ML051320235
| ML051320235 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/05/2005 |
| From: | Domonique Malone Nuclear Management Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Morgan M, NRR/NRC/DRIP/RLEP, 415-2232 | |
| References | |
| Download: ML051320235 (8) | |
Text
NMC Committed to Nuclear Excellce Palisades Nuclear Plant Operated by Nuclear Management Company, LLC May 5, 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 Supplementar" Information to Support the Application for Renewed Operating License for the Palisades Nuclear Plant In a letter dated March 22, 2005, Nuclear Management Company, LLC (NMC) submitted an application for renewal of the operating license for the Palisades Nuclear Plant. This letter provides additional information supplementing the application.
NMC has determined that the summary listing of component types for Engineered Safety Features (ESF) provided in Table 2.3.2-1 did not specify certain component types which were and are included in scoping and screening, and were subject to aging management review. These component types (piping and fittings, pumps, spray nozzles, and trisodium phosphate baskets) are shown as in-scope for license renewal in the Scoping Boundary Drawings for Safety Injection, Containment Spray and Shutdown Cooling (LR-M-204-1, LR-M-204-1A, LR-M-204-1B, LR-M-203-1 and LR-M-203-2), that were submitted in support of the application, and referenced on page 2-78. These component types are also listed as being subject to aging management review in the text of Section 2.3.2 on page 2-71 of the application.
Accordingly, this letter revises Table 2.3.2-1 of the application to include the additional component types. Piping and fittings, pumps, spray nozzles, and trisodium phosphate baskets have been added to the table as separate line items. The additional line items to be added to Table 2.3.2-1 are provided in Enclosure 1. To be consistent with Table 2.3.2-1, Table 3.2.2-1 is also revised to add the corresponding aging management review results for these component types. The additional line items to be added to Table 3.2.2-1 are provided in Enclosure 2. It has been concluded that the addition of these line items does not result in the need to revise Table 3.2.1 or other text related to ESF.
27780 Blue Star Memorial Highway
- Covert, Michigan 49043-9530 Telephone: 269.764.2000
NMC has also reviewed the other Section 2 mechanical and civil/structural summary tables for similar inconsistencies. This review identified the need to incorporate additional component types in Table 2.3.3-1 for the Chemical and Volume Control System (CVCS). Similar to ESF, these component types are shown in the referenced Scoping Boundary Drawings as being in-scope, and the text in Section 2.3.3.1 on page 2-83 lists the component types as being subject to aging management review, but the component types were not itemized in the table. Therefore, Enclosure 1 also includes line items for pumps and accumulators to be added to Table 2.3.3-1, and Enclosure 2 includes the corresponding aging management review results in Table 3.3.2-1 for these component types. It has been concluded that the addition of these line items does not result in the need to revise Table 3.3.1 or other text related to CVCS.
As a separate issue, NMC has revisited the need for two Time-Limited Aging Analyses (TLAA) discussions included as Sections 4.7.3 and 4.7.4 of the application. NMC had included these discussions under a very conservative interpretation of the TLAA criteria in 10 CFR 54.3(a). Upon further review it has been concluded that the issues do not meet the 10 CFR 54.3(a) criteria for a TLAA. The Section 4.7.3 discussion of Code Case N-481 is unnecessary since this code case will no longer be in use when the plant enters the period of extended operation. The Risk Informed Inservice Inspection Program calculations discussed in Section 4.7.4 were used for determining inspection intervals. The risk at any point in time is unaffected by this evaluation, and is not time-limited. Accordingly, this letter hereby withdraws the information in Sections 4.7.3 and 4.7.4, and replaces the section titles with "Not Used." The titles for these section numbers in Table 4.1-1 are also changed to "Not Used," and the disposition information is deleted. To conform with these changes, Appendix A, Sections A4.5.3 and A4.5.4, are also deleted.
NMC understands that the need to provide this supplementary information may cause some limited impact on the overall review schedule. 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.
SummarV of Commitments This letter contains no new commitments or changes to existing commitments.
