ML20133B428

Requests Addl Info Re Plant Third 10-yr ISI Program Plan Associated Requests for Relief from ASME Boiler & Pressure Vessel Code,Section Xi.Response to Be Submitted within 60 Days of Ltr Receipt

ML20133B428
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	12/31/1996
From:	Linh Tran NRC (Affiliation Not Assigned)
To:	Donnelly P CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
TAC-M96210, NUDOCS 9701030174
Download: ML20133B428 (6)

Text

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December 31, 1996 Mr. Patrick M. Donnelly, Plant Manager l

Big Rock Point Plant Consumers Power Company 10269 U.S. 31 North Charlevoix, MI 49720

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING THE BIG ROCK POINT PLANT THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN ASSOCIATED REQUESTS FOR RELIEF (TAC NO. M96210)

Dear Mr. Donnelly:

The staff, with assistance from its contractor, Idaho National Engineering Laboratory (INEL), is reviewing and evaluating the third 10-year interval i

inservice inspection program plan associated requests for relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI requirements for the Big Rock Point Plant.

In order for the staff to continue and complete its review, we need additional information'and ask that.you reply to the enclosed RAI. We request that you respond within 60 days of receiving this letter.

1 In' addition, to expedite the review process, please send a copy of the RAI l

response to our contractor, INEL, at the following address:

4 Michael T. Anderson 4

INEL Research Center 2151 North Boulevard PO Box 1625 t

[

Idaho Falls, Idaho 83415-2209 If you have any questions regarding this matter, please do not hesitate to contact me at (301) 415-1361.

Sincerely, i

Original signed by 4

i Linh N. Tran, Project Manager Project Directorate 111-1 Division of Reactor Projects - III/IV Office of Nuclear Reactor Regulation Docket No. 50-155 j

Enclosure:

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December 31, 1996

't Mr. Patrick M. Donnelly, Plant Manager Big Rock Point Plant Consumers Power Company 10269 U.S. 31 North Charlevoix, MI 49720

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING THE BIG ROCK POINT PLANT THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN ASSOCIATED REQUESTS FOR RELIEF (TAC NO. M96210)

Dear Mr. Donnelly:

The staff, with assistance from its contractor, Idaho National Engineering Laboratory (INEL), is reviewing and evaluating the third 10-year interval inservice inspection program plan associated requests for relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI requirements for the Big Rock Point Plant.

In order for the staff to continue and complete its review, we need additional information and ask that you reply to the enclosed RAI. We request that you respond within 60 days of receiving this letter.

4 1

In addition, to expedite the review process, please send a copy of the RAI response to our contractor, INEL, at the following address:

Michael T. Anderson INEL Research Center 2151 North Boulevard PO Box 1625 Idaho Falls, Idaho 83415-2209 4

If you have any questions regarding this matter, please do not hesitate to contact me at (301) 415-1361.

Sincerely, YT%

Linh N. Tran, Project Manager Project Directorate III-1 Division of Reactor Projects - III/IV Office of Nuclear Reactor Regulation Docket No. 50-155 4

Enclosure:

RAI cc w/ encl: See next page

Mr. Patrick M. Donnelly, Plant Manager Big Rock Point Nuclear Plant cc:

Mr. Thomas A. McNish Michigan Department of Attorney Vice President & Secretary General Consumers Power Company Special Litigation Division 212 West Michigan Avenue 630 Law Building Jackson, Michigan 49201 P.O. Box 30212 Lansing, Michigan 48909 Judd L. Bacon, Esquire Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Jane E. Brannon, County Clerk County Building Annex 203 Antrim Street Charlevoix, Michigan 49720 Office of the Governor Room 1 - Capitol Building Lansing, Michigan 48913 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Drinking Water and Radiological Protection Division Michigan Department of Environmental Quality 3423 N. Martin Luther King Jr Blvd P. O. Box 30630 CPH Mailroom Lansing, Michigan 48909-8130 U.S. Nuclear Regulatory Commission Resident Inspector's Office Big Rock Point Plant l

10253 U.S. 31 North Charlevoix, Michigan 49720 Mr. Robert A. Fenech Vice President-Nuclear Operations Palisades Plant 27780 Blue Star Memorial Hwy.

Covert, Michigan 49043 l

i he 1996 N

l

. _. ~.

I REQUEST FOR ADDITIONAL INFORMATION i

RELATED T0 i

THIRD 10-YEAR INTERVAL INSERVICE INSPECTION (ISI) REQUEST FOR RELIEF l

FOR j

CONSUMERS P0NER COMPANY i

SIG ROCK P0 INT PLANT D0CKET EMBER 50-155 i

1.

