ML050940434

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Letter Transmitting Palisades Nuclear Plant Application for Renewed Operating License
ML050940434
Person / Time
Site: Palisades Entergy icon.png
Issue date: 03/22/2005
From: Domonique Malone
Nuclear Management Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
+KBR1SISP20050607
Download: ML050940434 (11)


Text

NMC Committed to Nuclear Excellence Palisades Nuclear Plant Operated by Nuclear Management Company, LLC March 22, 2005 10 CFR 54 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Palisades Nuclear Plant Docket 50-255 License No. DPR-20 Application for Renewed Operating License Pursuant to U. S. Nuclear Regulatory Commission (NRC) regulations 10 CFR Parts 50, 51, and 54, Nuclear Management Company, LLC (NMC) hereby applies for renewal of the Operating License for the Palisades Nuclear Plant.

The current operating license for the Palisades Plant expires at midnight, March 24, 2011. NMC requests that the Palisades Operating License be extended for 20 years beyond the current expiration date to midnight, March 24, 2031.

The enclosed "Application for Renewed Operating License, Palisades Nuclear Plant" is submitted for docketing in accordance with the applicable requirements of 10 CFR Part 54, Sections 54.17, 54.19, 54.22, and 54.23. This application meets the timeliness requirements of 10 CFR 2.109(b) and 10 CFR 54.17(c), and provides the administrative, technical, and environmental information sufficient to support the NRC findings required by 10 CFR 54.29.

In accordance with the requirements of 10 CFR 54.21, measures are described in this application which provide assurance that the effects of aging will be adequately managed, consistent with the current licensing basis, for the requested period of extended operation. In some cases, new aging management programs or enhancements to existing programs are described.

Accompanying this application, in accordance with 10 CFR 54.23 and 10 CFR 51, is an Applicant's Environmental Report. During the performance of the environmental review, no new and significant information was identified that would either invalidate NRC Category 1 findings in NUREG-1437, or require additional evaluation.

27780 Blue Star Memorial Highway. Covert, Michigan 49043-9530 Telephone: 269.764.2000

This application is being submitted in electronic form following the guidance contained in the NRC Final Rule on Electronic Maintenance and Submission of Information (68 FR 58792). Enclosure 1 is a compact disc (CD) containing the entire License Renewal Application, including the Applicant's Environmental Report, in Adobes pdf format suitable for entry into the NRC ADAMS system. The CD contains two files:

001 - Palisades LRA.pdf (publicly available) 002 - Palisades ER.pdf (publicly available)

Please contact Mr. Darrel Turner, License Renewal Project Manager, at 269-764-2412, or Mr. Robert Vincent, License Renewal Licensing Lead, at 269-764-2559, if you require additional information related to this request.

Summary of Commitments, "Preliminary Commitments Related to License Renewal for the Palisades Nuclear Plant," summarizes the various actions, new programs, and program enhancements committed to by NMC in this application. These preliminary commitments are subject to change, by mutual agreement of NMC and the NRC, during the review. The final list of commitments will be listed in the NRC Safety Evaluation Report. All other statements provided in the application are considered to be descriptive and supporting information.

I declare under penalty of perjury that the foregoing is true and correct. Executed on March 22, 2005.

Daniel J. Malone Site Vice President, Palisades Nuclear Plant Nuclear Management Company, LLC Enclosures (2)

CC Administrator, Region IlIl, USNRC (w/o Enclosure 1)

Project Manager, Palisades, USNRC (w/o Enclosure 1)

Resident Inspector, Palisades, USNRC (w/o Enclosure 1)

Director, Office of Nuclear Reactor Regulation (w/o Enclosure 1)

License Renewal Project Manager, Palisades, USNRC Document Control Desk 27780 Blue Star Memorial Highway C

Covert, Michigan 49043-9530 Telephone: 269.764.2000

ENCLOSURE 1 LICENSE RENEWAL APPLICATION COMPACT DISK PALISADES NUCLEAR PLANT

ENCLOSURE 2 PRELIMINARY COMMITMENTS RELATED TO LICENSE RENEWAL FOR THE PALISADES NUCLEAR PLANT

Preliminary Commitments Related to License Renewal for the Palisades Nuclear Plant Commitment Source 1

Each year, following the submittal of the Palisades License LRA Section Renewal Application and at least three months before the 1.4 scheduled completion of the NRC review, NMC will submit an amendment to the application pursuant to 10 CFR 54.21 (b).

This amendment will identify any changes to the Current Licensing Basis of the facility that materially affect the contents of the License Renewal Application, including the FSAR supplement, that have not already been submitted.

2 NMC will submit an equivalent margins analysis, completed in LRA Section accordance with 10 CFR 50 Appendix G Section IV.A.1, for 4.2.1 NRC approval, at least three years before any reactor vessel beltline material upper shelf energy decreases to less than 50 ft-lb.

