ML053070017
| ML053070017 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/28/2005 |
| From: | Harden P Nuclear Management Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML053070017 (17) | |
Text
NMC Committed to Nuclear Excell, e Palisades Nuclear Plant Operated by Nuclear Management Company, LLC October 28, 2005 10 CFR 54 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Palisades Nuclear Plant Docket 50-255 License No. DPR-20 NMC Response to NRC Requests for Additional Information Dated September 28, 2005 Relating to License Renewal for the Palisades Nuclear Plant In a letter dated September 28, 2005, the Nuclear Regulatory Commission (NRC) transmitted Requests for Additional Information (RAls) regarding the License Renewal Application for the Palisades Nuclear Plant. Enclosure 1 provides the NMC responses to those requests.
In addition, in a letter dated August 19, 2005, NMC provided a preliminary response to RAI 4.3-15, and stated that if the final analysis results differed from those provided, an updated response would be provided. The analysis has now been completed, and the results differ slightly from the preliminary results provided. Enclosure 2 provides an updated response to RAI 4.3-15.
Please contact Mr. Darrel Turner, License Renewal Project Manager, at 269-764-2412, or Mr. Robert Vincent, License Renewal Licensing Lead, at 269-764-2559, if you require additional information.
Summary of Commitments This letter contains no new commitments or changes to existing commitments.
I declare under penalty of perjury that the foregoing is true and correct. Executed on October 28, 2005.
Paul A. H1rden Site Vice President, Palisades Nuclear Plant Nuclear Management Company, LLC 27780 Blue Star Memorial Highway
- Covert, Michigan 49043-9530 Telephone: 269.764.2000 1AI/
Enclosures (2) cc Administrator, Region 111, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC License Renewal Project Manager, Palisades, USNRC 27780 Blue Star Memorial Highway
- Covert, Michigan 49043-9530 Telephone: 269.764.2000
ENCLOSURE 1 NMC Responses to NRC Requests for Additional Information Dated September 28, 2005 (11 pages)
ENCLOSURE 1 NMC Responses to NRC Requests for Additional Information Dated September 28, 2005 RAI 4.5.2(a)
In response to RAI 4.5.2, the applicant provided an excerpt from its report entitled "30th Year Physical Tendon Surveillance of Palisades Nuclear Plant 2002," as Enclosure 4. In Section Vill of this enclosure (page 1 of the enclosure), the applicant stated that "as a result of the generator change and the re-tensioning of a large number of vertical tendons these must now be excluded from this analysis." The staff requests the applicant to explain:
a) When the generator change and re-tensioning of a large number of vertical tendons were done, and, b) Since a large number of vertical tendons were excluded from the analysis, explain how the time-limited aging analysis (TLAA) for these excluded tendons is performed.
NMC Response to NRC RAI 4.5.2(a) a) The steam generator replacement was completed in 1991; this outage occurred between the 15-year and 20-year surveillance.
b) As can be seen in the excerpt from the report entitled "30th Year Physical Tendon Surveillance of Palisades Nuclear Plant 2002," (See pages 8 and 10 of this enclosure) measurement of tendon liftoff force has been performed on previously de-tensioned and re-tensioned tendons. V72, V128, V126, V116, 48AE and 52AE were all re-tensioned during the steam generator replacement project. Since retensioning, these tendons have all been selected and tested during a subsequent surveillance (1992, 1997 or 2002). The surveillance test results for each of these tendons were acceptable (above the minimum required value). The tendons are excluded from the regression analysis solely because they have been previously de-tensioned and re-tensioned. They are not excluded from future testing under the Containment Inservice Inspection Program; this testing will assure the continued acceptability of these tendons in accordance with 10 CFR 54.21 (c)(1)(iii).
1
ENCLOSURE 1 NMC Responses to NRC Requests for Additional Information Dated September 28, 2005 RAI 4.5.2(b)
Based on the information provided in the response to RAI 4.5.2, the applicant is requested to explain how the 95% confidence curves provided in Enclosure 4 were established.
NMC Response to NRC RAI 4.5.2(b)
Response
The following is a general description of the method used for determining the confidence interval in the tendon regression analyses from Agresti and Finlay':
Strength is a function of the average tension, so the confidence interval is for the average tension at a point in time.
The confidence interval for the average tension at time "X" is i'+/-t 1+
x-..)
