ML052410206
| ML052410206 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/25/2005 |
| From: | Harden P Nuclear Management Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML052410206 (70) | |
Text
i VA NMC Committed to Nuclear Excellence Palisades Nuclear Plant Operated by Nuclear Management Company, LLC August 25, 2005 10 CFR 54 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Palisades Nuclear Plant Docket 50-255 License No. DPR-20 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit During the period June 20 through 24, 2005, an NRC team conducted an on-site audit of Aging Management Programs (AMPs) described in the Application for Renewed Operating License - Palisades Nuclear Plant, submitted on March 31, 2005. During that audit a number of written questions were asked by the team, and verbal and/or written responses were provided by NMC. The NRC audit team requested that the NMC written responses to a number of the team's questions be documented in a docketed letter.
This letter fulfills that request. ,
Enclosure I provides the text of, and the NMC response to, each NRC request. The questions in Enclosure 1 are quoted from the written questions provided by the audit team. Each question was discussed extensively with the auditors during interviews, often with wider scope than indicated by the written question. In addition, nearly all questions were asked in the context of a specific aging management program. The NMC responses provided in this letter, therefore, are focused on the specific question asked relative to the specific program under discussion, and do not necessarily address every subject that came up during the course of the interviews. provides a revised LRA Section B2.1.12, Non-EQ Electrical Commodities Condition Monitoring Program, that incorporates responses to several Aging Management Program audit questions, as well as questions asked during theAging Management Review audit. This revised program description incorporates several new or clarified NRC positions communicated during the audits.
27780 Blue Star Memorial Highway e Covert, Michigan 49043-9530 Telephone: 269.764.2000
Please contact Mr. Darrel Turner, License Renewal Project Manager, at 269-764-2412, or Mr. Robert Vincent, License Renewal Licensing Lead, at 269-764-2559, if you require additional information.
Summary of Commitments This letter contains five new commitments, as follows:
NMC will submit, for NRC review and approval, a comparison of EPRI TR-105714 revision 5 with revision 3 to identify the material changes that impact aging management and justify their acceptability by October 31, 2005. If necessary, the submittal will include a Water Chemistry Program description, revised to identify and justify use of TR-105714, Revision 5, as an exception to the NUREG 1801 program description.
NMC will submit, for NRC review and approval, a comparison of TR-102134 revision 6 with revision 3 to identify the material changes that impact aging management and justify their acceptability by October 31, 2005. If necessary, the submittal will include a Water Chemistry Program description, revised to identify and justify use of TR-1 02134, Revision 6, as an exception to the NUREG 1801 program description.
NMC will submit, for NRC review and approval, a comparison of TR-1 07396 revision I with revision 0 to identify the material changes that impact aging management and justify their acceptability by October 31, 2005. If necessary, the submittal will include a Closed Cycle Cooling Water Program description, revised to identify and justify use of TR-1 07396, Revision 1, as an exception to the NUREG 1801 program description.
NMC will revise the ASME Section Xl IWB, IWC, IWD, IWF Aging Management Program descriptions in LRA Appendices A and B to reflect the 2001 edition including the 2002 and 2003 addenda of ASME Section Xl. The revised program descriptions will identify exceptions to this code taken by the program, if any, that impact aging management effectiveness. Appropriate justification will also be provided to show that the exceptions, if any, still provide an acceptable level of aging management. The revised program descriptions will be submitted for NRC review and approval by October 31, 2005.
NMC will revise the Containment Inservice Inspection Program description in the LRA to identify use of the 1998 edition as an exception to GALL. Exceptions taken to the 1998 edition, if any, will be identified and justified as part of the program description. A comparison of the 1998 edition with the 1995 edition/1996 addendum referenced in NUREG 1801, revision 0, or the 2001 edition, including the 2002 and 2003 addenda, referenced in NUREG 1801, draft revision I (publicly released on August 12, 2005), will also be developed to support the adequacy of the 1998 edition of IWE and IWL for aging management.
The revised program description and comparison will be submitted for NRC review and approval by October 31, 2005.
27780 Blue Star Memorial Highway . Covert, Michigan 49043-9530 Telephone: 269.764.2000
Two Preliminary Commitments (i.e., subject to acceptance in the NRC SER for the renewed operating license), identified in NMC letter dated March 22, 2005, are hereby revised, and one withdrawn, as follows:
Preliminary Commitment 6 in Attachment 2 of the Palisades LRA transmittal letter dated March 22, 2005, is hereby revised to read as follows: NMC will re-evaluate effects of primary water stress corrosion cracking in all Alloy 600 components for which the current analyses found acceptable crack sizes at 40 years, to identify those for which the analysis would predict unacceptable crack sizes at 60 years, and to identify appropriate additional inspections for them. NMC will revise the Alloy 600 Program as needed to reflect the results of these re-evaluations. The revised Alloy 600 Program will be submitted for NRC review and approval by March 24, 2009.
Preliminary Commitment 33 from NMC LRA transmittal letter dated March 22, 2005, is hereby revised to read as follows: NMC will participate in industry initiatives that will generate additional data on aging mechanisms relevant to reactor vessel internals (RVI), including void swelling, and develop appropriate inspection techniques to permit detection and characterization of features of interest. Recommendations for augmented inspections and techniques resulting from this effort will be incorporated into the Reactor Vessel Internals Program as applicable. The revised Reactor Vessel Internals Program will be submitted for NRC review and approval by March 24, 2009.
Preliminary Commitment 34 from NMC LRA transmittal letter dated March 22, 2005, is hereby withdrawn.
One new preliminary commitment (i.e., subject to acceptance in the NRC SER for the renewed operating license) is provided, as follows:
NMC will revise the governing procedure for the Flow Accelerated Corrosion Program to include the value of 87.5% of nominal wall thickness for non safety related piping as a trigger point to initiate engineering analysis to confirm that remaining wall thickness is acceptable to support the intended function or to determine corrective action, as applicable. This requirement will be implemented by March 24, 2009.
I declare under penalty of perjury that the foregoing is true and correct. Executed on August 25,05 Paul A. Harden Site Vice President, Palisades Nuclear Plant Nuclear Management Company, LLC 27780 Blue Star Memorial Highway
- Covert, Michigan 49043-9530 Telephone: 269.764.2000
Enclosures (2) cc Administrator, Region 111, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC License Renewal Project Manager, Palisades, USNRC 27780 Blue Star Memorial Highway . Covert, Michigan 49043-9530 Telephone: 269.764.2000
ENCLOSURE I Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit (51 Pages)
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question I Non-EQ Electrical Commodities Condition Monitoring Program Preventive Actions (ISG-17 XL.E4)
No information is provided in Non-Segregated Phase Bus and Connections AMP.
Provide this element [NMC Tracking No. 18]
NMC Response to NRC Question 1 See page 5 of Enclosure 2 for a revised LRA Section B2.1.12 Non-EQ Electrical Commodities Condition Monitoring Program which incorporates the response to this question.
A new bullet, Non-Segregated Phase Bus and Connections, has been added under Preventive Actions in response to this question.
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 2 B.3.1 Electrical Equipment Qualification Program Description Provide EQ Component Reanalysis Attributes [NMC Tracking No. 20]
NMC Response to NRC Question 2 LRA section B3.1, Program Description, on page B-160, is hereby revised to add the following:
EQ Component Reanalysis Attributes (NUREG-1801 X.El)
The reanalysis of an aging evaluation is normally performed to extend the qualification by reducing excess conservatism incorporated in the prior evaluation. Reanalysis of an aging evaluation to extend the qualification of a component is performed on a routine basis pursuant to 10 CFR 50.49(e) as part of an EQ program. While a component life limiting condition may be due to thermal, radiation, or cyclical aging, the vast majority of component aging limits are based on thermal conditions. Conservatism may exist in aging evaluation parameters, such as the assumed ambient temperature of the component, unrealistically low activation energy, or in the application of a component (de-energized versus energized). The reanalysis of an aging evaluation is documented according to the station's quality assurance program requirements, which requires the verification of assumptions and conclusions. As already noted, important attributes of a reanalysis include analytical methods, data collection and reduction methods, underlying assumptions, acceptance criteria, and corrective actions (if acceptance criteria are not met). These attributes are discussed below.
Analytical Methods: The analytical models used in the reanalysis of an aging evaluation are the same as those previously applied during the prior evaluation. The Arrhenius methodology is an acceptable thermal model for performing a thermal aging evaluation. The analytical method used for a radiation aging evaluation is to demonstrate qualification for the total integrated dose (that is, normal radiation dose for the projected installed life plus accident radiation dose). For license renewal, one acceptable method of establishing the 60-year normal radiation dose is to multiply the 40-year normal radiation dose by 1.5 (that is, 60 years/40 years). The result is added to the accident radiation dose to obtain the total integrated dose for the component. For cyclical aging, a similar approach may be used. Other models may be justified on a case-by-case basis.
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit Data Collection and Reduction Methods: Reducing excess conservatism in the component service conditions (for example, temperature, radiation, cycles) used in the prior aging evaluation is the chief method used for a reanalysis. Temperature data used in an aging evaluation is to be conservative and based on plant design temperatures or on actual plant temperature data. When used, plant temperature data can be obtained in several ways, including monitors used for technical specification compliance, other installed monitors, measurements made by plant operators during rounds, and temperature sensors on large motors (while the motor is not running). A representative number of temperature measurements are conservatively evaluated to establish the temperatures used in an aging evaluation. Plant temperature data may be used in an aging evaluation in different ways, such as (a) directly applying the plant temperature data in the evaluation, or (b) using the plant temperature data to demonstrate conservatism when using plant design temperatures for an evaluation. Any changes to material activation energy values as part of a reanalysis are to be justified on a plant-specific basis. Similar methods of reducing excess conservatism in the component service conditions used in prior aging evaluations can be used for radiation and cyclical aging.
Underlying Assumptions: EQ component aging evaluations contain sufficient conservatism to account for most environmental changes occurring due to plant modifications and events. When unexpected adverse conditions are identified during operational or maintenance activities that affect the normal operating environment of a qualified component, the affected EQ component is evaluated and appropriate corrective actions are taken, which may include changes to the qualification bases and conclusions.
Acceptance Criteria and Corrective Actions: The reanalysis of an aging evaluation could extend the qualification of the component. If the qualification can not be extended by reanalysis, the component is to be refurbished, replaced, or requalified prior to exceeding the period for which the current qualification remains valid. A reanalysis is to be performed in a timely manner (that is, sufficient time is available to refurbish, replace, or requalify the component if the reanalysis is unsuccessful).
