ML18066A354

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Forwards Response to NRC 980923 RAI Re Util 970729 Response to GL 97-01, Degradation of CRDM Nozzle & Other Vessel Closure Head Penetrations
ML18066A354
Person / Time
Site: Palisades Entergy icon.png
Issue date: 12/20/1998
From: Haskell N
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-97-01, GL-97-1, NUDOCS 9812290272
Download: ML18066A354 (6)


Text

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A CMS Energy Company December 20, 1998 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555 Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert. Ml 49043 DOCKET 50-255 - LICENSE DPR PALISADES PLANT Tel: 616 764 2276 Fax: 616 764 2490 Nstbsn L. Hs*ksll Director, Licensing RESPONSE TO GENERIC LETIER 97-01, "DEGRADATION OF CONTROL ROD DRIVE MECHANISM NOZZLE AND OTHER VESSEL CLOSURE HEAD PENETRATIONS," REQUEST FOR ADDITIONAL INFORMATION On April 1,_1997, the NRC issued Generic Letter (GL) 97-01, "Degradation of Control Rod Drive Mechanism Nozzle and Other Vessel Closure Head Penetrations."

Consumers Energy responded to GL 97-01 in letters dated April 28, 1997, and July 29, 1997. On September 23, 1998, the NRC issued a request for additional information (RAI) regarding our July 29, 1997, response.

This letter provides the Consumers Energy response to the RAI in the attachment.

Nuclear Energy Institute (NEI) Project Number 689, "Generic Responses to the NRC Requests for Additional Information on Generic Letter 97-01," has been submitted under separate cover to the NRC on December 11, 1998, by the NEI. The format of this response conforms with NRC and NEI recommendations to utilize the generic industry response to this issue.

SUMMARY

OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.

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than L. Haskell Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Attachment 9812290272 981220 PDR ADOCK 05000255 P

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ATTACHMENT CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 RESPONSE TO GENERIC LETTER 97-01, "DEGRADATION OF CONTROL ROD DRIVE MECHANISM NOZZLE AND OTHER VESSEL CLOSURE HEAD PENETRATIONS," REQUEST FOR ADDITIONAL INFORMATION 3 Pages

RESPONSE TO GENERIC LETTER 97-01, "DEGRADATION OF CONTROL ROD DRIVE MECHANISM NOZZLE AND OTHER VESSEL CLOSURE HEAD PENETRATIONS," REQUEST FOR ADDITIONAL INFORMATION NRC REQUESTED INFORMATION Designate which crack susceptibility model is being endorsed for the assessment of GEOM penetration nozzles at your plant.

CONSUMERS ENERGY RESPONSE The response to this question is included in Enclosure 4, "CEOG Response to NRC Requests for Additional Information," of the NEI December 11, 1998, submittal, particularly the Response to Question 1 therein.

NRC REQUESTED INFORMATION Indicate how the susceptibility model being endorsed relates to the CEOG's integrated program for assessing the GEOM penetration nozzles at ABB-CE designed plants, and whether or not the design of the susceptibility model is consistent with the contents of Topical Report CE NPSD-1085.

CONSUMERS ENERGY RESPONSE The response to this question is included in Enclosure 4, "CEOG Response to NRC Requests for Additional Information," of the NEI December 11, 1998, submittal, particularly the Response to Question 2 therein.

NRC REQUESTED INFORMATION If the ABB-CE PITM model is being endorsed for the assessment of GEOM penetration nozzles at your plant, address items a. - e. below.

If the PITM models are being endorsed for the assessment of vour GEOM penetration nozzles:

a.

Provide an expanded discussion and additional details describing how the time-to-failure model in the PITM relates to the PITM's time-to-initiation model. In particular, include an expanded discussion of how the PITM model relates growth of postulated flaws to the time-to-initiation model, and how the two aspects relate to each other and to the probability of failure methodology.

