ML052000230
| ML052000230 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/02/2005 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Morgan M, NRR/NRC/DRIP/RLEP, 415-2232 | |
| Shared Package | |
| ML05200229 | List: |
| References | |
| Download: ML052000230 (6) | |
Text
Exceptions to GALL Program Elements (after PBD reviews to eliminate exceptions)
Element 5.7 through 5.10 Corrective Actions GALL 5.3 Confirmation Palisades 5.1 5.2 5.4 5.5 5.6 Parameters Monitored, Inspected, Process Program Section Scope of Program Preventive Actions and/or Tested Detection of Aging Effects Monitoring and Trending Acceptance Criteria Admin Controls Operating Experience Alloy 600 Inspection None None None None None None None Program XI.M11 LR-AMPBD ALLOY600 ASME Section XI None None None None None None None XI.M1, XI.M3, IWB, IWC, IWD, IWF Inservice Inspection Program LR-AMPBD XI.S3 ASMEISI Bolting Integrity None None None None None None None Program XI.M18 LR-AMPBD BOLTINTEG Boric Acid Corrosion None None None None None None None XI.M10 Program LR-AMPBD-04-BAC Buried Services None None None None None None None Corrosion Monitoring XI.M34 Program LR-AMPBD BURIEDSVC None None NUREG-1801, section XI.M21.3 states that, For pumps, the parameters monitored include NUREG-1801 states The extent and schedule of inspections and testing in accordance with EPRI
- 1. See 5.3 and 5.4 above for a discussion of exceptions to the Gall Report related to
- 1. See 5.3 and 5.4 above for a discussion of None flow and discharge and suction pressures. For TR-107396, assure detection of corrosion before performance and functional testing of pumps exceptions to the Gall heat exchangers, the parameters monitored the loss of intended function on the component. and heat exchangers. Report related to include flow, inlet and outlet temperatures, and Performance and functional testing in accordance performance and differential pressure. Palisades does not with EPRI TR-107396, ensures acceptable functional testing of pumps credit active flow testing for managing age- functional testing of the CCCW System or and heat exchangers.
related degradation of CCCW components. components serviced by the CCCW System.
However, performance of selected heat Palisades does not credit active performance and exchangers is monitored in accordance with functional testing for managing age-related the Master Heat Exchanger Testing Plan (Ref. degradation of CCCW components. However, 8.15). The performance and operability testing performance of selected heat exchangers is Closed Cycle Cooling of selected pumps, including flow, suction and monitored in accordance with the Master Heat Water Program XI.M21 discharge pressure, is monitored in accordance Exchanger Testing Plan (Ref. 8.15). The with the ASME Section XI Subsection IWP performance and operability testing of selected LR-AMPBD Inservice Testing Program, EM-09-04, pumps, including flow, suction and discharge CCCW Inservice Testing of Selected Safety-Related pressure, is monitored in accordance with the Pumps (Ref. 8.16). This is generally in ASME Section XI Subsection IWP Inservice accordance with the position taken by Fort Testing Program, EM-09-04, Inservice Testing Calhoun Station and V.C. Summer Nuclear of Selected Safety-Related Pumps (Ref. 8.16).
Station in their license renewal applications, This is generally in accordance with the position and accepted by the NRC in their respective taken by Fort Calhoun Station, and V.C. Summer Safety Evaluation Reports (References 8.35 & Nuclear Station, and accepted by the NRC in 8.36). See section 4.2 for a detailed discussion their respective Safety Evaluation Reports of Closed-Cycle Cooling Water Program Heat (References 8.35 & 8.36) See section 4.2 for a Exchanger and Pump performance and detailed discussion of Closed-Cycle Cooling functional testing. Water Program Heat Exchanger and Pump performance and functional testing.
J:\LIC_Renewal\License Renewal - ALL\Application for License Renewal\Palisades Precedent Tables\Programs Precedent Table\Precedents for Program Exceptions.doc 3/2/05 11:00 am
Element 5.7 through 5.10 Corrective Actions GALL 5.3 Confirmation Palisades 5.1 5.2 5.4 5.5 5.6 Parameters Monitored, Inspected, Process Program Section Scope of Program Preventive Actions and/or Tested Detection of Aging Effects Monitoring and Trending Acceptance Criteria Admin Controls Operating Experience Containment Inservice None None None None None None None Inspection Program XI.S1, XI.S2, X.S1 LR-AMPBD CONTISI Containment Leak None None None None None None None Rate Testing program XI.S4 LR-AMPBD CONTLRT J:\LIC_Renewal\License Renewal - ALL\Application for License Renewal\Palisades Precedent Tables\Programs Precedent Table\Precedents for Program Exceptions.doc 3/2/05 11:00 am
Element 5.7 through 5.10 Corrective Actions GALL 5.3 Confirmation Palisades 5.1 5.2 5.4 5.5 5.6 Parameters Monitored, Inspected, Process Program Section Scope of Program Preventive Actions and/or Tested Detection of Aging Effects Monitoring and Trending Acceptance Criteria Admin Controls Operating Experience None NUREG-1801 (Ref. 8.1)Section XI.M30 None None None None None states, The quality of fuel oil is maintained by additions of biocides to minimize biological activity, stabilizers to prevent biological breakdown of the diesel fuel, and corrosion inhibitors to mitigate corrosion.