2 The confidence interval for the average is narrower than the confidence interval for an individual tendon. This happens because the average will be aggregated from many tendons, and many of those individual tendons will be lower than the average. For comparison, the confidence interval for an individual tendon is f +t 1+ 1
+
(X2.Y)2 In these formulas, t is a standard t-statistic with n-2 degrees of freedom.
The regression analysis for each group of tendons using the data from the last surveillance report has been revised to project out to 60 years. Plots have also been added with time on a logarithmic scale. The results for the vertical and horizontal regressions are slightly different from those previously reported due to the following corrections: The test results from tendon V334 were incorrectly excluded from the vertical data. The test results from tendon 84DF were incorrectly included in the horizontal data.
The analysis results and plots of dome, vertical and horizontal tendon projections out to 60 years are provided below. These pages supersede the corresponding pages (40, 41, 42, 45, 47, 48 and 50) of Enclosure 4 to NMC letter of July 25, 2005. This information demonstrates the adequacy of the time limited aging analysis for the containment tendons.
1 Agresti, A., Finlay, B., (1997). Statistical Methods for the Social Sciences. Upper Saddle River, New Jersey: Prentice-Hall.
2
ENCLOSURE 1 NMC Responses to NRC Requests for Additional Information Dated September 28, 2005 ENGINEERING FILF NUMBER:
371 PRECISION SURVEILLANCE CORPORATION 3468 WATLING STREET EAST CHICAGO, INDIANA 46312 PHONE: (219) 397-5826 FAX: (219) 397-5867 MAIN 30TI I YEAR TENDON SURVEILLANCE AT Tl IE TITLE:
PALISADES NUCLEAR PLANT TIUTLE POST TENSIONING SURVEILLANCE REPORT PREPARED BY:
PAUL C. SMITII REVIEWED BY:
CI[RISTOPIIER F. COX. P.E.
APPROVED BY:
RONALD D. IIOUGII. P.E.
ENGINEERING DEPARTMENT AB!STRACT 11113US U1 IMI 111:
llt.
FINGS CM fl111F1111 YEAR PIYSwAI. MtUN RVULIAMT AT TIl PAI.ISIW MNXLLAR IAT ItD tlWO; nxCTIW AW (lA1flAMIl AND RI-)*I3fl InFllN. Till:
4*TtS.t(AK IS RkACI 1)1 IrAT N( IANIU4AL DIORAAMlnNa nn'Ti-ir rInT-TnsONNa SYS1tI IAS UCI7IlRXFV InI1 PAl iSA sP1.'T CS'TAINJTB1 r, m nG REVISION CONTROL LOG PAGIS At I 1 C11)
Al mi-1-31. Al-Al16, 11-till. Cl ni. Ml-Df29 kI-ll7.l-V-)17.(114 M 4442, 4S. 47. 43 5' I - -1. ___
3
ENCLOSURE I NMC Responses to NRC Requests for Additional Information Dated September 28, 2005 30THt YEAR TENDON SURVEILLANCEATTIHE NMC S
PALISADES NUCLEAR PLANT Committedto NuclearExceO fo VIII. COMPARISON WITH ORIGINAL INSTALLATION I)ATA A comparison of the liftoff forces from this surveillanc to the original installation lock-off forces is made in an effort to detect any evidence of system degradation. Thc lock-off forces arc compared in order to detect any abnormal force loss which would possibly indicate an underestimation of the creep, shrinkage and/or clastic shortening effects in the Containment Building.
A l The losses for the tendon groups werc found to be 15.76% for the dome tendons, 11.91% for the vertical tendons and 16.27% for the horizontal tendons. Based upon a comparison with the results from other facilities, these losses are less than has been experienced at younger containments and does not indicate any degradation of the system.
A regression analysis was conducted on each of the tendon groups and the graphs arc shown on the following pages along with the input data for force, test dates and age (time stressed). All three analysis show each group remaining above the minimum requirements well beyond the next surveillance period.
