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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
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consumers Power l'OWERINli MICHlliAN'S l'ROliRESS Palisades Nuclear Plant: 27780 Blue Star Memorial ~ighway, Covert, Ml 49043
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December 18, 1995 U S Nuclear Regulatory Commission .i\'
Document Control Desk ~<
Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT PRELI Mi NARY THERMAL ANNEALING REPORT, SECTION 3, FRACTURE TOUGHNESS RECOVERY AND REEMBRITTLEMENT ASSURANCE PROGRAM - RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION On October 12, 1995, Consumers Power Company submitted Section 3 of our Preliminary Thermal Annealing Report (TAR), The Fracture Toughness Recovery and Reembrittlement As*surance Program, to permit initial NRC review. By letter dated November 16, 1995, the NRC requested additional information and clarification of information on that section of our preliminary TAR. Attachment 1 of this letter provides the requested additiolia15nformation and clarifications.
~c .
SUMMARY
OF COMMITMENTS
. _Jbis Letter contains oo_oew _commitmen.ts ..
Richard W. S_rpedley Manager, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Attachment i 2 . 9512 l 8 r .... .
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ATTACHMENT 1 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION DATED 11/16/95 THERMAL ANNEALING REPORT, SECTION 3 FRACTURE TOUGHNESS RECOVERY AND REEMBRITTLEMENT ASSURANCE PROGRAM
- Thermal Annealing Report Section 3 Fracture Toughness Recovery and Reembrittlement Assurance Program Request for Additional Information
- 1. This section of the report should address the issue of the potential for temper embrittlement (TE) or other forms of non-hardening embrittlement of the Palisades beltline materials resulting from the annealing heat treatment.
Particular emphasis should be placed on weld heat affected zone (HAZ) materials.
What research/analyses/procedures will be used to demonstrate that TE is not a concern?
CPCo believes that the proposed surveillance program will identify any temper embrittlement which may occur. We plan to fabricate a limited number of additional irradiated HAZ specimens to specifically address this issue. The specimens will be annealed at 850°F and then fractured. The fracture surfaces will be examined by scanning electron microscopy for intergranular fractures. If no intergranular fracture is found, no further testing will be performed. However, if evidence of intergranular fracture is found, broken plate and weld specimens from previously tested surveillance capsules will be examined. If intergranular fracture is found in the plate or weld material, the Section 3 surveillance program will adequately measure the effects of intergranular fracture on the fracture toughness of the material, therefore, no further *testing of HAZ material is required. If no intergranular failure is found in the plate or weld material, the surveillance program will be revised to include HAZ material.
o Chemistry considerations - particularly phosphorus levels.
Compare/contrast Palisades beltline materials with existing studies.
Temper embrittlement that is caused by heat treatments at approximately 850°F is not expected in materials with phosphorus concentrations less than 0.02%. 1 The average phosphorus concentrations of the Palisades reactor vessel beltline plates range from 0.009% to 0.016%. Best estimate phosphorus levels reported for the welds are 0.017% for the axial welds and 0.013% for the circumferential weld.
Phosphorus levels for the steam generator welds ranged from 0.006% to 0.012%
for the weld fabricated with weld wire heat. number W5214 and from 0.007% to 0.016% for the weld fabricated with weld wire heat number 348009. Phosphorus concentrations for the supplemental surveillance weld representing weld wire heat number 27204 has phosphorus concentrations ranging from 0.008% to 0.010%.
1 Pelli, R. and Torronen, K., "State of the Art Review on Thermal Annealing", AMES Report No. 2, December 1994, p. 26.
o Metallurgical considerations - grain size, width of coarse-grained HAZ 2
region, welding parameters, plate fabrication parameters.
Compare/contrast Palisades beltline materials with existing studies.
The basis document for the ASME code case addressing the requirements for an in-place dry anneal of a PWR reactor vessel states the following' about temper embrittlement:
"Western RPV steels and weldments are potentially susceptible to temper embrittlement in the temperature range recommended for thermal annealing. Temper embrittlement involves segregation of impurity elements (e.g., P, Sn, Sb) to grain boundaries in the steel microstructure. 2 This causes a weakening of the grain boundaries which is manifested by an increased TT and reduced USE and ductility. Temper embrittlement will also cause a change in fracture mode from transgranular to intergranular which is readily discernible with scanning electron microscope observation of Charpy specimen fracture surfaces. Temper embrittlement has been observed in foreign RPV steel weldments 3 but is considered to be primarily a concern for the weld heat affected zone (HAZ). The foreign steels generally have higher P and alloy content (Cr, Mo, V) which is known to exacerbate temper embrittlement. Extensive annealing studies on U.S. materials in both industry and NRC sponsored programs 4 have thus far indicated that temper embrittlement should not be a serious concern for annealing treatments. This includes experimental evidence showing a lack of intergranular fracture on irradiated impact specimens that have received annealing treatments. The recovery of toughness in weld HAZs is the subject of significant ongoing research efforts. However, in western RPV weldments of low P content with small coarse grained HAZs, the effects on toughness will be less significant than what have been observed with foreign steels."
