct paragraph of the Regulations to ensure that the request is evaluated in accordance with the appropriate criteria, as discussed below.
The Regulations provide that a licensee may propose an alternative to CFR or Code requirements in accordance with 1 O CFR 50.55a(a)(3)(i) or 10 CFR 50.55a(a)(3)(ii).
Under 10 CFR 50.55a(a)(3)(i), the proposed alternative must be shown to provide an acceptable level of quality and safety, i.e., essentially, be equivalent to the original Enclosure
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I requirement in terms of quality and safety. Under 10 CFR 50.55a(a)(3)(ii), the licensee must show that compliance with the original requirement results in a hardship or unusual.
difficulty without a compensating increase in the level of quality and safety. Examples of hardship and/or unusual difficulty include, but are not limited to, excessive radiation exposure, disassembly of components solely to provide access for examination, and development of sophisticated tooling that would result in only minimal increases in examination coverage.
A licensee may also submit a request for relief from ASME requirements. In accordance with 10 CFR 50.55a(g)(5)(iii), if a licensee determines that conformance with certain Code requirements is impractical for its facility, the licensee shall notify the Commission and submit, as specified in §50.4, information to support that determination*. When a licensee determines that an inservice inspection requirement is impractical, e.g., the examination is limited by physical restrictions and the component would have to be redesigned or replaced to enable inspection, the licensee should cite 10 CFR 50.55a(g)(5)(iii). The NRC may, giving due consideration to the burden placed on the licensee, impose an alternative examination requirement.
B.
- For Request for Relief No. RR-4, the coverage calculations contained in the attached EPRI report are presented in terms of head-side, boss-side and skew angles. It is assumed that these designations represent the four Code-required examination directions (2 axial and 2 circumferential). However, these designations are confusing when considering the circumferential scan directions and the cumulative coverage for the welds. Provide clarification regarding the coverage summary and, if possible, a cumulative coverage for the nozzle-to-vessel welds.
The schedule for timely completion of this review requires that the licensee provide the above
- -equested information and/or clarifications within 30 days of receipt of this request for information.