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 3 B.3.1 Electrical Equipment Qualification Monitored/inspected Provide details of monitoring or inspection of component parameters to ensure that a component is within bounds of its qualified or as a mean to modify the qualified life during the extended period of operation. [NMC Tracking No. 21]
NMC Response to NRC Question 3 The current EQ program monitors temperature as necessary to ensure the calculations are conservative, or as a means to modify the qualified life during the extended period of operation.
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 4 In the scope attribute of the GALL FM program, the staff suggests the following:
The program includes preventive measures to mitigate fatigue cracking of metal components of the reactor coolant pressure boundary caused by anticipated cyclic strains in the material.
Identify the preventive measures that mitigate fatigue cracking. [NMC Tracking No. 68]
NMC Response to NRC Question 4 The Palisades Fatigue Monitoring Program includes preventive measures designed to mitigate fatigue cracking of the metal components of the reactor coolant pressure boundary caused by cyclic strains in the materials. Preventive measures are consistent with the aging management program recommended in NUREG 1801Section X.M1.
The Fatigue Monitoring Program monitors plant transients that have been identified as causing cyclic strains that contribute significantly to the cumulative usage fatigue factor.
Using inputs from plant instrumentation to define the transients, the thermal transient cycles are counted. If it becomes necessary, a computer program will be employed to update the cumulative usage factor calculations for viewing, trending and evaluation.
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 5 Identify the basis for selection of locations subject to local monitoring, especially those that may be more limiting than those identified in NUREG/CR-6260 and those that are identified subsequently. [NMC Tracking No. 69]
NMC Response to NRC Question 5 The locations defined in NUREG/CR-6260 were considered during the development of the program, but represent only about one third of the Palisades components being monitored. The most limiting Palisades locations identified during program development were also evaluated for monitoring. The Palisades program includes the most limiting locations that warrant either cycle counting or stress-based monitoring.
The criterion for selecting monitored locations is based on the following:
- Only locations with a design basis fatigue usage factor greater than 0.40 were considered. The cutoff value of 0.4 is somewhat arbitrary, but was selected to ensure at least a 50% margin on design basis cumulative fatigue usage for a potential 60-year operating period (i.e., 1.5 x 0.4 = 0.60, which has greater than 50% margin compared to an allowable value of 1.0).
- Field experience that suggests a fatigue concern may exist.
The term local monitoring does not necessarily imply direct monitoring of the location of concern. In cycle-based fatigue monitoring like that used at Palisades, the actual data being used to define specific thermal transients may be coming from locations that are physically separated from the location of concern. The term local monitoring is interpreted to mean identification of a location of interest for either cycle counting or stress-based monitoring.
As stated in LRA Section B3.2 on page B-168, Palisades has a comprehensive Operating Experience Program (OEP) that monitors industry issues/events and assesses these for applicability to its own operations. In addition, the Palisades Corrective Action Program (CAP) is used to track, trend and evaluate plant issues/events. Those issues and events, whether external or plant specific, that are potentially significant to the Fatigue Monitoring Program at Palisades will be evaluated.
The Fatigue Monitoring Program will be augmented, as appropriate, if these evaluations show that program changes or monitoring of additional locations will enhance program effectiveness. Using the OEP and CAP to focus on industry and plant operating experience ensures that Fatigue Monitoring Program issues are addressed in a timely manner and that age related deterioration of SSC within the scope of the Fatigue Monitoring Program will be effectively managed throughout the license renewal period.
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Enclosure I Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 6 Clarify the meaning of "should not exceed" or similar expression when referring to a CUF <1.0 (whether or not it constitutes a commitment to a particular acceptance criterion) [NMC Tracking No. 71]
NMC Response to NRC Question 6 This question appears to be directed specifically at the statement on page 4-17 of the application, which reads, uTherefore the CUF should not approach 0.5 in 60 years..." In this instance, it is not a commitment to use 0.5 or any value less than 1.0 as the acceptance criterion. This was a conclusion that could have been stated as "...will not approach..." or, "... is not expected to approach ..."
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 7 Confirm that non-design-basis transients will (vice "may") be addressed prior to the period of extended operation. [NMC Tracking No. 72]
NMC Response to NRC Question 7 As indicated in the LRA Section B3.2, Scope of Program, on page B-165, non-design basis transients have already been included in the development of the Fatigue Monitoring Program. The design parameters for these non-design-basis transients are being developed at this time. These parameters will be used to design fatigue usage and/or cycle counting algorithms to be implemented in the fatigue monitoring program prior to entering the period of extended operation.
Therefore, "will" be addressed is the accurate statement.
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 8 Please confirm that loss of material, if it reduces wall thickness to a point below the ASME allowable, will trigger an engineering evaluation even if the wall thickness is more than 60% of nominal. [NMC Tracking No. 78]
NMC Response to NRC Question 8 NMC will revise the governing procedure for the Flow Accelerated Corrosion Program to include the value of 87.5% of nominal wall thickness for non safety related piping as a trigger point to initiate engineering analysis to confirm that remaining wall thickness is acceptable to support the intended function or to determine corrective action, as applicable. This requirement will be implemented by March 24, 2009.
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 9 LRA Section B1.1 Program Revisions - In the Palisades LRA Section B1.1, the applicant states that if a Palisades program is fully consistent with NUREG-1801, but is based on a different revision (usually later) of a code or standard referenced in the NUREG-1801 program description, the program is not considered to have an exception to NUREG-1801. However, because the GALL Report (NUREG-1801) guidance is based on specific revisions of the reference documents, the applicant must state the revision applicable to the specific aging management program. Then, ifthis revision is different than the revision referenced in the GALL Report, the applicant must declare this as an exception and provide the appropriate justification. The applicant is requested to identify the specific revision of the GALL reference that is being committed to in the application. Finally, the applicant is requested to identify those that should be considered as exceptions based on the discussion above. Each exception should be justified. [NMC Tracking No. 80]
NMC Response to NRC Question 9 NMC understands the NRC position that revisions of codes or standards used in AMPs that are not the same as those referenced in the GALL, are to be identified as exceptions to GALL. Therefore, code or standard revisions that are used in Palisades' programs, but are not referenced by either the 2001 or 2005 GALL descriptions, will be treated as exceptions to the GALL, and justification will be provided as required.
Revisions or supplements to the affected program descriptions will be submitted to the NRC as described below.
Preliminary review indicates that the programs which are potentially affected by this position are as follows:
XI.M1 - ISI - See response to question 11 [NMC Tracking No. 82] for the ASME Code discussion and a commitment to submit a revised program description which identifies the code used in the AMP.
XI.M2 - Primary Chemistry - The 2001 and 2005 GALL revisions reference EPRI TR-105714 Rev 3, and the Palisades AMP is based on Rev 5. NMC will submit, for NRC review and approval, a comparison of EPRI TR-1 05714 revision 5 with revision 3 to identify the material changes that impact aging management and justify their acceptability by October 31, 2005. If necessary, the submittal will include a Water Chemistry Program description, revised to identify and justify use of TR-105714, Revision 5, as an exception to the NUREG 1801 program description.
XL.M2 - Secondary Chemistry - 2001 and 2005 GALL revisions reference TR-1 02134 Rev 3, and the Palisades AMP is based on Rev 6. NMC will submit, for NRC review and approval, a comparison of TR-102134 revision 6 with revision 3 to identify the material changes that impact aging management and justify their acceptability by October 31, 10
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit 2005. If necessary, the submittal will include a Water Chemistry Program description, revised to identify and justify use of TR-102134, Revision 6, as an exception to the NUREG 1801 program description.
XI.M3 - Reactor Vessel Head Closure studs - See response to question 11 [NMC Tracking No. 82] for the ASME code discussion and a commitment to submit a revised program description which identifies the code used in the AMP.
XI.M11 - Nickel Alloy - The 2005 GALL revision deletes the XI.M11 program entirely.
Therefore, no code or standard comparison or program description revision is required.
XI.M16 - Reactor Vessel Internals - The 2005 GALL revision deletes this program.
Therefore, no code or standard comparison or program description revision is required.
Xl.M18 - Bolting Integrity - See response to question 11 [NMC Tracking No. 82] for the ASME Code discussion and a commitment to submit a revised program description which identifies the code used in the AMP. The reference to EPRI 104213 December 1995 is the same in NUREG 1801 and the AMP. Since the AMP uses standards referenced by GALL, no code or standard comparison or program description revision is required.
XI.M21 - Closed Cycle Cooling - The 2001 and 2005 revisions of NUREG 1801 reference EPRI TR 107396 revision 0 and the Palisades AMP is based on revision 1.
NMC will submit, for NRC review and approval, a comparison of TR-107396 revision 1 with revision 0 to identify the material changes that impact aging management and justify their acceptability by October 31, 2005. If necessary, the submittal will include a Closed Cycle Cooling Water Program description, revised to identify and justify use of TR-1 07396, Revision 1, as an exception to the NUREG 1801program description.
XI.S1 & S2 - IWE and IWL- See response to question 16 [NMC Tracking No. 113] for the ASME Code discussion and a commitment to submit a revised program description which discusses the code used in the AMP.
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 10 The notes A through D provided for PNP LRA Tables 3.1.2-1 through 3.1.2-4, Table 3.2.2-1, Tables 3.4.2-1 through 3.4.2-1 and Tables 3.5.2-1 through 3.5.2-10 are not consistent with the notes provided in Table 4.2-2 of NEI 95-10 Revision 5, January 2005. Please clarify that the text accompanying these notes is the wording that was intended. For example, the text for note A for Tables 3.1.2-1 through 3.1.2-4 states the following "Consistent with NUREG-1 801 item for component, material, environment, and aging management program. AMP is consistent with NUREG-1801 AMP." The statement "and aging management program" should state "and aging effect" to be consistent with Table 4.2-2. [NMC Tracking No. 81]
NMC Response to NRC Question 10 The differences between the LRA Standard Notes (Notes A through J) language (in LRA Sections 3.1, 3.2, 3.4 and 3.5) and the NEI 95-10 language for the standard notes were unintentional editorial errors. Notes A through J in the LRA are intended to have the same language and meaning as the standard industry notes introduced in the standard LRA format in 2003, and carried forward as Appendix D of NEI 95-10 Revisions 4, 5, and 6. In all the definitions of notes A through D in the LRA, "and aging management program" is hereby revised to state "and aging effect." Note that this response has no impact on the results reported in the LRA 3.x.2 tables.
