ML052070776

RAI, Related to License Amendment Request for One-Time Extension to the Technical Specification Action Completion Time for Restoring a Service Water Train to Operable Status

ML052070776
Person / Time
Site:	Palisades
Issue date:	07/29/2005
From:	Padovan L NRC/NRR/DLPM/LPD3
To:	Harden P Nuclear Management Co
Padovan L, NRR/DLPM, 415-1423
References
TAC MC6544
Download: ML052070776 (5)

Text

July 29, 2005 Mr. Paul A. Harden Site Vice President Nuclear Management Company, LLC Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530

SUBJECT:

PALISADES PLANT REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST FOR ONE-TIME EXTENSION TO THE TECHNICAL SPECIFICATION ACTION COMPLETION TIME FOR RESTORING A SERVICE WATER TRAIN TO OPERABLE STATUS (TAC NO. MC6544)

Dear Mr. Harden:

Nuclear Management Company, LLCs (NMCs) letter of May 26, 2005, submitted a supplement to its license amendment request of April 1, 2005, for a one-time extension to the technical specification action completion time for restoring a service water train to operable status. The Nuclear Regulatory Commission staff is reviewing your request and finds that additional information is needed as shown in the enclosed request for additional information (RAI).

I discussed the enclosed RAI with Ms. Amy Hazelhoff of your organization on June 23, 2005, and she agreed to respond by August 31, 2005. Please contact me at (301) 415-1423 if you have questions.

Sincerely,

/RA/

L. Mark Padovan, Project Manager, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-255

Enclosure:

RAI cc w/encl: See next page

July 29, 2005 Mr. Paul A. Harden Site Vice President Nuclear Management Company, LLC Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530

SUBJECT:

PALISADES PLANT REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST FOR ONE-TIME EXTENSION TO THE TECHNICAL SPECIFICATION ACTION COMPLETION TIME FOR RESTORING A SERVICE WATER TRAIN TO OPERABLE STATUS (TAC NO. MC6544)

Dear Mr. Harden:

Nuclear Management Company, LLCs (NMCs) letter of May 26, 2005, submitted a supplement to its license amendment request of April 1, 2005, for a one-time extension to the technical specification action completion time for restoring a service water train to operable status. The Nuclear Regulatory Commission staff is reviewing your request and finds that additional information is needed as shown in the enclosed request for additional information (RAI).

I discussed the enclosed RAI with Ms. Amy Hazelhoff of your organization on June 23, 2005, and she agreed to respond by August 31, 2005. Please contact me at (301) 415-1423 if you have questions.

Sincerely,

/RA/

L. Mark Padovan, Project Manager, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-255

Enclosure:

RAI cc w/encl: See next page DISTRIBUTION PUBLIC OGC LRaghavan DLPMDPR EDuncan, RGN-III PDIII-1 Reading ACRS LPadovan THarris ADAMS Accession Number: ML052070776 OFFICE PDIII-1/PM PDIII-1/LA PDIII-1/SC NAME LPadovan THarris LRaghavan DATE 7/29/05 7/29/05 7/29/05 OFFICIAL RECORD COPY

Palisades Plant cc:

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

Request for Additional Information Palisades Nuclear Plant, Docket No. 50-255 License Amendment Request: One-time Extension to Technical Specification Action Completion Time for Restoration of a Service Water Train to Operable Status Risk Assessment

1. Nuclear Management Companys (NMCs) letter of May 26, 2005, provided an estimated increase in core damage frequency (CDF) and large early release frequency (LERF) from this one-time service water (SW) Completion Time (CT) extension. Please provide the following information:

a. Describe how NMC calculated the increases in CDF and LERF. Specifically, what probabilistic risk assessment (PRA) model parameters were changed, and by how much? For example, were the 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> added to the average test and maintenance for a cycle, a year, or some other period? Discuss the basis for the method used, and any assumptions used.

b. How was the benefit of the compensatory measures calculated? Provide the following:

(1) which compensatory measures were quantified (2) brief description of how they were modeled (3) failure probability of each

2. NMCs letter of April 1, 2005, provided an estimate of the incremental conditional core damage probability (ICCDP) and incremental conditional large early release probability (ICLERP) for this one-time SW CT extension. Please provide the following information:

a. Was credit for compensatory measures used in the calculation of these metrics?

b. If yes, please provide the ICCDP and ICLERP without credit for the compensatory measures.

3. NMCs April 1, 2005, submittal states: "One hundred percent of the required SWS [service water system] post accident cooling capability can be provided by any two SWS pumps if SWS flow, either to the non-critical header or to the critical loads inside the containment, is capable of being isolated. One hundred percent of the required SWS post accident cooling capability can be provided by any one SWS pump if SWS flow, both to the non-critical header and to the critical loads inside the containment, are capable of being isolated." The qualitative assessment of seismic risk states that the SWS is important to provide auxiliary feedwater (AFW) pump P-8C with a suction source.

Enclosure

a. How many SW pumps are required for seismic scenarios where the SWS is needed to supply a suction source for AFW pump P-8C, assuming SWS flow to the non-critical header, or to the critical loads inside the containment, is isolated? If greater than two, how did NMC factor this into the risk assessment?

b. How many SW pumps are required for seismic scenarios where the SWS is needed to supply a suction source for AFW pump P-8C, assuming SWS flow to the non-critical header, and to the critical loads inside the containment, is isolated? If greater than one, how was this factored into the risk assessment?

4. The seismic risk discussion in NMCs letter of May 26, 2005, concludes that removing P-7C from service for the extended CT would not result in a significant change in the individual plant examination of external events results, and would not have a significant impact on the calculated delta CDF or LERF. Apparently, NMC considered only seismic scenarios where the SWS is needed to supply a suction source for AFW pump P-8C.

a. Please provide an estimate of the change in risk from these scenarios when SW pump P-7C is out of service, or otherwise demonstrate that this change in risk is small.

b. Are these the only seismic scenarios that are expected to be adversely impacted when SW pump P-7C is out of service? If "no," please provide an estimate of the change in risk from these scenarios when SW pump P-7C is out of service, or otherwise demonstrate that this change in risk is small for the other seismic scenarios.

PRA Model Scope and Quality

1. Attachment 1 to NMCs letter of May 26, 2005, listed the Level A peer review findings and their resolution. Attachment 2 listed Level B peer review findings remaining to be resolved.

Please provide a listing of the resolved Level B peer review findings along with how they were resolved (in similar format to Attachment 1 of NMCs letter of May 26, 2005).

2. NMCs letter of May 26, 2005, provided the resolution of the PRA peer review comments.

Combustion Engineering Owners Group fact and observation, PEER-2000 AS-09 emergency diesel generator (EDG) repair, stated that the PRA model included repair of an out-of-service EDG, including support system failures. Service water is a support system for the Palisades EDGs. Does the current Palisades PRA model credit repair or recovery of service water? If yes, please provide information on the following:

a. What is the CDF, LERF, increase in CDF, and increase in LERF for the extended SW CT assuming no recovery or repair is credited for an out-of-service SW pump?

b. Calculate the ICCDP and ICLERP for the extended SW CT assuming no recovery or repair is credited for an out-of-service SW pump.

c. Describe how service water recovery or repair is credited in the 10 CFR 50.65 (a)(4) risk assessment when the plant configuration includes an out-of-service SW pump or train.