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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*
POWERINii MICHlliAN"S PROliREll Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 March 11 , 1996
- u S Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT INSERVICE INSPECTION PRESSURE TEST PROGRAM - REQUESTS FOR RELIEF Two relief requests are attached (Attachment 1) which require NRC approval prior to use. These relief requests propose alternative testing per 10 CFR Part 50.55a(a)(3) within the Palisades lnservice Inspection Pressure Test Program.
Relief Request PR-02 requests that alternative testing be allowed for components under the reactor vessel. Current Code requirements (ASME Section XI, IWA and IWB) specify that these pressure retaining components shall be subject to visual examinations during system pressure tests. The area under the reactor vessel is extremely b?zardous during the hot shutdown conditicms when pressure testing is performed. The hazardous conditions include not only high radiation fields but also confined spaces and heat stress conditions. The alternative testing proposed is to conduct the test in accordance with ASME Section XI, IWA-5244, "Buried Components" with a leakage calculation performed to determine the total PCS leak rate.
Relief Request PR-04 requests that the ASME Nuclear Code Case N-522, "Pressure
9603200017 960311 ; I PDR ADOCK 05000255 I, .I G PDR I I
,180167 A CM5 ENER6Y COMPANY
- ** 2 In accordance with 10 CFR Part 50.55a(a)(3), approval of Relief Requests numbers PR-02 and PR-04 is requested as alternatives to the requirements of ASME Section Xl-1989. . I
SUMMARY
OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.
Richard W Smedley Manager, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades 2 Attachments
ATTACHMENT 1 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 INSERVICE INSPECTION PRESSURE TEST PROGRAM - REQUESTS FOR RELIEF RELIEF REQUESTS PR-02 AND PR-04
- RELIEF REQUEST NUMBER: PR-02 COMPONENT IDENTIFICATION Code Class: 1
References:
IWA-5211 Table IWA-5210~1 IW8-5210 Table IW8-2500-1 Examination Category: 8-P
==
Description:==
Alternative Testing for the Reactor Vessel Within the Reactor Cavity CODE REQUIREMENT IWA-5211 states that the pressure retaining components within each system boundary shall be subject to system pressure tests as specified in Table IWA-5210-1 under which conditions VT-2 Visual Examinations are performed.
Table IWA-5210-1 requires a system leakage test and a system hydrostatic test be performed in accordance with Table IW8-2500-1, Category 8-P.
IW8-521 0 states that the pressure retaining components shall be tested at the frequency given and visually examined by the method specified in Table IWB-2500-1, Examination Category 8-P.
Table IWB-2500-1, Examination Category 8-P requires a system leakage test be performed each refueling outage on the pressure retaining boundary associated with normal reactor start-up and a system hydrostatic test be performed each inspection interval on the pressure retaining boundary of all Class 1 components.
BASIS FOR RELIEF Pursuant to 1 OCFR50.55a(a)(3)(ii), an alternative to the visual VT-2 examination specified by the requirements is requested on the basis that they would result in hardship and unusual difficulty without a compensating increase in the level of quality and safety. Also, per 1 OCFR50.55a(a)(3)(i), the proposed alternate examination will provide an acceptable level of quality and safety.
The area under the reacfor vessel is extremely hazardous when the Plant is at Hot Shutdown Conditions for system leakage testing. Radiation levels are expected to be 2.5 rem/hr (on contact), which is the maximum measured during cold shutdown. General dose is 1.5 to 2 rem/hr in the area. Assuming 2 persons in this area at one-half. hour per person, a total of 1.5 to 2 rem of dose would be received.
- 2 In addition to radiation concerns, access to the area under the vessel poses* various industrial hazards. Of primary concern is confined spaces and heat stress.
Ambient air temperatures with the Primary Coolant System at full pressure and temperature are expected to be approximately 300 degrees. Access under these conditions would require significant ventilation for cooling. The access tube to this area is only 30 inches in diameter. This size limits the amount of ventilation possible while allowing personnel access.
