ML052730460

Summary of a Telephone Conference Call Held on August 24, 2005, Between the NRC and NMC, Concerning Responses to Follow-Up Questions from the Site Aging Management Program and Aging Management Review Audit

ML052730460
Person / Time
Site:	Palisades
Issue date:	09/28/2005
From:	Morgan M NRC/NRR/DRIP/RLEP
To:	Nuclear Management Co
Morgan M, NRR/NRC/DRIP/RLEP, 415-2232
References
TAC MC6433
Download: ML052730460 (11)

Text

September 28, 2005 LICENSEE: Nuclear Management Company, LLC FACILITY: Palisades Nuclear Plant

SUMMARY

OF A TELEPHONE CONFERENCE CALL HELD ON AUGUST 24, 2005, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION (NRC) AND NUCLEAR MANAGEMENT COMPANY, LLC (NMC)

CONCERNING RESPONSES TO FOLLOW-UP QUESTIONS FROM THE SITE AGING MANAGEMENT PROGRAM AND AGING MANAGEMENT REVIEW AUDIT (TAC NO. MC6433)

The U.S. Nuclear Regulatory Commission staff (the staff) and representatives of NMC held a telephone conference call on August 24, 2005, to discuss and clarify the applicants responses to follow-up questions from the site aging management program and aging management review 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/

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

ML052730460 DOCUMENT NAME: E:\Filenet\ML052730460.wpd OFFICE PM:RLEP LA:RLEP SC:RLEP NAME MMorgan YEdmonds S Lee DATE 09/27/2005 09/22/2005 09/28/2005 cc:

Robert A. Fenech, Senior Vice President Special Litigation Division Nuclear, Fossil, and Hydro Operations 525 West Ottawa St.

Consumers Energy Company Sixth Floor, G. Mennen Williams Building 1945 Parnall Rd. Lansing, MI 48913 Jackson, MI 49201 Manager, Regulatory Affairs Arunas T. Udrys, Esquire Nuclear Management Company, LLC Consumers Energy Company 27780 Blue Star Memorial Highway 1 Energy Plaza Covert, MI 49043 Jackson, MI 49201 Director of Nuclear Assets Regional Administrator, Region III Consumers Energy Company U.S. Nuclear Regulatory Commission Palisades Nuclear Plant 801 Warrenville Road 27780 Blue Star Memorial Highway Lisle, IL 60532-4351 Covert, MI 49043 Supervisor John Paul Cowan Covert Township Executive Vice President & Chief Nuclear P.O. Box 35 Officer Covert, MI 49043 Nuclear Management Company, LLC 700 First Street Office of the Governor Hudson, WI 54016 P.O. Box 30013 Lansing, MI 48909 Jonathan Rogoff, Esquire Vice President, Counsel & Secretary U.S. Nuclear Regulatory Commission Nuclear Management Company, LLC Resident Inspectors Office 700 First Street Palisades Plant Hudson, WI 54016 27782 Blue Star Memorial Highway Covert, MI 49043 Douglas E. Cooper Senior Vice President - Group Operations Michigan Department of Environmental Palisades Nuclear Plant Quality Nuclear Management Company, LLC Waste and Hazardous Materials Division 27780 Blue Star Memorial Highway Hazardous Waste and Radiological Covert, MI 49043 Protection Section Nuclear Facilities Unit Paul A. Harden Constitution Hall, Lower-Level North Site Vice President 525 West Allegan Street Palisades Nuclear Plant P.O. Box 30241 Nuclear Management Company, LLC Lansing, MI 48909-7741 27780 Blue Star Memorial Highway Covert, MI 49043 Michigan Department of Attorney General

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 August 24, 2005 with NMC, LLC Dated: September 28, 2005 ADAMS Accession No.: ML052730460 HARD COPY RLEP RF M. Morgan (PM)

E-MAIL:

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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 CALL TO DISCUSS FOLLOW-UP QUESTIONS FROM THE SITE AGING MANAGEMENT PROGRAM AND AGING MANAGEMENT REVIEW AUDITS AUGUST 24, 2005 Participants Affiliations Michael Morgan U.S. Nuclear Regulatory Commission (NRC)

Juan Ayala NRC Kurt Cozens NRC Kaihwa Hsu NRC Michael Kennedy Information Systems Laboratories, Inc. (ISL)

Malcolm Patterson ISL Farideh Saba ISL Darrel Turner Nuclear Management Company, LLC (NMC)

Bill Russell NMC Bill Roberts NMC Pete Wolfinger NMC Enclosure 1

RESPONSES TO FOLLOW-UP QUESTIONS FROM THE SITE AGING MANAGEMENT PROGRAM AND AGING MANAGEMENT REVIEW AUDITS PALISADES NUCLEAR PLANT LICENSE RENEWAL APPLICATION AUGUST 24, 2005 The U.S. Nuclear Regulatory Commission (NRC) staff (the staff) and representatives of Nuclear Management Company, LLC (NMC), held a telephone conference call on August 24, 2005, to discuss and clarify the applicants responses to follow-up questions from the Palisades Nuclear Plant (PNP) Aging Management Program (AMP) and Aging Management Review (AMR) audits.

