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Category:CORRESPONDENCE-LETTERS
MONTHYEARML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML20210G8351999-07-29029 July 1999 Final Response to FOIA Request for Documents.Records in App a Encl & Will Be Available in PDR ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20209B2081999-06-29029 June 1999 Discusses Closure of Response to RAI Re GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity. Rvid,Version 2 Issued as Result of Review of Responses.Info Should Be Reviewed & Comments Submitted by 990901 ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML18068A5831999-05-0303 May 1999 Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432 ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20217A8191999-04-29029 April 1999 Forwards Listed Matls Related to Palisades Plant June 1999 Initial License Exam ML20206E8271999-04-28028 April 1999 Forwards Palisades Plant Annual Radiological Environ Operating Rept for 1998. There Were No Reportable Events During This Period ML20207B4661999-04-23023 April 1999 Forwards Copy of Final Exercise Rept for Biennial Radiological Emergency Preparedness Exercise Conducted on 981201 for Palisades Npp.No Deficiencies Noted.Seven New Arcas Identified ML18066A4531999-04-0707 April 1999 Forwards ITS Pages 3.1.4-2 & 3.1.4-8,revising Completion Time for Action D.1,as Requested by NRC 990406 Telcon,Per TS Change Request Submitted 980126.Change Submitted Does Not Alter Conclusions of No Signficant Hazards Considerations ML18066A4481999-04-0202 April 1999 Responds to Violations Noted in Insp Rept 50-255/98-06. Corrective Actions:Nuclear Performance Assessment Dept Has Reviewed Observations & Agrees That Field Observations by Qualified Personnel Are Important Aspect of Program ML18066A4471999-03-30030 March 1999 Confirms Completion of Util Review of Design Engineering Contractor Cable Ampacity Evaluation.Evaluation Available at Plant for NRC Review ML18066A4411999-03-30030 March 1999 Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review ML18066A4441999-03-26026 March 1999 Submits Certification of Financial Assurance for Decommissioning of Palisades Nuclear Plant.Certified Rept of Status of Consumers Energy Co Decommissioning Funding & Trust Agreement Encl as Attachments 1 & 2 ML18066A4401999-03-25025 March 1999 Forwards Revised Best Estimate Fluence Evaluation Using Industry Data, Providing Justification for Using Industry Data to Determine Best Estimate Fluence.Review of Info & SE Requested ML18066A4191999-03-23023 March 1999 Forwards 1998 Annual Radioactive Effluent Release & Disposal Rept, for Palisades Plant,Providing Summary of Quantities of Radioactive Liquid & Gaseous Effluent Releases & Solid Radioactive Waste Processed During 1998 ML18066A4231999-03-22022 March 1999 Forwards Answers to 990311 Telcon Request for Addl Clarification & Revs Re ITS Section 3.4.Markups of Previously Submitted TS Pages & Revised Pages for Section 3.4 Also Encl ML20204F2091999-03-18018 March 1999 Requests That Listed TS Change Requests (Tscrs) Be Issued with Allowance That Tscrs Be Fully Implemented within Sixty Days of Issuance.Request Will Allow Time for Completion of Final Training & Procedure Changes Associated with Amend ML18066A4121999-03-18018 March 1999 Concludes That Mod to Provide Automatic Switchover of Control Room Heating,Ventilation & Air Conditioning (CRHVAC) Sys to Emergency Mode Is Not Needed to Meet Regulatory Requirements.Mod Commitment Cancelled ML18066A4141999-03-18018 March 1999 Forwards Rev 4 to COLR, Containing Limits for Fuel Cycle 14 & Future Cycles ML20204E5861999-03-16016 March 1999 Submits Current Limits of Property Insurance Maintained at Consumers Energy Co Operating Nuclear Power Plants ML18066A4131999-03-11011 March 1999 Responds to NRC 990210 Ltr Re Violations Noted in Insp Rept 50-255/98-22.Corrective Actions:Analytical Evaluation, EA-C-PAL-98-1067-01, P-50A Case to Cover Stud Evaluation, Was Submitted to NRC on 981220 ML18068A5241999-02-12012 February 1999 Resubmits Relief Request 12,with Addl Info That Includes Specific Locations Where Relief Request Would Be Applied,Per 10CFR50.55a(g)(5)(iii) ML18068A5211999-02-11011 February 1999 Informs NRC That Implementation of Formal Industry Position on Severe Accident Mgt at Palisades Plant Was Completed on 981217 ML20203F2541999-02-10010 February 1999 Informs That Beginning 990216,DE Hills Will Be Chief of Operations Branch Which Includes Operator Licensing Function 1999-09-30
