ML20041E304
| ML20041E304 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 03/03/1982 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| LSO5-82-03-013, LSO5-82-3-13, NUDOCS 8203100350 | |
| Download: ML20041E304 (9) | |
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UNITED S*TATES DISTRIBUTION
,y) g NUCLEAR REG.ULATORY COMMISSION Docket 3 *-
- y WASHING TON, D. C. 20555 NRC PDR March 3,1982 OR Read ng NSIC Docket No. 50-155 DCrutchfield 6" %9 R
n HSmith LS05-82-03-013 REmch s'[u OELD
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OI&E Mr. David VandeWalle gg.F \\
ACRS (10)
,.w' g,9f SEPB
,7 Nuglear Licensing Administrator
.A DChaney
' Consumers Power Company 1945 West Parnall Road y
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GJohnson Jackson, Michigan 49201
Dear Mr. VandeWalle:
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SUBJECT:
BIG ROCK POINT - INSERVICE INSPECTION ( A-01)
We have begun our review of your inservice inspection program. We find that we need additional information in order to complete that review.
Please respond to the enclosed requests for additional information within 30 days of receipt of this letter.
The reporting and/or recordkeeping requirements contained in this letter affect fewer then ten respondents; therefore., OMB clearance is not required under P.L.96-511.
Si cerely, 7 11
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Dennis M. Crutchfield, ief.
Operating Reactors Branch #5 5,(
Division of Licensing
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Enclosure:
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Request for Additional 6
Information gSu O cc w/ enclosure:
See next page 8203100350 020303 PDR ADOCK 05000155 G
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h Mr. David J. VandeWalle March 3,1982 CC I
Mr. Paul A. Perry, Secretary U. S. Environmental Protection Consumers Power Company Agency 212 West Michigan Avenue Federal Activi, ties Branch Jackson, Michigan 49201 Region V OfffEe ATTN:
Regional Radiation Representative Judd L. Bacon, Esquire 230 South Dearborn Str'et Consumers Power Company Chicago, Illinois 60'J4 2.12 West Michigan Avenue Jackson, Michigan 49201 Peter B. Bloch, Chairman Atomic Safety and Licensi.g Board Joseph Gallo, Esquire U. S. Nuclear Regulatory Commission Isham, Lincoln & Beale Washington, D. C.
20555 1120 Connecticut Avenue Room 325 Dr. Oscar H. Paris
. Washington, D. C.
20036 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Peter W. Steketee, Esquire Washington, D. C.
20555 505 Peoples Building Grand Rapids, Michigan 49503
~ Mr. Frederick J. Shon Atomic Safety and Licensing Board Alan S. Rosenthal, Esq., Chairman U. S. Nuclear Regulatory Commission Atomic Sa.fety & Licensing Appeal Board Washington, D. C.
20555 U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Big Rock Point Nuclear ' Power Plant ATTN:
Mr. C. J. Hartman Mr. John O'Neill, II Plant Superintendent Route 2, Box 44 Charlevoix, Michigan 49720 Maple City, Michigan 49664 Chri sta-Maria Charlevoix Public Library Route 2, Box 108C 107 Clinton Street Charlevoix, Michigan 49720 Charlevoix, Michigan William J. Scanlon, Esquire Chairman 2034 Pauline Boulevard County Board of S'upervisors Ann Arbor, Michigan 48103 Charlevoix County Charlevoix, Michigan 49720 Resident Inspector Big Rock Point Plant Office of the Governor (2) c/o U.S. NRC Room 1 - Capitol Building RR #3, Box 600 Lansing, Michigan 48913 Charlevoix, Michigan 49720 Herbert Semmel Mr. Jim E. Mills Counsel for Christa Maria, et al.
Route 2, Box 108C Urban Law Institute Charlevoix, Michigan 49720 Antioch School of Law 263316th Street, NW Washington, D. C.
20460 e
Mr. David J. VandeWalle. March 3,1982 i
cc Dr. John H. Buck Atomic Safety and Licensing Appeal Board U..S. Nuclear Regulatory Commission Washington, D. C.
20555 I
Ms. JoAnn Bier 204 Clinton Street Charlevoix, Michigan 49720 Thomas S'. Moore Atomic Safety and Licensing Appeal Board j
U. S. I!uclear Regulatory Commission Washington, D. C.
20555 James G. Ke'ppler, Regional Administrator Nuclear Regulatory Commission, Region III Office of Inspection and Enforcement 799 Roosevelt Road
-Glen Ellyn, Illinois 60137 i
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REQUEST FOR ADDITIONAL INFORMATION INSERVICE INSPECTION PROGRAM Big Ro*ck Point 1.
Request for Relief, RR-Al (pg II-25, Ref. 1) (B-A; Bl.11, Bl.12)
. Thir. relief request concerns' volumetric examination of longitudinal and circumferential pressure retaining welds in the core region of the reactor vessel. Access to these welds is prevented on the outside by the concrete shield and on the inside by a non-removable thermal shield.
