ML18057B444
| ML18057B444 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/20/1991 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9201030277 | |
| Download: ML18057B444 (3) | |
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JAN 1 7 '92 12: 44 r
-.l F re CPCO PAL I SADES consumers Power POWERING MICHlliAN"'S PIUl&RDS Pati!illdes Ni,,clMr Plant: 27790 Slut St11r Mtmori&I Hi11hway. CQvwn, Ml '9043 December 20, 1991 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 e
PAGE.002 GB $lade GeneNI M411Qger DOCKET 50-255 - LICENSE OPR PALISADES PLANT - CONFIRMATION OF COMMITMENTS FOR THE SAFETY RELATED PIPING REVERIFICATION PROGRAM
- UPDATE Consumers Power Companyletter dated January 10, 1990, provided the Project Plan for the Palisades "Safety Related Piping Reverification Program."
On August 30, 1990, a meeting was he1d at NRC headquarters to discuss preliminary results of phase I of the Palisades Safety Related Piping Reverification Program (SRPRP} and proposed changes to the program based on those results.
During t~e week following the meeting, an inspection of our safety related piping reverification program was performed by Region III personnel. This inspection independently verified results and information we supplied at the August 30, 1990 meeting with the NRC.
A subsequent letter dated September 18, 1990 reviewed the information presented at the meeting and requested that Consumers Power Company conwnit to some additional program actions..Consumers Power Company's November 28, 1990 letter provided the co1m1itments to the additional program actions.
The purpose of this letter is to u~date the status of those commitments noting where we have had to revise some of the *actions associated with those conrnitments based on the progress of our SRPRP program. listed below are the NRC requests with the original and revised responses as appropriate.
NRC Reauest,
Co111nit to completion of phase I modifications no later that the refueling outage following the steam generator replacement outage.
Original CPCCL.Besconse Completion of all P-hase I modifications will be completed no later than the start up from the first refueling outage following the current steam generator replacement and refueling outage.
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JAN 1.7 '92 12: 44 F. CPCO PALI SADES
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- Ucd1ted CPCo Response No change in ~tatus is required.
N,RC Request Conrnit to a piping support preventative maintenance program.
Original CPCo Respons~
We will review our inservice inspection program in light of our experiences with the.piping reverification program, and will either modify the existing program's inspection scope and procedures as necessary or will develop an alternative program to assure that all subject hangers remain in their design configuration. This action will be complete by December 1991.
U~dated Ce&o Resoonse An evaluation of the discrepancies from the SRPRP walkdowns, review of recent inservice inspection findings and a review of historical corrective actions needed to return supports to an o~erating condition has indicated that recurring problems can be isolated to loose or missing fasteners related to component supports.
While reviewing our options as to how to integrate the expanded hanger inspection into our plant pro~ram, we had originally thought that we would modify our ISi hanger inspect1on program* so tfiat future inspections of hanger supports would assure that the hangers are specifically inspected for loose or missing fasteners. While this is the correct long term plan, we also realized that all of the remaining pipe supports would be inspected during the completion of the SRPRP program and that this inspection would probably happen sooner than the ISI program as the ISI program 1s on a ten year cycle.
Therefore, it is our intention to reinspect previous discrepant supports for two additional outages after the discrepant condition is identified. These re-inspections will be performed in conjunction with planned SRPRP inspections assoc;ated with the phase II scope of work.
Any recurrent defic;enc;es identified after two subsequent inspections will either be corrected to resolve the discrepancy or subsequent augmented inspections of the hangers w111 be included in a revision to the ISI ~rogram to assure that the recurrent discrepant support conditions are inspected at an interval co11111ensurate with their recurrence.
The ISi program will be subsequently revised after each SRPRP walkdown phase to include new recurring discrepant supports until two outages past completion of all SRPRP support walkdowns.
At this* point in time, the lSI prograr.1 revisions will be complete and a final table of recurrent dtscrepant supports will be identified in the program. The identified supports will*then be inspected as a part of the existing ISI program with! appropriate inspection intervals in ltne with their historical degradation interval.
NRC Regyest Co111111t to a reevaluation of the project schedule, including an assessment of which modifications could be completed during non-outage per,iods.
Qi:iginal CPCg Response
FRttCPCO PALISADES PAGE.004 JAN 1 7 '92 12: 45
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1'¥ As we are completing our phase I work, we are validating our phase I man-hour estimates and determining the scope of our ~hase II program.
As we near completion of that validation and scoping effort, we will review our phase I efforts in total and reevaluate the phase II completion schedule. Current plans are to complete all phase I analytical efforts by the end of 1991 and to complete all phase I modifications or repairs by the end of the 1992 refueling outage, which is expected to begin in the first quarter of 1992.
During the completion of the phase I P-rogram, we will review each required modification or repair to determine if t~e modification or repair can be completed when the plant is on-line or whether the modification or repair must wait to be completed during an outage. Modifications which can be completed while the plant is on~line will be performed in a timely manner after identification without reliance on an outage.
The phase II program is currently scheduled to start in January of 1992 and be completed in* 1996.
Upclated CPCo Response As noted above we had estimated that our phase I analytical efforts would be completed by the end of 1991.
We are now forecasting that final completion of the phase I analytical work will be by the end of January, 1992.
As noted in our response to the first comment, all ~hase I modifications or repairs will be completed"by the end of the 1992 refueling outage.
We have reviewed each of the required modifications or repairs and intend to complete six modifications or repairs to sup~orts on the auxiliary feedwater system prior to the beginning of the 1992 refueling outage. All of the other modifications or repairs identified will require an outage to complete.
Our phase II program efforts have started as we are assembling walkdown packages and making plans for the phase II efforts.
We have scheduled a meeting with NRR for January 1992 to review the results of our phase I efforts and to lay out our phase II completion plans and schedule.
- Note that in response to deficiency D-1 in Inspection Report 91-202, we submitted the October 7, 1991 letter that requested NRCs approval of the proposed changes to the plants piping stress allowable criteria. The NRC is in the process of completing our request.
As a remindert since the calculations supporting the Phase I modifications or repairs have used the new criteria as their oasis, we need the NRC's approval of our revised criteria to implemen..t these modifications.
4/P~
Gerald 8 Slade General Manager cc Administrator, Region III, USNRC NRC Resident Inspector
- Palisades I