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML18068A5831999-05-0303 May 1999 Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432 ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20217A8191999-04-29029 April 1999 Forwards Listed Matls Related to Palisades Plant June 1999 Initial License Exam ML20206E8271999-04-28028 April 1999 Forwards Palisades Plant Annual Radiological Environ Operating Rept for 1998. There Were No Reportable Events During This Period ML20207B4661999-04-23023 April 1999 Forwards Copy of Final Exercise Rept for Biennial Radiological Emergency Preparedness Exercise Conducted on 981201 for Palisades Npp.No Deficiencies Noted.Seven New Arcas Identified ML18066A4531999-04-0707 April 1999 Forwards ITS Pages 3.1.4-2 & 3.1.4-8,revising Completion Time for Action D.1,as Requested by NRC 990406 Telcon,Per TS Change Request Submitted 980126.Change Submitted Does Not Alter Conclusions of No Signficant Hazards Considerations ML18066A4481999-04-0202 April 1999 Responds to Violations Noted in Insp Rept 50-255/98-06. Corrective Actions:Nuclear Performance Assessment Dept Has Reviewed Observations & Agrees That Field Observations by Qualified Personnel Are Important Aspect of Program ML18066A4471999-03-30030 March 1999 Confirms Completion of Util Review of Design Engineering Contractor Cable Ampacity Evaluation.Evaluation Available at Plant for NRC Review ML18066A4411999-03-30030 March 1999 Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review ML18066A4441999-03-26026 March 1999 Submits Certification of Financial Assurance for Decommissioning of Palisades Nuclear Plant.Certified Rept of Status of Consumers Energy Co Decommissioning Funding & Trust Agreement Encl as Attachments 1 & 2 ML18066A4401999-03-25025 March 1999 Forwards Revised Best Estimate Fluence Evaluation Using Industry Data, Providing Justification for Using Industry Data to Determine Best Estimate Fluence.Review of Info & SE Requested ML18066A4191999-03-23023 March 1999 Forwards 1998 Annual Radioactive Effluent Release & Disposal Rept, for Palisades Plant,Providing Summary of Quantities of Radioactive Liquid & Gaseous Effluent Releases & Solid Radioactive Waste Processed During 1998 ML18066A4231999-03-22022 March 1999 Forwards Answers to 990311 Telcon Request for Addl Clarification & Revs Re ITS Section 3.4.Markups of Previously Submitted TS Pages & Revised Pages for Section 3.4 Also Encl ML20204F2091999-03-18018 March 1999 Requests That Listed TS Change Requests (Tscrs) Be Issued with Allowance That Tscrs Be Fully Implemented within Sixty Days of Issuance.Request Will Allow Time for Completion of Final Training & Procedure Changes Associated with Amend ML18066A4141999-03-18018 March 1999 Forwards Rev 4 to COLR, Containing Limits for Fuel Cycle 14 & Future Cycles ML18066A4121999-03-18018 March 1999 Concludes That Mod to Provide Automatic Switchover of Control Room Heating,Ventilation & Air Conditioning (CRHVAC) Sys to Emergency Mode Is Not Needed to Meet Regulatory Requirements.Mod Commitment Cancelled ML20204E5861999-03-16016 March 1999 Submits Current Limits of Property Insurance Maintained at Consumers Energy Co Operating Nuclear Power Plants ML18066A4131999-03-11011 March 1999 Responds to NRC 990210 Ltr Re Violations Noted in Insp Rept 50-255/98-22.Corrective Actions:Analytical Evaluation, EA-C-PAL-98-1067-01, P-50A Case to Cover Stud Evaluation, Was Submitted to NRC on 981220 ML18068A5241999-02-12012 February 1999 Resubmits Relief Request 12,with Addl Info That Includes Specific Locations Where Relief Request Would Be Applied,Per 10CFR50.55a(g)(5)(iii) ML18068A5211999-02-11011 February 1999 Informs NRC That Implementation of Formal Industry Position on Severe Accident Mgt at Palisades Plant Was Completed on 981217 ML18066A4051999-02-10010 February 1999 Requests Copy of Consumers Energy (Palisades) Formal Response to RAI Dtd 990512 (USI A-46) ML18066A3921999-01-29029 January 1999 Forwards Licensee Interpretation of TS Requirements for Performance of SRs as Applied to Instrumentation Channel Calibr.Ltr Established No New Commitments ML18066A3891999-01-28028 January 1999 Submits Response to Concern Expressed in Insp Rept 50-255/98-06 Re Whether Palisades ISI Program Was Being Conducted IAW Applicable Requirements 1999-09-30