The following additional information is requested:
(a) Identify the por.tions of any welds which might be accessible for examination because of their proximity to any access ports or other penetrations in the concrete shield.
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(b) Is it possible to perform surface or remote visual examination on these welds to supplement volumetric examinations? Please provide an estimate of the percentage of each weld which may be accessib,le
- for these supplementary examinations.
2.
Request for Relief, RR-A2 (pg 11-25', Ref. 1) (B-A; Bl.12)
This relief request concerns volumetric examination-of the longitudinal pressure-retaining welds in the reactor vessel shell above the beltline cir-cumferential weld.
Apparently, these welds are totally inaccessible from the outside due to the' external shield wall, and 70 to 75% of the length of these welds is inaccessible from the inside due to interferences by internal i
components.
For the 25 to 30% of these welds which is accessible from the in-side of the ve sel, no technique is claimed to be available for examination of the longitudinal welds.
The following additional information is requested:
(a) Please identify the techniques -for volumetric examination of the longitudinal w61ds'that you have surveyed which are not appropriate
-for this application, and justify your position that no techniques are available for the examination of the longitudinal welds.
(b) Is it possible to perform surface or remote visual excminations on these welds to supplement volumetric examinations? Please provide 1~
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e an estimate of the percentage of each weld which may be accessible for these supplementary examinations.
3.
Request for Relief, RR-A3 (pg 11-26, Ref. 1) (B-A; Bl.21, Bl.22)
Relief is requested from volumetric examination of the meridional and circumferential welds in the reactor vessel bottom head. The meridional welds are inaccessible from inside the reactor vessel becausE"of the core support l
plate.
Poor geometry due to 40 penetrations on the bottom head makes the meridional welds inaccessible from the outside.
The circumferential shell-to-bottom head weld is not accessible with existing equipment from the inside and the concrete wall prevents inspection from the outside.
The following additional information is requested:
(a) Identify the portions of any welds which might be accessible for examination because of their proximity to any access ports or other penetrations in the concrete shield.
(b) Is it possible to perform surface or remote visual examination on these welds to supplement volumetric examinations? Please provide
, an estimate of the percentage of each weld which may be accessible for these supplementary examinations.
Requests for Relief, RR-A4, 6-9, 11-13 (pgs 11-27-.11-31, Ref. 1) (B-D, 4.
B3.90, B3.100; B-F, B5.10)
These relief requests concern volumetric examination of primary nozzle-to-vessel welds and nozzle inside radius sections (Category B-D) and nozzle-to-safe end welds (Category B-F).
In each case, access from outside the reactor vessel is prevented by the concrete shi. eld.
From the inside, mechanized volumetric-inspection is not possible due to interfert.nces and equipment limitations.
During baffle repair on some of these nozzles, remote visual inspections were completed with no indications noted.
The following additional information is requested:
(a) Are you prepared to commit to a remote visual examination of the accessible areas of these nozzles? Please provide an estimate of the percentage of each area which may be accessible for a. remote visual exam'ination.
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5 5.
Request for Relief, RR-A5 (pg 11-27, Ref.1) (B-D; B3.90, B3.100)
This request for relief applies to surface examinations of these welds and inside radius sections on the14-inch steam outlet nozzles. These nozzles are inaccessible for surface examination, as they are subnerged in shielding water during refueling. Mechanized ultrasonic and visual examinations are pro-posed as alternatives to surface examination of these ar,eas.
Table IWB-2500-1 of.the code (Ref. 2) requires only volumetric examination for these areas.
Since your request states that ultrasonic examination is possible, please explain why you believe a request for relief is necessary for this item.
6.
Request for Relief, RR-A14 (pg 11-31, Ref. 1) (B-H; B8.10)
Relief is requested from volumetric examination of the 12 suspension rod brackets which are integrally welded to the reactor vessel. Their locations are not access'ible to ultrasonic examination equipment.
Access for remote Visual examination was to be explored during the next outage.
The following information is requested:
(a) What information has been learned concerning your ability to perform
, a remote visual inspection in these areas, since Ref. I was issded?
(b) Will you commit to performing remote visual examinations'as alter-natives to the required volumetric examinations?
7.
Requests for Relief, RR-A15, 16 (pgs II-32, 33, Ref. 1).(B-H; B8.10)
Relief is requested from volumetric examination of the vessel hanger lugs and stabilizer brackets. The locations of these items make them inacce'sible s
to volumetric examination.
These components are said to be non-load-bearing in that undsr normal operation they are subjected to no shear stresses.
Defects in these welds are claimed to have minimal effect on the components' support functions.
The~following additional information is requested:
(a) The welds.which attach these support components to the vessel are under tension as is the base material of the vessel.
These welds are also areas of stress concentration; please show why a flaw in one of these welds would not propagate to-the vessel base material and, therefore, affect the primary pressure boundary.
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(b) Have you considered a rigorous remote visual inspection program as an alternative to the volumetric examination of these welds?
j 8.