PROPOSED ALTERNATE EXAMINATION Palisades Nuclear Plant shall determine leakage from piping and components in the area under the reactor vessel in accordance with paragraph IWA-5244 "Buried Components" of ASME Section XI, 1989 Edition, no Addenda. This requirement will be satisfied by conducting Palisades' System Operating Procedure SOP 1, "Primary Coolant System (PCS)," which completes the PCS leak rate calculation.
Plant Technical Specification ~.1.5 states, "If the primary coolant system leakage exceeds 1 gpm and the source of the leakage is not identified, reduce unidentified primary coolant system leakage to less than 1 gpm within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, or place the reactor in hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown condition within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />." Technical Specification 3.1.5d invokes a more restrictive leakage limit of 0.6 gpm during startups. Technical Specification Table 4.2.2, Item 7 requires this leak rate determination on a daily basis. These limits are approved as documented in Palisades Facility Operating License DPR-20, through Amendment No 1 61 and are applicable at all times when the Primary Coolant System is greater than cold shutdown conditions.
- APPLICABLE TIME PERIOD This alternative is requested for the third ten-year interval of the lnservice Inspection Program for Palisades, which concludes in August of 2005.
- RELIEF REQUEST NUMBER PR-04 COMPONENT IDENTIFICATION Code Class: 2
References:
IWA-5211 IWA-5240 Table IWC-2500-1 IWC-521 O(a)
Examination Category: C-H
==
Description:==
Alternative Pressure Testing of Containment Penetration Piping Containment Isolation System (CIS)
Penetrations:
MZ-1a Purge Air Exhaust MZ-1b Purge Air Exhaust Bypass MZ-1c Purge Air Exhaust MZ-10 Service Air ,
MZ-10a Service Air MZ-11 Condensate to Shield Cooling Surge Tank MZ-17 Containment Pressure Instrument Line MZ-18 Transfer Winch Cable MZ-18a Fuel Transfer Tube MZ-19 Personnel Air Lock MZ-21 Hydrogen Monitoring Return Line MZ-21a Hydrogen Monitoring Supply Line MZ-25 Clean Waste Receiver Tank Vent MZ-26
- Nitrogen to Quench Tank MZ-27 ILRT Fill Line MZ-28 Containment Air Sample Line MZ-33 Safety Injection Tank Drain MZ-37 Primary System Drain Tank Recirculation MZ-38 Containment Building Heating Steam Return MZ-39 Containment Building Heating Steam Supply MZ-40a Hydrogen Monitoring Return Line MZ-40b Hydrogen Monitoring Supply Line MZ-41 Degasifier Pump Discharge MZ-42 Demin Water to Quench Tank MZ-44 Primary Coolant Pump Controlled Bleed Off MZ-46 Containment Vent Header MZ-47 Primary System Drain Tank Pump Suction MZ-48 Containment Pressure Instrument Lines MZ-49 Clean Waste Receiver Tank Circulation Lirie MZ-50 Emergency Access MZ-51 Equipment Hatch MZ-52a Containment Sump Level Instrument MZ-52b Containment Sump Level Instrument MZ-64 Reactor Cavity Fill and Recycle MZ-65 Instrument Air MZ-66 ILRT Instrument Line MZ-67 Clean Waste Receiver Tank Pump Discharge MZ-68 Air Supply to Air Room MZ-69 Clean Waste Receiver Tank Pump Suction MZ-72 Reactor Cavity Drain and Recycle
- 2 CODE REQUIREMENT IWA-5211 states, "The pressure retaining components within each system boundary shall be subject to system pressure tests under which conditions visual examination VT-2 is performed in acco.rdance with IWA-5240 to detect leakages."
IWC-521 O(a) states, "The pressure retaining components within each system boundary shall be subjected to a system pressure test conducted during a system functional test, a system pressure test conducted during a system inservice test, or a hydrostatic test, and visually examined by the method specified in Table IWC-2500-1, Examination Category C-H."
