ML18054A575
| ML18054A575 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/02/1989 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-88-011, IEB-88-11, NUDOCS 8903080260 | |
| Download: ML18054A575 (3) | |
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consumers Power l'llWEIUllli MIClllliAll'S l'IUllilUJS General Offices:
1945 West Parnell Road, Jackson, Ml 49201 o (517) 788-1636 March 2, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO NRC BULLETIN 88 PRESSURIZER SURGE LINE THERMAL STRATIFICATION Kenneth W Berry Dirutor Nuclear Licensing G.
C Bulletin 88-11, Pressurizer Surge Line Thermal Stratification, dated cember 20, 1988, requires addressees who cannot meet the schedule described in the Bulletin to inform the NRC of an alternative schedule with justification for the requested schedule.
The purpose of this letter is to inform the NRC staff of our actions taken to resolve the NRC concerns associated with the issue of pressurizer surge line thermal stratification and to provide an alternative schedule.
In accordance with Requested Action I.a of the Bulletin, Palisades has completed the VT-3 inspection of the pressurizer surge line and found no discrepancies.
This inspection was completed in December, 1987, prior to the issuance of the Bulletin.
The inspection included a visual of the surge line supports and ultrasonic and liquid penetrant inspection of welds.
The results of the inspection are available for NRC inspection.
Verbal discus-sions with the NRC Staff have indicated that completion of the inspection prior to issuance of the Bulletin is acceptable provided we have no reason to believe the results would have changed.
In the time period subsequent to the inspection we have no reason to question the validity of the results.
With respect to Requested Action l.b, the Combustion Engineering Owners Group (CEOG) became aware of this issue in April of 1987 when INPO issued a draft SER on surge line thermal cycling observed in a German nuclear plant.
The CEOG proceeded to initiate a data collection program in June 1987 followed by actual data collection activities at two CEOG plan~s in June and August of 1988.
OC0289-0072-NL04
Nuclear Regulatory Commission Palisades Plant
- Response to Bulletin 88-11 March 2, 1989 In October 1988, the CEOG authorized the ongoing CEOG program, "Reduction and Analysis of Pressurizer Surge Line Data Collected from CEOG Plants", to address surge line therm.al stratification concerns.
NRC Bulletin 88-11 was subsequently issued in December, 1988.
Requested Action l.b requires that within four months of receipt of the Bulletin, licensees of plants in operation over ten years demonstrate that the pressurizer surge line meets the applicable design codes and other regulatory commitments for the licensed life of the plant.
The NRC Bulletin suggested this could be accomplished by performing a plant specific or generic bounding analysis.
Licensees of plants in operation less than ten years were requested to complete the analysis within one year.
These NRC Bulletin items prompted the CEOG to request a meeting with the NRC Staff.
The NRC Staff and the CEOG met on February 13, 1989 in the White Flint NRC offices.
During this meeting, the CEOG presented the goals and scope of the ongoing CEOG surge line program which included a presentation of actual plant data and a discussion on the issue of therm.al stratification.
The CEOG then requested relief from the four month/one year schedule requirement in Requested Action l.b and suggested that the CEOG program be allowed to proceed on schedule.
As a result of this meeting, the CEOG and NRC Staff agreed on several action items to be completed as follows:
- 1.
The CEOG will perform a preliminary bounding evaluation of CEOG surge lines using actual data collected from CEOG plants by July 1, 1989.
This activity will address the intent of Requested Action l.b.
- 2.
Actual plant data will be used to define loading conditions for input to the fatigue and stress evaluations.
- 3.
The CEOG agreed to meet with NRC Staff to discuss the load definitions prior to finalizing the bounding analysis described in item 1 above.
Palisades Plant is a participant in the CEOG program and agrees to support the above actions and alternative schedule for responding to NRC Bulletin 88-11 Requested Action l.b.
Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, NRC NRC Resident Inspector - Palisades OC0289-0072-NL04 2
CONSUMERS POWER COMPANY Palisades Plant Docket 50-255 - License DPR-20 RESPONSE TO NRC BULLETIN 88-11 At the request of the Commission and pursuant to the Atomic Energy Act of 1954 and the Energy Reorganization Act of 1974, as amended, and the Commission's Rules and Regulations thereunder, Consumers Power Company submits our response to NRC Bulletin 88-11 dated December 20,1988, entitled,"Pressurizer Surge Line Thermal Stratification." Consumers Power Company's response is dated March 2, 1989.
CONSUMERS POWER COMPANY By -:::----:--:--:::--:c~~~--=~~=-~-:-:-~
, Vice President rations Sworn and subscribed to before me this 2nd day of March 1989.
Ann Avery, Not. y Public Jae son County, Michigan My commission expires December 7, 1992 OC0289-0072-NL04