ML18065A722
| ML18065A722 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/17/1996 |
| From: | Reinhart M NRC (Affiliation Not Assigned) |
| To: | Smedley R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| TAC-M95196, NUDOCS 9605240186 | |
| Download: ML18065A722 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Richard W. Smedley Manager, Licensing Palisades Plant 27780 Blue Star Memorial Highway Covert, MI 49043 May 1 7, 1 996.
SUBJECT:
PALISADES PLANT - EVALUATION OF BORIC ACID PUMP INSERVICE TESTING RELIEF REQUEST (TAC NO. M95196)
Dear Mr. Smedley:
By letter dated April 4, 1996, you submitted a request for relief from a requirement of the Palisades Inservice Testing Program.
The request identified a requirement of the Ame~ican Society of Mechanical Engineers _
(ASME) Boiler and Pressure Vessel Code (the Code) that you have.determined.is impractical to meet with the current plant design configuration.
The applicable regulation, 10 CFR 50.55a, allows the NRC to grant relief for Code requirements that are impractical due to limitations in the plant design.
The Palisades Inservice Testing Program has been updated for the third 10-year interval, which began August 21, 1995.
The third interval program adopted the 1989 Edition of Section XI of the Code fo~ inservice testing.
To comply with the requirements of the 1989 Edition of the Code, flow instrumentation was added to the boric acid pumps during the 1995 refueling outage.
Subsequent to installation of the.flow instrumentation problems have been encountered in the calibration of the instrument loop, which consists of a flow element and flow transmitter. The flow element and transmitter are usually calibrated at the factory as a matched set; however, post-installation testing indicated that the flow element had to be replaced to meet system temperature requirements.
As a result of the replacement of the flow element, the manufacturer must perform a field procedure.to correctly calibrate the set.. The procedute ts scheduled for the second quarter of 1996.
Until this calibration is complete, no measurement of flow is practical.
You have indicated that in the interim, testing is being performed using a fixed resistance recirculation flow path..
This alternative.testing is consistent with the guidance of Position 9 of Generic Letter 89-04 for quarterly testing on minimum flow recirculation with a more substantial flow test performed during plant shutdown conditions.
While the in~tallation of instruments is not considered a backfit (reference Question Group 105 in Appendix A of NUREG-1482), where licensees must install new instrumentation, a reasonable period for completing the installation is in order.
The problems experienced following install*tion of the boric acid pump flow instrumentation were unforeseen.
As a result, the plant design.does not yet allow for flow measurement in accordance with Inservice Testing Program
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Richard May 17, 1996 requirements (i.e., it is impractical).
Imposing the requirement to measure flow during inservice testing woul~ result in a burden to the licensee in that calibration by the manufacturer would need to be expedited, which could cause schedular problems with the activity, or the plant would be required to shut down until testing in conformance with the Code could be completed.
Compliance with the requirement of the Code to measur& flow is impractical, and imposition of the requirement would result in a burden to the licensee; therefore, the ~RC grants relief pursuant to 10 CFR 50.55a(f)(6)(i) for the short period from now until the calibrattgn is completed.
The interim period-should last no longer than two quarters, when testing in compliance with the Code requirements should be practical according to the current schedule for
. the calibration.*
The staff has determined that granting of this relief is authorized by law, will not endaryger life or property or the common defense and security, and is otherwise in the interest of the public giving due consideration to the burden upon the licensee if the requirements were imposed on the facility.
If you have any questions regarding this review,* plea~e contact Robert Schaaf at (301) 415-1312.
Docket No. 50-255 cc:
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- j Original Signed By:
Mark R~inhart, Acti~g Direct6r Project Di rectorate,**1I1-1
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. * "-Of.fi ce oLNuclear Reacto.r Regulation
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G:\\WPDOCS\\PALISADE\\PAL951~6:RLF To receive a copy of this document, Indicate In the box: :c** = Copy "without"aitachment/enclosure. "E" = Copy with attachment/enclosure "N" = No copy
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requirements (i.e., it is impractical).
Imposing the requirement to measure flow during inservice testing would result in a burden*to the licensee in that calibration by the manufacturer would need to be expedited, which could cause schedular problems with the activity, or the plant would be required to shut down until testing in conformance with the Code could be completed.
Compliance with the requirement of the Code to measure flow is impractical, and imposition of the requirement would result in a burden to the licensee; therefore, the NRC grants relief pursuant to 10 CFR 50.55a(f)(6)(i) for the short period from now until the calibration is completed.
The interim period should last no longer than two quarters, when testing in compliance with the Code requirements should be practical according to the current schedule for the ca 1 i brat ion.
The staff has determined that granting of this relief is authorized by law, wi.11 not en.danger life or property or the common defense and security, and is otherwise in the interest of the public giving due consideration to the burden upon the licensee if the requirements were imposed on the facility.
If you
. have any questions regarding this review, please contact Robert S~haaf at (301) 415-1312.
Docket No. 50-255 cc:
See next page Sincerely,
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Mark Reinhart; Acting Director Project Directorate 111-1 Divisfon of Reactor Projects - III/IV Office of Nuclear Reactor Regulation I
Mr. Richard W. Smedley Consumers Power Company
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cc:
Mr. Thomas J. Palmisano Plant General Manager Palisades Plant 27780 Blue Star Memorial Highway Covert, Michigan 49043 Mr. Robert *A. Fenech Vice President, Nucle~r Operations Palisades Plant 27780 Blue Star Memorial Highway Covert, Michigan 49043 M. I. Miller, Esquire Sidley & Austin 54th Floor One First National Plaza*
Chicago, Illinois 60603 Mr. Thomas *A. McNish Vice President &.Secretary Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consumers Power Company 212 West Michigan Avenue Jackson, Michigan* 49201 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351
- Jerry Sarno Township Supervisor Covert Township 36197 M-140 Highway Covert, Michigan 49043 Office of the Governor Room 1 - Capitol Buil9ing Lansing, Michigan 48913 U.S. Nuclear Regulatory Commission Resident Inspector's Office Palisades Plant '
27782 Blue Star Memorial Highway Covert, Michigan 49043 Palisades Plant Drinking Water and Radiological Protection Division Michigan Department of Environmental Quality 3423 Martin Luther King Blvd P. 0. Box 30630 Lansing, Michigan 48909-8130 Gerald Charnoff, Esquire Shaw, Pittman, Potts and Trowbridge 2300 N Street, N. W.
Washington DC 20037 Michigan Department of Attorney
- General
- Special Litigation Division 630 Law Building P.O. Box 30212 Lansing, Michigan 48909 May 1996