ML18068A524

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Resubmits Relief Request 12,with Addl Info That Includes Specific Locations Where Relief Request Would Be Applied,Per 10CFR50.55a(g)(5)(iii)
ML18068A524
Person / Time
Site: Palisades 
Issue date: 02/12/1999
From: Haskell N
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-255-98-06, 50-255-98-6, NUDOCS 9902250027
Download: ML18068A524 (7)


Text

A CMS Energy Company February 12, 1999 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, Ml 49043 Tel: 616 764 2276 Fax: 616 764 2490 Nathan L. Ha*lcell Director, Licensing DOCKET 50-255 - LICENSE DPR PALISADES PLANT REVISION OF INSERVICE INSPECTION RELIEF REQUEST NO. 12 In a letter dated October 6, 1998, Consumers Energy submitted Relief Request (RR)

No. 12 for the Palisades' lnservice Inspection (ISi) Program. This relief request was in response to an inspector follow up* item noted during a NRC Inspection (50-255/98006) of the ISi Program.

RR No. 1.2 is being resubmitted with additional information as requested by the NRC.

This additional information includes the specific locations where the relief request would be applied..

This relief request is being submitted pursuant to the requirements of 10 CFR 50.55a(g)(5)(iii) since the configuration of the weld joints in question will not allow access to both sides of the welds for the two direction axial examination. A two-sided examination is therefore considered to be impractical.

SUMMARY

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

Nathan L. Haskell Director, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades 0 ?, '0 \\) *~ ~)

~-

Attachment

ATTACHMENT CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 REVISION OF INSERVICE INSPECTION RELIEF REQUEST NO. 12 5 Pages

RELIEF 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, B-F, C-F-1 and C-F-2 89.11, 89.31, 85.130, C5.11, C5.21 and C5.51 Pressure Retaining Welds in Piping In accordance with ASME Section XI, 1989 Edition, table IWB-2500-1 and IWC-2500-1 a surface and volumetric examination is required on 100% of the weld length as identified below:

A.

B.

C.

D.

E.

F.

B-J/89.11 B-J/89.31 B-F/85.130 C-F-1/C5.11 C-F-1/C5.21 C-F-2/C5.51 BASIS FOR RELIEF Nominal pipe size 4 inch or larger circumferential welds.

Nominal pipe size 4 inch or larger branch pipe connection welds.

Nominal pipe size 4 inch or larger dissimilar metal butt welds.

Austenitic or high alloy piping welds ;:: 3/8 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 welds ;:: 3/8 inch nominal wall thickness for piping > 4 inch nominal pipe size.

Pursuant to 10 CFR 50.55a(g)(5)(iii), the code required volumetric examinations by ultrasonic examination from both the upstream and downstream direction of the welds are considered to be impractical at certain terminal ends and structural discontinuities. Refer to Attachment A, "Single Side Axial Examinations" for a listing of the welds associated with this relief request.

1

RELIEF REQUEST NUMBER RR-12 In accordance with ASME 1989 Edition,Section XI, Appendix Ill, ArtiCle 111-4100, a 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.

The code required volumetric examinations are performed utilizing pulse-echo ultrasonic examination techniques. The access limitations from either the upstream or downstream directions do not allow the required axial ultrasonic angle beam examination. The code required transverse ultrasoniq angle beam examinations required by Appendix Ill, Article 4430 are not limited. For the welds identified in Attachment A, "Single Side Axial Examinations", which are scheduled for examination during the third interval, the examination volume is limited to access from only one side of the weld seam when scanning from the axial direction.

It has been well established that detection of a substantial number of inner granular stress corrosion cracks (IGSCC) located on the far side of the weld cannot be detected with suitable reliability, using the best available technology. This conclusion is based on the performance of the Electric Power Research Institute (EPRI) Performance Demonstration Initiative (POI) candidates, EPRI experience on field removed samples and a EPRI research project. Suitable reliability for this purpose as defined by EPRI I POI is 80%

detection with a false call rate less than 20%. This rate is obtainable for mechanical and thermal fatigue cracks, but not for IGSCC. As identified by EPRI I POI, the single sided endorsement for the examination of any austenitic weld where the ultrasonic beam is required to propagate through the austenitic weld material is applicable only to welds where ultrasonic examination from both sides of the weld are impossible due to the configuration (i.e. pipe to valve, pump, penetration, etc.).

The 23 similar metal welds associated with this relief request are not susceptible to any known IGSCC. The 4 dissimilar metal (Austenitic to lnconel) welds are potentially susceptible to primary water stress corrosion cracking (PWSCC). The other 4 dissimilar metal (Austenitic to Ferritic) welds are not susceptible to IGSCC. Currently, no POI dissimilar metal weld examination qualification program has been established by EPRI.

