ML053560008

Request for Additional Information Related to Request for Relief from ASME Section XI Code Requirements for Repair of Pressurizer Nozzle Penetrations

ML053560008
Person / Time
Site:	Palisades
Issue date:	12/28/2005
From:	Padovan L Plant Licensing Branch III-2
To:	Harden P Nuclear Management Co
padovan L, NRR/DORL, 415-1423
References
TAC MC8170
Download: ML053560008 (5)

Text

December 28, 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 REQUEST FOR RELIEF FROM ASME SECTION XI CODE REQUIREMENTS FOR REPAIR OF PRESSURIZER NOZZLE PENETRATIONS (TAC NO. MC8170)

Dear Mr. Harden:

Your letter of August 11, 2005, requested relief from certain requirements of the 1989 Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, related to repair of pressurizer nozzle penetrations. The specific relief requested is to use an alternative to ASME Code, Section Xi, IWA-3300, Flaw Characterization, IWB-3142.4, Acceptance by Analytical Evaluation, and IWB-3420,Characterization.

We are reviewing your request, and find that we need additional information as shown in the enclosed request for additional information (RAI). I discussed this RAI with Ms. Amy Hazelhoff of your organization on December 15, 2005, and she agreed to respond by February 3, 2006.

Please contact me at (301) 415-1423 if you have questions.

Sincerely,

/RA/

L. Mark Padovan, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-255

Enclosure:

RAI cc w/encl: See next page

December 28, 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 REQUEST FOR RELIEF FROM ASME SECTION XI CODE REQUIREMENTS FOR REPAIR OF PRESSURIZER NOZZLE PENETRATIONS (TAC NO. MC8170)

Dear Mr. Harden:

Your letter of August 11, 2005, requested relief from certain requirements of the 1989 Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, related to repair of pressurizer nozzle penetrations. The specific relief requested is to use an alternative to ASME Code, Section Xi, IWA-3300, Flaw Characterization, IWB-3142.4, Acceptance by Analytical Evaluation, and IWB-3420,Characterization.

We are reviewing your request, and find that we need additional information as shown in the enclosed request for additional information (RAI). I discussed this RAI with Ms. Amy Hazelhoff of your organization on December 15, 2005, and she agreed to respond by February 3, 2006.

Please contact me at (301) 415-1423 if you have questions.

Sincerely,

/RA/

L. Mark Padovan, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-255

Enclosure:

RAI cc w/encl: See next page DISTRIBUTION PUBLIC LPLIII-1 R/F LPadovan LRaghavan THarris CLipa, Rgn-III OGC ACRS BElliot Dorl Dpr ADAMS Accession Number: ML053560008 OFFICE NRR/LPL3-1/PM NRR/LPL3-1/LA NRR/LPL3-1/BC NAME LPadovan THarris LRaghavan DATE 12/28/05 12/28/05 12/28/05 OFFICIAL RECORD COPY

Palisades 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 Michael B. Sellman Consumers Energy Company President and Chief Executive Officer 1 Energy Plaza Nuclear Management Company, LLC Jackson, MI 49201 700 First Street Hudson, MI 54016 Regional Administrator, Region III U.S. Nuclear Regulatory Commission Jonathan Rogoff, Esquire Suite 210 Vice President, Counsel & Secretary 2443 Warrenville Road Nuclear Management Company, LLC Lisle, IL 60532-4351 700 First Street Hudson, WI 54016 Supervisor Covert Township Douglas E. Cooper P. O. Box 35 Senior Vice President - Group Operations Covert, MI 49043 Palisades Nuclear Plant Nuclear Management Company, LLC Office of the Governor 27780 Blue Star Memorial Highway P. O. Box 30013 Covert, MI 49043 Lansing, MI 48909 Stephen T. Wawro, Director U.S. Nuclear Regulatory Commission of Nuclear Assets Resident Inspector's Office Consumers Energy Company Palisades Plant Palisades Nuclear Plant 27782 Blue Star Memorial Highway 27780 Blue Star Memorial Highway Covert, MI 49043 Covert, MI 49043 Michigan Department of Environmental Quality Laurie A. Lahti, Manager Waste and Hazardous Materials Division Regulatory Affairs Hazardous Waste and Radiological Nuclear Management Company, LLC Protection Section Palisades Nuclear Plant Nuclear Facilities Unit 27780 Blue Star Memorial Highway Constitution Hall, Lower-Level North Covert, MI 49043 525 West Allegan Street P.O. Box 30241 Lansing, MI 48909-7741 November 2005