Temper embrittlement has become an issue as a result of research on thermally induced phosphorus migration to the grain boundaries of a simulated HAZ 2
American Society for Metals, The Metals Handbook 9th Edition Volume 1, Properties and Selection: Irons and Steels, pp. 468-469, 684-685, 701-704, 1987.
3 Pelli, R. and T6rr6nen, K., "State of the Art Review on Thermal Annealing,"
European Commission, DG XII - Joint Research Centre, Institute for Advanced Materials, DG XI - Safety of Nuclear Installations, Aging Materials and Evaluation Studies (AMES) Report No. 2, December, 1994.
4 NUREG/CR-6327, "Models for Embrittlement Recovery Due to Annealing of Reactor Pressure Vessel Steels," E. Eason, J. Wright, R. Odette, E. Mader, February 1995.
- 3 microstructure. In this study, a uniform-coarse grain micros~ructure was created by heat treating material to 1200°C (2134°F) for 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. A reactor vessel weld should have seen such high temperatures for very short time periods due to the heat sink effect of the heavy wall plate material. As a result, the coarse grain region of HAZ in the vessel should be very small and nonuniform. This is not expected to be an issue for the Palisades reactor vessel.
o Have fracture surfaces from Palisades surveillance materials previously been examined for evidence of intergranular fracture? If so, what were the results?
Two unirradiated steam generator weld material Charpy specimens. were examined for intergranular fracture as part of Consumers Power Company's investigation into the cause of higher than expected values for initial RT NOT* One specimen was from Heat W5214 and one from Heat 348009. The fracture surfaces of these specimens were examined and concluded to be transgranular cleavage with no evidence of intergranular fractures.
In addition, one irradiated and annealed transverse plate Charpy specimen, Plate D-3803-1 (TL), from the surveillance program was recently tested and the fracture surface showed no signs of intergranular fracture.
o Will there be an experimental program to examine HAZ impact toughness for the Palisades beltline materials? If such a program is planned, the program should include surveillance materials with plate materials and weld materials and process parameters similar to those*
used for the vessel weldments.
See the above response to the first item for a description of the experimental program.
The examination will be performed on HAZ material from one of the intermediate shell plates of the Palisades reactor vessel surveillance program. The HAZ material was created by welding two Palisades plate materials using the same type procedure, weld wire and weld flux as the Palisades beltline axial welds. The weld wire heat number differs from that of the beltline welds.
o How will the annealing heat treatment affect the fracture toughness of the Palisades HAZ beltline materials?
Exposure to neutron fluence is known to reduce the fracture toughn*ess of base metal and weld metal to a greater extent than has been observed in HAZ material.
The annealing heat treatment is expected to recover approximately the same percentage of transition temperature and upper shelf energy in the HAZ material as is expected for the other beltline materials. Thus, it is expected that the HAZ material will continue to have greater fracture toughness than the base metal and weld metal.
2.
Section 3. 1.4.2 states that reconstituted specimens will be tested in the 4
same orientation as the original. What was the original orientation of the specimens in the weld metal? Please provide a drawing showing the orientation.
The weld specimens were originally oriented parallel to the principal rolling direction of the plate and perpendicular to the direction of the weld. A figure showing the orientation is attached.
- 3. Section 3.1.5.2.a states that CVN [Charpy V-notch] specimen halves with.
"extensive" evidence of plastic deformation will be eliminated from further consideration. How is "extensive" deformation defined?
Charpy V-notch specimen halves will be examined as part of the selection process.
ASTM E 1253-88 requires that the central test section have a minimum of 14 mm of base metal or weld metal with no plastic deformation from previous testing. A specimen that cannot meet this criteria will be classified as having extensive deformation.
- 4. Section 3. 2. 2 states that the original surveillance capsules will be annealed and "If possible", reinserted prior to restart. Explain, what is meant by "If possible."
We plan to remove the remaining original surveillance capsules from the reactor vessel during the core unloading and to anneal them in parallel with the reactor vessel anneal. We then plan to reinstall the capsules during core reload.
