ML052140634

Summary of a Telephone Conference Held on July 20, 2005, Between the NRC and Nuclear Management Company, LLC Concerning Responses to Open Questions from the Site Aging Management Program Audit

ML052140634
Person / Time
Site:	Palisades
Issue date:	08/02/2005
From:	Morgan M NRC/NRR/DRIP/RLEP
To:	Nuclear Management Co
Morgan M, NRR/DRIP/RLEP, 415-2232
References
TAC MC6433
Download: ML052140634 (10)

Text

August 2, 2005 LICENSEE: Nuclear Management Company, LLC FACILITY: Palisades Nuclear Plant

SUMMARY

OF A TELEPHONE CONFERENCE HELD ON JULY 20, 2005, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION (NRC)

AND NUCLEAR MANAGEMENT COMPANY, LLC (NMC) CONCERNING RESPONSES TO OPEN QUESTIONS FROM THE SITE AGING MANAGEMENT PROGRAM AUDIT (TAC NO. MC6433)

The NRC staff (the staff) and representatives of Nuclear Management Company, LLC (NMC) held a telephone conference on July 20, 2005, to discuss and clarify the applicants responses to open questions from the site aging management program audit. The conference call was useful in clarifying these responses. provides a listing of the conference call participants. Enclosure 2 contains a listing of the questions discussed with the applicant, including a brief description on the status of the items.

The applicant had an opportunity to comment on this summary.

/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

Enclosures:

As stated cc w/encls: See next page

ML052140634 DOCUMENT NAME: E:\Filenet\ML052140634.wpd OFFICE PM:RLEP LA:RLEP SC:RLEP NAME MMorgan (S. Lee for) MJenkins S Lee DATE 08/02/2005 08/02/2005 08/02/2005 Palisades Nuclear 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 Inspectors 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 Senior Vice President - Group Operations Quality Palisades Nuclear Plant Waste and Hazardous Materials Division Nuclear Management Company, LLC Hazardous Waste and Radiological 27780 Blue Star Memorial Highway Protection Section Covert, MI 49043 Nuclear Facilities Unit Constitution Hall, Lower-Level North Paul A. Harden 525 West Allegan Street Site Vice President P.O. Box 30241 Palisades Nuclear Plant Lansing, MI 48909-7741 Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Covert, MI 49043

Palisades Nuclear Plant cc:

Robert A. Vincent Licensing Lead - License Renewal Project Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 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, MI 48909-7721

DISTRIBUTION: Summary of telephone conference held on July 20, 2005 with NMC, LLC Dated: August 2, 2005 ADAMS Accession No.: ML052140634 HARD COPY RLEP RF M. Morgan (PM)

E-MAIL:

RidsNrrDrip RidsNrrDe G. Bagchi K. Manoly W. Bateman J. Calvo R. Jenkins 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 L. Raghavan T. Mensah OPA

LIST OF PARTICIPANTS FOR TELEPHONE CONFERENCE TO DISCUSS RESPONSES TO OPEN QUESTIONS FROM THE SITE AGING MANAGEMENT PROGRAM AUDIT JULY 20, 2005 Participants Affiliations Michael Morgan U.S. Nuclear Regulatory Commission (NRC)

Kurt Cozens NRC Michael Kennedy Information Systems Laboratories, Inc. (ISL)

Darrel Turner Nuclear Management Company, LLC (NMC)

Robert Vincent NMC Enclosure 1

RESPONSES TO OPEN QUESTIONS FROM THE AGING MANAGEMENT PROGRAM AUDIT PALISADES NUCLEAR PLANT LICENSE RENEWAL APPLICATION JULY 20, 2005 The U.S. Nuclear Regulatory Commission staff (the staff) and representatives of Nuclear Management Company, LLC (NMC), held a telephone conference call on July 20, 2005, to discuss and clarify the applicants responses to open questions from the Palisades Nuclear Plant (PNP) Aging Management Program audit. The following questions were discussed during the telephone conference call.

Question B2.1.5-002 This question is presented for clarification purposes. The response is not consistent with the discussions during the audit on-site. Per the project teams discussions with the applicant, PNP does not have any buried piping which is managed by the B2.1.5 AMP and is subject to selective leaching. It was the teams understanding that all materials susceptible to selective leaching are in the fire protection system and are managed by the Fire Protection AMP. Does PNP intend to modify the LRA AMP B2.1.5, to delete the discussion on management of selective leaching or has the team misunderstood PNP representatives statements; i.e., B2.1.5 is not used in conjunction with AMR line items identifying components made from materials that are susceptible to selective leaching?

Discussion: Based on the discussion with the applicant, this question will be deferred for further clarification during the August 1 thru 5, 2005 audit. The staff agreed to the proposal.

Question B2.1.5-007 This question is presented for clarification purposes. The response is not relevant to the question originally asked by the project team. The applicant should provide additional information related to operating experience (OE) as was discussed during the during the teams site interviews.

Discussion: Based on the discussion with the applicant, this question will be deferred for further clarification during the August 1 thru 5, 2005 audit. The staff agreed to the proposal.

Question B2.1.5-008 This question is presented for clarification purposes. The applicants response is the same as provided in its response to Question B2.1.5-009. The project team requests the applicant to:

(1) identify how many times it has excavated buried piping; (2) identify which pipes or systems were excavated; (3) provide the results observed from these inspections, and (4) identify the years when these inspections were performed.