1

RESPONSE TO GENERIC LETTER 97-01, "DEGRADATION OF CONTROL ROD DRIVE MECHANISM NOZZLE AND OTHER VESSEL CLOSURE HEAD PENETRATIONS," REQUEST FOR ADDITIONAL INFORMATION

b.

Provide the latest PITM susceptibility ranking of GEOM penetration nozzles and, if applicable, of the vessel head instrumentation nozzles at your plant relative to the rankings of those at the other GEOG member plants.

c.

Provide a description of how the PITM model for assessing postulated flaws in vessel head penetration nozzles was bench-marked, and list and discuss the standards the models were bench-marked against.

d.

Provide any additional information regarding how the model will be refined to allow the input of plant-specific inspection data into the model's analysis methodology.

e.

Describe how the variability in the product forms, material specifications, and heat treatments used to fabricate each GEOM penetration nozzle at the GEOG member utilities are addressed in the PITM model.

CONSUMERS ENERGY RESPONSE The response to this question is included in Enclosure 4, "CEOG Response to NRC Requests for Additional Information," of the NEI December 11, 1998, submittal, particularly the Response to Question 1 therein. As stated therein, the CEOG now endorses the use of the EPRI model for the assessment of primary water stress corrosion cracking in Alloy 600 reactor vessel head penetrations.

Items a through e are no longer applicable to Palisades.

NRC REQUESTED INFORMATION If the Dominion Engineering susceptibility model is being endorsed for the assessment of GEOM penetration nozzles at your plant, address items f - i. below.

If the susceptibilitv model developed bv Dominion Engineering is being endorsed for the assessment of vour GEOM penetration nozzles:

f Provide a description of how the various product forms, material specifications, and heat treatments used to fabricate each GEOM penetration nozzle at the GEOG member utilities are handled in the Dominion Engineering susceptibility model.

2

RESPONSE TO GENERIC LETTER 97-01, "DEGRADATION OF CONTROL ROD DRIVE MECHANISM NOZZLE AND OTHER VESSEL CLOSURE HEAD PENETRATIONS," REQUEST FOR ADDITIONAL INFORMATION CONSUMERS ENERGY RESPONSE

f.

The response to this question is included in Enclosure 4, "CEOG Response to NRC Requests for Additional Information," of the NEI December 11, 1998, submittal, particularly the Response to Question 3 therein.

NRC REQUESTED INFORMATION

g.

Provide any additional information, if available, regarding how the model will be refined to allow the input of plant-specific inspection data into the model's analysis methodology.

CONSUMERS ENERGY RESPONSE

g.

The response to this question is included in Enclosure 4, "CEOG Response to NRC Requests for Additional Information," of the NEI December 11, 1998, submittal, particularly the Response to Question 5 therein.

NRC REQUESTED INFORMATION

h.

Describe how the Dominion Engineering crack initiation and crack growth models for assessing postulated flaws in vessel head penetration nozzles were bench-marked, and provide a listing and discussion of the standards the models were bench-marked against.

CONSUMERS ENERGY RESPONSE

h.

The response to this question is included in Enclosure 4, "CEOG Response to NRC Requests for Additional Information," of the NEI December 11, 1998, submittal, particularly the Response to Question 4 therein.

NRC REQUESTED INFORMATION

1.

Provide the latest model susceptibility rankings of GEOM penetration nozzles in GEOG member plants based on the results of the Dominion Engineering susceptibility model analyses of these GEOM and /Cl nozzles.

3

RESPONSE TO GENERIC LETTER 97-01, "DEGRADATION OF CONTROL ROD DRIVE MECHANISM NOZZLE AND OTHER VESSEL CLOSURE HEAD PENETRATIONS," REQUEST FOR ADDITIONAL INFORMATION CONSUMERS ENERGY RESPONSE

i.

The response to this question is included in Enclosure 4, "CEOG Response to NRC Requests for Additional Information," of the NEI December 11, 1998, submittal, particularly the Response to Question 6 therein.

4