ML18057A328

Responds to Request for Addl Info Re Second 10-yr Interval Insp Program,Per 900418 Telcon.Util 900329 Response Revised to Reflect That Certain Components in Class 2 Sys Should Not Be Exempted,Per IWC-1220 of 1974 ASME Code Section XI

ML18057A328
Person / Time
Site:	Palisades
Issue date:	07/13/1990
From:	Smedley R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9007170130
Download: ML18057A328 (13)

Text

consumers Power POWERINli MICHlliAN'S PROliRESS General Offices: 212 West Michigan Avenue, Jackson, Ml 49201 * (517) 788-0550 July 13, 1990 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

RESPONSE TO PALISADES SECOND TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM REQUEST FOR ADDITIONAL INFORMATION (TAC NO 72622)

Consumers Power Company was informed during a telephone conference call on April 18, 1990 that additional information and changes to our March 29, 1990 response were required. These changes were necessary to enable the NRG staff to complete their review and evaluation of the Palisades Inservice Inspection Program which was originally submitted to the NRG on December 19, 1988.

Consumers Power Company's response to the concerns identified during the telephone conference call are detailed in Attachment 1.

Consumers Power Company agrees that certain components in Class 2 systems should not be exempted per IWC-1220 1974S75 Section XI of the ASME Code.

Therefore, it was necessary to revise our March 29, 1990 submittal to incor-porate the comments received during our April 18, 1990 telephone conference.

Changes were required in the Class 2 exam tables, the previous line size exemption was removed from regenerative heat exchanger Class 2 shell welds.

Items 2D and 2E from our March 29, 1990 letter have been revised to remove the previous exclusions which had been taken on Emergency Core Cooling subsystems, Containment Spray System and the Class 2 pumps. Items 2H and 2I from our March 29, 1990 have also been revised.

OC0790-0790-NL02 A CMS" ENERGY COMPANY

As requested by the NRC staff, a copy of this information is being forwarded to Boyd W Brown, Idaho National Engineering Laboratory, P 0 Box 1625, Idaho Falls, Idaho 83415-2209, in order to expedite the review.

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Richard W. Smedley Staff Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachments OC0790-0790-NL02

ATTACHMENT 1 Consumers Power Company Palisades Plant Docket 50-255 RESPONSE TO NRC QUESTIONS ON SECOND TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM July 13, 1990 7 Pages OC0790-0790-NL02

1 NRC CONCERN Regenerative heat exchanger E-56A and E-56B have been excluded from examination requirements based on Section XI, IWC-1220(c).

CPCo RESPONSE The Class 2 portion of the regenerative heat exchanger was previously exempted from examination based on the inlet nozzle line size being less than four inches. During the telecon it was pointed out that this line size exemption was taken in error. Therefore, the Class 2 examination tables are being revised to include circumferential shell welds numbers 01 and 02 on heat exchanger E-56A for examination during the second, third and fourth intervals. Also, vessel supports S-02 and S-03 on E-56A have been added to the examination schedule during the second, third and fourth intervals. The nozzle welds are exempted from examination, per Section XI, Category C-B, footnote (2).

On vessel E-56B the Section XI, Category C-A welds will not be examined as allowed by footnote (3) of this category. The vessel supports on E-56B will not be examined as allowed by Section XI, IWF-2510 (b).

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2 NRC CONCERN Item 2. D., from Consumers Power Company letter to the NRC dated March 29, 1990 applied the pressure temperature exclusion from the 1974 edition, Sununer 1975 addenda of Section XI, paragraph IWC-1220(a) to three subsystems attached to the SIRW Tank. This system is part of an emergency core cooling system and this exclusion should not be applied to these subsystems.

CPCo RESPONSE This exclusion has been removed from these three subsystems and examinations are now scheduled for the welds and hangers for all three lines. Table Al has also been revised to reflect this change (Attachment 2).

The three affected lines are:

ESS-6-SIS-CRH Line is found on page 451 in the exam tables.

ESS-6-SDC-REl Line is found on page 435 in the exam tables.

ESS-6-SRT-REl Line is found on page 461 in the exam tables.

On line ESS-6-SIS-CRH weld numbers 214, 215, 225, 226, 237, 238, 242 and 243 have been scheduled for examination during the second, third and fourth intervals. Additionally, all pipe hangers on this line are now scheduled for examination during the second, third and fourth intervals.

On line ESS-6-SDC-REl weld numbers 210, and 204 have been scheduled for exam-ination during the second, third and fourth interval Additionally, pipe hanger 207 PR is also scheduled for examination during the second, third and fourth intervals.

On line ESS-6-SRT-REl weld number 201 has been scheduled for examination during the second, third and fourth intervals.