Discussion: Based on the discussion with the applicant, this question will be deferred for further clarification during the August 1 thru 5, 2005 audit. The staff agreed to the proposal.

Question B2.1.5-009 This question is presented for clarification purposes. The applicants response to this question is incomplete since it only provides the conclusion that the failures were design discrepancies.

Please describe the type of failure mechanisms (not just the conclusion), that have occurred in the Auxiliary Feedwater and Fire Protection Systems piping (including year, location and a brief description of the event). Then explain why these failures were not age-related.

Enclosure 2

Discussion: Based on the discussion with the applicant, this question will be deferred for further clarification during the August 1 thru 5, 2005 audit. The staff agreed to the proposal.

Question B2.1.7-004 This question is presented for clarification purposes. The applicants response to this question references ASME Section XI, Subsection IWE instead of IWL, which is the subject of this question. Does the applicant intend to modify its response to correct this apparent typographical error?

Discussion: The applicant determined that this was a typographical error and the applicant also indicated that the question is clear. This applicant will correct this error.

Question B2.1.10-011 This question is presented for clarification purposes. The applicants response primarily focuses on the qualification of personnel. The project teams question was intended to focus on the actual inspection methodology. Please provide a technical justification as to how the visual inspection is equivalent, which the applicant has stated, and assures the same level flaw identification and documentation as would be achieved by VT-1 and VT-3.

Discussion: Based on the discussion with the applicant, this question will be deferred for further clarification during the August 1 thru 5, 2005 audit. The staff agreed to the proposal.

Question B2.1.10-017 This question is presented for clarification purposes. Only the first two sentences of the applicants response touch on the essence of the project teams question. The subsequent sentences of the applicants response address history, and what actions are taken should a crack larger than 1/4 inch be identified during an inspection. The focus of the teams question is a request for the applicant to justify why the 1/4 inch wide crack is technically acceptable. Neither of the first two sentences provide a satisfactory justification as to why this size crack is acceptable. The response only provides a comparison to the gap permitted at the bottom of a fire door. It is not clear to the team why a 1/4 inch crack in a fire seal would respond during a fire in a manor similar to the gap at the bottom of the fire door. Please enhance the response to characterize the technical basis for accepting the 1/4 inch crack. Without such a technical justification, the team would not be able to accept the exception proposed by the LRA.

Discussion: Based on the discussion with the applicant, this question will be deferred for further clarification during the August 1 thru 5, 2005 audit. The staff agreed to the proposal.

Question B2.1.10-023 This question is presented for clarification purposes and is a generic question. This is an open issue until a decision is made on how to capture enhancements to the AMPs for the license renewal (i.e., in Appendix A or a commitment list). During the interviews, the auditor asked the applicant to add the industrys and NRCs new position on underground piping inspection to the response to this question. Note that selective leaching is applicable to the underground piping that is managed by the fire protection AMP. Therefore, selective leaching mechanism should be discussed.

Discussion: Based on the discussion with the applicant, this question will be deferred for further clarification during the August 1 thru 5, 2005 audit. The staff agreed to the proposal.

Question B2.1.14-003 This question is presented for clarification purposes. The testing frequency of the Shield Cooling System heat exchanger is not addressed. GALL recommends a maximum interval of five years for the heat exchanger performance testing. Is it the applicants intent to reduce the inspection frequency to a 5-year periodicity?

Discussion: Based on the discussion with the applicant, this question will be deferred for further clarification during the August 1 thru 5, 2005 audit. The staff agreed to the proposal.

Question B2.1.19-005 The response itself is acceptable. However, an LRA supplement is needed to actually add to the Structural Monitoring Program that the inspection of unreinforced block walls will be on a more frequent basis than reinforced walls. This would result in the PNP AMP agreeing with the recommendation in the GALL AMP for block walls.

Discussion: Based on the discussion with the applicant, this question will be deferred for further clarification during the August 1 thru 5, 2005 audit. The staff agreed to the proposal.

Question B2.1.19-006 The response itself is acceptable. However, an LRA supplement is needed to actually add to the Structural Monitoring Program that inspection of inaccessible areas will be performed when they become accessible due to excavation from normal PNP activities.

Discussion: Based on the discussion with the applicant, this question will be deferred for further clarification during the August 1 thru 5, 2005 audit. The staff agreed to the proposal.

Question B2.1.19-008 This question is presented for clarification purposes. The response mentions how the Structural Monitoring Program at PNP requires more frequent inspections of areas showing signs of aging, such as the wall cracks. However, the response does not identify the frequency of future inspections of the cracked wall under the Structural Monitoring Program. Is it the intent of the applicant to identify the frequency in its response? Instead, the response gives the flood barrier inspection frequency for the room where the wall cracks exist. Is it the intent of the applicant to docket this frequency under oath and affirmation?

Discussion: Based on the discussion with the applicant, this question will be deferred for further clarification during the August 1 thru 5, 2005 audit. The staff agreed to the proposal.

Responses to the following open questions were acceptable:

Question B2.1.5-010 Question B2.1.10-008 Question B2.1.10-022 Question B2.1.14-011 Question B2.1.18-009 Question B2.1.18-010