Scone / 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 l

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 j

examination requirements, set forth in the ASME Code Section XI, " Rules for Inservice 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.

The staff, with assistance from their contractor, have reviewed the information provided by the licensee in the July 18, 1996, submittal. This submittal included the requests for relief from the ASME Code Section XI requirements that the licensee has determined to be impractical.

2.

Additional Information Reauired Based on the above review, the staff have concluded that the following information and/or clarification is needed to complete the review of the ISI Program Plan:

-A.

Based on the initial review of the licensee's submittal, the staff have concluded that appropriate paragraphs of the regulations have not been referenced in all cases.

For each of Requests for Relief RR-A15 through RR-A22, cite the appropriate paragraph of the regulations to ensure that the request is evaluated in accordance with the appropriate criteria, as discussed below. Verify that the regulatory basis has been adequately supported.

The regulations provide that a licensee may propose an alternative to CFR or Code requirements in accordance with 10 CFR 50.55a(a)(3)(1) or 10 CFR 50.55a(a)(3)(ii).

Under 10 CFR 50.55a(a)(3)(1), the proposed alternative Enclosure

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.must be shown to provide an acceptable level of quality and safety, i.e.,

i essentially, be equivalent to the original requirement in terms of quality i

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 i

i difficulty without a compensating increase in the level of quality and l

safety.

Examples of hardship and/or unusual difficulty include, but are

.not limited to, excessive radiation exposure, disassembly of com>onents solely to provide access for examination, and development of sop 11sticated 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 Commusion and submit, as specified in 10 CFR 50.4, information to support that determination. When a licensee determines that an inservice inspection requirement is impractical, e.g., the system would have to be redesigned, or a component t

would have to be 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 each of Requests for Relief RR-A15 through RR-A22, describe how volumetric examination coverage is determined at Big Rock Point Plant and confirm that the subject welds have been examined in four directions to the extent

~.ctical.

In each of these requests, the angle beam coverage is presen m.a terms of "two directional coverage achieved." However, there is no indication of which two of the four required directions (two axial and two circumferential) have been examined.

The examination

)

requirements for the subject welds are contained in Section V, Article 4,

)

Paragraph T-441.3.2.5, Angle Beam Scanning, which states (in part):

"The examination volume shall be scanned with angle beam search units directed both at right angles to the weld axis and along the weld axis. Wherever feasible, each examination shall be performed in two directions, i.e., approaching the weld from opposite directions and parallel to the weld from opposite directions. These examinations shall be conducted using two beam angles (nominal 45' and 60') from each direction."

C.

For Requests for, Relief RR-16, RR-A18, RR-A19, RR-A20, RR-A21 and RR-A22, provide a detailed technical discussion, including drawings if necersary, describing the component and the factors limiting examination.

Considering that the coverage achieved was low for each of these requests (e.g., <50%), describe how reasonable assurance of continued structural integrity will be provided for'the subject welds.

D.

Provide a listing of the specific welds included in each of Requests for i

Relief RR-A18 through RR-A22.

d 3

1 E.

In accordance with 10 CFR 50.55a(c)(3), 10 CFR 50.55a(d)(2), and 10 CFR 50.55a(e)(2), ASME Code cases may be used as alternatives to Code requirements.

Code cases that the NRC has approved for use are listed in i

Regu1 story Guide 1.147, Inservice Inspection Code Case Acceptability, with any additional conditions deemed necessary by the NRC. Code Cases Dal l

referenced in Regulatory Guide 1.147 may be adopted only if authorized by the NRC on a case-by-case basis.

In some cases, use of unapproved Code Cases may be acceptable for use when certain conditions are included. To ensure consistent implementation, licensees proposing the use of currently unapproved Code Case (s), must commit to such conditions, if applicable.

1 In Request for Relief RR-A23, the licensee has proposed to implement the alternatives contained in ASME Code Case N-522, Pressure Testing of Containment Penetration Piping for Class 2 containment penetrations associated with non-safety class systems. This Code Case may be considered acceptable for use with the following conditions:

a) The leak test is performed at the peak calculated containment design pressure; and 1

b) a test procedure is used that provides for detection and location of i

through-wall leakages in the pipe segments that are being tested.

i In order to authorize the proposed alternative, incorporation of the above conditions into Request for Relief RR-23 is necessary. Confirm that the conditions stated above will be met.

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