Request for Additional Information (RAI)

Related to Request for Relief from ASME Section XI Code Requirements For Repair of Pressurizer Nozzle Penetrations Palisades Nuclear Plant Docket No. 50-255 to Nuclear Management Companys (NMCs) submittal of August 11, 2005, provided information (NMC responses) that the Nuclear Regulatory Commission (NRC) needs (NRC Conditions) for utilities to use WCAP-15973-P as a reference. However, the NRC needs more information to complete its review. Please supply the additional information requested below.

4.1 General Corrosion Assessment

a. Section 2.4 of WCAP-15973-P, Low Alloy Steel Component Corrosion Analysis Supporting Small-Diameter Alloy 600/690 Nozzle Repair/Replacement Program, Revision 1, indicates that Palisades pressurizer nozzles need further analysis using actual thickness measurements to determine acceptable hole diameters.

RAI 4.1.a Provide the actual thickness measurement for all nozzles that are being evaluated in this relief request, or justify not needing the measurements.

b. NMCs response to NRC Condition 1 indicates that an analysis performed by Westinghouse Electric Company calculated the limiting (allowable) diameter for pressurizer heater sleeve penetrations for Palisades relative to the following:

(1) the reduction in the effective weld shear area, and (2) the required area of reinforcement for the nozzle bore holes for each type nozzle (and heater sleeve) in the pressurizer, primary coolant system piping, and steam generator primary head for each Combustion Engineering, Inc., plant RAI 4.1.b Provide the following information for the weld shear stress and reinforcement area analyses:

1. Identify the criteria used to determine the allowable bore-hole size, and include any American Society of Mechanical Engineers code criteria.

2. Identify the pressure and thermal transient conditions assumed in the analysis.

3. Explain how the information in response to a, b.(1) and b.(2) was used to calculate the ENCLOSURE

allowable bore-hole size.

c. NMCs response to NRC Condition 5 indicates that initial sleeve penetration diameter was 1.173 inches.

RAI 4.1.c Identify nominal, minimum, and maximum sleeve penetration diameter values for Palisades, and explain why 1.173 inches was used in the analysis.

4.2 Thermal Fatigue Crack Growth Assessment NMCs response to NRC Condition 3 says that although Palisades water-solid operation of its pressurizer practically eliminates in-surge and out-surge transients postulated in Westinghouse Calculation Note CN-CI-02-71, a plant-specific flaw fatigue growth analysis was performed.

The analysis, provided as Attachment 2 to NMCs letter of August 11, 2005, used a 220 oF in-surge transient in lieu of the 320 oF in-surge transient applied in the generic analysis. The plant-specific flaw fatigue growth analysis was not provided in Attachment 2.

RAI 4.2 Provide the linear elastic fracture mechanics (LEFM) analysis, and include an evaluation of the available Charpy impact test data to demonstrate the reference temperature (RTNDT) used in the LEFM is limiting for all Palisades nozzle penetrations included in this relief request.

4.3. Stress Corrosion Crack Growth Assessment NMCs response to NRC Condition 2 indicates that if a pressurizer heater sleeve is repaired at Palisades, NMC will perform a review of the Palisades reactor coolant system chemistry histories, over the last two operating cycles, to confirm that the conditions required by the topical report have been met.

RAI 4.3 Confirm that the conditions required by the topical report were met for the previous two cycles.