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 11 GALL identifies an explicit edition and addenda of the ASME code as its basis for the Aging Management Program. The LRA does not explicitly identify the edition and addenda. Please identify the edition and addenda of the ASME Code or provide a justification for not having it. [NMC Tracking No. 82]
NMC Response to NRC Question 11 The ASME Section Xl IWB, IWC, IWD, IWF Aging Management Program (AMP), to be reviewed by NRC for license renewal purposes, will be based on the 2001 edition, through the 2003 addenda, of ASME Section Xl. The 2001 edition, including the 2002 and 2003 addenda, are referenced in NUREG 1801, draft Revision 1, publicly released on August 12, 2005, as providing an acceptable AMP. NMC will revise the ASME Section Xl IWB, IWC, IWD, IWF Aging Management Program descriptions in LRA Appendices A and B to reflect the 2001 edition including the 2002 and 2003 addenda of ASME Section Xl. The revised program descriptions will identify exceptions to this code taken by the program, if any, that impact aging management effectiveness. Appropriate justification will also be provided to show that the exceptions, if any, still provide an acceptable level of aging management. The revised program descriptions will be submitted for NRC review and approval by October 31, 2005.
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 12 The response to Bulletin 2004-01 is for PZR penetration and steam space piping connection. The response does not address other RCS PWSCC locations. Please provide description how other PWSCC locations are addressed. [NMC Tracking No. 86]
NMC Response to NRC Question 12 Palisades Nuclear Plant has 251 Alloy 600 penetrations, all of which are contained within the primary coolant system (PCS). The reactor vessel contains two alloy 600 penetrations, which are two (2) Reactor flange leak detector taps The reactor pressure vessel head has 54 Alloy 600 penetrations, which are categorized as follows: (45) -
Control Rod Drive (CRD) Alloy 600 nozzles that are J-welded at the reactor head inner-diameter (ID) and then butt-welded to the CRD flange above the reactor head; (8)
Incore instrumentation (ICI) nozzles that are J-welded at the reactor head ID and then butt-welded to the ICI flange above the reactor head; (1) - Reactor vent line nozzle that is J-welded at the reactor head ID and then butt-welded to the reactor vent line above the reactor head. The pressurizer contains 136 Alloy 600 penetrations, which are categorized as follows: (1) 3-inch ID X 6-inch outer diameter (OD) PORV nozzle located in the upper head; (1) 4-inch spray line nozzle assembly; (1) 12-inch surge line nozzle; (3) 3-inch ID X 6-inch OD valve nozzles; (8) 1-inch level nozzles, four upper and four lower; (2) 1-inch temperature element nozzle penetrations; (120) - Pressurizer heater penetrations, which are J-welded to the internal cladding of the vessel lower head.
Each steam generator contain two (total of 4) Alloy 600 penetrations, which are the bowl plugs. The primary coolant piping contains 55 Alloy 600 penetrations, which are categorized as follows: (4) inch, schedule 140, safety injection and shutdown cooling inlet nozzles; (1) inch, schedule 140, shutdown cooling outlet nozzle; (1) 12-inch schedule 140 surge nozzle; (22) - Temperature measurement, Inconel SB-166 nozzles on the primary loops; (1) 2-inch, schedule 160 hot leg drain; (4) inch, schedule 160 cold leg drain; (10) - 3%-inch, schedule 160, pressure measurement and sampling nozzles. (8) - %-inch, schedule 160, pressure measurement nozzles. (2) inch, schedule 160 spray nozzles. (2) inch, schedule 160 charging inlet nozzles.
See the response to question 38 for additional discussion about the Alloy 600 Program.
As noted, the response contains a commitment to submit a revised program for NRC review and approval prior to the period of extended operation.
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 13 Since buried stainless steel components are not coated, what are the parameters that are monitored/inspected for stainless steel components. Is this an exception to the GALL AMP? [NMC Tracking No. 92]
NMC Response to NRC Question 13 The Buried Services Corrosion Monitoring Program contains the requirements to perform a visual inspection of external surfaces of buried stainless steel components, inspecting for evidence of MIC, Crevice, and Pitting Corrosion.
This is not an exception to the GALL AMP.
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 14 In the PNP LRA, the applicant states that Palisades does not credit active flow testing for managing age-related degradation of CCCW components. However, performance of selected heat exchangers is monitored in accordance with the Master Heat Exchanger Testing Plan. Provide documentation to justify that the master Heat Exchanger program provides the same level of aging management as would be achieved by the performance and functional testing recommended in EPRI TR-107396. This should cover all three elements related to the exception, i.e., parameters monitored, tested and/or inspected; detection of aging effects and monitoring and trending. [NMC Tracking No. 103]
NMC Response to NRC Question 14 NMC has concluded that the exceptions identified in LRA Section B2.1.6 were not required. A review of the supporting data, for the testing performed on the closed cycle cooling water systems pumps and heat exchangers, revealed that the required pump and heat exchanger testing defined in NUREG 1801 is performed. At the time of the on-site audit, it appeared that there could be one remaining exception related to the test frequency for pumps and heat exchangers in the Shield Cooling Water System.
Subsequent reviews have confirmed, however, that the shield cooling system is in-scope as a pressure boundary only, so performance testing of shield cooling pumps and heat exchangers is not required for aging management.
Therefore, LRA Section B2.1.6 is her6by revised as follows:
On page B-42, under NUREG-1801 Consistency, replace the entire section with the following statement: "The closed Cycle Cooling Water Program is consistent with NUREG 1801,Section XI.M21, "Closed-Cycle Cooling Water System"."
On pages B-42 and B-43 under the heading of Exceptions to NUREG-1 801, replace the entire section with the following statement: "None."
On page B-44 under the heading of Parameters Monitored, Tested , and/or Inspected, replace the last paragraph, including exception bullet, with the following statements.
"This program monitors the effects of corrosion by surveillance testing and inspection.
For pumps, the parameters monitored include flow, discharge and suction pressures.
For heat exchangers, the parameters include flow, inlet and outlet temperatures, and differential pressures as appropriate. This element is consistent with NUREG 1801,Section XI.M21, "Closed-Cycle Cooling Water System"."
On pages B-44 and B-45 under Detection of Aging Effects, replace the last paragraph, including exception bullet, with the following statements. "Performance and functional testing ensures acceptable functioning of system or components. For systems or components in continuous operation, performance adequacy is determined by monitoring data trends . Components not in operation are periodically tested to ensure 16
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit operability. This element is consistent with NUREG 1801, Section XL.M21, "Closed-Cycle Cooling Water System"."
On page B45 and B-46 under Monitoring and Trending, replace the last paragraph, including both exception bullets, with the following statements: "Performance and functional testing are performed at least every 18 months to demonstrate system operability, and tests to evaluate heat removal capability of the system and degradation of system components are performed every five years. This element is consistent with NUREG 1801, Section XL.M21, "Closed-Cycle Cooling Water System"."
On page B-46 and B-47 under Acceptance Criteria, replace the last paragraph, including both exception bullets, with the following statement: "This element is consistent with NUREG 1801,Section XI.M21, "Closed-Cycle Cooling Water System"."
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 15 In the PNP LRA, the applicant states that the performance and operability testing of selected pumps, including flow, suction and discharge pressure, is monitored in accordance with ASME Section Xl, Subsection IWP, Inservice Testing Program. Please provide documentation that the pump testing under the ASME Section Xl, Subsection IWP, Inservice Testing provides the same level of aging management as would be achieved by implementing the performance and functional testing requirements recommended in EPRI TR-107396. This should cover all three elements related to the exception, i.e., parameters monitored, tested and/or inspected; detection of aging effects and monitoring and trending. [NMC Tracking No. 104]
NMC Response to NRC Question 15 The pumps in the closed cycle cooling water systems are those associated with the Component Cooling Water (CCS) System, Emergency Diesel Generator (EDG) Jacket Cooling Water systems, and Shield Cooling System (SCS).
The CCS pumps, P-52A, B, C, are tested under a quarterly surveillance procedure, which records suction and discharge pressure, pump dp, flow rate, and heat exchanger dp. The Diesel Jacket Water Cooling System pumps, P-211 A&B, are skid-mounted equipment and are driven directly from the diesels. Discharge pressure and temperature are recorded for these pumps in accordance with accepted practices for testing of skid-mounted equipment. For the non-safety related Shield Cooling System pumps, P-77 A & B, no specific functional testing is completed other than operational parameter monitoring of the system. Since the Shield Cooling Water System is in scope for a pressure boundary function only, the pump testing is not required to age manage the pumps.
During the audit, a follow up question was asked about testing of heat exchangers in closed cycle cooling water systems. The heat exchangers in the closed cycle cooling water systems are those associated with the Component Cooling Water (CCS) System, Emergency Diesel Generator (EDG) Jacket Cooling Water systems, and Shield Cooling System (SCS).
The master heat exchanger Testing plan shows that the CCS heat exchangers, E-54 A and B, are inspected every other refueling outage using the ET/EPRI single tube method; the diesel jacket water coolers, E-22 A and B, are inspected every 18 months, and the Shield Cooling heat exchanger, E-64, is eddy current tested once every ten years. Since the Shield Cooling heat exchanger is in scope for pressure boundary only, an inspection interval of ten years is sufficient to monitor for degradation of the pressure boundary function.
This testing is consistent with that described in NUREG 1801, Section XL.M21.
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 16 Provide the documentation that approves the use of the 1998 edition (no addenda) of the ASME B&PV code by Palisades for IWE and IWL inspections. [NMC Tracking No.
113]
NMC Response to NRC Question 16 The NRC approved use of the 1998 edition in a letter dated September 27, 2002, "Palisades Plant - Evaluation of Containment In-service Inspection Relief Requests (TAC Nos. MB4216 and MB4218)".
The Palisades Containment Inservice Inspection Program references the 1998 edition, no addenda, for Section Xi, Subsections IWE and IWL, except that the personnel qualification process is based on the 1992 edition through 1992 addendum. NMC will revise the Containment Inservice Inspection Program description in the LRA to identify use of the 1998 edition as an exception to GALL. Exceptions taken to the 1998 edition, if any, will be identified and justified as part of the program description. A comparison of the 1998 edition with the 1995 edition/1996 addendum referenced in NUREG 1801, revision 0, or the 2001 edition, including the 2002 and 2003 addenda, referenced in NUREG 1801, draft revision 1 (publicly released on August 12, 2005), will also be developed to support the adequacy of the 1998 edition of IWE and IWL for aging management. The revised program description and comparison will be submitted for NRC review and approval by October 31, 2005.
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 17 Provide details on the diesel driven fuel pump tests. Provide an example of the test results. [NMC Tracking No. 144]
NMC Response to NRC Question 17 During the discussions, the auditor was specifically interested in verifying conformance with the NUREG-1801 statement, "The diesel-driven fire pump inspection program requires that the pump be periodically tested to ensure that the fuel supply line can perform the intended function". In the LRA transmittal letter dated March 22, 2005, , Commitment 22, NMC made a commitment to, " Revise diesel-driven fire pump performance test procedures to more specifically address requirement to inspect and monitor fuel oil supply line for aging related degradation, and to document inspection results." As discussed in LRA Section B2.1, the LRA describes programs as if enhancements have been incorporated. The program, when enhancements are complete, will be consistent with the quoted NUREG 1801 statement.