Therefore, for the Austenitic to lnconel ~elds the austenitic techniques will be used by EPRI I POI qualified examination personnel with a single sided austenitic endorsement.

The Austenitic to Ferritic dissimilar welds, which are limited to access from the ferritic side of the weld, will be examined using EPRI I POI qualified personnel and techniques for single sided ferritic.

2

RELIEF REQUEST NUMBER RR-12 Proposed Alternative Examination Where the component configuration will not allow an ultrasonic angle beam examination for the axial scans (upstream and downstream), the following will be performed (which is the best available technology as demonstrated through the EPRI I POI program):

A.

For the similar metal welds, 100% of the required volume will be examined in one axial direction by ultrasonic examination using personnel and techniques qualified through the EPRI I POI Program for single sided access relating to the material type to be examined.

B.

For the Austenitic to lnconel dissimilar metal welds, 100% of the required volume will be examined in one axial direction by ultrasonic examination using personnel and techniques qualified through EPRI I POI program for single sided austenitic.

C.

For the Austenitic to Ferritic dissimilar metal welds, 100% of.the required volume will be examined in one axial direction by ultrasonic examination using personnel and techniques qualified through EPRI I POI program for single sided ferritic.

0.

100% of the required volume for the transverse scans will be performed in both directions as required by Appendix Ill, Article 4430.

E.

The code required surface examination will be performed.

3

RELIEF REQUEST NUMBER RR-12 ATTACHMENT A SINGLE SIDE AXIAL EXAMINATIONS Component Reference ID Configuration Material T~pe ESS~12-SIS-1A1-10 Tee to Valve Austenitic ESS-12-SIS-1A1-9 Valve to Tee Austenitic ESS-12-SIS-1 B1-13 Valve to Tee Austenitic ESS-12-SIS-1 B1-14 Tee to Valve Austenitic ESS-12'-SIS-2A 1-12 Valve to Tee Austenitic ESS-12-SIS-2A 1-13 Tee to Valve Austenitic ESS-12-SIS-2B1-12 Valve to Tee Austenitic ESS-12-SIS-2B 1-13 Tee to Valve Austenitic PCS-4-PRS-1 P2-3 Pipe to Fitting Austenitic PCS-42-RCL-1 H-3/12 Branch Connection Ferritic PCS-42-RCL-2H-3/12 Branch Connection Ferritic PCS-30-RCL-1A-11/12 Branch Connection Ferritic PCS-30-RCL-1 B-10/12 Branch Connection Ferritic PCS-30-RCL-2A-11/12 Branch Connection Ferritic PCS-30-RCL-2B-10/12 Branch Connection Ferritic PCS-12-SIS-1A1-11 Valve to Safe End Austenitic/lnconel PCS-12-SIS-1B1-15 Valve to Safe End Austenitic/lnconel PCS-12-SIS-2A 1-14 Valve to Safe End Austenitic/lnconel PCS-12-SIS-2B 1-14 Valve to Safe End Austenitic/lnconel PCS-30-RCL-1A-9 Pump to Transition Austenitic/Ferritic PCS-30-RCL-1 B-9 Pump to Transition Austenitic/Ferritic PCS-30-RCL-2A-10 Pump to Transition Austenitic/Ferritic PCS-30-RCL-2B-9 Pump to Transition Austenitic/Ferritic ESS-12-SIS-1A1-8 Elbow to Valve Austenitic ESS-12-SIS-1 B1-12 Elbow to Valve Austenitic ESS-12-SIS-2A1-11 Elbow to Valve Austenitic ESS-12-SIS-2B1-11 Elbow to Valve Austenitic Section XI Cat / Item B-J I B9.11 B-J I B9.11 B-J I B9.11 B-J I B9.11 B-J I B9.11 B-J I B9.11 B-J I B9.11 B-J I B9.11 B-J I B9.11 B-J I B9.31 B-J I B9.31 B-J I B9.31 B-J I B9.31 B-J I B9.31 B-J I B9.31 B-F I B5.130 B-F I B5.130 B-F I B5.130 B-F I B5.130 B-F I B5.130 B-F I B5.130 B-F I B5.130 B-F I B5.130 C-F-1 I C5.11 C-F-1 I C5.11 C-F-1 I C5.11 C-F-1 I C5.11

RELIEF REQUEST NUMBER RR-12 ATTACHMENT A SINGLE SIDE AXIAL EXAMINATIONS Comgonent Reference ID Configuration Material T¥ge ESS-3-SIS-CRA-214 Pipe to Valve Austenitic ESS-3-SIS-CRA-215 Valve to Reducer Austenitic FWS-18-FWL-1S1-246 Pipe to Valve Ferritic FWS-18-FWL-281-245 Elbow to Valve Ferritic Section XI Cat I Item C-F-1 I C5.21 C-F-1 I C5.21 C-F-2 I C5.51 C-F-2 I C5.51