ML052080205
| ML052080205 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/27/2005 |
| From: | Morgan M NRC/NRR/DRIP/RLEP |
| To: | Harden P Nuclear Management Co |
| Morgan M, NRR/DRIP/RLEP, 415-2232 | |
| References | |
| TAC MC6433 | |
| Download: ML052080205 (8) | |
Text
July 27, 2005 Paul A. Harden Site Vice President Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Covert, MI 49043
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (RAI) FOR THE REVIEW OF THE PALISADES NUCLEAR PLANT, LICENSE RENEWAL APPLICATION (TAC NO. MC6433)
Dear Mr. Harden:
By letter dated March 22, 2005, Nuclear Management Company, LLC, (NMC or the applicant) submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54), to renew the operating license for Palisades Nuclear Plant (PNP), for review by the U.S. Nuclear Regulatory Commission (NRC). Subsequently, on May 5, 2005, the NRC received a supplement to the license renewal application. The NRC staff is reviewing the information contained in the license renewal application (LRA) and supplement and has identified, in the enclosure, areas where additional information is needed to complete the review.
These questions were discussed with your staff, Mr. Robert Vincent, and a mutually agreeable date for this response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-2232 or via e-mail at MJM2@nrc.gov.
Sincerely,
/RA/ (S. Lee for)
Michael J. Morgan, Project Manager License Renewal Section A License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket No.: 50-255
Enclosure:
As stated cc w/encl: See next page
ML052080205 Document Name: E:\\Filenet\\ML052080205.wpd OFFICE PM:RLEP LA:RLEP SC:RLEP NAME MMorgan (S. Lee for)
MJenkins SLee DATE 07/27/05 07/27/05 07/27/05
Palisades Nuclear Plant cc:
Robert A. Fenech, Senior Vice President Nuclear, Fossil, and Hydro Operations Consumers Energy Company 1945 Parnall Rd.
Jackson, MI 49201 Arunas T. Udrys, Esquire Consumers Energy Company 1 Energy Plaza Jackson, MI 49201 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, IL 60532-4351 Supervisor Covert Township P.O. Box 35 Covert, MI 49043 Office of the Governor P.O. Box 30013 Lansing, MI 48909 U.S. Nuclear Regulatory Commission Resident Inspectors Office Palisades Plant 27782 Blue Star Memorial Highway Covert, MI 49043 Michigan Department of Environmental Quality Waste and Hazardous Materials Division Hazardous Waste and Radiological Protection Section Nuclear Facilities Unit Constitution Hall, Lower-Level North 525 West Allegan Street P.O. Box 30241 Lansing, MI 48909-7741 Michigan Department of Attorney General Special Litigation Division 525 West Ottawa St.
Sixth Floor, G. Mennen Williams Building Lansing, MI 48913 Manager, Regulatory Affairs Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Covert, MI 49043 Director of Nuclear Assets Consumers Energy Company Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 John Paul Cowan Executive Vice President & Chief Nuclear Officer Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Jonathan Rogoff, Esquire Vice President, Counsel & Secretary Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Douglas E. Cooper Senior Vice President - Group Operations Palisades Nuclear Plant Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Covert, MI 49043 Robert A. Vincent Licensing Lead - License Renewal Project Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043
Palisades Nuclear Plant cc:
Darrel G. Turner License Renewal Project Manager Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Mr. James Ross Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 Mr. Douglas F. Johnson Director, Plant Life Cycle Issues Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Secretary Federal Energy Regulatory Commission 888 First Street, NE, Room 1A Washington, DC 20426 Chairperson Michigan Public Service Commission PO Box 30221 Lansing, MI 48909-7721
DISTRIBUTION: Letter to P. Harden, Re: RAIs for Palisades LRA, Dated: July 27, 2005 ADAMS Accession No.: ML052080205 HARD COPY RLEP RF M. Morgan (PM)
E-MAIL:
RidsNrrDrip RidsNrrDe G. Bagchi K. Manoly W. Bateman J. Calvo R. Jenkins J. Fair RidsNrrDssa RidsNrrDipm D. Thatcher R. Pettis G. Galletti C. Li K. Winsberg (RidsOgcMailCenter)
R. Weisman M. Mayfield A. Murphy S. Smith (srs3)
S. Duraiswamy Y. L. (Renee) Li RLEP Staff P. Lougheed, RIII J. Ellegood, RIII M. Garza, RIII A. Stone, RIII L. Raghavan T. Mensah OPA
Enclosure PALISADES NUCLEAR PLANT LICENSE RENEWAL APPLICATION (LRA)
REQUEST FOR ADDITIONAL INFORMATION (RAI)
RAI 2.1 Use of Alternatives to Seismic Anchors or Equivalent Anchors Palisades License Renewal Project Guideline LRPG 3, Scoping and Screening for License Renewal, Revision 3, Section 6.1.3, provides guidance for establishing system boundaries for non-safety-related (NSR) piping systems connected directly to safety-related (SR) piping systems. The guideline states, in part, that for NSR systems, structures, or components (SSCs) directly connected to SR SSCs, the NSR piping and supports up to and including the first anchor, or equivalent anchor, beyond the SR/NSR interface, are within the scope of license renewal. An alternative to specifically identifying a seismic anchor or series of supports comprising an equivalent anchor(s) that support the SR/NSR piping interface is to include enough of the NSR piping run to conservatively encompass the anchor(s) and ensure the piping and anchor intended functions are maintained. The guideline states that the following examples are typically used to establish the end of pipe stress analysis models and can be used to define conservative end points in the license renewal boundary:
A flexible connection is generally considered a pipe stress analyses model end point because the flexible connection does not support loads or transfer loads across it on to connecting piping.
