ML051470154

RAI, Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized-Water Reactors

ML051470154
Person / Time
Site:	Palisades
Issue date:	06/09/2005
From:	Jaffe D NRC/NRR/DLPM/LPD3
To:	Domonique Malone Nuclear Management Co
Jaffe D, NRR/DLPM, 415-1439
References
GL-04-002, TAC MC4701
Download: ML051470154 (4)

Text

June 9, 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 PLANT - REQUEST FOR ADDITIONAL INFORMATION (RAI)

RELATED TO GENERIC LETTER 2004-02, POTENTIAL IMPACT OF DEBRIS BLOCKAGE ON EMERGENCY SUMP RECIRCULATION AT PRESSURIZED-WATER REACTORS (TAC NO. MC4701)

Dear Mr. Malone:

By letter dated March 7, 2005, Nuclear Management Company, LLC (the licensee) provided the 90-day response to U.S. Nuclear Regulatory Commission (NRC) Generic Letter (GL) 2004-02 for the Palisades Plant. The GL requested the licensee perform an evaluation of the emergency core cooling system and containment spray system recirculation functions in light of the information provided in the GL and, if appropriate, take additional actions to ensure system function. Additionally, addressees were requested to submit to the NRC the information specified in the GL.

The NRC staff has completed its preliminary review of your response and has determined it needs additional information requested in the enclosure to complete our review.

This RAI requests additional information about your overall plans and schedules and not any information on detailed plans or extensive analyses. In light of this, please provide the additional information requested in the enclosure within 30 days of receipt of this letter.

Sincerely,

/RA/

David H. Jaffe, 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

June 9, 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 PLANT - REQUEST FOR ADDITIONAL INFORMATION (RAI)

RELATED TO GENERIC LETTER 2004-02, POTENTIAL IMPACT OF DEBRIS BLOCKAGE ON EMERGENCY SUMP RECIRCULATION AT PRESSURIZED-WATER REACTORS (TAC NO. MC4701)

Dear Mr. Malone:

By letter dated March 7, 2005, Nuclear Management Company, LLC (the licensee) provided the 90-day response to U.S. Nuclear Regulatory Commission (NRC) Generic Letter (GL) 2004-02 for the Palisades Plant. The GL requested the licensee perform an evaluation of the emergency core cooling system and containment spray system recirculation functions in light of the information provided in the GL and, if appropriate, take additional actions to ensure system function. Additionally, addressees were requested to submit to the NRC the information specified in the GL.

The NRC staff has completed its preliminary review of your response and has determined it needs additional information requested in the enclosure to complete our review.

This RAI requests additional information about your overall plans and schedules and not any information on detailed plans or extensive analyses. In light of this, please provide the additional information requested in the enclosure within 30 days of receipt of this letter.

Sincerely,

/RA/

David H. Jaffe, 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 DISTRIBUTION PUBLIC LRaghavan THarris EDuncan PDIII-1 R/F DJaffe DLPMDPR DSSADPR ACRS OGC DCullison/DSolorio Accession No.: ML051470154

• RAI input from the staff without any major change OFFICE PDIII-1/(A)PM PDIII-I /LA DSSA/SPLB/SP* PDIII-1/SC NAME DJaffe THarris DCullison/DSolorio LRaghavan DATE 06/09/05 06/02/05 05/23/05 06/09/05 OFFICIAL RECORD COPY

REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 2004-02, POTENTIAL IMPACT OF DEBRIS BLOCKAGE ON EMERGENCY SUMP RECIRCULATION AT PRESSURIZED-WATER REACTORS NUCLEAR MANAGEMENT COMPANY, LLC PALISADES PLANT DOCKET NO. 50-255 By letter dated March 7, 2005, Nuclear Management Company, LLC (the licensee) provided the 90-day response to U.S. Nuclear Regulatory Commission (NRC) Generic Letter (GL) 2004-02 for the Palisades Plant. The GL requested that addressees perform an evaluation of the emergency core cooling system and containment spray system recirculation functions in light of the information provided in the GL and, if appropriate, take additional actions to ensure system function. Additionally, addressees were requested to submit to the NRC the information specified in the GL. The NRC staff has completed its preliminary review of your response and has determined it needs the following additional information to complete our review:

1. In your 90-day response to GL 2004-02, you indicated that you intend to use future test results, industry guidance, and NRC guidance to account for chemical precipitants in your evaluation and their availability will impact the schedule for performing an evaluation. The cooperative NRC-Electric Power Research Institue tests in progress at the University of New Mexico are designed to determine if chemical effects occur, but are not designed to measure head loss associated with any chemical effects. The NRC staff notes that some chemical effects have been observed in the initial three tests.

2. In your 90-day response to GL 2004-02, you indicated that you intend to use industry owners group guidance and component manufacturer data to evaluate long-term performance degradation of downstream susceptible components caused by debris-laden fluid and their availability will impact the schedule for performing an evaluation.

For both of these issues, you stated that the evaluation may occur after the September 1, 2005, response due date, depending on the schedule for testing and the availability of industry guidance. This is contrary to the information request in GL 2004-02, which requests that chemical and downstream effects be addressed in the September 1, 2005, response. This delay is also contrary to the NRC staffs position that there are sufficient bases to address sump vulnerability to chemical effects and that the September response will be incomplete if the evaluation is incomplete, the design is not complete, or there is no schedule for upgrades. In this light, please discuss your plans and schedule for evaluating chemical effects and the long-term downstream effects. In addition, please discuss any plans for performing testing to support your evaluation of these effects.

ENCLOSURE

Palisades Plant cc:

Robert A. Fenech, Senior Vice President Michigan Department of Attorney General Nuclear, Fossil, and Hydro Operations Special Litigation Division Consumers Energy Company 525 West Ottawa St.

1945 Parnall Rd. Sixth Floor, G. Mennen Williams Building Jackson, MI 49201 Lansing, MI 48913 Arunas T. Udrys, Esquire Manager, Regulatory Affairs Consumers Energy Company Nuclear Management Company, LLC 1 Energy Plaza 27780 Blue Star Memorial Highway Jackson, MI 49201 Covert, MI 49043 Regional Administrator, Region III Director of Nuclear Assets U.S. Nuclear Regulatory Commission Consumers Energy Company 801 Warrenville Road Palisades Nuclear Plant Lisle, IL 60532-4351 27780 Blue Star Memorial Highway Covert, MI 49043 Supervisor Covert Township John Paul Cowan P. O. Box 35 Executive Vice President & Chief Nuclear Covert, MI 49043 Officer Nuclear Management Company, LLC Office of the Governor 700 First Street P. O. Box 30013 Hudson, WI 54016 Lansing, MI 48909 Jonathan Rogoff, Esquire U.S. Nuclear Regulatory Commission Vice President, Counsel & Secretary Resident Inspector's Office Nuclear Management Company, LLC Palisades Plant 700 First Street 27782 Blue Star Memorial Highway Hudson, WI 54016 Covert, MI 49043 Douglas E. Cooper Michigan Department of Environmental Quality Senior Vice President - Group Operations Waste and Hazardous Materials Division Palisades Nuclear Plant Hazardous Waste and Radiological Nuclear Management Company, LLC Protection Section 27780 Blue Star Memorial Highway Nuclear Facilities Unit Covert, MI 49043 Constitution Hall, Lower-Level North 525 West Allegan Street P.O. Box 30241 Lansing, MI 48909-7741 October 2003