Projections to 40 years after installation (38 years of plant life) show a dome projection of 643 kips with a minimum requirement of 584 kips, vertical value of 666 kips against a minimum requirement of 615 kips and a horizontal projection of 647 kips against a minimum of 615 kips. As a result of the generator change and the retensioning of a large number of vertical tendons these must now be excluded from this analysis. This results in only two data points each for the Twentieth and Twventy-fifth year surveillances leading to a somewhat ermtic forecast profile. With only two points to plot the projection does not have enough points to provide extensive indications of trend at this time. However, a review of losses for the vertical group do not give any indication of group deterioration and there is little doubt that the group will remain above minimum values throughout the next surveillance interval. Dome and horizontal tendons show forecast curves consistant with imput from a larger field of data and will also remain above minimum levels beyond the next surveillance.
A review of previous surveillance data indicated that the current common tendons used during this surveillance were in fact detensioned during the first surveillance and new tendons should be selected from a pool of tendons where only liftoffs were performed (fifleenth year surveillance onvards). In addition, earlier surveillances used the hammer method for evaluating the liftoff point although this should have a minimal effect on the regression analysis due to the reduced weighting of older data.
A Changed info.
40 4
ENCLOSURE 1 NMC Responses to NRC Requests for Additional Information Dated September 28, 2005 30111 Y'EAR TENDON SURVEILLANCE AT TIHE NMC)
PALISADES NUCLEAR PIANrT Commitredt NuclearExceIIen.?
TABLE XIl: CONIPARISON OF ORIGINAL LOCKOFF FORCES TO AS FOUND FORCES TENDON LIFTOFF FORCE J
LOSS PERCENTAGE I AVERAGE l ORIGINAL l
30 YEARS
( (kips) l PERCENTAGE Dl-18 l
780.0 657.2 122.8 15.74 Dl-38 783.8 675.9 Detensioned first surveillanec D2-43 776.25 654.8 121.45 15.65 15.76 D3_20 783_75 1
659.25
__124_
15._8_9 D3-20 1 83.75 659.25 J 124.5 j
15.89 V'-14 776.25 695 81.25 10A7 V-16 750.0 677.8 72.2 9.63 V-30 780.0 664.7 115.3 J
14.78 V-t 16 776.0 740.4 Rctcnsioned at Gcncmtor Changc V-302 761.25 669.1 92.15 12.11 7_
9 8.
11.91 ^f
/A\\lV-334 781 682.9 98.1 12.56 II-22AF 765.0 650.7 114.3 14.94 11-23BD 780.0 629.0 151.0 19.36 11-24BD 750.0 610.3 139.7 18.63 11-25BD 780.0 638.6 141.4 18.13 16.27 11-62BF 780.0 660.8 119.2 15.28 11-78CE 783.75 695.5 88.25 11.26 11-84DF 772.5 662.5 Detensioned first surveillance
/1 Changed info.
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ENCLOSURE 1 NMC Responses to NRC Requests for Additional Information Dated September 28, 2005 PALISADES REGRESSION ANALYSIS NMC Committed to Nuclear Exuc nce DOME TENDONS Forecast Forecast Lower Years Value Bound 1
679 664 3
668 659 5
664 656 10 657 652 15 653 648 20 650 644 25 648 642 30 646 639 35 645 637 40 643 635 45 642 633 50 641 632 55 640 631 60 640 629 Dome Tendons 700 660 660 640 620 600 50 560 Forecast Value Lower Bound Minimum Design 0
20 40 60 80 Dome Tendons 700 680 660
-_f--'._
, 11 D
1I 1
1.
.I11 6u40 I-X ForecastValue
- Lwer Bound
-1giurrum Design 620 600 1
10 100 42 6
COI
ENCLOSURE 1 NMC Responses to NRC Requests for Additional Information Dated September 28, 2005 PALISADES REGRESSION ANALYSIS Cemmiitudto Woofea &Ex~cs~9 VERTICAL TENDONS Rev I.
Included V334 which is common tendon and was excluded in error.
Increases projection at 60 years by 3 kips or 0.45%.
Forecast Forecast Lower Years Value Bound 1
680 665 3
677 667 5
676 668 10 674 668 15 673 667 20 672 665 25 671 664 30 671 663 35 670 662 40 670 661 45 670 660 50 669 659 55 669 658 60 669 658 1-_._1___
Vertical Tendons 690_
680 670 660 650.,
640-630 620 610 0
20 40 60 80
[-Forecast Value
[--Lower Bound
-Minmmurn Design I.
I.VI al T e
- o. _
G..
rp.