Table IWC~2500-1, Examination Category C-H, specifies a frequency of examination of once per inspection period for inservice or functional testing and once per inspection interval for hydrostatic testing.
BASIS FOR RELIEF Pursuant to 10CFR50.55a(a)(3)(i), the proposed alternative provides an acceptable level of quality and safety.
The proposed alternative will reduce the level of redundant testing. Imposition of the IWC-2500-1 test requirements would result in additional testing as follows:
- 1. Water systems would be flooded and pressurized through the associated penetration test tap and a VT-2 visual examination performed during the pressurization period.
. 2. Air and gas systems would be tested in an identical fashion to 10CFR50, Appendix J test method and a VT-2 visual examination would be performed during the pressurization period.
For the penetrations listed, 10CFR50, Appendix J testing is performed by draining the test volume, if required, venting downstream of the test volume and pressurizing the test volume to 55 psig. The rate of pressure decay is determined and compared to acceptance criteria based on allowable containment leak rate.
Leakage from water systems would be indicated during the 10CFR50, Appendix J test more readily than the IWC-2500-1 test due to the lower density of the air test medium.
Based on this fact, the use of the Appendix J test program is conservative when
- 3 Leakage from air and other gas systems would be indicated by 10CFR50, Appendix J testing in a similar manner to an IWC-2500-1 test. Based on this fact, the two programs are essentially equivalent.
The specified frequency of testing for the 10CFR50, Appendix J test program is once per refueling cycle, which is approximately 18 months. The IWC-2500-1 specified test frequency is once per inspection period which is approximately 3-1/3 years. A comparison of the specified test frequencies indicates the 10CFR50, Appendix J test program is conservative when compared to the ASME Section XI test program.
Palisades 10CFR50, Appendix J testing is performed by plant auxiliary operators (AO's). Palisades certifies the AO's as VT.;2 Level II examiners in accordance with Section XI. Therefore, Appendix J testing is performed by personnel trained to recognize unacceptable leakage from a pressure boundary.
PROPOSED ALTERNATIVE In lieu of the requirements specified in IWA-5211 and IWC-5210, Palisades will follow the guidance of Code Case N-522 for pressure testing of safety class 2 containment penetrations associated with non-safety class systems.
Testing required by 10CFR50.55, Appendix J may be used as an alternative to the rules in Table IWC-2500-1, Category C-H, for pressure testing piping that penetrates a containment vessel, when:
- 1. The piping and isolation valves that are part of the containment system are Class 2, but the balance of the piping system is outside the scope of Section XI.
APPLICABLE TIME PERIOD The proposed alternative is requested for the third ten-year interval of the lnservice Inspection Program for Palisades, which concludes in August of 2005.
ATTACHMENT 2 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 INSERVICE INSPECTION PRESSURE TEST PROGRAM - REQUESTS FOR RELIEF ASME CODE CASE N-522 1 Page
" . .:
- CASE N-522 CASES OF ASME BOILER AND PRESSURE VESSEL CODE Approval Date: December 9, 1993 See Numerical Index for expiration and any reaffirmation dates.
Case N-522 Pressure Testing of Containment Penetration Piping Section XI, Division 1 Inquiry: What altem.ative to the niles of Table IWC-2500-1, Category C-H may be used for pressure testing piping that penetrates a containment vessel, when the piping and isolation valves that are part of the contain-ment system are Class 2 but the balance of the piping system is outside the scope of Section XI?
Reply: It is the opinion of the Committee that 10 CFR 50, Appendix J, may be* used as an alternative to the rules in Table IWC-2500-1, Category C-H, for pressure testing piping that penetrates a containment vessel, when*
the piping and isolation valves that are part of the con-tainment system are Class 2 but the balance of the pip-ing system is outside the scope of Section XI?
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