ML051110134
| ML051110134 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/28/2005 |
| From: | Raghavan L NRC/NRR/DLPM/LPD3 |
| To: | Domonique Malone Nuclear Management Co |
| Jaffe D, NRR/DLPM, 415-1439 | |
| References | |
| TAC M98923, TAC M98924, TAC M99344, TAC M99650, TAC MC6545, TAC MC6550 | |
| Download: ML051110134 (5) | |
Text
April 28, 2005 Mr. Daniel J. Malone Site Vice President Palisades Nuclear Plant Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Covert, MI 49043-9530
SUBJECT:
PALISADES NUCLEAR POWER PLANT - CLARIFICATION OF INSERVICE TESTING INTERVAL FOR CERTAIN RELIEF VALVES - RELIEF REQUESTS 28, 30, AND 31 (TAC NO. MC6550)
Dear Mr. Malone:
By letter dated March 23, 2005, Nuclear Management Company, LLC (NMC, the licensee) requested clarification of statements made by the U.S. Nuclear Regulatory Commission (NRC) in its safety evaluation (SE) for valve relief requests VRR-28, VRR-30, and VRR-31.
[
Reference:
NRCs March 6, 1998, letter to Consumers Energy, the previous licensee, Staff Review of Requests for Relief from Certain Pump and Valve Inservice Testing Requirements at the Palisades Plant (TAC NOS. M98923, M98924, M99344, and M99650).] The requested clarification relates to the extension of the licensees Inservice Testing (IST) Program interval as allowed by the American Society of Mechanical Engineers (ASME) Code.
IWA-2430(e) states that for power units that are out of service continuously for 6 months or more, the inspection interval during which the outage occurred may be extended for a period equivalent to the outage and the original pattern of intervals extended accordingly for successive intervals.
The Code also requires that Class 1 pressure relief valves be tested at least once every 5 years, and that a minimum of 20 percent of the valves from each valve group shall be tested within any 24-month interval. The Code requires that Class 2 and 3 pressure relief valves be tested at least once every 10 years, and that a minimum of 20 percent of the valves from each valve group shall be tested within any 48-month interval.
Relief Request VRR-30 pertains to relief valve RV-0401, a Class 1 valve in the shutdown cooling system. Because it is a one valve group, the Code would require that this valve be tested every 24 months. The licensee requested and was authorized to test this valve at least once every 10 years during full core off-loads unless testing has been performed in the previous 24 months.
Relief Request VRR-28 pertains to relief valves RV-0402, RV-0403, RV-0954, RV-0955 and RV-2109. These Class 2/3 relief valves are in the component cooling system, engineering safeguards system, and spent fuel pool cooling system. They are designed to protect the shutdown cooling heat exchangers, and the spent fuel pool cooling heat exchangers from
D. Malone thermal expansion of water when the heat exchangers are isolated for maintenance or inspection. Because there are five valves in this group, the Code would require, for example, that one valve from this group be tested every 2 years. The licensee requested and was authorized to test these valves when the associated heat exchanger is isolated for maintenance or inspection unless they have been tested within the last 48 months. The SE authorizing this alternative also states:
If a full core off-load or an alternate means of cooling the spent fuel pool is not feasible to accommodate the appropriate interval, some other method of assuring operational readiness must be provided, such as enhanced quality assurance and preventive maintenance. The use of other methods would require review and approval by the NRC staff prior to implementation.
Relief Request VRR-31 pertains to relief valves RV-3162 and RV-3164, Class 2 valves in the discharge header and supply line for the shutdown cooling system. Because it is a two-valve group, the Code would require that one of these valves be tested every 48 months. The licensee requested and was authorized to test these valves at least once every 10 years during full core off-loads when testing has not been performed in the previous 48 months. The SE authorizing this alternative has the same caveat as did the SE for VRR-28.
NMC has extended the Palisades Nuclear Power Plant (Palisades) IST Program, third 10-year testing interval from August 21, 2005, to March 24, 2006, in accordance with the ASME Code,Section XI, 1989 Edition, Subsection IWA-2430(e). This extension recaptures the 215-day extended outage the licensee experienced in 2001, to repair their control rod drive mechanisms. The licensee, in their March 23, 2005, letter, requests clarification as to whether the extension for the specified relief valves is acceptable given the very specific language used in the NRC staffs SE (i.e., the SE specifies 10 years as opposed to more generally referring to a 10-year interval).
The NRC staff notes that there is a difference between a 10-year IST Program Interval and a components test interval (e.g., quarterly, once each refueling outage, 5 years, 10 years).
While the Code allows a licensee to extend its IST Program interval based on an extended outage, it does not offer that same flexibility to the test intervals.
Therefore, revised alternatives need to be authorized to extend the test interval beyond that specified in the NRC staffs March 6, 1998, SE. However, the specific 10 year words in the NRCs March 6, 1998, SE were not meant to remove any Inservice Inspection/IST Program 10-year interval extension flexibility permitted by the ASME Code.
D. Malone The inference from reading the licensees relief requests VRR-28, VRR-30, and VRR-31, and most recent letters (dated March 23, and March 31, 2005), is that full core off-loads are only performed at Palisades once every 10 or more years. The NRC staff will consider the licensees request to extend the test intervals for valves in relief requests VRR-28, VRR-30, and VRR-31, on a one time basis, until the next scheduled full core off-load, i.e., fall 2007, in the NRCs response to your March 31, 2005, letter (TAC MC6545). For future IST Program 10-year intervals, the NRC staff is considering requiring that these valves be tested every full core off-load unless they have been tested in the previous 24 or 48 months as applicable.
If you have any questions regarding this issue, please contact Mr. David H. Jaffe at 301-415-1439 or by e-mail at dhj@nrc.gov.
Sincerely,
/RA/
L. Raghavan, Chief, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-255 cc: See next page
D. Malone The inference from reading the licensees relief requests VRR-28, VRR-30, and VRR-31, and most recent letters (dated March 23, and March 31, 2005), is that full core off-loads are only performed at Palisades once every 10 or more years. The NRC staff will consider the licensees request to extend the test intervals for valves in relief requests VRR-28, VRR-30, and VRR-31, on a one time basis, until the next scheduled full core off-load, i.e., fall 2007, in the NRCs response to your March 31, 2005, letter (TAC MC6545). For future IST Program 10-year intervals, the NRC staff is considering requiring that these valves be tested every full core off-load unless they have been tested in the previous 24 or 48 months as applicable.
If you have any questions regarding this issue, please contact Mr. David H. Jaffe at 301-415-1439 or by e-mail at dhj@nrc.gov.
Sincerely,
/RA/
L. Raghavan, Chief, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-255 cc: See next page DISTRIBUTION PUBLIC OGC DTerao DFischer PDIII-1 R/F ACRS LRaghavan DJaffe THarris EDuncan, RGN-III DLPM DPR ADAMS ACCESSION NO.: ML051110134 OFFICE EMEB PDIII-1/PM PDIII-1/LA EMEB/SC PDIII-1/SC NAME DFischer DJaffe THarris DTerao LRaghavan DATE 4/28/05 4/27/05 4/26/05 4/28/05 4/28/05 OFFICIAL RECORD COPY
Palisades 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 Inspector's 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 October 2003