Since the Fire Protection Program presently does not contain a specific inspection of the diesel driven fire pump fuel supply lines, there are no test results available for review.
20
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 18 Provide justification for acceptance of cracks no wider than 114". Identify where any cracks or defects in seals have been observed. [NMC Tracking No. 148]
NMC Response to NRC Question 18 LRA Section B2.1.10, Fire Protection Program, Exceptions to NUREG 1801, is hereby revised to delete exception 3 on page B-73. In addition, Acceptance Criteria on page B-79 is hereby revised to read as follows:
"Acceptance criteria are defined in the Palisades procedures used to perform tests and inspections of the Fire Protection System. Fire seal and conduit wrapping inspection results are acceptable if there are no visual indication of cracking, separation of seals from building structures and components, and no rupture or puncture of seals. Fire door inspection results are acceptable if there are no visual indications of wear, holes, damaged or missing parts, and clearances are within limits. Diesel-driven fire pump inspections are acceptable if there is no evidence of corrosion or leaks on the fuel oil supply line. Acceptance criteria for the diesel-driven fire pump capacity is contained within the test procedure.
This element is consistent with NUREG-1 801, Sections XLM26, "Fire Protection" as clarified by ISG-4.
This element is consistent with NUREG-1801, Sections XL.M27, "Fire Water System" as clarified by ISG-4."
The balance of this question was discussed during the on-site interview and need not be docketed.
21
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 19 GALL states that no corrosion is acceptable in the fuel supply line for diesel- driven fire pump. LRA states that acceptance criteria for the diesel-driven fire pump capacity is contained within the test procedure. Provide acceptance criteria for fuel supply line for diesel driven fire pump to show consistency with the GALL. [NMC Tracking No. 149]
NMC Response to NRC Question 19 In the LRA transmittal letter dated March 22, 2005, Attachment 2, Commitment 22, NMC made a commitment to,," Revise diesel-driven fire pump performance test procedures to more specifically address requirement to inspect and monitor fuel oil supply line for aging related degradation, and to document inspection results." As discussed in LRA Section B2.1, the LRA describes programs as if enhancements have been incorporated. While the specific acceptance criteria have not yet been developed, this element will be consistent with NUREG-1801, Section XL.M26, Fire Protection System as clarified by ISG-04 upon completion of this enhancement.
See the response to NRC Question 18 for additional relevant information. Note that this response removes the exception defined in the LRA on page B-79 for Acceptance Criteria.
22
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 20 Elaborate on the differences between NFPA monitoring and trending against PNP FP implementing procedures. [NMC Tracking No. 153]
NMC Response to NRC Question 20 Based on discussions during the interview and a detailed review of the applicable sections of NFPA-25, it has been concluded that Palisades complies with the specific monitoring and trending of results as specified in NFPA-25. This new understanding serves as the basis for not taking exception to the GALL on this issue. NMC's review of NFPA-25 for monitoring and trending of system performance testing identified two sections where requirements are stated.
NFPA-25 step 5-3.5.2 states that the pump test curve shall be compared to the unadjusted field acceptance test curve and the previous annual test curves.
This guidance is demonstrated in the fire suppression water system functional test and fire pump capacity test procedure which states, "This procedure facilitates trending hydraulic performance of Fire Pumps P-9A, P-9B, and P-41, including comparison of current pump performance with original and historical pump performance."
NFPA-25 step 4-3.1 states that underground and exposed piping shall be flow tested to determine the internal condition of the piping at minimum 5-year intervals. Flow test shall be made at flows representative of those expected during a fire for the purpose of comparing the friction loss characteristics of the pipe with those expected for the particular type of pipe involved, with due consideration given to the age of the pipe and to the results of previous flow tests. Any flow test results that indicate deterioration of available water flow and pressure shall be investigated to the complete satisfaction of the authority having jurisdiction to ensure that adequate flow and pressure are available for fire protection.
This testing guidance is demonstrated in the fire suppression water system flow test procedure, which states, "To determine operability of fire suppression water system by performing a flow test to determine if there is any system degradation or obstruction.
The procedure contains acceptance criteria and requirements to initiate a condition report if acceptance criteria are not met." Flow testing is required to be performed every three (3) years.
The Palisades program meets the requirements as identified above. Continued implementation of this program provides reasonable assurance that the effects of aging of the applicable components will be adequately managed for the period of extended operation.
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit Based on the above, the exception taken to the NUREG 1801 Xl.M27 and ISG-04 under Monitoring and Trending is hereby withdrawn and the following changes are made to the LRA.
On page B-73 of the LRA delete exception #2 and replace with Not Used..
On Page B-78 and B-79 under Monitoring and Trending, replace the last paragraph, including the exception bullet, with the following statement: "Results of system performance testing are monitored and trended as specified by NFPA codes and standards. The element is consistent with Section XL.M27, "Fire Water System" as clarified by ISG-04.
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 21 LRA states that the program focuses on managing loss of material due to corrosion, MIC, or biofouling of carbon steel and cast-iron components exposed to water. However, LRA Table 3.3.2-7 lists bare copper, bronze, copper alloy and stainless steel components in raw water as the components that their aging effects are managed by fire protection AMP. Clarify this discrepancy. [NMC Tracking No. 155]
NMC Response to NRC Question 21 The Fire Protection Program is intended to include all materials/components of Table 3.3.2-7 that credit the Fire Protection Aging Management Program. The last sentence of the first paragraph of Scope of Program on page B-74 is hereby revised to read, "The program focuses on managing loss of material due to corrosion, MIC, or biofouling of components; and aging management of fire barrier components."
25
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 22 How the accessible medium voltage cables aging will be managed? [NMC Tracking No.
175]
NMC Response to NRC Question 22 See page 3 of Enclosure 2 for a revised LRA Section B2.1.12 Non-EQ Electrical Commodities Condition Monitoring Program which incorporates the response to this question.
All cables are managed as part of a spatial cable commodity. The Scope of Program section has been revised to incorporate the commodities Cables and Connections and Low Signal Sensitive Instrumentation Cables and Connections 26
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 23 Identify the cables involved in this program. [NMC Tracking No. 180]
NMC Response to NRC Question 23 The following cables are included:
A1103 (SERVICE WATER PUMP P7B BREAKER NO. 152-103),
Al105 (2400V. BUS #1C INCOMING FROM SAFEGUARDS BUS Breaker #152-105)
Al 106 (2400V. BUS #1C INCOMING FROM STARTUP TRANS., BRK #152-106)
A1202 (2400V. BUS #1D INCOMING FROM STARTUP TRANS BRKR #152-202)
A1204 (SERVICE WATER PUMP P7A BREAKER NO. 152-204)
A1205 (SERVICE WATER PUMP P7C BREAKER NO. 152-205)
A1303 (2400V BUS #lE INCOMING FROM STARTUP TRANSFORMER BRKR #152-303)
A2102 (4160V. BUS #1A INCOMING FROM STARTUP TRANS BRKR #252-102)
A2202 (4160V. BUS #1B INCOMING FROM STARTUP TRANS BRKR #252-202)
A2302 (4160V BUS #1F S/U POWER BRKR #252-302)
A2402 (4160V BUS #1G S/U POWER BRKR #252-402)
F95 (SAFEGUARDS SCHEMES) 27
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 24 Explain the difference between significantly greater than the bounding design parameter value and significantly more severe than specified service environment for the cable.
[NMC tracking No. 183]
NMC Response to NRC Question 24 Bounding design parameter has the same meaning as specified service environment.
The terms are used interchangeably.
28
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 25 Provide the type of test to be performed for detecting deterioration of the insulation system. [NMC tracking No. 187]
NMC Response to NRC Question 25 See Page 8 of Enclosure 2 for a revised LRA Section B2.1.12 Non-EQ Electrical Commodities Condition Monitoring Program which incorporates the response to this question.
The last bullet under Detection of Aging Effects has been revised in response to this question.
29
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 26 Explain how loose connection will be identified without thermography or resistance measurement. [NMC tracking No. 189]
NMC Response to NRC Question 26 See pages 5 and 6 of Enclosure 2 for a revised LRA Section B2.1.12 Non-EQ Electrical Commodities Condition Monitoring Program which incorporates the response to this question.
The first bullet under Parameters Monitored, Inspected and/or Tested has been revised, and a new second bullet added, in response to this question.
30
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 27 Provide details experience that is the basis for the statement that aging degradation is a slow process. GALL requires an engineering evaluation to be performed to determine test interval. [NMC Tracking No. 193]
NMC Response to NRC Question 27 See page 7 of Enclosure 2 for a revised LRA Section B2.1.12 Non-EQ Electrical Commodities Condition Monitoring Program which incorporates the response to this question.
The second bullet under Detection of Aging Effects has been revised in response to this question.
31
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 28 GALL requires that all circuits in the scope of this program will be tested. Will all cables and connections in the scope of this program be tested? [NMC Tracking No. 196]
NMC Response to NRC Question 28 Periodic testing will be performed on all these medium voltage cables to provide an indication of the insulation condition. The cables will be tested with the connections made up, as the test leads are connected at the breaker connection point.
See page 8 of Enclosure 2 for a revised LRA Section B2.1.12 Non-EQ Electrical Commodities Condition Monitoring Program which incorporates the response to this question. The third bullet under Detection of Aging Effects, first paragraph, last sentence, has been deleted in response to this question.
32
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 29 Modified GALL requires that inspection frequency is based on actual field data but not to exceed 2 years. Provide manhole inspection frequency. Provide inspection results of underground manholes if available. Provide a copy of the inspection program if available. [NMC Tracking No. 199]
NMC Response to NRC Question 29 See page 8 of Enclosure 2 for a revised LRA Section B2.1.12 Non-EQ Electrical Commodities Condition Monitoring Program which incorporates the response to this question.
The last bullet under Detection of Aging Effects has been revised in response to this question. Note that there is currently no formal inspection program, so no inspection results are available.
33
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 30 Palisades program B.1.2, "Quality Assurance Program and Administrative Controls" does not address the special requirements identified in GALL XI. El, E2, E3, and E4 program. Address these requirements. [NMC Tracking No. 202, 203, 204, 205]
NMC Response to NRC Question 30 See pages 9, 10 and 11 of Enclosure 2 for a revised LRA Section B2.1.12 Non-EQ Electrical Commodities Condition Monitoring Program which incorporates the response to this question.