3 At the appropriate time, prior to exceeding the PTS screening LRA Section criteria, Palisades will select the optimum alternative to manage 4.2.2 PTS in accordance with NRC regulations and make relevant submittals to obtain NRC review and approval.

4 NMC will evaluate the effect the increase in variable speed LRA Section charging pump out-of-service events may have on these lines 4.3.13 (Charging Lines Inboard of the Regenerative Heat Exchanger),

and will take actions necessary to ensure these lines meet licensing basis design criteria for the extended operating period. NMC will complete this evaluation and will advise the NRC of the results, and of any necessary corrective actions, before the end of the current licensed operating period.

5 NMC will monitor the cumulative number of pressurizer LRA Section temperature element nozzle fatigue cycles within the Fatigue 4.7.2 Monitoring Program, and maintain a special action level to ensure that appropriate actions are taken if at any time the cycle count for any design basis event since 1993 reaches the number assumed by these analyses.

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Commitment Source 6

NMC will re-evaluate effects of primary water stress corrosion LRA Section cracking for all Alloy 600 components for which the current 4.7.2 analyses found acceptable crack sizes at 40 years to identify those for which the analysis would predict unacceptable crack sizes at 60 years, and to identify appropriate additional inspections for them. NMC will complete these re-evaluations before the period of extended operation.

7 The supporting calculations for the Palisades RI-ISI program LRA Section will be reviewed, and updated as needed, to reflect a 60-year 4.7.4 operating period; and the program inspection scope will be updated accordingly, before the period of extended operation.

8 In a periodic FSAR update following NRC issuance of the LRA Section renewed operating license, in accordance with 10 CFR A1.0 50.71 (e), the summary descriptions of Aging Management Programs and Time Limited Aging Analyses, provided in Appendix A, will be incorporated into appropriate sections of the FSAR.

9 The Quality Program implementation procedures will be LRA Section expanded to apply the elements of corrective action, B13.2 confirmation process, and administrative controls to both safety related and non-safety related systems, structures, and components that are subject to aging management review for license renewal.

10 Review and revise ASME ISI Master Plan, procedures that LRA Section implement credited License Renewal Programs, and plant B2.1.3 maintenance procedures to reflect and reference the, applicable guidance provided in NUREG-1339 and EPRI TR-104213 for safety and non-safety related bolting. These revisions should also include instructions for selection of bolting material and use of lubricants and sealants, in accordance with the guidelines of EPRI NP-5769 and the additional recommendations of NUREG-1339 to prevent or mitigate degradation and failure of safety-related bolting.

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Commitment Source 11 Evaluate the high strength bolting used for component supports LRA Section for susceptibility to cracking as described in NUREG-1 801, B2.1.3 Section XI.M.18, "Parameters Monitored/Inspected," and implement appropriate inspection requirements to provide adequate age-management for these bolts. This is to be completed prior to the end of the current operating license.

12 Revise applicable plant procedures to include criteria for LRA Section observing susceptible SSC, within the scope of license B2.1.4 renewal, for boric acid leakage and degradation, during system walkdown inspections.

13 Revise applicable plant procedure(s) to include explicit LRA Section acceptance criteria for boric acid inspections.

B2.1.4 14 Revise applicable plant procedures to include inspection of LRA Section structural steel and non-ASME component supports for B2.1.4 evidence of boric acid residue and boric acid wastage/corrosion on a periodic frequency.

15 A Buried Services Corrosion Monitoring Program will be LRA Section developed and implemented. Features of the program will B2.1.5 include development and implementation of procedures for inspection of selected buried SSCs for corrosion, pitting and MIC. The periodicity of these inspections will be based on -

opportunities for inspection such as scheduled excavation and maintenance work.

16 Develop and implement procedures for periodic draining and LRA Section cleaning of diesel fuel oil storage tanks, Emergency Diesel B2.1.9 Generator day tanks, and Diesel Fire Pump Day Tanks. These procedures shall include steps to perform a visual inspection of interior tank surfaces for signs of degradation or corrosion, with acceptance criteria, corrective actions, and documentation of inspection results.

17 Develop and implement procedures for periodic draining of LRA Section water accumulated in the bottom of the fuel oil storage tanks B2.1.9 and fuel oil day tanks for the Diesel Generators and Diesel Fire Pumps.

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Commitment Source 18 Develop and implement procedures for periodic ultrasonic LRA Section measurement of thickness of the bottom of Fuel Oil Storage B2.1.9 Tanks, Emergency Diesel Generator Day Tanks, and Diesel Fire Pump Day Tanks.

19 The Structures Monitoring Program shall be revised to include LRA Section specific inspection criteria and documentation requirements for B2.1.10 verifying that walls, ceilings and floors that serve as Fire Protection Program fire barriers are verified to be free from aging related degradation that would impact the fire barrier's intended function.

20 Plant procedures shall be revised to more specifically address LRA Section aging related degradation and expectations for documentation B2.1.1 0 of fire door condition.

