ML18054B561
| ML18054B561 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/17/1990 |
| From: | Holahan G Office of Nuclear Reactor Regulation |
| To: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| PAL-90-016, PAL-90-16, TAC-76069, NUDOCS 9004230323 | |
| Download: ML18054B561 (7) | |
Text
Docket No. 50-255 Serial No. PAL-90-016 Mr. David P. Hoffman UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 April 17, 1990 Vice President, Nuclear Operations Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201
Dear Mr. Hoffman:
SUBJECT:
STEAM GENERATOR REPLACEMENT PROJECT (TAC 76069)
On August 1, 1989, Consumers Power Company (CPCo) met with the NRC staff tc preser1t preliminary plans for the replacement of the Palisades Plant steam generators.
At that time, CPCo stated that the replacement project would not involve a change to the Techr.ical Specifications or an unreviewed safety question; therefore, it was CPC0 1s intent to conduct the replacement pursuant to 10 CFR 59.59(a)(l) based on either a pr~liminary finding or the fact that other plants have rr.aclt this determination. Additional discussions regarding the replacement project have taken place during periodic Management Meetings on September 28, 1989, February 13, 1990, and March 16, 1990, and at a meeting to discuss specifically the project on November 9, 1989.
At each of these meetings, CPCo stated its intent to use the provisions of 10 CFR 50.59(a)(l).
The nature of these meeti~gs were such that only broad descriptions of various aspects of the project and its organization were discussed.
The staff has reminded CPCo that 10 CFR 50.59(b){l) requires that written safety e:valuaticr.s must be prepared providing the basis for the: deterri1inaticns that no unreviE\\'ied safe:ty questions are involved.
The staff is concerned, hcwEver, that technical issues could evolve which preclude the application of 10 CFR 50.59(a)(l). Therefore, we believe that CPCo should continue to me~t with th~ staff to discuss, in detail, various aspects of the project, including the project plan.
A few of the areas for detailed discussion are known now, i.e. containment, narrow-gap welding, and ALARA considerations, but it is not possible to identify completely all such areas.
To assist with this identification process, CPCo is requested to meet with the staff in the near future.
Issues which commonly have been addressed by other licensees undertaking steam generator replacement include but are not limited to the following:
- 1.
The ider.tification of safety-related equipment, systems, and
, components which may be affected by the replacement project,
- 2.
The integrity of safety-related systems, and/or components which would be removed during the project, consideration of laydown loads ar.~
reinsta11ation of equipment following steam generator replacement,
- 3.
Th~ a<lequacy of cranes, rigging, and other equipment and ccW;ponents used for hoisting and removal/installation of components, (1,,tf rn D f c* f "0
-£. -
- 4.
The load path to be used for transport of the steaw. generators during removal and installation, including underpinning and shoring of existing floors,
- 5.
The effect of any change in mass or center of gravity of the replacement steam generators on the seismic analysis for the containment structure and the NSSS,
- 6.
The effect of steam generator design changes upon the analyses of all transients and accidents,
- 7.
The method for storing the used steam generators,
- 8.
The effect of reattachment of the stearr, gcr1erators upon primary coo 1 ant pn:ssure boundary,
- 9.
Radiological considerations (on-site and within containment) during and following the project, including environmental monitoring and
- 10. The effect of the access opening upon containment strength during all phase5 of the replacement project and upon the strength and integrity of contairiment fol10\\'1irig cornpletior1, including consideration of reinforceme-nt, tendcn &nd tendon duct replacement, and concrete age and strength effects.
Under 10 CFR 50.59, CPCo can proceed with the 5team generator replacement project without prior Commission review or approval provided a deterwination is made (by CPCo) that no unreviewed safety question is involved and no change to a technical specification is required.
The written safety evaluaticn(s) suppcrtir:g ycur d~tErrr.inatior1, as required by 10 CFR 50.59(b)(l), need not be SLit.r.1i tted to the Commission.
The staff, however may elect as part of our regu1atory responsibility to examine selected portions or all cf your safety evaluation. Completion of your 10 CFR 50.59 evaluatior1 at thE-earliest possible time is crucial, if we are to avoid a potential delay in the project shculd a licensee amendment ultimately be required.
cc:
SE*e next po.ge Sincerely,
~~aJ/Sv(-=or Division of Reactor Projects - III, IV, V & Special Projects Office of Nuclear Reactor Regulation
Mr. Kenneth W. Berry Consumers Power Company cc:
M. I. Miller, Esquire Sidley & Austin 54th Floor One First National Plaza Chicago, Illinois 60603 Mr. Thomas A. McNish, Secretary Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Regional Administrator, Region III U.S. Nuclear Regulatory Co111T1ission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Jerry Sarno Township Supervisor Covert Township 36197 M-140 Highway Covert, Michigan 49043 Office of the Governor Room 1 - Capitol Building Lansing, Michigan 48913 Mr. Gerald B. Slade Plant General Manager Palisades Plant 27780 Blue Star Memorial Hwy.
Covert, Michigan 49043 Resident Inspector c/o U.S. Nuclear Regulatory Co111T1ission Palisades Plant 27782 Blue Star Memorial Hwy.
Covert, Michigan 49043 Pali sades Plant Nuclear Facilities and Envirorvnental Monitoring Section Office Division of Radiological Health P.O. Box 30035 Lansing, Michigan 48909
- . 4.
The load path to be used for transpor~ of thE steam generators during removal and installation, including underpinning and shoring of existing floors,
- 5.
The effect of any change in mass or center of gravity of the replacement steam generators on the seismic analysis for the containment structure and the NSSS,
- 6.
The effect of steam generator design changes upon the analyses of all transients and accidents,
- 7.
The method for storing the used steam generators,
- 8.