I declare under penalty of perjury that the foregoing is true and correct. Executed on Daniel J. Malone Site Vice President, Palisades Nuclear Plant Nuclear Management Company, LLC 27780 Blue Star Memorial Highway
- Covert, Michigan 49043-9530 Telephone: 269.764.2000
Enclosures (2) cc Administrator, Region Ill, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC License Renewal Project Manager, Palisades, USNRC 27780 Blue Star Memorial Highway. Covert, Michigan 49043-9530 Telephone: 269.764.2000
ENCLOSURE I Supplementary Information for Application for Renewed Operating License -
Palisades Nuclear Plant Table 2.3.2-1 Additions Table 2.3.3-1 Additions
Enclosure I Supplementary Information for Application for Renewed Operating License -
Palisades Nuclear Plant Additions to Palisades Application for Renewed Operating License for Table 2.3.2-1 Engineered Safeguards System Component Group Intended Function Piping and fittings Fluid Pressure Boundary Pumps Fluid Pressure Boundary Spray Nozzles Spray Pattern TriSodium Phosphate Baskets Structure Functional Support Additions to Palisades Application for Renewed Operating License for Table 2.3.3-1 Chemical and Volume Control System Component Group Intended Function Pumps Fluid Pressure Boundary Accumulators Fluid Pressure Boundary
ENCLOSURE 2 Supplementary Information for Application for Renewed Operating License -
Palisades Nuclear Plant Table 3.2.2-1 Additions Table 3.3.2-1 Additions
I Supplementary Information for Application for Renewed Operating License - Palisades Nuclear Plant Additions to Table 3.2.2-1 Engineered Safety Features - Engineered Safeguards System - Summary of Aging Management Evaluation Aging Effect NUREG -
Component Intended Requiring Aging Management 1801 Volume Type Function Material Environment Management Programs 2 Line Item Table I Item Notes Piping and Fluid Pressure Stainless Treated Cracking Water Chemistry V.D1.1-a 3.2.1-15 A, 214 Fittings boundary Steel Water (Int)
Program One Time V.D1.1-a 3.2.1-15 A, 214 Inspection Program Loss of Water Chemistry V.D1.1-a 3.2.1-05 H, 205, Material Program 214 One Time V.D1.1-a 3.2.1-05 H, 205, Inspection 214 Program Pumps Fluid Pressure Stainless Treated Loss of Water Chemistry V.D1.2-a 3.2.1.05 H, 205, Boundary Steel Water (Int)
Material Program 214, 215 One-Time V.D1.2-a 3.2.1.05 H, 205, Inspection 214, 215 Program Spray Spray Pattern Stainless Air (Int)
None None Required F, 208, Nozzles Steel 214 TriSodium Structure Stainless Containment None None Required J. 213, Phosphate Functional Steel Air (Ext) 214 Baskets Support NOTES:
Note 205 Note 208 Note 213 Note 214 Note 215 Palisades manages pitting and crevice corrosion.
Palisades spray nozzles are stainless steel. GALL indicates carbon steel.
Component is not in GALL.
This row was added to the original application in a supplemental letter.
This component normally operates at below 140 degrees F. Therefore, SCC is not an applicable aging mechanism.
Supplementary Information for Application for Renewed Operating License - Palisades Nuclear Plant Additions to Table 3.3.2-1 Auxiliary Systems - Chemical and Volume Control System - Summary of Aging Management Evaluation Aging Effect Aging NUREG -1801 Component Intended Requiring Management Volume 2 Line Type Function Material Environment Management Programs Item Table I Item Notes Accumulators Fluid Stainless Loss of Water F, 333, 382, Pressure Steel Treated Material Chemistry 397 boundary Water (Int)
Program One-Time F, 333, 382, Inspection 397 Program Pumps Fluid Stainless Treated Loss of Water VII.E1.5-a 3.3.1-04 H, 333, 398 Pressure Steel Water (Int)
Material Chemistry Boundary Programr One-Time VIL.E1.5-a 3.3.1-04 H, 333, 398 Inspection Program NOTE TEXT REPLACEMENTS Note 333 This line item was added to the original application in a supplemental letter.
Note 382 This line item includes all tanks in the CVC system except Boric Acid Storage Tanks.
Note 397 GALL component material is carbon steel.
Note 398 GALL identifies cracking. However, temperature is <1400F. Therefore, cracking is not an aging effect. Palisades item has loss of material.