21 Develop and implement procedures to perform visual LRA Section inspections for fire door clearances.

B2.1.10 22 Revise diesel-driven fire pump performance test procedures to LRA Section more specifically address requirement to inspect and monitor B2.1.10 fuel oil supply line for aging related degradation, and to document inspection results.

23 Develop and implement procedures for inspection of below LRA Section grade fire protection system piping. Inspections shall occur B2.1.10 when below grade piping is excavated for maintenance, and shall include pipe wall thickness (NDE or direct measurement) and documentation of aging related degradation of pipes.

Procedures shall include acceptance criteria, and criteria for further corrective actions if acceptance criteria are not met.

24 Plant procedures shall be revised to more specifically address LRA Section identification of aging related degradation and expectations for B2.1.10 documentation of fire hydrant condition. Also, these revisions shall include provisions to perform flow testing for fire hydrants within the scope of License Renewal that are credited for fire suppression in the Palisades current licensing basis.

25 Develop and implement procedures to replace all sprinkler LRA Section heads prior to the end of the 50 year service life, or for testing of B2.1.10 a representative sample of sprinkler heads prior to the end of the 50 year service life and at 10 year intervals thereafter, per requirements of NFPA 25, Section 5.3.

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Commitment Source 26 A Non-EQ Electrical Commodities Condition Monitoring LRA Section Program will be developed and implemented. Features of the B2.1.12 program will include development and implementation of procedures to conduct periodic inspection of insulated cables and connectors, test sensitive instrumentation circuits, test medium voltage cables, and inspect manhole water levels.

27 A One Time Inspection Program will be developed and LRA Section implemented. Features of the program are as described in the B2.1.13 Enhancement section of LRA Section B2.1.13.

28 Revise crane and fuel handling machine inspection procedures LRA Section to specifically inspect for general corrosion on passive B2.1.15 components making up the bridge, trolley, girders, etc., and to inspect rails of Bridge Cranes for wear. Revision should also include documentation of results of these inspections, acceptance criteria, and qualification requirements for inspectors and crane supervisors.

29 The Reactor Vessel Integrity Surveillance Program will ensure LRA Section that additional neutron fluence due to the power uprate will be B2.1.16 accounted for when calculating fluence and developing pressure-temperature and LTOP curves for the extended operating period.

30 Document and establish requirement to save and store all LRA Section pulled and tested reactor vessel surveillance capsules for future B2.1.16 reconstitution use.

31 Evaluate and revise as necessary, the surveillance capsule LRA Section withdrawal and testing schedule of FSAR Table 4-20 such that B2.1.16 at least one capsule remains in the reactor vessel and is tested during the period of extended operation to monitor the effects of long-term exposure to neutron irradiation.

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Commitment Source 32 Develop a program level procedure to implement and control LRA Section Technical Specification and FSAR activities associated with the B2.1.16 Reactor Vessel Integrity Surveillance Program, including activities associated with surveillance capsules, pressure-temperature limit curves, LTOP setpoints, neutron embrittlement calculation methodology, neutron fluence calculations and control, and documentation requirements. Title of procedure should be, "Reactor Vessel Integrity Surveillance Program.'

33 Palisades will participate in the industry initiatives to evaluate LRA Section the effect of Changes in Dimensions due to Void Swelling, and B2.1.17 will report to the NRC at least two years prior to the end of the current operating license the result 34 Palisades will participate in industry initiatives that will generate LRA Section additional data on aging mechanisms relevant to RVI and B2.1.17 develop appropriate inspection techniques to permit detection and characterization of features of interest. Palisades will incorporate any recommended augmented inspections as appropriate.

35 Incorporate into the Structural Monitoring Program all structural LRA Section members listed in Tables 3.5.2-1 through 3.5.2-10 that will use B2.1.19 the Structural Monitoring Program as an AMR 36 Enhance system walkdown procedures to more specifically LRA Section address the types of components to be inspected, and to B2.1.20 specifically describe the relevant degradation mechanisms and effects of interest, and for use of the Corrective Action Program to document aging related degradation, identified during the inspections, that may affect the ability of the SSC to perform its intended function.

37 A Fatigue Monitoring Program will be developed and LRA Section implemented. Features of the program will include monitoring B3.2 and tracking selected cyclic loading transients (cycle counting) and their effects on critical reactor pressure boundary components and other selected components.

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I James McKnight - Palisades License Renewal Applicat in; Page I From:

NRRINFOREVIEW To:

Juan Ayala; Michael Morgan Date:

4/1/05 4:36PM

Subject:

Palisades License Renewal Application Place:

NRRWebServices NRRInfoReview reviewed Vol 1 and Vol 2 of the Palisades license renwal application, as well as the drawings. There is no sensitive information in the application and it may be released without restriction including posting to the web.

CC:

NRRWebServices; Samson Lee