[Table view] |
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consumers Power GB Slade General Manager POWERIN&
MICHl&AN'S PRD&RESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 MAR 13 1992 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - ANALYSIS AND SCHEDULE FOR IMPLEMENTATION OF A FLUX REDUCTION PROGRAM - 10CFR50.61 - PRESSURIZED THERMAL SHOCK In accordance with 10CFR50.6l(b)(4), each pressurized water reactor, for which the value of RTprs is projected to exceed the PTS screening criterion before the expiration date of the operating license, is required to submit, by March 16, 1992, an analysis and schedule for implementation of flux reduction programs as are reasonably practicable to avoid exceeding the PTS screening criteria set forth in paragraph (b)(2) of 10CFR50.61. Attachment 1 to this letter provides background information, describes present flux reduction efforts and discusses possible additional future flux reduction efforts and other methods of complying with 10CFR50. 61.
Our December 16, 1991 submittal which reported projected values of RTprs for reactor beltline materials estimated that, without additional fluence reduction, the screening criterion will be exceeded in 2005. However, the NRC staff has expressed concerns regarding the fluence calculation methodology and the determination of the best estimate weld material chemistry reported in that submittal. In responding to these concerns, Consumers Power Company has developed more extensive data which supports a conclusion that the screening criterion will not be exceeded before the end of licensed life in 2007. This information will be documented in a revision to the December 16, 1991 submittal and will be submitted by April 30, 1992. Until the NRC has had the opportunity to review this revised information and made a determination with respect to its acceptability, it would not be prudent to select and implement additional flux reduction methodology; therefore, the information in Attachment 1 should be considered preliminary. A final report will be submitted after the NRC determination has been made.
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Gerald B Slade cJ' -
General Manager CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment
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ATTACHMENT 1 Consumers Power Company Pali sades Pl ant Docket 50-255 ANALYSIS AND SCHEDULE FOR IMPLEMENTATION OF A FLUX REDUCTION PROGRAM
- Page 1 INTRODUCTION Consumers Power Company's December 16, 1991 submittal indicated that the reactor vessel beltline circumferential weld is projected to exceed the PTS screening criterion in March 2007 and the axial welds are projected to exceed the screening criterion in November 2005. These dates assume Cycle 9 fluence is maintained until the screening criteria is exceeded or the expiration date of the operating license is reached. Since the PTS screening criteria will be exceeded prior to the 2007 expiration date of the Palisades Operating License, this information is submitted in accordance with the requirements of 10CFR50.61. Specifically, the information provides an analysis and schedule for implementation of potential flux reduction programs as deemed reasonably practicable to avoid exceeding the PTS screening criteria.
This information should be considered preliminary, in that the company is actively responding to NRC questions regarding vessel weld chemistry and fluence calculations used in our December 16, 1991 submittal. The outcome of these discussions will have a direct impact on the scope and schedule of the selected flux reduction program. A final report date will be established at the conclusion of the aforementioned discussions.
- Page 2 BACKGROUND In 1986, it was recognized that the Palisades reactor vessel base metal material would exceed the PTS screening criterion before the 2007 expiration date of the Palisades Operating License. This conclusion was based on the then existing requirements of 10CFRS0.61. Subsequent analyses based on the requirements of Regulatory Guide 1.99 Rev 2 reached the same conclusion; however, the limiting reactor vessel material has changed from base metal to the axial welds. The latest analysis, submitted on December 16, 1991, concluded that the limiting material continues to be the axial welds.