The following questions were discussed during the telephone conference call.

Question 3.5.1-07W2 The PNP Structural Monitoring Program AMP does not discuss the need or lack of need to perform periodic ground water monitoring to ensure that the below-grade water chemistry does not become aggressive in the future. Justify not performing periodic ground water monitoring during the current licensing basis (CLB) and potential extended license period to check water chemistry for non-aggressiveness. See Question 3.5.1-21W2. Response needs to be docketed.

Discussion: The applicant indicated that the question is clear. The applicant will answer the question as part of their formal, docketed response to the AMR/AMP audit report.

Question 3.5.1-21W2 The PNP Structural Monitoring Program AMP does not discuss the need or lack of need to perform periodic ground water monitoring to ensure that the below-grade water chemistry does not become aggressive in the future. Justify not performing periodic ground water monitoring during the CLB and potential extended license period to check water chemistry for non-aggressiveness. See Question 3.5.1-07W2. Response needs to be docketed.

Discussion: The applicant indicated that the question is clear. The applicant will answer the question as part of their formal, docketed response to the AMR/AMP audit report.

Question 3.3.1-30W1 In LRA Table 3.5.2-8 (Table 2) on page 3-364 for component type Fire Barrier- Auxiliary Bldg -

Concrete, Protected, explain why a GALL Volume 2 line item and a Table 1 item are shown with a Note H for the aging effect loss of material. The audit team feels that these two columns should be blank with a Note H. Response needs to be docketed.

Discussion: The applicant indicated that the question is clear. The applicant will answer the question as part of their formal, docketed response to the AMR/AMP audit report.

Question 3.3.1-20W1 In LRA Table 3.5.2-8 (Table 2) on page 3-364 for component type Fire Barrier- Auxiliary Bldg -

Fire Stop, Protected, explain why a GALL Volume 2 line item and a Table 1 item are shown with a Note H for the aging effect loss of material. The audit team feels that these two columns should be blank with a Note H. Also applies to LRA Table 3.5.2-8 on page 3-366 for component type Fire Barrier - Intake Structure Bldg - Fire Stop, Protected for aging effect loss of material; to LRA Table 3.5.2-8 on page 3-368 for component type Fire Barrier - Turbine Bldg

- Fire Stop, Protected for aging effect loss of material and to LRA Table 3.5.2-8 on page 3-370 Enclosure 2

for component type Fire Barrier - Water Treatment Bldg - Fire Stop, Protected for aging effect loss of material. Response needs to be docketed.

Discussion: The applicant indicated that the question is clear. The applicant will answer the question as part of their formal, docketed response to the AMR/AMP audit report.

Question 3.3.1-24-03-S In the discussion column of Table 3.3.1, Item 24 of the PNP LRA, the applicant refers to the boric acid corrosion monitoring, one time inspection, and system monitoring programs for managing loss of material of the closure bolting. GALL Volume 1, Table 3 recommends bolting integrity program for this line item. LRA Tables 3.3.2-1, 3.3.2-2, 3.3.2-3, 3.3.2-5, 3.3.2-7, 3.3.2-8, 3.3.2-9, 3.3.2-11, 3.3.2-12, 3.3.2-13, 3.3.2-14, and 3.3.2-15 credits bolting integrity program for managing loss of material aging effect for carbon steel and low alloy steel fasteners in air and reference GALL VII.I.2-a and Table 3.3.1, Item 24. Please clarify this discrepancy between LRA Table 1, Item 24 and the above mentioned Table 2 line items.

Response needs to be docketed.

Discussion: The applicant indicated that the question is clear. The applicant will answer the question as part of their formal, docketed response to the AMR/AMP audit report.

Question 3.3.1-05-07-S In LRA Section 3.3.2.5, the applicant states that the Open Cycle Cooling Water program is credited for the internal environments of applicable auxiliary systems and external surfaces of carbon steel components in auxiliary systems for managing the aging effect of loss of material.

However, the open cycle cooling water program is not used in Table 2 line items where this Table 1 item is addressed. Clarify this discrepancy. Response needs to be docketed.

Discussion: The applicant indicated that the question is clear. The applicant will answer the question as part of their formal, docketed response to the AMR/AMP audit report.

