ML052430767
| ML052430767 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/31/2005 |
| From: | Morgan M NRC/NRR/DRIP/RLEP |
| To: | Harden P Nuclear Management Co |
| Morgan M, NRR/DRIP/RLEP, 415-2232 | |
| References | |
| TAC MC6433 | |
| Download: ML052430767 (9) | |
Text
August 31, 2005 Paul A. Harden Site Vice President Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Covert, MI 49043
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (RAI) FOR THE REVIEW OF THE PALISADES NUCLEAR PLANT, LICENSE RENEWAL APPLICATION (TAC NO. MC6433)
Dear Mr. Harden:
By letter dated March 22, 2005, Nuclear Management Company, LLC, (NMC or the applicant) submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (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.
The question was 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 via e-mail at 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
ML052430767 Document Name: E:\\Filenet\\ML052430767.wpd OFFICE PM:RLEP LA:RLEP SC:RLEP NAME MMorgan (S. Lee for)
MJenkins SLee DATE 08/31/05 08/31/05 08/31/05
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 David Lewis Pillsbury Winthrop Shaw Pittman, LLP 2300 N Street, N.W.
Washington, D.C. 20037 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, MI 48909-7721
DISTRIBUTION: Letter to P. Harden, Re: RAIs for Palisades LRA, Dated: August 31, 2005 ADAMS Accession No.: ML052430767 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
Enclosure PALISADES NUCLEAR PLANT LICENSE RENEWAL APPLICATION (LRA)
REQUEST FOR ADDITIONAL INFORMATION (RAI)
RAI 2.3.3.7-1 LRA Section 2.3.3.7, on Page 2-114, states that the boundaries of the portions of the Fire Protection System within the scope of license renewal include five legs that tap off the fire main loop to supply various sprinkler systems, deluge systems and hose stations within the auxiliary building, turbine building, intake structure, and hydrant stations.
LRA Section 2.1.1.1 identifies the current licensing basis as a plant information source for license renewal. The current licensing basis for fire protection is contained in the PNP fire hazards analysis (FHA), 10 CFR Part 50 Appendix R analysis and fire protection safety evaluation report(s).
License renewal Drawing, LR-216, Sheet 2, shows fire hose stations FHS 1, FHS 6, FHS 2 and FHS 4 (Locations F-3 and F-4) as outside the scope of license renewal. Based on the information available in the PNP current licensing basis, the staff cannot determine if these fire hose stations should be excluded from the scope of license renewal.
In order for the staff to complete its review, provide the fire area and the room number in which these fire hose stations are located. Justify the exclusion of these fire hose stations from the scope of license renewal in accordance with the requirements of 10 CFR Part 54.4(a)(3).
RAI 2.3.3.7-3 The PNP Plant Fire Hazards Analysis (FHA) Report,Section II, ?Definitions, states that a fire area, as used in Appendix R, is defined as an area sufficiently bounded to withstand hazards associated with the area and, as necessary, to protect important equipment within the area from fire outside the area. The FHA report describes Fire Areas 1 though 19 and 21 through 36. Each fire area evaluation contains a section, ?Fire Barriers Defining the Areas. These fire barriers are included in the current licensing basis and are within the scope of license renewal. Fire Area 9, ?Screen House (Intake Structure), describes ?A radiant energy shield wall and a horizontal distance of at least 20" separates one diesel fire pump from the others...
LRA Section 2.3.3.7 of the fire protection system states, ?The Fire Protection System (FPS) includes the diverse design and operational features intended to prevent and mitigate the effects of fires.
Building structures have been designed and arranged to prevent the spread of fire and to ensure integrity of redundant safe shutdown systems and areas.
LRA Section 2.4.7, ?Intake Structure, lists building framing-concrete, below grade (wall, foundation, slab, grout, reinforcement, trenches, cable pits, tunnels, etc.) as a component group subject to an AMR. Although fire barrier is identified as one of intended functions for this component group, based on review of the above LRA sections it is not clear that all fire barriers and the radiant energy shield wall in the screen house (intake structure) described in the Fire Hazards Analysis (Fire Area 9) are included within the scope of license renewal.
Enclosure Confirm that all fire barriers and components such as, doors, dampers and penetration seals described in the plant FHA report are included within the scope of license renewal or provide information to describe why any of the fire barriers or the radiant energy shield are excluded from the scope of license renewal.