Based on the conclusion that the screening criteria would be exceeded prior to the end of licensed life, Palisades initiated a fuel management program in 1988 with Cycle 8. The purpose of this program was to reduce neutron fluence at the vessel inside diameter (ID). Due to the long lead times involved, manufacturing of special assemblies was not possible at that time; however, 16 fuel assemblies were reconstituted. Those fuel assemblies had four rows of stainless steel rods on the outside of the fuel assembly and were placed at the outer perimeter of the core. The selected positions were chosen to maximize flux reduction at the axial weld positions which were limiting.
These reconstituted fuel assemblies were used for Cycle 8 only. In 1991, flux reduction efforts continued with Cycle 9 which utilized 16 hafnium inserts placed in thrice burned fuel. These fuel assemblies were placed on the core perimeter to maximize flux reduction at the axial welds. In 1992, Cycle 10 fuel will use eight shielded fuel assemblies manufactured by the fuel vendor.
They will have two rows of stainless steel rods on opposite sides of the fuel assembly and can be reused for six cycles. These fuel assemblies will have low enrichment and, therefore, will provide improved flux reduction. The 16 hafnium insert fuel assemblies used in Cycle 9 will be reused in Cycle 10.
Additionally, development of the PIDAL incore monitoring methodology has allowed greater flexibility in core design by allowing 1/4 core rotational symmetry (versus INCA's 1/8 core reflective symmetry) which provides 22 additional core locations for new fuel. Cycle 10 will be the first core to take advantage of this methodology.
Figures 1 through 4 provide a pictorial of core peripheral patterns for Cycles 1-7 and Cycles 8-10. Table 1 provides neutron flux data versus azimuth for 1/8 core symmetry for Cycles 1 through 10. The axial welds are at the 0° and 30° locations while the peak fluence for the circumferential weld occurs at the 16°location. The data illustrates the success of our ongoing fuel management program to significantly reduce vessel fluence. Cycle 11 will be discussed later in this enclosure.
While not part of the Palisades flux reduction program, an extensive dosimetry program was initiated in 1988 corresponding to the beginning of life (BOL) of Cycle 8. The purpose of this program is to develop plant specific benchmarks to verify the accuracy of DOT calculations used to predict reactor vessel fluence. This program utilizes both in-vessel and ex-vessel dosimetry. Ex-vessel dosimetry was removed at the end of Cycle 8 and verified that fluence calculations were conservative when compared to measured values. In-vessel dosimetry was installed at the beginning of Cycle 9. During the present plant refueling outage, both the in-vessel and ex-vessel dosimetry have been removed
- Page 3 for analysis. It is estimated that results of the analysis will be available in mid-1992. These results will provide a direct comparison of the calculated and measured fluxes at both the ID and OD of the reactor vessel for the same fluence history. This is considered the best data available to confirm plant specific accuracy of the calculational DOT model. While this program will not necessarily show a reduced vessel flux, it will significantly increase the confidence level of the DOT model and will form the bases to preclude any fluence bias or uncertainty penalties.
Present and Future Flux Reduction Efforts Methods to achieve further flux reduction to the critical reactor vessel welds include:
- Neutron Pads
- More Aggressive Fuel Management Core Barrel Replacement Reactor Vessel Replacement
- *Reactor Vessel Annealing
- *Integrated Surveillance Program
- These are considered equivalent or alternatives to flux reduction.
Neutron Pads Neutron pads installed on the core barrel were selected for further study based on cost/benefit, availability of technology, and implementation schedule. A preliminary neutron pad analysis was conducted by Westinghouse.
The basic conclusions of the analysis were:
- A flux reduction factor of two could be achieved at the axial locations.
Similar reductions could be achieved on the circumferential weld.
- Stainless steel or tungsten encapsulated in stainless steel cans are suitable shield material.
- Detailed engineering, manufacturing, tooling and installation would require approximately 18-24 months.
- Pads could provide a minimum of six years additional vessel lifetime if installed not later than BOL for Cycle 12.
Figure 5 illustrates the neutron pad design for axial welds. Figure 6 shows the expected reduction in neutron flux as a fraction of pad thickness for stainless steel. Tungsten is approximately 50% more effective than stainless steel.