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3 NRC CONCERN Item 2. E., from Consumers Power Company letter to the NRC dated March 29, 1990 determined that the Containment Spray System did not perform an emergency core cooling function and was not required to be tested as allowed by Section XI, 1974 edition Summer 1975 addenda, paragraph IWC-1220(b). 10CFRS0.55a(b) (2)

(iv) requires that pipe welds in CHR systems be examined. This federal regulation takes precedence over the Section XI paragraph. Verify that the ISI Program will be revised to include a representative sample of welds in the Containment Spray System.

CPCo RESPONSE This exclusion has now been removed from this system and an appropriate sampling of welds and pipe restraints have been added to the examination tables.

The affected lines are:

ESS-14-CSS-lPA Line is found on page 325 in the exam tables.

ESS-14-CSS-lPB Line is found on page 330 in the exam tables.

ESS-14-CSS-lPC Line is found on page 336 in the exam tables.

ESS-10-CSS-lPA Line is found on page 326 in the exam tables.

ESS-10-CSS-lPB Line is found on page 333 in the exam tables.

ESS-10-CSS-lPC Line is found on page 339 in the exam tables.

ESS-8-CSS-lPA Line is found on page 327 in the exam tables.

ESS-8-CSS-lPB Line is found on page 334 in the exam tables.

ESS-8-CSS-lPC Line is found on page 340 in the exam tables.

ESS-6-CSS-lPA Line is found on page 327 in the exam tables.

ESS-6-CSS-lPB Line is found on page 334 in the exam tables.

ESS-10-CSS-1P3 Line is found on page 426 in the exam tables.

ESS-8-CSS-TCA Line is found on page 432 in the exam tables.

ESS-10-CSS-SLA Line is found on page 409 in the exam tables.

ESS-10-CSS-SLB Line is found on page 417 in the exam tables.

ESS-8-CSS-SLA Line is found on page 410 in the exam tables.

ESS-8-CSS-SLB Line is found on page 418 in the exam tables.

ESS-8-CSS-SLA Line is found on page 412 in the exam tables.

ESS-8-CSS-SLB Line is found on page 421 in the exam tables.

ESS-6-CSS-SLA Line is found on page 412 in the exam tables.

ESS-6-CSS-SLB Line is found on page 420 in the exam tables.

There are 237 category C-F welds contained within these lines and 31 (13%) of these welds have been scheduled for examination during the second, third and fourth intervals.

The following is a line by line summary for each line with scheduled weld and pipe hanger examinations.

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4 On line ESS-14-CSS-SLA weld numbers 201, 201LI, 201LO, 202, 202LW, 203, 203LI, 203LO and 208 have been scheduled for examination during the second, third and fourth intervals. Additionally, all pipe hangers on this line are now scheduled for examination during the second, third and fourth intervals.

On line ESS-10-CSS-lPA weld numbers 209 and 227 have been scheduled for exam-ination during the second, third and fourth intervals.

On line ESS-10-CSS-lPB both pipe*hangers have been scheduled for examination during the second, third and fourth intervals.

On line ESS-8-CSS-lPA weld numbers 211, 212, 212PL-1, 212PL-2, 212PL-3, 212PL-4, 213, 214 and 215 have been scheduled for examination during the second , third and fourth intervals. Additionally, all pipe hangers on this line are now scheduled for examination.

On line ESS-6-CSS-lPA weld number 211 has been scheduled for examination during the second, third and fourth intervals.

On line ESS-10-CSS-1P3 weld number 201 has been scheduled for examination during the second, third and fourth intervals. Additionally, both pipe hangers on this line are now scheduled for examination.

On line ESS-8-CSS-TCA weld number 201 has been scheduled for examination during the second, third and fourth intervals.

On line ESS-10-CSS-SLA weld numbers 201 and 210 have been scheduled for examination during the second, third and fourth intervals. Additionally, pipe support 207PS and pipe hanger 207PR are now scheduled for examination.

On line ESS-8-CSS-SLA (Page 410) weld numbers 211, 213 and 219 have been scheduled for examination during the second, third and fourth intervals.

On line ESS-8-CSS-SLA (Page 412) weld numbers 223, 226, 228, 229, 234 and 235 have been scheduled for examination during the second, third and fourth intervals. Additionally, all pipe hangers on this line are now scheduled for examination during the second, third and fourth intervals.

On line ESS-6-CSS-SLA weld number 221 and pipe hanger 221PR have been scheduled for examination during the second, third and fourth interval.

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5 NRC CONCERN Page 40, from Consumers Power Company letter to the NRC dated March 29, 1990 applied the pressure and temperature exclusion and the controlled chemistry exemptions from the 1974 edition, Summer 1975 addenda of Section XI, paragraphs IWC-1220(a) and (c) to the Containment Spray Pumps, Charging Pumps, Concentrated Boric Acid Pumps, High Pressure Safety Injection Pumps and Low Pressure Safety Injection Pumps. These systems are part of the emergency core cooling and containment heat removal systems and should not have these exemptions applied to these pumps.