Palisades tests the fuel in T-10A periodically for microbiological growth.
There is no operational experience that indicates a positive test for microbiological growth. In the event a test would come back positive for microbiological growth, an evaluation would be performed, per the corrective action program, to determine whether addition of biocides should be performed.
Palisades performs periodic tests for particulates on the fuel oil storage tanks. Additionally, the stored fuel in T-10A Fuel Oil Storage Tank is filtered approximately every three years, or as needed (Ref. 8.30). The fuel oil storage tanks have a relatively fuel oil high Diesel Fuel Monitoring turnover rate. T-10A typically has an and Storage Program XI.M30 operating volume of 38,000 gallons, with an average fuel consumption of LR-AMPBD 76,000 gallons. T-926 has a typical DSLFUEL operating volume of 15,000 gallons, with an average fuel consumption rate of 35,000 gallons per year. Based on these activities, and high fuel turnover in the storage tanks, an assessment (Ref. 8.31) has determined that there is no need to add fuel oil stabilizers to the diesel fuel.
Palisadess fuel oil is procured to meet ASTM D975 (Ref. 8.23) standards, which includes specifications and acceptance criteria for a Copper Strip Corrosion Test. Additionally, samples are periodically analyzed by an off-site facility for relative corrosivity of the fuel by a Copper Strip Corrosion Test. All Copper Strip Corrosion tests performed in the last 5 years have returned results that meet the ASTM standard.
Consequently, Palisades does not add corrosion inhibitors to the diesel fuel.
This is generally in accordance with the position taken Dresden and Quad cities Nuclear power Plants and accepted in NUREG 17967 pages 3-247 through 252.
Electrical Equipment None None None None None None None Qualification Program X.E1 LR-AMPBD-11-EEQ Fatigue Monitoring None None None None None None None Program X.M1 LR-AMPBD FATIGUE J:\LIC_Renewal\License Renewal - ALL\Application for License Renewal\Palisades Precedent Tables\Programs Precedent Table\Precedents for Program Exceptions.doc 3/2/05 11:00 am
Element 5.7 through 5.10 Corrective Actions GALL 5.3 Confirmation Palisades 5.1 5.2 5.4 5.5 5.6 Parameters Monitored, Inspected, Process Program Section Scope of Program Preventive Actions and/or Tested Detection of Aging Effects Monitoring and Trending Acceptance Criteria Admin Controls Operating Experience None None None XI.M26 XI.M27 XI.M26 None NUREG-1801,Section XI.M26, as clarified by NUREG-1801,Section XI.M27, as clarified by NUREG-1801, as clarified ISG-04, Detection of Aging Effects, states, ISG-04, states that the results of system by ISG-04, states Visual inspection (VT-1 or equivalent) of performance testing are monitored and trended Inspection results are approximately 10% of each type of seal Visual as specified by the NFPA codes and standards. acceptable if there are no inspection (VT-1 or equivalent) of the fire barrier At Palisades, inspection and testing is visual indications of walls, ceilings, and floors Visual inspection performed as outlined in Fire Protection cracking, separation of (VT-3 or equivalent) detects any signs of Implementing Procedures. NFPA codes of seals from walls and degradation of the fire door Palisades does record are identified in the Palisades Fire components, separation of not qualify the personnel performing the visual Protection Program Report (FPPR) (Ref. 8.27) layers of material, or XI.M26, XI.M27 inspections of fire barrier walls, ceilings, floors, and/or FSAR (Ref. 8.9). This is generally in ruptures or punctures of Fire Protection penetration seals and fire doors to the NDE type accordance with the position taken by the seals. Palisades Program of qualification as stated in NUREG-1801 and Dresden and Quad Cities Nuclear Power inspection acceptance ISG -04. Per FPSP-SO-2 (Ref. 8.57), FPSP-RP- Stations in their License Renewal Application criteria states that no LR-AMPBD 11 (Ref. 8.55), and FPSP-RP-12 (Ref. 8.56) (Ref. 8.45) and approved by the NRC in the cracks of 1/4 wide or FIREPROT inspectors for fire barriers/doors/fire seals are associated Safety Evaluation Report greater are allowed. The qualified to perform those inspections, but are not acceptance criteria are necessarily qualified to VT-1 or VT-3. There are derived from fire test no regulatory requirements or any other type of reports, and are acceptable.
requirements specifying that these inspections be No precedent identified to performed to VT-1 or VT-3 standards. This is date.