RAI 2.3.3.7-4 The current licensing basis for fire protection is contained in the Plant Fire Hazards Analysis (FHA)
Report, 10 CFR Part 50 Appendix R analysis, and fire protection safety evaluation report (SER).
The plant FHA describes Fire Areas 25A, South Heating Boiler Room, and 25B, North Heating Boiler Room, located in the turbine building elevation 590'. The fire hazards analysis describes each of these rooms as being protected by automatic wet pipe suppression systems.
License renewal drawing LR-216, Sheet 2, depicts sprinkler systems in the following areas as outside the scope of license renewal: boiler rooms, office (elevation 607'), cold chemical and IC labs (elevation 590'), and office (elevation 590') at Location F-7 and maintenance storage (elevation 590'), and tech and maintenance office (elevation 590').
Provide the basis for excluding the sprinkler systems for the above-mentioned rooms from the scope of license renewal or revise the license renewal drawings accordingly.
RAI 2.3.3.7-5 LRA Section 2.4.3, on page 2-225, System Function Listing, S0100-FP, has a comment that containment exterior wall is an Appendix R fire barrier. However, LRA Table 2.4.3-1 does not include fire barrier/protection as an intended function.
Provide information to clarify that Table 2.4.3-1 does not need to describe fire protection as an intended function, or revise the table to define fire protection as an intended function.
RAI 2.3.3.7-6 LRA Section 2.4.6 for the feedwater purity building, on Page 2-234, states that the water purity building is within the scope of license renewal based on fire protection requirements to achieve safe shutdown. It also states that, on page 2-235, the feedwater purity boiler room in the south end of the building houses a diesel fuel oil transfer pump and piping, and this is the only area in this structure that is within the scope of license renewal. Further, the system function S0800-FP, on Page 2-235, states that the building provides structural and/or functional support to fire protection-related components. However, LRA Table 2.4.6-1 does not identify fire protection/barrier as an intended function.
Provide information to clarify that fire barrier is not an intended function for the feedwater purity building, or revise Table 2.4.6-1 to define fire barrier as an intended function.
RAI 2.3.3.7-7 LRA Section 2.4.10 of the turbine building, on Page 2-251, states that the turbine building also contains fire barrier concrete commodities credited in fire protection requirements for achieving safe shutdown. Further, the system function listing, on Page 2-252 states that this section includes fire protection as one of the functions. However, LRA Table 2.4.10-1 does not include fire protection as an intended function.
Enclosure Provide information to clarify that fire barrier is not an intended function for the turbine building, or revise Table 2.4.10-1 to define fire barrier as an intended function.
RAI 2.3.3.7-9 The following components are shown on the fire protection license renewal drawings as within the scope of license renewal. However, LRA Table 2.3.3-7 of the fire protection system does not list these components as being subject to an AMR. These components serve a pressure boundary intended function, and are passive and long-lived. Clarify if these components are included in Table 2.3.3-7 as part of any other component group. If not, justify the exclusion of these components from being subject to an AMR in accordance with the requirements of 10 CFR Part 54.21(a)(1).
a.
Flexible connections on LR-216, Sheet 1, at Locations B-4, C-4, and E-5.
b.
Lube oil coolers on LR-216, Sheet 1, at Locations B-4 and RAI 3.3.2.7-1 The PNP fire hazards analysis (FHA), in fire area 9 screen house (intake structure), describes,
?A radiant energy shield wall... separates one diesel fire pump from the others... Table 3.5.2-8 of the LRA does not specifically identify radiant energy shields, but references carbon steel fire barriers in the auxiliary building, intake building and containment. It is unclear what these metal barriers are and what there function is. Table 3.5.2-8 references the Fire Protection Program, Section B2.1.10, as the Aging Management Program addressing these barriers. However, Section B2.1.10 does not specifically address radiant energy shields, and refers to the Structural Monitoring Program, Section B2.1.19 for fire barriers, such as walls, floors, and ceilings. Identify where the radiant energy shields referenced in the FHA are included in the AMR and which program manages their aging effects. Also verify that the Table 3.5.2-8 should include a reference to the Structural Monitoring Program, Section B2.1.19 for these barriers or identify where in the Fire Protection Program, Section B2.1.10 they are addressed.