ML062750004
| ML062750004 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/02/2006 |
| From: | Padovan L NRC/NRR/ADRO/DORL/LPLIII-1 |
| To: | Harden P Nuclear Management Co |
| L.M. Padovan, LPL3-1 | |
| References | |
| TAC MC2720, TIA 06-04 | |
| Download: ML062750004 (6) | |
Text
November 2, 2006 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 TASK INTERFACE AGREEMENT (TIA) 2006-04, "IMPACT OF HEAT EXCHANGER OUT-OF-SERVICE ON SHUTDOWN COOLING SYSTEM TRAINS AT PALISADES" (TAC NO. MC2720)
Dear Mr. Harden:
On July 28, 2006, the Region III office of the U.S. Nuclear Regulatory Commission requested technical assistance from the Office of Nuclear Reactor Regulation in TIA 2006-04 for Palisades Nuclear Plant. We are reviewing Region IIIs request and find that we need additional information as shown in the enclosed request for additional information (RAI). We discussed this RAI with Ms. Amy Hazelhoff of your organization on September 26, 2006, and she agreed to respond by November 15, 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
Mr. Paul A. Harden November 2, 2006 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 TASK INTERFACE AGREEMENT (TIA) 2006-04, "IMPACT OF HEAT EXCHANGER OUT-OF-SERVICE ON SHUTDOWN COOLING SYSTEM TRAINS AT PALISADES" (TAC NO. MC2720)
Dear Mr. Harden:
On July 28, 2006, the Region III office of the U.S. Nuclear Regulatory Commission requested technical assistance from the Office of Nuclear Reactor Regulation in TIA 2006-04 for Palisades Nuclear Plant. We are reviewing Region IIIs request and find that we need additional information as shown in the enclosed request for additional information (RAI). We discussed this RAI with Ms. Amy Hazelhoff of your organization on September 26, 2006, and she agreed to respond by November 15, 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 LPL3-1 R/F RidsNrrPMMPadovan RidsNrrLATHarris RidsNrrDorlLple RidsRgn3MailCenter RidsOgcRp RidsAcrsAcnwMailCenter SSun RidsNrrDorlDpr RTelson JRobinson ADAMS Accession Number: ML062750004 OFFICE LPL3-1/PM LPL3-1/LA LPL3-1/BC (A)
NAME LPadovan:ca THarris MMurphy DATE 10/ 5/06 10/4/06 11/2/06 OFFICIAL RECORD COPY
Palisades 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 Suite 210 2443 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 Inspector's 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 Michigan Department of Attorney General Special Litigation Division 525 West Ottawa St.
Sixth Floor, G. Mennen Williams Building Lansing, MI 48913 Michael B. Sellman President and Chief Executive Officer Nuclear Management Company, LLC 700 First Street Hudson, MI 54016 Jonathan Rogoff, Esquire Vice President, Counsel & Secretary Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Douglas E. Cooper Senior Vice President and Chief Nuclear Officer Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Stephen T. Wawro, Director of Nuclear Assets Consumers Energy Company Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Laurie A. Lahti, Manager Regulatory Affairs Nuclear Management Company, LLC Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043
ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION (RAI)
RELATED TO TASK INTERFACE AGREEMENT (TIA) 2006-04, "IMPACT OF HEAT EXCHANGER OUT-OF-SERVICE ON SHUTDOWN COOLING SYSTEM TRAINS AT PALISADES" PALISADES NUCLEAR PLANT DOCKET NO. 50-255 The shutdown cooling system (SDCS) at Palisades consists of two SDC pumps, two SDC heat exchangers (HXs), and associated valves and piping. It is supported by the component cooling water system (CCWS), service water system (SWS), and ultimate heat sink (UHS) for heat removal. The SDCS has a common suction line from the reactor coolant system (RCS) hot-leg to two pumps. The discharge of the pumps is directed to a common header which, in turn, splits to each of two SDCHXs, and then returns to a common header before dividing into four low-pressure safety injection headers to the RCS cold-legs.
During a recent refueling outage in Mode 6 with low reactor cavity water level, repair activities of the SDCS caused Nuclear Management Company to isolate one SDCHX. When Nuclear Regulatory Commission inspectors inquired into how this condition satisfied technical specification (TS) 3.9.5 (which requires two operable SDCS trains), Nuclear Management Company (NMC) indicated that only one SDCHX and two SDC pumps constitute two operable trains of SDCS. NMC completed a Title 10 of the Code of Federal Regulations (10 CFR) 50.59 screening document (screening out a full 10 CFR 50.59 review) to support a revision to the TS bases to "clarify" that two operable SDCS trains only required one operable SDCHX and two SDC pumps. The basis for the screening conclusion, in essence, is that removing one SDCHX does not expose the SDCS to increased risk from a single active failure (since NMC indicated that SDCHXs were considered not vulnerable to active failure). Thus, NMC indicated that two operable SDS pumps and one SDCHX would satisfy Palisades TS limiting condition for operation (LCO) 3.9.5 that requires two operable SDCS trains during refueling outage with low water level in the reactor cavity.
In order to determine compliance with the SDCS requirements of TS LCO 3.9.5 for Palisades, the staff requests NMC to provide information to justify that the SDCS will continue to function even with an active single failure in the SDCS or its supporting systems, including the CCWS, SWS, and UHS. The requested information includes the following:
(1)
Applicable sections of the Updated Final Safety Analysis Report, operating and maintenance procedures, and administrative controls for the SDCS, CCWS, SWS and UHS illustrating measures that protect against loss of SDCS function in Mode 6 due to any single active failure including, but not limited to, inadvertent closure of power-operated valves in the heat flow paths between the reactor and Lake Michigan.
(2)
System flow diagrams of the SDCS, CCWS, SWS and UHS that would be used to perform the failure mode and effects analysis for the SDCS with designated numbers for major components in the systems and indication of the isolation valve positions with low water in the reactor cavity during a refueling outage.
(3)
The failure modes and effects analysis for the SDCS considering protection/barriers against a single active failure in the SDCS and essential supporting systems (CCWS, SWS, UHS) during the conditions where TS LCO 3.9.5 applies. The results of the analysis should demonstrate that the remaining SDCHX satisfies the single-failure criterion and remains functional.
(4)
An analysis to demonstrate that even with the degraded SDCS, one SDCS train (one SDC pump, and one SDCHX) is sufficient to perform the required function to maintain the RCS temperature within the refueling outage conditions where TS LCO 3.9.5 applies.