The effect of reattachment of the steam generators upon primary coolant pressure boundary,
- 9.
Radiological considerations (on-site and within containment) during and following the project, including environmental monitoring and
- 10. The effect of the access opening upon containment strength during all phases of the replacement project and upon the strength and integrity of containment following completion, including consideration of reinforcement, tendon and tendon duct replacement, and concrete age and strength effects.
Under 10 CFR 50.59, CPCo can proceed with the steam generator replacement project without prior Commission review or approval provided a determination is made (by CPCo) that no unreviewed safety question is involved and no change to a technical specification is required. The written safety evaluation(s) supporting your determination, as required by 10 CFR 50.59(b)(l), need not be submitted to the Commission.
The staff, however may elect as part of our regulatory responsibility to examine selected portions or all of your safety evaluation. Completion of your 10 CFR 50.59 evaluation at the earliest possible time is crucial if we are to avoid a potential delay in the project should a licensee amendment ultimately be required.
cc: See next page Sincerely, Original signed by Gary M. Holahan, Acting Director Division of Reactor Projects - III, IV, V & Special Projects Office of Nuclear Reactor Regulation DISTRIBUTION Docket Fi le MRShuttleworth ACRS(lO)
LCunningham CMcCracken JPartlow NRC & Local PDRs ADeAgazio fiBagchi PD31 Reading OGC CYCheng RJones TMurley WRussel /
JZwolinski EJordan FCongel LMarsh EMurphy CPTan Rl-lermann FMiraglia JRichardson
- See previous concurrence
- PM/PD31:DRSP *(A)O/PD3l:DRSP ADeAgazio JThoma 03/22/90 03/22/90 AThadani K\\~i chman
- 4.
The load path to be used for transport of the steam generators during removal and installation, including underpinning and shoring of existing floors,
- 5.
The effect of any change in mass or center of gravity of the replacement steam generators on the seismic analysis for the conta nment structure and the NSSS,
- 6.
The effect of steam generator design changes upon t7han lyses of all transients and accidents,
- 7.
The method for storing the used steam generators, I
- 8.
The effect of reattachment of the steam generat/r,~ upon primary coolant pressure boundary,
- 9.
Radiological considerations (on-site and wittJ*fn containment) during and following the project, including environment9'l monitoring and
- 10.
The effect of the access opening upon co~~inment strength during all phases of the replacement project and upon the strength and integrity of containment following completion, including):'onsideration of reinforcement, tendon and tendon duct replacement, and concrete age and strength effects.
Under 10 CFR 50.59, CPCo can proceed with the ~earn generator replacement project without prior Commission review or a.proval provided a determination is made (by CPCo) that no unreviewed safety question is involved and no change to a technical specification is required.
The written safet~ evaluation(s) supporting your determination, as req%ir by 10 CFR 50.59(b)(l), need not be submitted to the Commission.
The staff however may elect as part of our regulatory responsibility to examine s lected portions or all of your safety evaluation.
I trust the above will 2 beneficial in completing a thorough determination to assure no unreviewJH safety questions exist.
cc:
See next page
/
DISTRIBUTION II Docket File NRC & Local MRShuttleworth
~ADeAgazio ACRS(lO)
I GBagchi LCunningham
/
RHermann CMcCracken
/
FMiragl ia JPartlow
//
JRichardson
- See preyi°~us concurrence
- PM/PD3l1: DRSP *(A) D/PD31: DRSP ADeAga;i'io JThoma 03/2?/90 03/22/90 i
Si nlere ly, Gary M. Holahan, Acting Director Division of Reactor Projects - III, IV, V & Special Projects Office of Nuclear Reactor Regulation PD Rs PD31 Reading JZwo l ins ki OGC EJordan CY Cheng FCongel RJones LMarsh TMurley EMurphy WRussell CPTan
- AD/PD31:DRSP (A)D:DRSP JZwo l ins ki GHolahan 03/ /90 03/ /90 AThadani KWichman
~..... ~... *.,
"" "'T.he reporting and/or recordkeeping requirements of this letter affect fewer th~ ten respondents; therefore, OMB clearance under PL 96-511 is not reqU'ired.
Sincerely,
.\\
Gary M. Holahan, Acting Director cc:
See next page DISTRIBUTION Docket File NRC & Local PDRs PD31 Reading JZwo l ins ki MRShuttleworth ADeAgazio OGC EJordan ACRS(lO)
GBagchi CYCheng FCongel LCunningham RHermann RJones LMarsh CMcCracken FMiraglia n~urley EMurphy JPartlow JRichardson WRussell CPTan AThadani KWichman
- See previous concurrence
- PM/PD31:DRSP
- (A)D/PD31:DRSP ADeAgazio JThoma 03/7-1/90 03/2~/90 Division of Reactor Projects - III, IV, V & Special Projects Office of Nuclear Reactor Regulation gp{k._~~,4..,.;
- (A)AD/PD31 :DlfSP JZwo l inski 03/zz/90 (A)D:DRSP GHolahan 03/ /90 The reporting and/or recordkeeping requirements of this letter affect fewer than ten respondents; therefore, OMB clearance under PL 96-511 is not required.
cc:
See next page DISTRIBUTION Docket File NRC & Local PDRs PD31 Reading JZwolinski MRShuttleworth ADeAgazio OGC EJordan ACRS(l9Jjp(U
~
PM/PD~P (A~D/~:DRSP ADeAgazio JThoma 03/;J-/90 03/~/90 Sincerely, Gary M. Holahan, Acting Director Division of Reactor Projects - III, IV, V & Special Projects Office of Nuclear Reactor Regulation 1
~~31:DRSP r
JZwol inski 03/'J?f-90 (A)D:DRSP GHolahan 03/ /90