The element Corrective actions has been revised in response to this question.
34
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 31 10CFR54.21 (d) requires a summary description of the programs and activities for managing the effects of aging for license renewal. The LRA states that the aging management of the bottom surface of carbon steel tanks will be managed using the OTI program in lieu of GALL AMP XL.M29, but there is no commitment to that effect in Appendix A of the application. Please revise the FSAR summary description of the OTI program to include an explicit commitment to that effect. [NMC Tracking No. 207]
NMC Response to NRC Question 31 The final paragraph of LRA Section A2.13 One-Time Inspection Program is hereby revised to include a fifth bullet as follows:
This program is used for a variety of purposes, including the following:
To verify, for carbon steel storage tanks supported on earthen or concrete foundations, that excessive corrosion is not occurring on the bottom surfaces of the tanks.
35
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 32 The GALL Report AMP XL.M20 states that the program relies on implementation of the recommendations of Generic Letter 89-13 to ensure the effects of aging will be managed. However, in the PNP LRA, the applicant states that recommendations (d) a system walkdown inspection to ensure compliance with the licensing basis, and (e) a review of maintenance, operating and training practices and procedures were conducted as part of the generic letter response and are not associated with the on-going management of aging. Please justify not listing this as an exception to the GALL AMP.
[NMC Tracking No. 212]
NMC Response to NRC Question 32 Reviews have determined that the original statements in the Scope of Program discussion concerning implementation of recommendations (d) and (e) noted above were not correct. These activities are included in existing plant procedures as part of the ongoing management of aging, and are not an exception to the GALL.
Therefore, the second paragraph under LRA Section B2.1.14, Scope of Program, ("GL 98-13 required ... Water Program.") is hereby deleted.
36
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 33 The GALL Report AMP XI.M20 states that NRC Guidelines for Generic Letter 89-13 include "a test program to verify heat transfer capabilities." The LRA AMP specifies heat exchanger testing but does not specify what type of testing. Please provide documentation of the type and frequency of heat exchanger testing included in the Open Cycle Cooling Water Program. [NMC Tracking No. 213]
NMC Response to NRC Question 33 A summary of the type and frequency of testing for heat exchangers in scope of the Open Cycle Cooling Water Program for License Renewal is as follows:
Component Cooling Water Heat Exchangers (E-54 A & B) - one heat exchanger is tested using the ET/EPRI single tube test every other outage.
Control Room HVAC condensing Units (VC-10 and 11) are visually inspected once every two years. An additional procedure is completed every eighteen months to demonstrate the cooling capabilities of VC-10 and VC-11.
Engineered Safeguards Room cooling coil (VHX-27A &B) are inspected every other refueling outage.
Emergency Diesel Generators (1-1 and 1-2) jacket water coolers (E-22A&B) are visually inspected every 18 months and flow tested monthly.
Emergency Diesel generators (1-1 and 1-2) Lube Oil Coolers (E-31A&B) are visually inspected every 18 months and flow tested monthly.
Containment air coolers (VHX-1,2,3) cooling coils and are visually inspected every third refueling outage.
Note that the auditor also requested information related to the Shield Cooling Heat Exchanger as a follow up to this question. Shield Cooling is a closed cycle cooling system and beyond the scope of this question, Open Cycle Cooling. See question 14 for the requested information relating to Shield Cooling Heat Exchanger testing.
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 34 Palisades makes the following statement under element DETECTION OF AGING EFFECTS for masonry walls: Periodicity of examinations may vary, according to different reinforcement masonry configurations. Explain what is meant by this statement. An LRA supplement is needed to actually add to the Structural Monitoring Program that the inspection of unreinforced block walls will be on a more frequent basis than reinforced walls. [NMC Tracking No. 257]
NMC Response to NRC Question 34 A clarification to LRA section B2.1.19 "Structural Monitoring Program" is being provided to better demonstrate consistency with GALL Program XI.S5 "Masonry Wall Program" element #4. Specifically, the statement on page B-142 of the LRA that states "Periodicity of examinations may vary, according to different reinforcement masonry configurations." is hereby clarified to say, "In addition, inspections for unreinforced block walls that are not contained by bracing will be performed on a more frequent basis than the periodicity of at least once every 10 year interval specified for reinforced or braced block walls."
LRA Section A2.19 Structural Monitoring Program, page A-8, the following new sentence is hereby added to the end of the second paragraph:
"In addition, the program specifies that inspections for unreinforced block walls that are not contained by bracing will be performed on a more frequent basis than the normal frequency of once each 10 year interval specified for reinforced or braced block walls."
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 35 Will Palisades take advantage of inspection opportunities for structures required for license renewal and identified as inaccessible? As inaccessible areas become accessible by such means as excavation or other reason, will additional inspections of those areas be performed? An LRA supplement is needed to actually add to the Structural Monitoring Program that inspection of inaccessible areas will be performed when they become accessible due to excavation from normal PNP activities. [NMC Tracking No. 258]
NMC Response to NRC Question 35 Due to the lack of aggressive groundwater at Palisades, a plant specific program is not required to age manage inaccessible below grade concrete as discussed in ISG-3.
However, to validate this determination NMC will perform an inspection of opportunity on inaccessible concrete when excavation work uncovers a significant depth (i.e.,
several feet or more) of normally inaccessible concrete.
Accordingly, the following sentence is hereby added to LRA Section B2.1.19, Structural Monitoring Program, after the first paragraph of the "Detection of Aging Effects" section on page B-141:
"In addition, the program provides for inspections of opportunity of normally inaccessible below grade concrete when excavation work uncovers a significant depth (i.e., several feet or more) to provide access for inspection.
In addition, the following sentence is hereby added to LRA Section A2.19, Structural Monitoring Program, page A-8, following the second sentence of the first paragraph:
"In addition, the program provides for inspections of opportunity of normally inaccessible below grade concrete when excavation work uncovers a significant depth (i.e., several feet or more) to provide access for inspection.
39
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 36 Provide a comparison between the monitored parameters for EPRI Revision 3 and Revision 5. Explain why EPRI is acceptable (verification that non of the controlled parameters are relaxed in the later revisions). This may be needed to be considered as an exception. [NMC Tracking No. 261]
NMC Response to NRC Question 36 See response to question 9 [NMC Tracking No. 80] for a commitment to prepare and submit a comparison of the identified EPRI standards, justify differences, and revise the Water Chemistry Program description if necessary..
40
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 37 GALL XL.M2 states that in certain cases verification of the effectiveness of the chemistry control program is undertaken to ensure that significant degradation is not occurring and the component intended function will be maintained during the extended period of operation. An acceptable verification program is a one-time inspection of selected components at susceptible locations in the system.
LRA B2.1.21 states that The One-Time Inspection Program verifies that the Water Chemistry Program is managing the effects of aging of selected components in low flow or stagnant areas.
However, LRA has not provided any clarification that the low flow and stagnant locations are the only susceptible locations that require inspection by OTI program. Provide clarifications. [NMC Tracking No. 262]
NMC Response to NRC Question 37 While the most susceptible locations may be the low flow or stagnant potions of a particular system, it was not intended to limit the selection of susceptible locations to low flow or stagnant portions of a system. Upon implementation of the One-Time Inspection Program, NMC plans to group all identified components within the system with the same material, same environment, and same aging mechanism. From this group, the most susceptible locations will be selected for inspection. When determining the most susceptible locations, all portions of the system(s) will be considered, not just the low flow or stagnant sections. Therefore, the following changes are made to the Water Chemistry and One-Time Inspection Program descriptions in Appendix B of the LRA:
On page B-97, under Program Description, revise the first bullet of the third paragraph to read, "To verify the effectiveness of water chemistry control for managing the effects of aging in portions of piping exposed to a treated water environment."
On page B-103, under Detection of Aging Affects Related to XI.M32, One Time Inspection, revise the second paragraph in its entirety to read, "To verify that the Water Chemistry Program and the Closed Cycle Cooling Water Program are mitigating the applicable aging effects, visual examinations or other appropriate NDE methodology will be used when components are inspected."
On page B-156, under Detection of Aging Affects, revise the last sentence of the first paragraph to read, "In addition, inspections of selected components at susceptible locations of a system, performed under the One-Time Inspection Program, provide verification of the effectiveness of the Water Chemistry Program."
41
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 38 to the transmittal letter for the PNP LRA is a table of preliminary commitments related to license renewal. The project team notes that it will be necessary for the staff to review and approve the entire reactor vessel internals program prior to the period of extended operation, and will require adequate time to do so. For changes in dimension due to void swelling, there is already a commitment to report the result of evaluations at least two years prior to the period of extended operation (Item 33 of the table). Please revise the commitment to submit the entire program, addressing any results of other industry initiatives that affect the PNP AMP B2.1.17 (discussed in Item 34 of the table) for review at least 24 months prior to the period of extended operation to allow adequate time for NRC staff review and approval of the entire RV Internals program prior to the period of extended operation. [NMC Tracking No. 588]
NMC Response to NRC Question 38 Preliminary Commitments 33 and 34 in Attachment 2 of the Palisades LRA transmittal letter dated March 22, 2005, are hereby combined into a single new commitment 33 to read as follows:
Preliminary Commitment 33 from NMC LRA transmittal letter dated March 22, 2005, is hereby revised to read as follows: NMC will participate in industry initiatives that will generate additional data on aging mechanisms relevant to reactor vessel internals (RVI), including void swelling, and develop appropriate inspection techniques to permit detection and characterization of features of interest. Recommendations for augmented inspections and techniques resulting from this effort will be incorporated into the Reactor Vessel Internals Program as applicable. The revised Reactor Vessel Internals Program will be submitted for NRC review and approval by March 24, 2009.
Preliminary Commitment 34 is hereby withdrawn.
42
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 39 Enclosure 2 to the transmittal letter for the LPNP LRA is a table of preliminary commitments related to license renewal. The project team notes that it will be necessary for the staff to review and approve the Alloy 600 program prior to the period of extended operation, and will require adequate time to do so. Please revise the commitment to submit the re-evaluations (those discussed in item 6 of the table) for review at least 24 months prior to the period of extended operation to allow adequate time for NRC staff review and approval prior to the period of extended operation. [NMC Tracking No. 589]
NMC Response to NRC Question 39 Preliminary Commitment 6 in Attachment 2 of the Palisades LRA transmittal letter dated March 22, 2005, is hereby revised to read as follows:
NMC will re-evaluate effects of primary water stress corrosion cracking in all Alloy 600 components for which the current analyses found acceptable crack sizes at 40 years, to identify those for which the analysis would predict unacceptable crack sizes at 60 years, and to identify appropriate additional inspections for them. NMC will revise the Alloy 600 Program as needed to reflect the results of these re-evaluations. The revised Alloy 600 Program will be submitted for NRC review and approval by March 24, 2009.