I I
I I I
.I I I I..
l Vertical Tendons - Log Graph I
690 680 670 660 650 640 630 620 610
-
0-, 7 -
-1
--- I....... --
_-1 1_-_1_-
-Forecast Value
-Lawer Bound
-Minimum Design 1
10 100 45 7
C(?2
ENCLOSURE 1 NMC Responses to NRC Requests for Additional Information Dated September 28, 2005 30TH YEAR TENDON SURVEILLANCEATTIHE NMC PALISADES NUCLEAR PLANT Committedto NucIarExceienyo REGRESSION ANAIYSIS I)ATA TENDON TENDON TEST ORIGINAL AGE NUMBER FORCE DATE STRESS (TIME STRESSIED)
V20 659 2-21-92 9-5-69 22.47 V72 728
- 3-9-92 9-9-69 V128 680
- 2-21-92 9-3-69 V218 631 3-16-92 9-3-69 22.53 V'26 691 9-15-97 9-2-69 28.04 V126 745
- 7-31-97 9-9-69 V248 665 9-8-97 9-5-69 28.01 V334 684.4 8-1-97 9-4-69 27.91 V14 695 8-21-02 9-5-69 32.96 V16 679 8-21-02 9-4-69 32.96 V30 665 8-20-02 9-9-69 32.95 V116 740 9-20-02 9-3-69 33.05 V302 669 9-20-02 9-3-69 33.05 V334 682.9 8-21-02 9-4-69 32.96
- RETENSIONED AFTER GENERATOR ClIANGOUT TiEREFORE EXCLUDED.
A Rev 1.
Information added 47 8
ENCLOSURE 1 NMC Responses to NRC Requests for Additional Information Dated September 28, 2005 PALISADES REGRESSION ANALYSIS NNC Commied to NckearExcel blcp HORIZONTAL TENDONS REV. I.
Tendon S4DF result in 2002 removed from analysis as this tendon was detensioned in first surveillance.
Forecast drops by I kip (0. I 5%)
Forecast Forecast Lower Years Value Bound 1
682 666 3
671 661 5
666 658 10 659 654 15 655 650 20 652 647 25 650 644 30 648 641 35 647 639 40 646 637 45 644 635 50 643 634 55 642 632 60 642 631 Horizontal Tendons 690 -
80 670 660; 640 630 610 0
20 40 60 80
-Forecast Value Lower Bound
-Minimum Design Horizontal Tendons i
690 680 670 660 650 640 630 620 610
I II
, ',;, I 1 11 II; II
'- i
III177, t,
, ;
I -1 1, ,
,
-Focast Value
-Lower Bound
-Minimum Design 1
10 100 48 9
c002
ENCLOSURE 1 NMC Responses to NRC Requests for Additional Information Dated September 28, 2005 30TII YEAR TENDON SURVEILLANCE AT THE A
C PALISADES NUCLEAR PLANT Commiucdto Nuclesr ce nce REGRESSION ANA[XSIS DATA TENDON TENDON TEST ORIGINAL AGE NUMBER FORCE DATE STRESS (TIME STRESSED) 29AE 625 3.12.92 8-22-69 22.56 48AE 702
- 3-11-92 5-27-69 22.79 52AE 669
- 3-11-92 5-26-69 22.79 46BD 653 3-4-92 9-11-69 22.48 77BF 640 2-25-92 9-23-69 22.43 7ODF 672 2-24-92 9-22-69 22.43 68AC 646 8-27-97 5-19-69 28.27 69AE 653 8-19-97 5-16-69 28.26 26BD 658 8-22-97 9-15-69 27.93 72BF 654 8-7-97 9-22-69 27.87 28DF 674 8-5-97 9-15-69 27.89 22AE 651 9-8-02 8-25-69 33.04 23BD 629 9-23-02 9-16-69 33.02 24BD 610 9-8-02 9-15-69 32.98 25BD 639 9-23-02 9-15-69 33.02 62Bf l
661 10-16-02 6-2-69 33.37 78CE 696 10-20-02 9-24-69 33.07 84DF EXCLUDED 9.6-02 9-23-69 32.95
- RETENSIONED DURING GENERATOR CHANGOUT THEREFORE EXCLUDED
/j\\
Rcv 1. Information changed. 84DF detensioned during first surveillance and excluded 50 10
ENCLOSURE 1 NMC Responses to NRC Requests for Additional Information Dated September 28, 2005 RAI 4.5.3(a)
In response to RAI 4.5.3, the applicant provided a summary of the regression analysis data through tables and graphics in Enclosure 4. In the tables there are a number of tendons that appear to have been excluded from the analysis. These tendons are numbered as: D1-38, V334, and 65BF. The applicant is requested to provide the basis for exclusion of these tendons from the analysis.
