ML051790157
| ML051790157 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/28/2005 |
| From: | Morgan M NRC/NRR/DRIP/RLEP |
| To: | Domonique Malone Nuclear Management Co |
| Morgan M, NRR/DRIP/RLEP, 415-2232 | |
| References | |
| TAC MC6433 | |
| Download: ML051790157 (7) | |
Text
June 28, 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/ (S. Lee for)
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
ML051790157 Document Name: E:\\Filenet\\ML051790157.wpd OFFICE PM:RLEP LA:RLEP SC:RLEP NAME MMorgan (S. Lee for)
MJenkins SLee DATE 06/28/5 06/27/05 06/28/05
Palisades Nuclear 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 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 28,2005 ADAMS Accession No.: ML051790157 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)
RAI A2.3-1 On Page A-3 of the LRA, the first two sentences in Section A2.3, Bolting Integrity Program, are not consistent with the FSAR Supplement in NUREG-1800 (e.g., Page 3.1-23). Please clarify.
RAI B2.1.3-1 On Page B-25 of the LRA, the applicant states that the Structural Monitoring Program in LRA Section B2.1.19 is credited for the Palisades Bolting Integrity Program. On Page B-29, the applicant states that structural bolting and fasteners are inspected visually in accordance with the Structural Monitoring Program. However, bolting is not discussed in the Structural Monitoring Program. Please clarify why the Structural Monitoring Program is credited for the Bolting Integrity Program when bolting is not explicitly discussed in the Structural Monitoring Program.
RAI B2.1.3-2 On Page B-25 of the LRA, the applicant states that the system monitoring program in LRA Section B2.1.20 is credited for the Bolting Integrity Program; however, bolting is not mentioned in the system monitoring program. (1) Please clarify why the system monitoring program is credited for the Bolting Integrity Program when bolting is not discussed in the system monitoring program; (2) Under the system monitoring program, the applicant inspects piping systems visually to determine leakage during walkdowns. Most piping systems are covered with insulation. Discuss how bolting integrity (e.g., cracking, loss of preload, and loss of material due to corrosion) would be determined when bolts are covered with insulation.
RAI B2.1.3-3 On Page B-25 of the LRA, the applicant states that the ASME Section XI IWB, IWC, IWD, IWF Inservice Inspection (ISI) program in LRA Section B2.1.2 is credited for the Bolting Integrity Program. The ASME Section XI specifies periodic inservice examination on a sampling basis.
Please clarify whether all bolts in the Palisades plant that are covered under the LRA will be examined before entering extended period of operation. If not, provide a percentage of bolts that will be examined per the ISI program before entering extended period of operation and discuss whether this percentage is sufficient to show bolting integrity of the entire bolting population.
RAI B2.1.3-4 On Page B-26 of the LRA, the applicant states that the attributes of the Bolting Integrity Program are adequate to manage loss of preload without hot torquing; therefore, hot torquing to establish a preload will not be credited for aging management of bolting. The applicant needs to explain in detail which attributes of the Bolting Integrity Program are adequate to manage loss of preload without hot torquing.
RAI B2.1.3-5 On Page B-26 of the LRA, the applicant states that...The Bolting Integrity Program is consistent with NUREG-1801,Section XI.M18, Bolting Integrity. The applicant also states that
...Two enhancements are planned to bring the Bolting Integrity Program into conformance with the NUREG-1801 program description... These two statements seem to contradict each other.
Please clarify.
RAI B2.1.3-7 On Page B-28 of the LRA, the applicant states that normal maintenance practices and quality verification procedures for pressure retaining bolting includes a check of bolt torque and uniformity of gasket compression. Discuss whether there are similar procedures to verify the torque of structural bolting.
RAI B2.1.3-8 On Page B-30 of the LRA, the applicant states that MC component support bolting is evaluated in accordance with the acceptance standards of ASME Code Case N-491-2, Section 3410.
GALL XI.M18 recommends immediate replacement of the cracked bolt when indications of cracking is found in support bolting. Code Case N-491-2 provides guidance on examination and acceptance criteria, but it does not specify replacement. Discuss whether the Bolting Integrity Program has a process by which a cracked bolt will be replaced immediately.
RAI B2.1.3-9 On Page B-30 of the LRA, the applicant states that...Palisades Bolting Integrity Program makes no distinction regarding <immediate repairs, but instead relies upon the plant inservice inspection program and corrective action process to evaluate, prioritize and schedule repairs...
GALL XI.M18 recommends that immediate repairs be performed for major leaks that may cause corrosion or contamination. Explain whether major leaks that are caused by degraded bolting will be repaired immediately, including bolting replacement.
RAI B2.1.3-10 On Page B-31 of the LRA, the applicant states that the Bolting Integrity Program has been effective in identifying six instances of bolting degradation at Palisades in a timely manner. (1)
Discuss how the six instances of bolting degradation were dispositioned; (2) Discuss how the six instances of bolting degradation were detected (e.g., by routine maintenance, system walkdown, or leakage monitoring system); and (3) Describe degradation mechanism(s) of each of the six instances in question.