43
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 40 Since the tendon surveillance program has not had a common tendon defined for the life of the plant, and a complete set of surveillance results is not available for trending, is this an exception to GALL? If so, please justify. [NMC Tracking No. 594]
NMC Response to NRC Question 40 The Palisades tendon surveillance program was directed by Plant Technical Specifications until 10 CFR 50.55a invoked testing in accordance with ASME Section Xl, Subsection IWL, in 1996. Palisades Technical Specifications did not require the selection of common tendons. As a result, common tendons were not defined at Palisades until the 30-Year tendon surveillance conducted in 2002. The selected tendons did not meet the desired criteria in that they had been detensioned during the first tendon surveillance in the early 1970s. Therefore, LRA Section B2.1.7, Containment Inservice Inspection Program, Exceptions to NUREG 1801, is hereby revised to read, "The generally accepted definition of common tendon does not completely correspond with the XI.S2, ASME Section Xl Sub-Section IWL portion of the Containment Inservice Inspection Program, and is considered to be an exception to NUREG 1801."
This exception does not degrade the effectiveness of the program to assure an acceptable level of containment structural integrity at all times. The Palisades tendon surveillance program is designed to maintain the tendon force above minimum analysis requirements on a continuous basis from surveillance to surveillance. This is accomplished each surveillance by performing tendon force measurements, comparing the results against expected levels for tendon force, and assuring that any expected relaxation will not reduce tendon forces below minimum requirements beyond at least the next surveillance. Structural integrity does not rely solely on the projection of forces in a designated common tendon out to the end of plant life.
44
Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 41 ISG-4 and the GALL Report XI.M26 recommends periodic inspection and test of halon/carbon dioxide fire suppression system. During previous discussions with the NMC Technical staff, the NMC stated that the halon and C02 systems at Palisades are not in-scope of license renewal. For the project team to complete its review of consistency of PNP B2.1.10 with the GALL AMP, please identify all Palisades halon and C02 systems at Palisades. In addition, clarify why periodic inspection and test of halon/carbon dioxide fire suppression system, as recommended by GALL XI.M26, is not required for Palisades (is different for Palisades). [NMC Tracking No. 603]
NMC Response to NRC Question 41 The Palisades Plant has a CARDOX system that is for turbine generator hydrogen space purging, and not for fire protection. There is a halon fire protection system that is designed to mitigate the effects of a fire in the Critical Function Monitoring System (CFMS) trailer, located in the Turbine Building. No NRC license requirements are identified for the halon system. This single halon system does not protect any safety related or safe shutdown equipment.
Therefore, there are no Halon/Carbon Dioxide Fire Protection Systems in scope for license renewal, and no aging management program is required. Palisades uses water spray to protect some areas (e.g., cable spreading room) that are typically protected by either Carbon Dioxide or Halon at most plants.
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 42 Table 3.3.2-7 lists "valves and dampers" and "piping and fittings" as component groups with soil external environment. Explain how loss of material and selective leaching aging (for buried cast iron piping) aging effects of these components are managed by the fire protection AMP. In addition, similar to buried services corrosion AMP, provide frequency of inspection of the buried components that are managed by fire protection program. [NMC Tracking No. 604]
NMC Response to NRC Question 42 Table 3.3.2-7 for the Fire Protection System, on pages 3-154 through 3-157, indicate that cast iron components in soil and raw water environments are managed for Selective Leaching by the One-Time Inspection Program. The One-Time Inspection Program discussion in LRA Section B2.1.13, page B-100, summarizes the application of the program to selective leaching The buried "valves and dampers" and "piping and fittings" of the Fire Protection System are managed for Loss of Material by the Fire Protection Program. The Fire Protection Program discussion in LRA Section B2.1.10, page B-77, summarizes the application of the program to below grade fire protection system components.
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 43 The FSAR supplement currently does not contain the requirement to perform a system walkdown inspection and a review of maintenance, operating and training practices and procedures. The applicant in response to [Question 31] indicated that this is performed.
This question is to ensure that the FSAR Supplement is revised to include these two items. [NMC Tracking No. 605]
NMC Response to NRC Question 43 LRA Section A2.14, Open Cycle Cooling Water Program, page A-6, third sentence, is hereby revised to read as follows:
The aging effects are managed through (a) monitoring and control of biofouling, (b) flow balancing and flushing, (c) heat exchanger testing (d) routine inspection and maintenance program activities, (d) system walkdowns, and (e) review of maintenance, operating and training practices and procedures, to ensure that aging effects do not impair component intended function.
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Enclosure I Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 44 LRA B2.1.21, "acceptance criteria" states that some of the parameters monitored are used for diagnostic purposes only and do not have acceptance criteria recommended by the EPRI guidelines. Identify those diagnostic parameters that have acceptance criteria different from the recommended EPRI guideline. Explain why they are different at Palisades. (Note: this was asked as question [NMC Tracking No. 268]. However, the response was not docketed.) [NMC Tracking No. 606]
NMC Response to NRC Question 44 The acceptance criteria for the chemistry parameters required to be monitored and controlled are based on the EPRI guidelines, Palisades Technical Specifications and the Operating Requirements Manual. Some of the parameters are monitored for diagnostic purposes only. The EPRI guidelines do not contain acceptance criteria for parameters monitored only for diagnostic purposes.
This question arose during discussion of data for feedwater iron and copper transport.
At Palisades certain closed cooling water systems (DG Jacket Water, Component Cooling Water, and Shield Cooling System) are monitored for iron and copper, but there are no EPRI-specified "limits" associated with these parameters. This is an acceptable practice, and does not impact chemistry program effectiveness for aging management.
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Enclosure I Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 45 The FSAR supplement does not contain the requirement to perform testing of the new fuel oil prior to introduction into the storage tanks (As required by the Standard Review Plan) Please provide a justification for this omission or include this feature in Appendix A. This response will need to be docketed. Note: the testing is currently being performed by the applicant. [NMC Tracking No. 607]
NMC Response to NRC Question 45 LRA Section A2.9, last sentence, is hereby revised to read: Fuel oil quality is maintained by monitoring and controlling fuel oil contamination in accordance with the guidelines of the American society for Testing Materials (ASTM) Standards D 1796, D 2276, D 2709, and D 4057; and by verifying the quality of new oil before its introduction into the storage tanks.
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 46 GALL recommends visual inspection (VT-1 or equivalent) of approximately 10% of each type of penetration seal in walk downs is performed at least once every refueling outage.
Please provide a technical justification as to how the visual inspection method that the applicant will use is equivalent and assures the same level of flaw identification and documentation as would be achieved by VT-1 and VT-3. [NMC Tracking No. 623]
NMC Response to NRC Question 46 The ASME Section Xl Code identifies inspection and acceptance criteria to apply to various systems/components (i.e.. IWB-3520.1, IWB-3520.2) when using a VT-1 or VT-3 examination. IWA-221 1, VT-1 Examination states: 'VT-1 examinations are conducted to detect discontinuities and imperfections on the surfaces of components, including such conditions as cracks, wear, corrosion, or erosion." IWA-2213, VT-3 Examination states: "VT-3 examinations are conducted to determine the general mechanical and structural condition of components and their supports by verifying parameters such as clearances, settings, and physical displacements; and to detect discontinuities and imperfections, such as-loss of integrity at bolted or welded connections, loose or missing parts, debris, corrosion, wear, or erosion. VT-3 includes examinations for conditions that could affect operability or functional adequacy of snubbers and constant load and spring type supports."
Palisades' fire barrier penetration seal inspection surveillance procedure contains detailed inspection criteria, inspection methods, and acceptance criteria for each of the installed seal types. These requirements are equivalent to the level of detail required for a VT-1 inspection conducted under ASME Section Xl. Completed inspection procedures are signed off as acceptable, or any unacceptable condition is documented in the Corrective Action System and repaired or replaced as required. NMC considers this as equivalent to VT-1 or VT-3 examinations as used in ASME Section Xl and discussed in GALL.
It is also noted that NUREG 1801, draft revision 1, (as publicly released on August 12, 2005),Section XI.M26, removes reference to VT-1 and VT-3 from Detection of Aging Effects. It instead specifies that visual inspection by fire protection qualified inspectors of the fire barrier walls, ceilings, and floors, performed in walkdowns at least once every refueling outage, ensures timely detection of concrete cracking, spalling, and loss of material. Visual inspection by fire protection qualified inspectors detects any sign of degradation of the fire door such as wear and missing parts.
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Enclosure 1 Supplementary Information for the Palisades Application for Renewed Operating License Resulting from Aging Management Programs Audit NRC Question 47 NUREG 1801 Section XL.M26, Fire Protection, as modified by ISG-04, states under Detection of Aging Effects, "Periodic tests performed at least once every refueling outage, such as flow and discharge tests, sequential starting capability tests, and controller function tests performed on diesel-driven fire pump ensure fuel supply line performance. The performance tests detect degradation of the fuel supply lines before loss of the component intended function." Under Monitoring and Trending it states, "The performance of the fire pump is monitored during the periodic test to detect any degradation in the fuel supply lines. Periodic testing provides data (e.g., pressure) necessary for trending."
In LRA Section B2.1.10, Enhancement 4 states, "Detection of Aging Effects and Monitoring and Trending: Revise diesel-driven fire pump performance test procedures to more specifically address requirement to inspect and monitor fuel oil supply line for aging related degradation and to document inspection results." The enhancement does not indicate whether or not the revised procedures will be consistent with the quoted GALL paragraphs.
Please provide information to demonstrate that the revised procedures will be consistent with the GALL paragraphs quoted above, or, if not, identify any exceptions. [NMC Tracking No. 624]
NMC Response to NRC Question 47 LRA Section B2.1.10, Fire Protection Program, Detection of Aging Effects, second full paragraph on page B-77, is hereby revised to read as follows:
Testing of the fire pumps (e.g., diesel-driven fire pump flow and discharge tests, sequential starting capability tests, and controller function tests) is performed every 18 months to ensure that an adequate flow of water is supplied and that there is no degradation of the fuel line to the diesel-driven fire pump.
LRA Section B2.1.10, Fire Protection Program, Monitoring and Trending, third paragraph on page B-78', is hereby revised to read as follows:
Testing of the fire pumps is performed every 18 months to ensure that an adequate supply of water is supplied and that there is no degradation of the fuel line to the diesel driven fire pump. The performance tests detect degradation of the fuel supply lines before loss of the component intended function, and provide data (e.g., pressure) necessary for trending.