NMC Response to NRC RAI 4.5.3(a)
Tendons D1-38 and 65BF were excluded because they were de-tensioned and re-tensioned during the first surveillance; therefore, any data after that time is excluded as unrepresentative of the general population.
Tendon V334 was incorrectly excluded from the analysis. Apparently, V334 was mistakenly identified as V324, which was de-tensioned and re-tensioned during the first surveillance. The regression analysis prepared in response to RAI 4.5.2(b) includes tendon V334.
It was also noted that tendon 84DF was de-tensioned and re-tensioned during the first surveillance, and should have been excluded, along with D1-38 and 65BF. The regression analysis prepared in response to RAI 4.5.2(b) excludes 84DF.
11 Updated NMC Response to NRC RAI 4.3-15 (2 Pages)
NMC Response to NRC Follow Up Question Concerning RAI B2.1.3-1(d)
Original RAI 4.3-15 in NRC Letter Dated July 21, 2005 Section 4.3.14 indicates that Palisades has no shutdown cooling line inlet transition, and that the safety injection and shutdown cooling functions share a common nozzle.
As an alternate location to the shutdown cooling line inlet transition, provide the highest CUF at this location which includes the effect of the reactor coolant system environment, or select an alternative high CUF location equivalent to the shutdown cooling line inlet transition.
NMC Updated Response to NRC RAI 4.3-15 The original NMC response to RAI 4.3-15, in a letter dated August 19, 2005, stated:
Preliminary analysis results indicate that the limiting location in this area is at the end of the cladding near the safe end on the safety injection nozzle. This is the common nozzle that supports both safety injection and shutdown cooling.
The fatigue usage factor at this location is 0.0308. After applying the environmental factor of 15.35 for stainless steel, the environmentally corrected usage factor is 0.472.
The analysis which supports these values is in the process of being finalized. If these values change in the final, approved analysis, an updated response will be provided.
The final analysis has reached a different conclusion than reported in the above response. The fatigue usage factor and the environmentally corrected fatigue usage factors are accurate for the location reported above, but (1) the location evaluated is not the limiting location, and (2) because it is not a pressure boundary, the stainless steel cladding is not the material of concern for environmentally assisted fatigue.
The limiting location of concern occurs at the acute angle of the intersection at the inside surface of the safety injection nozzle and the inside surface of the primary coolant system pipe. The 60 year fatigue usage factor is 0.036. After applying the environmental factor of 1.79 for carbon steel, the environmentally corrected usage factor is 0.065.
The second most limiting location is at the opposite end of the safety injection nozzle at the extreme end of the safe end. The 60 year fatigue usage factor is 0.0097. After applying the environmental factor of 1.79 for carbon steel, the environmentally corrected usage factor is 0.017. Because this is the second most limiting location on this combined use nozzle, this value is assumed to correspond with the shutdown cooling line inlet transition.
It has also been determined, that the charging nozzle analysis used an excessively conservative environmental factor for the Alloy 600 material. The 1
NMC Response to NRC Follow Up Question Concerning RAI B2.1.3-1(d) correct value for Alloy 600 is 1.49 rather than the stainless steel value of 15.35 that was used.2 Therefore, the cumulative usage factor for the charging inlet nozzle would not exceed 1.0 as stated in LRA Table 4.3.14-1 on page 4-40. Use of the correct Fen for the Alloy 600 material results in a CUF of 0.456 (0.306 X 1.49), significantly less than 1.0.
The updated analysis concludes that the fatigue usage factors at all NUREG/CR-6260 sample locations, including the effects of the reactor coolant environment, will remain less than 1.0 for the extended operating period.
2 Fen for Alloy 600 material comes from Chopra, Omesh K, "Status of Fatigue Issues at Argonne National Laboratory," presented at EPRI Conference on Operating Nuclear Power Plant Fatigue Issues & Resolutions, August 22-23, 1996.
2