Question 3.1.1-02-01-P On page 3-59, only water chemistry (WC) is used for loss of material from the instrument nozzles. How is the effectiveness of the WC program to be verified? (Note that ISI is also applied to this component type to manage cracking).

Discussion: The applicant indicated that the question is clear. The applicant will answer the question as part of their formal, docketed response to the AMR/AMP audit report.

Question 3.1.1-02-02-P On page 3-59, cracking of instrument nozzles is managed but 3.1.1-02 is identified. Please clarify why 3.1.1-12 was not used.

Discussion: The applicant indicated that the question is clear. The applicant will answer the question as part of their formal, docketed response to the AMR/AMP audit report.

Question 3.1.1-13-01-P On page 3-41, for the PC sample heat exchanger shell, please confirm that 3.2.1-13 was intended or make some other correction to the AMR.

Discussion: The applicant indicated that the question is clear. The applicant will answer the question as part of their formal, docketed response to the AMR/AMP audit report.

Question 3.1.1-26-01-P On page 3-44, flanges are associated with the item for bolting. An alternative Table 1 item number (and Note) is needed.

Discussion: The applicant indicated that the question is clear. The applicant will answer the question as part of their formal, docketed response to the AMR/AMP audit report.

Question 3.1.1-36-02-P On page 3-40, this Table 1 item is applied to pump casings of Cast Austenitic Stainless Steel (CASS). In Table 1, the item explicitly excludes CASS, and therefore should not be applied to the CASS valve bodies and pump casings.

Discussion: The applicant indicated that the question is clear. The applicant will answer the question as part of their formal, docketed response to the AMR/AMP audit report.

Question 3.1.1-36-03-P On page 3-37, GALL Volume 2 Item IV.C2.2-h appears for Alloy 600 safe ends. This GALL Item refers to stainless steel components and does not appear to be appropriate. Please clarify.

Discussion: The applicant indicated that the question is clear. The applicant will answer the question as part of their formal, docketed response to the AMR/AMP audit report.

Question 3.1.1-36-04-P On page 3-38, GALL Volume 2 Item IV.C2.2-f appears twice for the water chemistry AMP applied to non-CASS valves. Is this a duplication, or is there a different GALL Item that was intended?

Discussion: The applicant indicated that this was a duplication. Therefore, this question is WITHDRAWN.

Question 3.1.1-38-01-P On page 3-40, loss of material from the internal surface of the quench tank is managed using the system monitoring program. The environment is listed as containment air. Is this correct?

According to the PNP FSAR Section 4.3.8, the tank is normally filled with nitrogen, which would seem an appropriate basis for use of the system monitoring AMP in lieu of the Boric Acid Control (BAC) program.

Discussion: The applicant indicated that the question is clear. The applicant will answer the question as part of their formal, docketed response to the AMR/AMP audit report.

Question 3.1.1-43-02-P On page 3-53 of the LRA, Note F implies that GALL specifies a material. It does not. GALL also recommends using water chemistry. Please provide the basis for managing this aging effect using only RVI Internals.

Discussion: The applicant indicated that the question is clear. The applicant will answer the question as part of their formal, docketed response to the AMR/AMP audit report.

Question 3.1.1-45-03-P On page 3-51 of the PNP LRA, GALL Volume 1 associates Item B3.3-a with 3.1.1-43, which addresses crack initiation and growth, dimension/void swelling, in addition to 3.1.1-45, which addresses crack initiation and growth. (Application of the RVI and WC program is consistent with GALL.)

Discussion: The applicant indicated that the question is clear. The applicant will answer the question as part of their formal, docketed response to the AMR/AMP audit report.

Question 3.1.2-06-P On page 3-56 of the PNP LRA, loss of material from the low-alloy steel tube bundle wrapper is managed using only the WC program. In the precedent tables, Item D1-8 is cited, but this calls for both the WC program and the SG Tube Integrity Program. Please identify how the effectiveness of the WC program will be verified.

Discussion: The applicant indicated that the question is clear. The applicant will answer the question as part of their formal, docketed response to the AMR/AMP audit report.

Question 3.2.1-11-01-P On page 3-76 of the PNP LRA, loss of fracture toughness of CASS is addressed. GALL AMP XI.M13 suggests that this aging effect does not require aging management for valve bodies and that the ISI program is sufficient for managing aging of these component types. The ASME Section XI ISI program manages cracking, not loss of fracture toughness. Please change the aging effect managed using ISI or explain how the ISI will be used to manage loss of fracture toughness.

Discussion: The applicant indicated that the referenced AMP should have been ?XI.M12 and not ?XI.M.13 and that they are consistent with GALL. Therefore, this question is WITHDRAWN.