Requests for Relief, RR-A17,'18, 19 (pgs 11-33, 34, 35, Ref. 1) (B-N-2; B13.20)
I i
The code requires visual examination of the sparger and core spray supports, the thermal shield supports and inlet diffuser be acket,' and the core support T
' brackets as they become accessible during a normal refueling _ outage.
With the I
i exception of items which were made actssible for other reasons, your requests 1
for relief propose the visual examinat. ion of onlf accessible. portions of the components.
Your requests appear to be consistent with the code requirements of Ref. 2, Table IUB-2500-1 for this item.
Please state why relief from code requirements is necessary on these items.
t 9.
Request for Relief, RR-A20 (pg 11-35, Ref. 1) (B-B; B2.51, B2.52) i
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Request for Relief, RR-A21 (pg II-37, Ref. 1) (B-D; B3.150, B3.160)
Request for Relief, RR-A29 (pg II-43, Ref. 1) (B-H; B8.40)
These requests for relief apply to examination of various welds on the steam drum.
Concern is expressed that very high radiation exposures would result from performing these code. examinations on all required welds of the steam drum.
Alternatively, it is proposed that only welds in these groups which are located on top of-the steam drum within 30 degrees either side of top-dead-center should be examined.
The proposed examinations are sa'id to-give sufficient information as to the integrity of the steam drum.
Please f
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provide 'rawings of the steam drum which show the locations of the longitudi-nal and circumferential welds, and the locations of all the. penetrations and their details. Drawings showing' the location and detail.s of the steam drum supports should also be provided.
If these drawings have previously been furnished to thc NRC, please document by reference.
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- 10.. Request for Relief, RR-A24 (pg 11-39, Ref. 1) (B-D; B3.150, B3.160) t Relief is requested to exempt inside radius sections of the cleanup de-mineralizer tank nozzles from volumetric inspection requirements.
The demin-eralizer tank nozzles are fabricated by welding square-ended pipe nipples into the tank shel'l.
The portion of the pipe nipple corresponding to a nozzle inside radius section has a radius of essentially zero, and apparently cannot be UT l
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inspected.
It is also noted that these nozzles are not subjected to the l
tnermal cycling stresses common ta other primary system components because the inlet temperature is required to be less than 110 F.
For this reason, it is claimed that the examinations are not required.
The following additional information is re' quested:
(a) Provide justification for your position that the,se examinations are not required for components that do not experience significant thermal cycling.
(b) Provide an estimate of the additional radiation exposure which would be incurred if these inspections, along with the remainder of the Category B-D testing, were to be attempted.
11.
Request for Relief, 'RR-A30 (pg 11-44, Ref.1) (B-F; B5.50)
Request for Relief, RR-A33 (pg 11-46, Ref. 1) (B-J; B9.11)
Request for Relief, RR-A34 (pg 11-47, Ref. 1) (B-J; B9.21)
Request for Relief, RR-A36 (pg 11-49, Ref. 1) (B-K-1;-B10.10)
These requests for relief apply to nondestructive testing of the following pipe welds:
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(a) 6-SCS-101-1 thru 12 (c) 12-MSS-105-9 and 10 (b) 4-SCS-101-17 thru 19 (d) 3-LPS-102-18 thru 23 and the following pipe attachment welds:
(e) 14-MRS-103-3PL-1 thru 8 (f) 14-MRS-105-3PL-1 thru 8.
Relief is requested from examination of these welds due primarily to various combinations of long vertical drop with attendant inaccessibility and high radiation fields.
The following additional information is requested:
(a) For each of the systems listed above, provide the percentage of welds which can be inspected.
(b) Provide more details on why scaffolding cannot be built on a sloping
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floor with proper restraints.
(c) Provide more information on the methods that were considered for reaching the welds with long, vertical drops.
Also, based on current industry safety standards, show why each of these methods was rejected.
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e 12.
Request for Relief, RR-A39 (pg 11-52, Ref. 1) (B-L-1; B12.10)
This item concerns volumetric and' surface examination of cleanup pump 1
and main recirculation pump casing welds. Relief from these requirements is
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not requested because the locations of the welds in thc e pump casings cannot be determined.
'The following additional information is required:
(a) To date, have you determined the locations of these welds? Have you determined whether or not relief from volumetric examination require-ments is required?
(b) If relief is required, show why ultrasonic examination of these welds cannot be performed.
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. 13.
Request for Relief, RR-A40 (pg 11-53, Ref.1) (B-M-2; B11.4'0)
Relief is requested from these requirements to visually inspect the internal surfaces of various main recirculation pump discharge and butterfly i
I valves.
Examination of the valves requires canplete draining o'f the reactor vessel.
Are you prepared to commit to a visual inspection of any of these valves'. internals if they are required to be disassembled for maintenance?
REFERENCES:
1.
Consumers Power Company letter, Proposed Request for Relief from Provisions
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of ASME B&PV Code - Section XI, Pursuant to 10CFR50 Section 50.55a(g)(6)(i),
November 17, 1980, Rev. 1.
2.
ASME Boiler and Pressure Vessel Code,Section XI, Division 1,1977 Edition with addenda.through Summer 1978.
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