Historically, installation of new surveillance capsules has proven to be a difficult task. The handling and annealing of the surveillance capsules may cause physical changes to the capsules that might impair their ability to be installed or properly secured. Modifications made to new capsules to aid in installation are not present
- in the original capsules. Because of their design and activity levels, capsule modifications may be difficult to complete within the refueling outage schedule requirements.
- It is anticipated that any modification required to successfully reinstall the surveillance capsules could be completed to support reinstallation during the next refueling outage after removal.
Clarifications
- 1. The annealing temperature and uncertainty were specified in Section 3.1.5.2.b as 85(J1F+/-25°F. RG 1.162 requires that the recovery estimates (Table 3.1.6.1 and 3. 1.6.3) would have been calculated using 825°F. Was this the case?
No. The calculations in Tables 3.1.6.1 and 3.1.6.3 were calculated using 850°F.
Calculations of recovery of the reactor vessel beltline materials have been performed at 850°F assuming the reactor vessel will be annealed at the planned 850°F. The annealing recovery program has been designed to address recovery at
850°F. Because the recovery program is intended to determine the expected 5
behavior of the Palisades surveillance material relative to the NUREG/CR-6327 .
equations, the measured recovery will be compared with the predicted recovery at the actual specimen annealing temperature. Actual recovery results will be used in the calculations in the final version of the Thermal Annealing Report.
- 2. The first note on Table 3. 1. 3-1 states that the W5214 welds used in the annealing verification program were taken from the highest copper or higher nickel chemistry region of the steam generator (SG) welds and "bound" the estimate for the reactor pressure vessel (RPV) welds. NRG interprets this statement to mean that the RPV welds are not expected to recover to as great a degree as the SG welds. Is *this interpretation correct?
No. The specimens were removed from the area of the steam generator W5214 weld which exhibited higher copper concentrations than other depths of the weld.
The higher chemistry factor of this material is expected to cause the test results of irradiated specimens to demonstrate greater embrittlement than expected for the reactor vessel material. In addition, the higher copper content of this material is expected to cause the test results*from the annealed material to demonstrate less percent recovery than would be expected for the reactor vessel. The RT NDT for the steam generator W5214 weld is expected to be higher than RTNDT for the reactor vessel W5214 welds whether pre-annealed or post-annealed, which is why we consider it to be bounding.
In a similar manner, the specimens were removed from the area of the steam generator 348009 weld which exhibited higher nickel concentrations than other depths of _the weld. The higher chemistry factor of this material is expected to cause the test results of irradiated specimens to demonstrate greater embrittlement than expected for the reactor vessel material. The similar copper content of this material is expected to cause the test results from the annealed material to demonstrate percent recovery similar to that .which would be expected for the reactor vessel. Therefore, the RT NDT for the steam generator 348009 weld is expected to be higher than RT NDT for the reactor vessel 348009 welds whether pre-annealed or post-annealed.
The following table demonstrates why we consider the steam generator surveillance material bounding.
- 6 Material Chemistry Before Before % After After Factor 2 Anneal Anneal Recovery Anneal Anneal 5
ARTNDT RTNDT ARTNDT RTNDT Vessel 232 256 1 265 3 90 3 26 3 36 3 W5214 Surveillance 267 294 304 82 4 53 63 W5214 Vessel 219 242 1 252 3 92 3 19 3 29 3 348009 Surveillance 227 250 260 92 4 20 30 348009 Notes: 1 TAR Section 1.1, Table 1.1.C-2 2 TAR Section 1.2, Table 1.2.C-1 3 TAR Section 1.1, Table 1.1.C-3 4 TAR Section 3.1, Table 3.1.6-1 5 Assumes fluence of 1.45 X 1019 at EOL
- 3. Section 3.2. 1.2 states that "application of the lateral shift method to the Charpy Upper Shelf Energy (USE) is more difficult because there is no generally accepted model of embrittlement. NRG expects that the trend curves from Figure 2 in RG 1. 99, Rev. 2 will still apply to describe USE decline after annealing.
We agree, predictions for reembrittlement have been calculated in accordance with the guidance of DG-1027, equation 15.
- 4. Section 3. 2. 2 correctly assumes that the procedures of 10 CFR 50. 61 will
____ be used for the chemistry factor calculation. The licensee discussed in this section the calculation of a "new" post-anneal chemistry factor. The staff recognizes the potential for annealing to alter the sensitivity to radiation embrittlement. This may be a potential consideration for a future revision of RG 1.99, Rev. 2 and/or the annealing RG (1. 162).
We acknowledge the NRC statement.
WELD METAL PRESSURE Vt:SS!L INSIDE SURFACE t
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l.ocat!on of weld metal charpy specimens within test plate.'