ML18067A786

Forwards Response to 971017 RAI Re ISI Program Relief Request RR-4

ML18067A786
Person / Time
Site:	Palisades
Issue date:	11/14/1997
From:	Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9711240291
Download: ML18067A786 (5)

Text

A CMS Energy Company 11Joma* t:. Bordlml Manager Licensing November 14, 1997 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

• DOCKET 50-255 - LICENSE DPR PALISADES PLANT RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION - INSERVICE INSPECTION PROGRAM RELIEF REQUEST RR-4 In a Safety Evaluation Report dated January 9, 1997, the NRC denied the Palisades lnservice Inspection Relief Request (RR) Number 4 on the basis that it provided estimated information rather than actual information. RR-4 concerned the lnservice Examination coverage of the Palisades Steam Generator nozzle~to-head welds. On June 3, 1997, RR-4 was resubmitted with the actual coverage information developed by EPRI. In a letter dated October 17, 1997, theNRC transmitted a request for additional information concerning RR-4 ..

The attachment to this letter contains the NRC requested items and provides our response to each item.

As requested in the NRC letter dated October 17, 1997, a copy of this submittal is being sent directly to the NRC's contractor, Idaho National Engineering and Environmental

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Michael T. Anderson .

INEEL Research Center 2151 North Boulevard I \

P.0.Box 1625 Idaho Falls,* Idaho 83415-2209 9711240291:1 971114 I1 j1 .....

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SUMMARY

OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.

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Thomas C. Berdine Manager, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Mr. Michael T. Anderson, INEEL Attachment

ATTACHMENT CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION INSERVICE INSPECTION PROGRAM RELIEF REQUEST RR-4 2 Pages

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION INSERVICE INSPECTION PROGRAM RELIEF REQUEST RR-4 NRC REQUESTED INFORMATION (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 of Code requirements in accordance with 10 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 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.

CONSUMERS ENERGY RESPONSE (A) Consumers Energy has reviewed Request for Relief No. RR-4 for the Steam Generator nozzle-to-head welds and determined that the appropriate paragraph of ls o

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examination coverage limitations due to physical restrictions or the alternative of the component requiring redesign or replacement to enable the ASME Code required examination. The basis for the relief request was provided in the June 3, 1997, submittal.

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RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION INSERVICE INSPECTION PROGRAM RELIEF REQUEST RR-4 NRC REQUESTED INFORMATION (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 reqarding the coverage summary and, if possible, a cumulative coverage for the nozzle-to-vessel welds.

CONSUMERS ENERGY RESPONSE (8) Identified below is clarification of the coverage calculations performed on the Palisades Steam Generator inlet and outlet nozzles. The directions indicated in the tables are the four code-required examination directions.

Request for Relief No. RR-4 is applicable to the following welds: 1-104-251, 1-102-251A, 1-102-2518, 2-104-351, 2-102-351A and 2-102-3518.

Inlet Nozzle to Shell Welds -Weld Number(s): 1-104-251 and 2-104-351 Percent of total weld exam volume covered:

45 ° and 60 ° Axial Scans from the shell side 79%

45 ° and 60 ° Axial Scans from the nozzle side 0%

45° and 60° Transverse Scans from the shell 63%

45° and 60° Transverse Scans from the nozzle 0%

Cumulative Coverage of Code Required Volume 35.5%

Outlet Nozzle to Shell Welds - Weld Number(s):

1-102-251A, 1-102-2518, 2-102-351A and 2-102-3518 Percent of total weld exam volume covered:

45 ° and 60 ° Axial Scans from the shell side 74%

45 ° and 60 ° Axial Scans from the nozzle side 0%

45° and 60° Transverse Scans

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the shell side 47%

45° and 60° Transverse Scans from the nozzle side 0%

Cumulative Coverage of Code Required Volume . 30.25%

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