These revised statements are consistent with the GALL paragraphs quoted in the question.
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Enclosure 2 Revised LRA Section B2.1.2, Non-EQ Electrical Commodities Condition Monitoring Program (13 Pages)
Enclosure 2 Revised LRA Section B2.1.2, Non-EQ Electrical Commodities Condition Monitoring Program License Renewal Application Section B2.1.2, Non-EQ Electrical Commodities Condition Monitoring Program, is hereby revised in its entirety. Changes have been made to this section in response to both AMP and AMR audit questions.
The revised LRA Section is as follows:
B2.1.12 Non-EQ Electrical Commodities Condition Monitoring Program Program Description The Non-EQ Electrical Commodities Condition Monitoring Program is a new program that manages aging in selected non-EQ commodity groups within the scope of 10 CFR 54. Program activities are responsive to the NRC guidance provided in NUREG-1801 and industry standards.
Palisades has identified each electrical commodity group requiring aging management for the three applicable sections of NUREG-1801 with the additional guidance provided in ISG-2 and draft ISGs-5, 15, 17 and 18, as follows:
- NUREG-1801 Program XL.E1, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements" requires a periodic inspection program that visually inspects accessible cables and connections in adverse localized environments with any identified degradation being evaluated and, as appropriate per plant procedures, entered into the plant corrective action process. The Non-EQ Electrical Commodities Condition Monitoring Program predominantly inspects for adverse aging from temperature, radiation, or moisture in the presence of oxygen.
Electrical pinned connectors are subject to pin corrosion from boric acid leakage, and periodic inspections are conducted in the Boric Acid Corrosion Program to preclude failures resulting from leakage.
The non-segregated bus in-scope of License Renewal was conservatively assessed, as discussed in draft ISG-17, to require aging management.
The "weak link" in maintaining a non-aging environment was identified to be unchecked water leakage through the housing seals and bus bar connections due to thermal cycling. Appropriate inspection activities are included in the periodic inspections.
- NUREG-1801 Program XL.E2, "Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits" requires routine calibration tests to be performed to identify potential existence of aging degradation of cables and connections used 1
Enclosure 2 Revised LRA Section B2.1.2, Non-EQ Electrical Commodities Condition Monitoring Program in low-level signal applications that are sensitive to reduction in insulation resistance (IR) such as radiation monitoring and nuclear instrumentation.
This is revised as discussed in draft ISG-15 which allows testing once every 10 years in lieu of TS surveillance test trending. The Non-EQ Electrical Commodities Condition Monitoring Program does subject sensitive instrumentation circuits, identified as requiring aging management, to periodic testing.
NUREG-1801 Program XI.E3, "Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements" requires a periodic test to provide an indication of the condition of the conductor insulation for those cables in-scope of License Renewal exposed to long periods of high moisture (greater than a few days at a time) and subjected to voltage stress (energized greater than 25% of the time). Periodic testing will be performed on these medium voltage cables to provide an indication of the insulation condition. The Non-EQ Electrical Commodities Condition Monitoring Program includes input from draft ISG-18 for periodic inspections of underground raceway manholes for the accumulation of water over the medium-voltage cables. Periodic inspections of underground manholes for the accumulation of water in the medium-voltage cable manholes will minimize the effects of water inside the underground manholes.
The fuse holders that were not inside active equipment were evaluated per draft ISG-5 and determined to have no aging effect that required management.
NUREG-1801 Consistency The Non-EQ Electrical Commodities Condition Monitoring Program is consistent with NUREG-1801, Sections Xl.E1, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," XI.E2, "Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits," and XI.E3, "Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," and guidance provided in ISG-2 and draft ISGs-5, 15,17 and 18.
Exceptions to NUREG-1801 None.
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Enclosure 2 Revised LRA Section B2.1.2, Non-EQ Electrical Commodities Condition Monitoring Program Enhancements A Non-EQ Electrical Commodities Condition Monitoring Program will be developed and implemented. Features of the program will include development and implementation of procedures to conduct periodic inspection of insulated cables and connectors, test sensitive instrumentation circuits, test medium voltage cables, and inspect manhole water levels.
Note that the element descriptions describe the program as it will be implemented. The program will be implemented prior to the period of extended operation.
Aging Management Program Elements The key elements of the Non-EQ Electrical Commodities Condition Monitoring Program are described below. The results of an evaluation of each key element against NUREG-1801, Sections XL.E1, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," XL.E2, "Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits," and XL.E3, "Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," and guidance provided in ISG-2 and draft ISGs-5, 15, 17 and 18, are also provided below.
Scope of Program Commodities within the scope of the Non-EQ Electrical Commodities Condition Monitoring Program include all non-EQ insulated cables and connections in-scope of License Renewal identified as requiring aging management, and any identified in the future to be in a newly-discovered localized adverse environment. The non-segregated phase bus, in-scope due to being a component of the SBO restoration path, is also included.
The specific commodity groups included within the scope of the Non-EQ Electrical Commodities Condition Monitoring Program are as follows:
Cables and Connections
- Signal Sensitive Instrumentation Cables and Connections
- Inaccessible Medium-Voltage Cables and Connections
- Non-Segregated Phase Bus and Connections The aging effects/mechanisms managed by the Non-EQ Electrical Commodities Condition Monitoring Program for these electrical commodities are as follows:
- Cable and connection jacket/insulation degradation, such as embrittlement and cracking, on a circuit section or component 3
Enclosure 2 Revised LRA Section B2.1.2, Non-EQ Electrical Commodities Condition Monitoring Program exposed to a localized adverse environment typically involving high temperature, radiation, and moisture levels
- Corrosion (Loss of Material) of the non-segregated bus duct internal metal components, and loose connections creating localized heating leading to electrical failure
- Loss of dielectric (insulation material) properties
- Promotion of water trees This element is consistent with NUREG-1 801,Section XI.E1, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," Section Xl.E2, "Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits,"Section XI.E3, "Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," and guidance provided in ISG-2 and draft ISGs-5, 15, 17 and 18.
Preventive Actions
- Accessible Non-EQ Electrical Cables and Connections This is a periodic visual inspection program and no actions are taken as part of this program to prevent or mitigate aging degradation. This element is consistent with NUREG-1 801,Section XI.El, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements."
Non-EQ Electrical Cables Used in Sensitive Instrumentation Circuits This is a periodic testing program to provide an indication of the condition of the conductor insulation and no actions are taken as part of this program to prevent or mitigate aging degradation. This element is consistent with NUREG-1 801,Section XI.E2, "Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits" and guidance provided in draft ISG-15.
- Inaccessible Non-EQ Medium-Voltage Cables The periodic testing program provides an indication of the condition of the conductor insulation. Periodic inspections of underground manholes, for the accumulation of water over the medium-voltage cables, will be conducted to minimize prolonged moisture conditions that promote the growth of water trees. This element is consistent with NUREG-1801, Section Xl.E3, "Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements" and guidance provided in draft ISG-18.
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Enclosure 2 Revised LRA Section B2.1.2, Non-EQ Electrical Commodities Condition Monitoring Program
- Non-Segregated Phase Bus and Connections This is an inspection program and no actions are taken as part of this program to prevent or mitigate aging degradation Parameters Monitored, Inspected, and/or Tested
- Accessible Non-EQ Electrical Cables and Connections A periodic visual inspection will be performed of accessible insulated cables and connections in-scope of License Renewal that may be subjected to a localized adverse environment. A localized adverse environment is defined as when any electrical insulation material is exposed to an aging environment that is significantly greater than the bounding design parameter value.
This program will focus on the metallic parts of the connection. The monitoring includes loosening of bolted connections due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation. A representative sample of electrical cable connections is tested. The following factors are considered for sampling: application (high, medium and low voltage, circuit loading, and location (high temperature, high humidity, vibration, etc.). The technical basis for the sample selected shall be documented.
This element is consistent with NUREG-1801, Section Xl.E1, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements" and guidance provided in ISG-2 and draft ISGs -17 and -18.
- Non-Segregated Phase Bus and Connections A periodic visual inspection will be performed for signs of water leakage or contamination into the non-segregated bus through the housing seals and signs of localized heating potentially from loose internal connections that may lead to electrical failure. This program will also provide for the inspection of the internal portion of the bus ducts for cracks, corrosion, foreign debris, excessive dust buildup, and evidence of water intrusion. The bus insulating system will be inspected for signs of cracking, melting, swelling, or discoloration, which may indicate overheating or aging degradation.
The (internal) bus supports will be inspected for structural integrity and signs of cracks. A representative sample of the bus 5
Enclosure 2 Revised LRA Section B2.1.2, Non-EQ Electrical Commodities Condition Monitoring Program connections will be inspected using thermography. The first inspection of non-segregated phase bus and connections under the program will be completed prior to entering the period of extended operation and every 10 years thereafter.
This element is consistent with NUREG-1 801,Section XI.E1, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements" and guidance provided in ISG-2 and draft ISGs- 17 and 18.
- Non-EQ Electrical Cables Used in Sensitive Instrumentation Circuits This is a periodic testing program to check insulation condition and no actions are taken as part of this testing program to prevent or mitigate aging degradation.
This element is consistent with NUREG-1801,Section XI.E2, "Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits" and guidance provided in draft ISG-15.
- Inaccessible Non-EQ Medium-Voltage Cables The periodic testing program provides an indication of the condition of the conductor insulation. Periodic inspections of underground manholes, for the accumulation of water over the medium-voltage cable levels, will be conducted to minimize the prolonged moisture conditions that promotes the growth of water trees.
This element is consistent with NUREG-1801, Section XL.E3, "Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," and guidance provided in draft ISG-18 Detection of Aging Effects Accessible Non-EQ Electrical Cables and Connections A periodic inspection of accessible insulated cables and connections in-scope of License Renewal will be performed at least once every 10 years. As stated in NUREG-1801, this is an adequate inspection period to preclude failures of the conductor insulationfJacket and connection since experience has shown that aging degradation is a slow process. The first inspection for License Renewal will be completed before the period of extended operation.
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Enclosure 2 Revised LRA Section B2.1.2, Non-EQ Electrical Commodities Condition Monitoring Program The accessible insulated cable and connections shall be visually inspected for insulation/jacket surface anomalies, such as discoloration, swelling, cracking, or surface contamination. Surface anomalies are a precursor indication of insulation degradation. If an unacceptable condition is identified for an insulated cable or connection, a determination would be made as to whether the same condition or situation is applicable to other accessible or inaccessible insulated cables and connections exposed to the same type of localized adverse environment.