Future Fuel Management While the neutron pad option is feasible, it would require significant development and installation costs and an extensive outage to accomplish. For
- Page 3 for analysis. It is estimated that results of the analysis will be available in mid-1992. These results will provide a direct comparison of the calculated and measured fluxes at both the ID and OD of the reactor vessel for the same fluence history. This is considered the best data available to confirm plant specific accuracy of the calculational DOT model. While this program will not necessarily show a reduced vessel flux, it will significantly increase the confidence level of the DOT model and will form the bases to preclude any fluence bias or uncertainty penalties.
Present and Future Flux Reduction Efforts Methods to achieve further flux reduction to the critical reactor vessel welds include:
Neutron Pads
- More Aggressive Fuel Management Core Barrel Replacement Reactor Vessel Replacement
- *Reactor Vessel Annealing
- *Integrated Surveillance Program
- These are considered equivalent or alternatives to flux reduction.
Neutron Pads Neutron pads installed on the core barrel were selected for further study based on cost/benefit, availability of technology, and implementation schedule. A preliminary neutron pad analysis was conducted by Westinghouse.The basic conclusions of the analysis were:
- A flux reduction factor of two could be achieved at the axial locations.
Similar reductions could be achieved on the circumferential weld.
- Stainless steel or tungsten encapsulated in stainless steel cans are suitable shield material.
- Detailed engineering, manufacturing, tooling and installation would require approximately 18-24 months.
- Pads could provide a minimum of six years additional vessel lifetime if installed not later than BOL for Cycle 12.
Figure 5 illustrates the neutron pad design for axial welds. Figure 6 shows the expected reduction in neutron flux as a fraction of pad thickness for stainless steel. Tungsten is approximately 50% more effective than stainless steel.
Future Fuel Management While the neutron pad option is feasible, it would require significant development and installation costs and an extensive outage to accomplish. For
- Page 4 this reason, it was decided to further investigate more aggressive fuel management concepts. The following peripheral fuel management options are presently being considered for Cycle 11 and beyond.
Number and Type of Fuel Assembly Option Hafnium Shielded Twice Burned Fuel A 16 16 16 B 16 24 8 c 24 24 Added options are possible by reaching the above configurations in two cycles versus one cycle. Basically this would depend on whether the shielded assemblies are manufactured or reconstituted.
Initial scoping studies indicate the benefit of this more aggressive fuel management concept is approximately equivalent to the flux reduction achieved for neutron pads. Option B provides the greatest flux reduction of the options being considered.
The scoping calculations indicate that a fuel management concept can provide a flux reduction estimated to extend lifetime by 5-6 years, operate within peaking factor limits, and have a cycle lifetime comparable to Cycle 10 (350 EFPD). The selected option should be available for Cycle 11, but not later than Cycle 12.
Core Barrel/Reactor Vessel Replacement These options are not considered to be economically feasible.
Reactor Vessel Annealing While not an option that reduces neutron flux, annealing is considered an equivalent option since it has been shown to eliminate embrittlement and return the vessel material to nearly its original condition. We have held exploratory discussions on annealing with MPR Associates, Inc. and Westinghouse. MPR would utilize proven Russian expertise and technology.
Presently, we are evaluating feasibility study proposals from both MPR and Westinghouse. These studies would evaluate conceptual equipment designs, thermal and stress analyses, implementation procedures, recovery and re-embrittlement rates, and associated costs and schedule. We expect to make a decision on the feasibility study within the next few months. The study is expected to take 7 to 10 months to complete. The decision to pursue annealing as an option, depends on decisions related to lifetime extension, regulatory requirements and economic risks.
- Page 5 Integrated Surveillance Program We are presently a participant in a Combustion Engineering sponsored reactor vessel owners group. The purpose of this group is to develop a comprehensive data bank of surveillance specimen information to identify vessels with similar materials and develop the methodology to allow use of surveillance data from one vessel to be used to determine embrittlement properties in a similar vessel. This approach would allow Palisades to use Section 2 of Regulatory Guide l.gg Rev 2, which allows a reduction in the margin term (used to account for uncertainty) when surveillance data is available. If successful, this integrated surveillance program could be used to demonstrate compliance with PTS screening criteria.
