ML022730377

RAI Application for Amendment to Revise Technical Specification 3.6.6.9 Concerning Surveillance Frequency of Containment Spray Nozzles

ML022730377
Person / Time
Site:	Palisades
Issue date:	10/07/2002
From:	Johnny Eads NRC/NRR/DLPM/LPD3
To:	Cooper D Consumers Energy
References
TAC MB4282
Download: ML022730377 (6)

Text

October 7, 2002 Mr. Douglas E. Cooper Site Vice President Palisades Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530

SUBJECT:

PALISADES PLANT - REQUEST FOR ADDITIONAL INFORMATION REGARDING SURVEILLANCE FREQUENCY OF CONTAINMENT SPRAY NOZZLES (TAC NO. MB4282)

Dear Mr. Cooper:

We are reviewing your application dated March 1, 2002, requesting an amendment to revise Palisades Technical Specification 3.6.6.9 regarding the containment spray nozzle inspection surveillance frequency. We find that additional information is needed to complete our review.

Our request for additional information is enclosed.

Based on discussions with R. Gerling of your staff, a mutually agreeable date for your response is within 60 days of the date of this letter. If you have any questions regarding this letter or if circumstances result in your need to revise the response date, please contact me at (301) 415-1471 or by e-mail at jhe@nrc.gov.

Sincerely,

/RA/

Johnny H. Eads, Acting Project Manager, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-255

Enclosure:

Request for Additional Information cc w/encl: See next page

ML022730377 OFFICE PDIII-1/PM PDIII-1/LA SPLB/SC PDIII-1/SC NAME JEads RBouling SWeerakkody LRaghavan DATE 10/03/02 10/03/02 10/03/02 10/04/02 Palisades Plant cc:

Mr. Robert A. Fenech, Senior Vice President Michigan Department of Attorney General Nuclear, Fossil, and Hydro Operations Special Litigation Division Consumers Energy Company 630 Law Building 212 West Michigan Avenue P.O. Box 30212 Jackson, MI 49201 Lansing, MI 48909 Arunas T. Udrys, Esquire Mr. Roy A. Anderson Consumers Energy Company Executive Vice President and 212 West Michigan Avenue Chief Nuclear Officer Jackson, MI 49201 Nuclear Management Company, LLC 700 First Street Regional Administrator, Region III Hudson, WI 54016 U.S. Nuclear Regulatory Commission 801 Warrenville Road Laurie A. Lahti Lisle, IL 60532-4351 Manager - Licensing Nuclear Management Company, LLC Supervisor 27780 Blue Star Memorial Highway Covert Township Covert, MI 49043 P. O. Box 35 Covert, MI 49043 Steven T. Wawro Nuclear Asset Director Office of the Governor Consumers Energy Company P. O. Box 30013 Palisades Plant Lansing, MI 48909 27780 Blue Star Memorial Highway Covert, MI 49043 U.S. Nuclear Regulatory Commission Resident Inspectors Office Mr. John Paul Cowan Palisades Plant Senior Vice President 27782 Blue Star Memorial Highway Palisades Plant Covert, MI 49043 Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Drinking Water and Radiological Covert, MI 49043 Protection Division Michigan Department of Environmental Quality 3423 N. Martin Luther King Jr Blvd P. O. Box 30630 CPH Mailroom Lansing, MI 48909-8130 March 2002

REQUEST FOR ADDITIONAL INFORMATION PROPOSED AMENDMENT ON CONTAINMENT SPRAY NOZZLE INSPECTIONS PALISADES PLANT By application dated March 1, 2002, the Nuclear Management Company, LLC (the licensee),

submitted a request to change Technical Specification (TS) 3.6.6.9 to allow performance of the surveillance requirement for the containment spray nozzle inspection following maintenance which could result in nozzle blockage rather than at the currently specified 10-year frequency.

Please provide the following additional information:

1. Experience at the Donald C. Cook Nuclear Plant (D. C. Cook), Unit 1, seems to indicate that boric acid plate-out with the potential to block flow through the containment spray headers and nozzles can occur following an inadvertent spray actuation (see Licensee Event Report (LER) 98-027-02).

(a) Has Palisades ever had an inadvertent actuation of containment spray?

(b) If yes, what type of inspection of the spray system piping and nozzles was done and what other steps were taken to ensure that no boric acid build-up occurred?

(c) If no, what type of inspection would be done following an inadvertent spray actuation?

Why is this method sufficient to detect blockage due to boric acid plate-out?

2. Experience at D. C. Cook, Units 1 and 2, seems to indicate that the typical test for blockage in the containment spray lines and nozzles may not be effective in detecting debris in the spray lines, at least the amount reported in LER 98-027-02.

Do the testing records for Palisades show any evidence that the TS-required containment spray flow blockage test may have a sensitivity to debris in the lines or nozzles which is too low (i.e., debris is present but not detected by this test)? For example, has construction debris or other debris been found in the containment spray system as a result of later inspections, tests, or repair work other than the containment spray system blockage test required by the TSs?

3. Describe any previous maintenance activities on the containment spray system that had the potential to introduce debris. What assurance is there that no such debris presently exists (including debris from construction)?

4. With respect to the foreign material exclusion (FME) controls at Palisades:

(a) Describe how the FME controls would prevent debris from remaining in the containment spray system piping, headers, and nozzles following maintenance, testing, or inspections which result in opening the system.

(b) Why are the FME controls sufficient, following any maintenance, testing, or inspection that results in opening the system, to ensure that nothing remains in the system sufficient to block the system and cause a decrease in spray flow?

ENCLOSURE

Why should a blockage test not be run to provide increased assurance that the containment spray system is still capable of performing its safety function after the system is opened?

5. Following maintenance on a component of the containment spray system, what specific criteria are used to determine whether a flow blockage test of the containment spray system is required? Who makes the decision? What level of management approves this decision?