ML051730291

Requests for Additional Information for the Review of the Palisades Nuclear Plant, License Renewal Application

ML051730291
Person / Time
Site:	Palisades
Issue date:	06/22/2005
From:	Morgan M NRC/NRR/DRIP/RLEP
To:	Domonique Malone Nuclear Management Co
Morgan M, NRR/NRC/DRIP/RLEP, 415-2232
References
TAC MC6433
Download: ML051730291 (7)

Text

June 22, 2005 Daniel J. Malone Site Vice President Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Covert, MI 49043

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION (RAIs) FOR THE REVIEW OF THE PALISADES NUCLEAR PLANT, LICENSE RENEWAL APPLICATION (TAC NO. MC6433)

Dear Mr. Malone:

By letter dated March 22, 2005, Nuclear Management Company, LLC, (NMC or the applicant) submitted an application pursuant to 10 CFR Part 54, to renew the operating license for Palisades Nuclear Plant (PNP), for review by the U.S. Nuclear Regulatory Commission (NRC).

Subsequently, on May 5, 2005, the NRC received a supplement to the license renewal application. The NRC staff is reviewing the information contained in the license renewal application (LRA) and supplement and has identified, in the enclosure, areas where additional information is needed to complete the review.

These RAIs were discussed with your staff, Mr. Robert Vincent, and a mutually agreeable date for this response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-2232 or e-mail MJM2@nrc.gov.

Sincerely,

/RA/

Michael J. Morgan, Project Manager License Renewal Section A License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket No.: 50-255

Enclosure:

As stated cc w/encl: See next page

ML051730291 Document Name: E:\\Filenet\\ML051730291.wpd OFFICE PM:RLEP LA:RLEP SC:RLEP NAME MMorgan MJenkins SLee (R. Auluck for)

DATE 06/21/05 06/21/05 06/22/05

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 Inspectors 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 Robert A. Vincent Licensing Lead - License Renewal Project Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043

Palisades Nuclear Plant cc:

Darrel G. Turner License Renewal Project Manager Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Mr. James Ross Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 Mr. Douglas F. Johnson Director, Plant Life Cycle Issues Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Secretary Federal Energy Regulatory Commission 888 First Street, NE, Room 1A Washington, DC 20426 Chairperson Michigan Public Service Commission PO Box 30221 Lansing, Michigan 48909-7721

DISTRIBUTION: Letter to D. Malone, Re: RAIs for Palisades LRA, Dated: June 22, 2005 ADAMS Accession No.: ML051730291 HARD COPY RLEP RF M. Morgan (PM)

E-MAIL:

RidsNrrDrip RidsNrrDe G. Bagchi K. Manoly W. Bateman J. Calvo R. Jenkins P. Shemanski J. Fair RidsNrrDssa RidsNrrDipm D. Thatcher R. Pettis G. Galletti C. Li K. Winsberg (RidsOgcMailCenter)

R. Weisman M. Mayfield A. Murphy S. Smith (srs3)

S. Duraiswamy Y. L. (Renee) Li RLEP Staff P. Lougheed, RIII J. Ellegood, RIII M. Garza, RIII A. Stone, RIII D. Jaffe L. Raghavan T. Mensah OPA

Enclosure PALISADES NUCLEAR PLANT LICENSE RENEWAL APPLICATION (LRA)

REQUESTS FOR ADDITIONAL INFORMATION (RAIs)

PACKAGE 1 - SYSTEM CONDITION MONITORING RAI B2.1.20-1(a)

NUREG-1801 XI.M29 states that the plant walk-downs cover the entire outer surface of the tank up to its surface in contact with soil or concrete. The applicant is requested to clarify if the entire exposed external surface of the above ground steel tanks are included within scope of the Systems Monitoring Program.

RAI B2.1.20-1(b)

The LRA AMR Tables credit the Systems Monitoring Program for managing external surfaces of elastomers, but elastomers are not specifically addressed in the Systems Monitoring program. The applicant is requested to clarify if elastomers are within scope of the Systems Monitoring Program and, if so, consider the unique aging degradation characteristics of elastomers in the specified environment and include a discussion of elastomers within each element of the program.

RAI B2.1.20-1( c)

Considering the limited shelf life and service life of elastomers for the specified environment, the applicant is requested to clarify if elastomers meet the definition of long-lived components within scope of license renewal.

RAI B2.1.20-2(a)

NUREG-1800 Item 4 indicates that the justification, including codes and standards, that the technique and frequency are adequate to detect the aging effects before a loss of SC intended function. Industry documents such as EPRI 1009743 (Aging Identification and Assessment Checklist), EPRI GS-7086 (Testing, Monitoring, and Maintenance of Aboveground Storage Tanks) and API 575 (Inspection of Atmospheric and Low-Pressure Storage Tanks) include inspection and testing practices for mechanical systems and components. The applicant is requested to clarify what codes and standards or manufacturers recommendations are applied to determine that the technique and frequency are adequate to detect degradation before the loss of intended component function.

RAI B2.1.20-2(b)

LRA AMR Tables credit the Systems Monitoring Program for managing change in material properties and cracking for elastomers used inside/outside containment. The applicant is requested to clarify how visual inspections are performed to detect changes in material properties and identify if other methods such as hardness testing or physical manipulation in combination with visual inspections are appropriate.

RAI B2.1.20-2( c)

The applicant is requested to clarify if sampling is applied to inspect a group of SCs or clarify if the entire surfaces of all accessible components are inspected.

RAI B2.1.20-2(d)

For those surfaces that are insulated, the applicant is requested to clarify if insulation will be removed to provide access for inspections. Where insulation is not removed, the applicant is requested to justify the basis that any potential degradation will be detected.

RAI B2.1.20-2(e)

For bolted connections, the applicant is requested to clarify how evidence of corrosion and wear will be detected where the threaded surfaces are not normally visible.

RAI B2.1.20-3 NUREG-1800 Section A.1.2.3.6 Item 4 states that qualitative inspections should be performed to the same predetermined criteria as quantitative inspections by personnel in accordance with ASME Code and through approved site specific programs. The applicant is requested to identify the inspection criteria such as ASME Code VT-1 examination, or other industry standards and identify the qualifications of personnel performing the inspections.