A point where buried piping enters the ground because the ground acts like an anchor.
Based on the staffs review of the applicants above scoping evaluation related to the 10 CFR 54.4(a)(2) criterion, the staff requires additional information to complete its review.
Specifically, the staff requests the applicant to provide the technical basis for establishing a flexible connection and a point where buried piping enters the ground, as adequate end points for determining piping within the scope of license renewal.
RAI 2.1 10 CFR 54.4(a)(2) Scoping Criteria for Non-safety-related SSCs By letter dated December 3, 2001, the NRC issued a staff position to the NEI, which described areas to be considered and options it expects an applicant to use in determining which SSCs meet the 10 CFR 54.4(a)(2) criterion (i.e., All non-safety-related SSCs whose failure could prevent satisfactory accomplishment of any safety-related functions identified in Paragraphs (a)(1)(i), (ii), (iii) of this section).
Specifically, the staffs concern is that Seismic II/I piping, though seismically supported, would be subjected to the same plausible aging effects as safety-related piping. For example, depending on piping material, geometrical configuration, operating condition such as water chemistry, temperature, flow velocity, and external environment, erosion and corrosion may be plausible aging effects for some Seismic II/I piping. Those effects, if not properly managed, could result in age-related failures and adversely impact the safety functions of safety-related SSCs.
Based on a review of the license renewal application (LRA), the applicants scoping and screening implementation procedures, and discussions with the applicant, the staff determined that additional information is required with respect to certain aspects of the applicants evaluation of the 10 CFR 54.4(a)(2) criteria. The staff requests the applicant provide the following information:
Section 2.1.2.1.2(3)(b) of the LRA states that as long as the supports for these piping systems are managed, falling of piping sections is not credible, and the piping section itself would not be in scope for 54.4(a)(2) due to physical impact hazard (although the leakage/spray/flooding hazard may still apply).
The staff requests that the applicant clarify if it considered flow accelerated corrosion (FAC) piping failures, as demonstrated in NRC Information Bulletin 2001-09, regardless of whether the piping supports remain intact.
Section 2.1.2.1.2(3)(a) of the LRA states that all pressurized liquid/steam systems in the general area of safety-related components, passive or active, be considered in scope for license renewal.
The staff requests that the applicant clarify if it utilized system pressure as a means to exclude any liquid or steam piping systems, or portions of systems from the scope of license renewal. Specifically, were nonpressurized liquid or steam systems considered within the scope of license renewal.
RAI 2.1 Consumables In Table 2.1-3 of Chapter 2 in NUREG-1800, guidance is given for screening consumables.
Table 2.1-3 states that consumables may be divided into the following four categories for the purpose of license renewal: (a) packing, gaskets, component seals, and O-rings; (b) structural sealants; (c) oil, grease, and component filters; and (d) system filters, fire extinguishers, fire hoses, and air packs. For Category (b), NUREG-1800, Table 2.1-3 states that these sub-components may perform a function without moving parts or a change in configuration, and they are not typically replaced. The table further states that it is expected that the applicants Structural Aging Management Program will address these items with respect to an aging management review program on a plant-specific basis. Section 2.1.3.2 of the LRA states, Consumables are a special class of short-lived items that can include packing, gaskets, component seals, O-rings, oil grease, component filters, system filters, fire extinguishers, fire hoses, and air packs.
The staff requests the applicant to clarify if it considered in the screening process structural sealants in the identification of short-lived components and consumables.