generally in accordance with the position taken by the Dresden and Quad Cities Nuclear Plants in their application for License Renewal, and subsequent NRC approval of this position in the associated Safety Evaluation Report Flow Accelerated None None None None None None None XI.M17 corrosion Program LR-AMPBD-15-FAC Non-EQ Electrical None None None None None None None XI.E1, XI.E2 Commodity Condition Monitoring Program LR-AMPBD XI.E3 NONEQELECOM Open Cycle Cooling None None None None None None None Water Program XI.M20 LR-AMPBD OCCW J:\LIC_Renewal\License Renewal - ALL\Application for License Renewal\Palisades Precedent Tables\Programs Precedent Table\Precedents for Program Exceptions.doc 3/2/05 11:00 am
Element 5.7 through 5.10 Corrective Actions GALL 5.3 Confirmation Palisades 5.1 5.2 5.4 5.5 5.6 Parameters Monitored, Inspected, Process Program Section Scope of Program Preventive Actions and/or Tested Detection of Aging Effects Monitoring and Trending Acceptance Criteria Admin Controls Operating Experience None None NUREG-1801, section XI.M23, Parameters Monitored/Inspected section, states, The None None None None number and magnitude of lifts made by the crane are also reviewed. Palisades does not track the number and magnitude of all lifts made by cranes. Administrative controls are implemented to ensure that only allowable loads are handled and fatigue failure of structural elements is not expected. A time-limited aging analysis report concludes that, at the current service level, there are no fatigue concerns for Containment polar crane and the Spent Fuel Pool crane as both the Containment polar and Spent Fuel Pool crane can not realistically approach the 20,000 to 100,000 Overhead Load rated lifts assumed for their design evaluation Handling Systems during the 60 year extended operating period XI.M23 Inspection Program (Ref. 8.25). Frequent inspections of cranes for indications of functional failures are LR-AMPBD conducted. However, Palisades does track the OVHDLOAD number and magnitude of lifts made that exceed the rated capacity of the cranes (Ref.
8.6). These are called engineered lifts, follow the requirements of ANSI B30.2, and are generally only used for the polar crane (L-
- 1) lifting the reactor head with lead shielding.
These lifts are numerically restricted, and evaluated by engineering analysis. This exception is generally in accordance with the position taken by the Dresden and Quad Cities Nuclear Power Stations in their License Renewal Application, and subsequently approved by the Nuclear Regulatory Commission in the associated Safety Evaluation Report (Ref. 8.26).
None None None XI.M32 None None None Section XI.M32.4 of NUREG-1801 requires plant-specific destructive examination of replaced piping due to plant modifications, or NDE that will detect cracking on the inside surfaces of the XI.M32, XI.M33, XI.M29 (partial) small bore piping. The current state of technology does not provide for an effective, reliable method of performing volumetric One-Time Inspection examinations of small-bore socket welds. The Program combination of these one-time volumetric examinations of a 10% sample of Class 1 butt LR-AMPBD welds, and the 100% VT-2 examinations of all ONETIME Class 1 and 2 HSS socket welds 2 NPS and under each refueling outage meets the intent of NUREG-1800 and -1801 to provide aging management for small-bore class 1 piping. This is generally in accordance with the position approved by the NRC for the Dresden/Quad Cities Nuclear Plants in their License Renewal Application and associated Safety Evaluation Report (Ref. 8.22).
Reactor Vessel None None None None None None None Integrity Surveillance XI.M31 Program LR-AMPBD VSLINTEGRITY J:\LIC_Renewal\License Renewal - ALL\Application for License Renewal\Palisades Precedent Tables\Programs Precedent Table\Precedents for Program Exceptions.doc 3/2/05 11:00 am
Element 5.7 through 5.10 Corrective Actions GALL 5.3 Confirmation Palisades 5.1 5.2 5.4 5.5 5.6 Parameters Monitored, Inspected, Process Program Section Scope of Program Preventive Actions and/or Tested Detection of Aging Effects Monitoring and Trending Acceptance Criteria Admin Controls Operating Experience Reactor Vessel 1. None None None None None None None Internals Inspection XI.M16 Program LR-AMPBD VSLINTERNALS Steam Generator Tube None None None None None None None Integrity Program XI.M19 LR-AMPBD SGINTEGRITY Structures Monitoring None None None None None None None Program XI.S5, XI.S6, XI.S7 LR-AMPBD STRUCTMON System Monitoring None None None None None None None Program XI.M29 LR-AMPBD (partial)
SYSMON Water Chemistry None None None None None None None Program XI.M2 LR-AMPBD CHEMISTRY Current AMP consistency rating: Total # of attributes: (23 Programs complete) x (10 Attributes per program) = 230. Total number of exceptions = 10 => (230-10)/230 = 95.6% consistency J:\LIC_Renewal\License Renewal - ALL\Application for License Renewal\Palisades Precedent Tables\Programs Precedent Table\Precedents for Program Exceptions.doc 3/2/05 11:00 am