Table 1 Palisades Fluence Through Cycle g At the Reactor Vessel Clad-Base Metal Interface Cycle Cycle Flux Cycle Length (n/cm 2/s)
(EFPD) 0 Degrees 16 Degrees 30 Degrees 45 Degrees 1 37g,4 4.5gE+lO 6.03E+l0 4.70E+l0 2.g8E+lO 2 44g,1 4.5gE+lO 6.03E+l0 4.70E+l0 2.g8E+lO 3 34g,5 4.5gE+lO 6.03E+l0 4.70E+l0 2.g8E+lO 4 327.6 4.5gE+lO 6.03E+l0 4.70E+l0 2.g8E+lO 5 3g4_6 4.5gE+lO 6.03E+l0 4.70E+IO 2.g8E+lO 6 333.4 4.87E+l0 6.25E+l0 4,7gE+lO 3.03E+l0 7 35g,g 4.87E+l0 6.25E+l0 4.7gE+lO 3.03E+l0 8 373.6 2.lOE+lO 4.76E+l0 2.28E+l0 l.73E+l0 g 2g8,5 2.0gE+lO 3.05E+l0 1. ggE+lO l.14E+l0 10 350 ~2.0gE+lO ~3.05E+l0 ~1.ggE+lO ~l.14E+l0 The limiting axial welds are at 0° and 30° which corresponds to go 0
, 270° and 30°, 150°, 210°, 330° respectively in Figures 1-4.
The limiting circumferential weld locations are at 16° which corresponds to
+/-16° on each side of 0°, go 180° and 270° on Figures 1-4.
0
- Figure 1 TYPICAL CYCLES 1 THROUGH 7 PERIPHERAL LOADING PATTERN Number of Accumulated Cycles 0 0 0 0 0 0 0 0 0 0 0
0 90° 270° 0 0 0
0 0 0 0 0 0 0 0 0 0 0 i.
//30° Axial Weld Azimuthal Location ALL PERIPHERAL ASSEMBLIES ARE FRESH FUEL
- Figure 2 CYCLE 8 PERIPHERAL LOADING PATTERN Stainless Steel 180° Shield Rods Number of Accumulat d Cycles 2
0 0
3 3 270° 3
J 0
0 0 J 3 0 I
r.
Axial Weld Azimuthal Location
- Fignre 3 CYCLE 9 PERIPHERAL LOADING PATTERN Number of Accumulat d Cycles 2 3 3 2 2 2 2 2 3 2 2 2 2 2
2 2 3 3 90° 270° 3 3 2
2 2
3 2 ..,
2 2 2 3 3 2
.**f:§
~~.:,';:_~ _-__
/30*
Axial Weld oo Azimuthal Location ASSEMBLIES REPRESENTED BY 3 ARE THRICE BURNED FUEL WITH HAFNIUM ABSORBERS
CYCLE 10 PERIPHERAL LOADING PATI'ERB
- Figure 4 Stainless Steel Shield Rods Number of
2 2 2 2 2 0 0 90.J 0 0 0 270 2
2 2 2
~*
Axial Weld Azimuthal Location ASSEMBLIES REPDSERTED BY 4 ARE 4X BUR.lfED FUEL WITH HAJ'lllIUM ABSORBERS ASSEMBLIES UPUSEJIT!D BY 0 ARE HEW SHIELD FUEL WITH SS SHIELD RODS AND 1. 2 W/O ENRICBMDT
\ \ I I
VESSEL 27C SURVEILLANCE*
CAPSULE HOLDER LOWER INTERNAL AXIAL WELD AZIMUTHAL LOCATION 30 0 330 S/G A Figure 4.3-5 Palisa~es Reactor Pressure Vessel - Lower Internals
Flux Reduction Factor
- Figure 6 10r-------------------------------------
.I
- ~ .......... ****************************************************** ************************************************************** ...... *********
- l. ......................................................................................... .
1~----..L-~--.l--~~l-----L-~--L-~__J 0 1 2 3 4 5 6 Inches of Stainless Steel Attached to ~rrel 0.5" gap Figure 4.3-1 Flux Reduction Benefits from the Addition of Steel