CPCo RESPONSE Page 40 from our March 29, 1990 letter, (Attachment 2) has been revised to eliminate these exclusions. Examinations are now scheduled f*or these pumps.

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6 NRC CONCERN Consumers Power Company response to Item 2.H. in CPCo letter dated March 29, 1990 needs to be revised to indicate that the intent of USNRC Regulatory Guide 1.150 will be met when examining reactor pressure vessel welds.

CPCo RESPONSE Consumers Power Company has adopted the position on USNRC Regulatory Guide 1.150 that has been developed by Westinghouse Electric Corporation. This position is incorporated in the Westinghouse procedure, CPAL-ISI-154, Revision 2, used for the performance of this testing. This procedure meets the intent of all the requirements specified in USNRC Regulatory Guide 1.150 for testing reactor vessel welds. Westinghouse will be performing our reactor vessel examinations during this ten year interval.

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7 NRC CONCERN Regarding item 2.I. from March 29, 1990 letter from Consumers Power Company to the NRC, NRC requires that previous response be revised to include a performance demonstration of ultrasonic testing instrumentation and procedures to prove that this equipment and procedures are capable of detecting outside diameter surface connected defects in the circumferential orientation in a laboratory test block.

CPCo RESPONSE These examinations are scheduled to be performed during the last refueling outage of the second interval. Prior to the performance of these examinations CPCo will demonstrate on a laboratory test block which contains crack type defects that the test equipment and procedures utilized are capable of detecting outside diameter surface connected defects in the circumferential direction.

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ATTACHMENT 2 Consumers Power Company Palisades Plant Docket 50-255 RESPONSE TO NRC QUESTIONS ON SECOND TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM July 13, 1990 2 Pages OC0790-0790-:-NL02

21 TABLE Al PRESSURE TEMPERATURE EXEMPTIONS IWC-1220(a), 74S75 Design Component Function Pressure Temperature CCS-10-CSH-lPl Component Cooling Line 150 psi 140°F ccs-10-CSH-1P4 Component Cooling Line 150 psi 140°F SFP-8-CPL-DLl Reactor Cavity Drain Line 125 psi 150°F SFP-6-CPL-SLl Reactor Cavity Drain Line 125 psi 150°F SFP-6-SRT-RLl Spent Fuel Pool Recirc Line 125 psi 150°F SFP-6-SRT-SLl Spent Fuel Pool Reci re Line 125 psi 150°F SFP-6-FPP-HXB Spent Fuel Pool Recirc Line 125 psi 150°F RWS-6-CWR-SL4 Clean Waste Relief Line so psi 180°F BASIS: IWC-1220(a) *allows exemptions from the NDT examination requirements of IWC-2520 where both the design pressure and temperature are equal to or less than 275 psig and 200°F, respectively. Design data was taken from manufacturers' drawings or Bechtel Specifications M-250 and M-259.

10 CFR 50.SSa requires that piping systems which perform ECCS, Residual Heat Removal (RHR), and Containment Heat Removal (CHR) function shall be inspected per IWC-1220, 74S75, Section XI. 10 CFR 50.55a permits the utilization of IWC-1220, 74S75, Section XI for other Class 2 piping systems. IWC-1220(a), 74S75 has been applied to all Class 2 piping.

Revision 2 OC0790-0790-NL02 7/9/90

40 Line Loop Functional Identifi- Pipe Identifi- Isometric Weld Multiple Identification cation Sizes(s) cation Number(s) Number(s) Loop Number Comment Containment Spray Pump a. P-54A B-29, 130 ML-19

b. P-54B B-31, 130 ML-19

c. P-54C B-31, 130 ML-19 Charging Pumps a. P-55A B-87, 131 ML-20

b. P-55B B-56, 131 ML-29

c. P-55C B-86, 131 ML-20 Concentrated Boric Acid a. P-56A B-55, 132 ML-21 Pump b. P-56B B-55, 132 ML-21 High-Pressure Injection - a. P-66A B-36, 133 ML-22 Pump b. P-66B B-50, 133 ML-22 Low-Pressure Injection a. P-67A B-29, 134 ML-23 Pump b. P-67B B-35, 134 ML-23 Concentrated Boric Acid a. T-53A B-29, 3 ML-23 Exempt per IWC-1220(c),

Tank b. T-53B B-55, 3 ML-24 74S75 Long-Term Cooling ESS-LTC ESS-LTC 6 II a.

b.

IA 1B B-52A B-60A 201-228 201-212 ML-24A ML-24A 1981 Mod e Safety Injection ESS-SlS 12" a. lAl A-7 1-8 ML-25 Class designation

b. lBl A-8 1-12 ML-25 changed from Class 1

c. 2Al A-9 1-11 ML-25 to Class 2 in 1983

d. 2Bl A-10 1-11 ML-25 Revision 2 OC0790-0790-NL02 7 /9/90