Electrical connections within the scope of license renewal are tested at least once every 10 years. Testing may include thermography, contact resistance testing, or other appropriate testing methods justified in the application. This test frequency is adequate to preclude failures of the electrical connections since experience has shown that aging degradation of electrical connections is a slow process. A 10-year testing frequency will provide two data points during a 20-year period, which can be used to characterize the degradation rate. The first tests for license renewal are to be completed before the period of extended operation.
This element is consistent with NUREG-1801, Section XL.EI, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements."
Non-EQ Electrical Cables Used in Sensitive Instrumentation Circuits All sensitive cables and connections in scope of license renewal are to be periodically tested (such as insulation resistance tests, time domain reflectometry tests, or other tests effective in determining cable insulation condition). The test frequency of these cables shall be determined by the applicant based on engineering evaluation, but shall not exceed ten years. This is an adequate period to identify cable and connection degradation to preclude excessive leakage currents since experience has shown that aging degradation is a slow process. The first tests for license renewal will be completed before the period of extended operation.
This element is consistent with NUREG-1801, Section XL.E2, "Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits", and guidance provided in draft ISG-15.
- Inaccessible Non-EQ Medium-Voltage Cables 7
Enclosure 2 Revised LRA Section B2.1.2, Non-EQ Electrical Commodities Condition Monitoring Program Identified in-scope inaccessible medium-voltage insulated cables (not designed for submergence), subject to long periods of high moisture conditions and voltage stress, are tested (such as power factor, partial discharge or polarization index or other testing that is state of the art at the time the test is to be performed) at least once every 10 years to provide an indication of the condition of the conductor insulation and the ability of the cable to perform its intended function. As stated in NUREG-1801, this is an adequate period to preclude failures of the conductor insulation since experience has shown that aging degradation is a slow process.
Periodic inspections (periodicity will be based on inspection results, but shall not exceed 2 years) of underground manholes, will be done to initiate action to remove any water noted which will minimize the catalyst of prolonged moisture conditions that promotes the growth of water trees. The first tests and inspections for license renewal will be completed before the period of extended operation.
This element is consistent with NUREG-1 801, Section XL.E3, "Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," and guidance provided in draft ISG-18.
Monitoring and Trending Trending actions are not included as part of this program because the ability to trend inspection or test results is limited and dependant on the specific type of test selected.
This element is consistent with NUREG-1 801, Section XL.E1, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," Section Xl.E2, "Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits," Section Xl.E3, "Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," and guidance provided in ISG-2 and draft ISGs-5, 15, 17 and 18.
Acceptance Criteria
- Accessible Non-EQ Electrical Cables and Connections The accessible insulated cables and connections are to be free from unacceptable levels of surface anomalies, which indicate 8
Enclosure 2 Revised LRA Section B2.1.2, Non-EQ Electrical Commodities Condition Monitoring Program conductor or connection insulation degradation. Unacceptable degradation is defined as a noted condition or situation that, if left unmanaged, could lead to a loss of intended function.
The acceptance criteria for each connection test are defined by the specific type of test performed and the specific type of cable connections tested.
This element is consistent with NUREG-1801, Section XL.E1, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements."
- Non-EQ Electrical Cables Used in Sensitive Instrumentation Circuits The acceptance criteria for each test is defined by the specific type of test performed and the specific circuit tested in the sensitive instrumentation circuits.
This element is consistent with NUREG-1801, Section XL.E2, "Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits" and guidance provided in draft ISG-15.
- Inaccessible Non-EQ Medium-Voltage Cables The acceptance criteria for each test is defined for the specific type of test performed and the specific cable tested. Periodic inspections of underground manholes, for the accumulation of water around medium-voltage cables, shall minimize time periods exposed to water.
This element is consistent with NUREG-1801, Section XL.E3, "Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements" and guidance provided in draft ISG-18.
Corrective Actions This element is consistent with the corresponding NUREG-1 801 aging management program elements. See Section B13.2 for further discussion.
The following additional information is also provided for the specific NUREG 1801 program shown:
- Accessible Non-EQ Electrical Cables and Connections 9
Enclosure 2 Revised LRA Section B2.1.2, Non-EQ Electrical Commodities Condition Monitoring Program All unacceptable visual indications of cable and connection jacket surface anomalies are subject to an engineering evaluation. Such an evaluation is to consider the age and operating environment of the component, as well as the severity of the anomaly and whether such an anomaly has previously been correlated to degradation of conductor insulation or connections. Corrective actions may include, but are not limited to, testing, shielding or otherwise changing the environment, or relocation or replacement of the affected cable or connection. When an unacceptable condition or situation is identified, a determination is made as to whether the same condition or situation is applicable to other accessible or inaccessible cables or connections.
Pursuant to 10 CFR Part 50, Appendix B, an engineering evaluation is performed when the test acceptance criteria are not met in order to ensure that the intended functions of the cable connections can be maintained consistent with the current licensing basis. Such an evaluation is to consider the significance of the test results, the operability of the component, the reportability of the event, the extent of the concern, the potential root causes for not meeting the test acceptance criteria, the corrective action warranted, and the likelihood of recurrence. When an unacceptable condition or situation is identified, a determination is made on whether the same condition or situation is applicable to other in-scope cable connections not tested.
- Non-EQ Electrical Cables Used in Sensitive Instrument Circuits Corrective actions such as circuit trouble-shooting are implemented in accordance with 10 CFR Part 50, Appendix B, when test results do not meet the acceptance criteria. An engineering evaluation is performed when the test acceptance criteria are not met in order to ensure that the intended functions of the electrical cable system can be maintained consistent with the current licensing basis. Such an evaluation is to consider the significance of the test results, the operability of the component, the reportability of the event, the extent of the concern, the potential root causes for not meeting the test acceptance criteria, the corrective actions required, and likelihood of recurrence.
- Inaccessible Non-EQ Medium-Voltage Cables An engineering evaluation is performed in accordance with 10 CFR Part 50, Appendix B, when the test acceptance criteria are not met in order to ensure that the intended functions of the electrical cables 10
Enclosure 2 Revised LRA Section B2.1.2, Non-EQ Electrical Commodities Condition Monitoring Program can be maintained consistent with the current licensing basis. Such an evaluation is to consider the significance of the test results, the operability of the component, the reportability of the event, the extent of the concern, the potential root causes for not meeting the test acceptance criteria, the corrective actions required, and the likelihood of recurrence. When an unacceptable condition or situation is identified, a determination is made as to whether the same condition or situation is applicable to other inaccessible, in-scope, medium-voltage cables.
Non-Segregated Phase and Bus Connections Pursuant to 10 CFR Part 50, Appendix B, further investigation and evaluation are performed when an acceptance criterion is not met.
Corrective actions may include but are not limited to increased inspection frequency, replacement, or rework of the affected bus duct insulation components. If an unacceptable condition or situation is identified, a determination is made as to whether the same condition or situation is applicable to other accessible or inaccessible bus ducts.
Confirmation Process, Administrative Controls These elements are consistent with the corresponding NUREG-1 801 aging management program elements. See Section B1.2 for further discussion.
Operating Experience Palisades has a comprehensive Operating Experience Program (OEP) that monitors industry issues/events and assesses these for applicability to its own operations. In addition, the Palisades Corrective Action Program (CAP) is used to track, trend and evaluate plant issues/events. Those issues and events, whether external or plant specific, that are potentially significant to the Non-EQ Electrical Commodities Condition Monitoring Program at Palisades are evaluated. The Non-EQ Electrical Commodities Condition Monitoring Program is augmented, as appropriate, if these evaluations show that program changes will enhance program effectiveness.
Using the OEP and CAP to focus on industry and plant operating experience ensures that Non-EQ Electrical Commodities Condition Monitoring Program issues are addressed in a timely manner and that age related deterioration of commodities within the scope of the Non-EQ 11
Enclosure 2 Revised LRA Section B2.1.2, Non-EQ Electrical Commodities Condition Monitoring Program Electrical Commodities Condition Monitoring Program will be effectively managed throughout the license renewal period.
Industry experience, as documented in SAND96-0344 "Aging Management Guideline for Commercial Nuclear Plants - Electrical Cables and Terminations," has shown three main causes of cable and connection failures well before a nominal 40 or 60-year service life:
Cables routed/installed in abnormal configurations, outside the prescribed or normal design guidelines and installation design criteria, may fail due to being exposed to temperatures well above the expected normal ambient temperature. PVC insulated cable insulation failures are the most common cable insulation failures to occur due to high temperature and/or radiation environments.
Sensitive instrumentation cable insulations (nuclear instrumentation
& radiation monitoring) have less tolerance for "loss of material properties" that adversely affect the circuit signals.
- Medium voltage power cable failures occur because of water-treeing (moisture & voltage stress).
Site-specific experience has shown that existing routine switchyard inspections detect loose connections in the switchyard. Existing periodic and routine switchyard inspections preclude failures of connections in the switchyard.
Abnormal plant configurations at Palisades were found to produce localized adverse environments in some specific cases. A corrective action document identified signs of cable jacket damage from improper design/installation that led to a localized adverse environment for the cables. In addition, LER 84-10 resulted from improper design and installation outside expected normal cable configurations. The Corrective Action Program corrected both plant configurations to eliminate the identified localized adverse temperature environments.
A medium-voltage cable failure has occurred at Palisades from the possible effects of water-treeing. LER 96-002 did demonstrate that this commodity group warrants periodic testing to preclude or minimize future failures. Palisades has also experienced that the underground manholes for the medium-voltage cables in-scope of License Renewal have experienced moisture for periods greater than a few days at a time.
One cable commodity-related assessment was conducted to address over-loaded cable trays. This analysis calculated power cable ohmic 12
Enclosure 2 Revised LRA Section B2.1.2, Non-EQ Electrical Commodities Condition Monitoring Program heating temperatures in those overloaded tray sections and compared it against the respective cable temperature rating to ensure that proper operating conditions exist and are maintained. The results of this analysis were considered when reviewing the plant electrical cables and connections, and were addressed when assessing and identifying those cables requiring aging management during the extended period of operation.
Since the Non-EQ Electrical Commodities Condition Monitoring Program is a new program, no NRC inspection reports, audits, self assessments, or program-specific corrective actions are available.
This element is consistent with NUREG-1 801, Section XL.E1, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," Section XL.E2, "Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits," and Section XL.E3, "Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements" with the additional guidance provided in ISG-2 and draft ISGs-5, 15, 17 and 18.
Conclusion The Non-EQ Electrical Commodities Condition Monitoring Program is a new program that uses as its bases, various industry and NRC standards. A number of existing activities are being consolidated into this new program. This program is consistent with NUREG-1801, Section XL.E1, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," Section XL.E2, "Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits," and Section XL.E3, "Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements" with the additional guidance provided in ISG-2 and draft ISGs-5, 15, 17 and 18.
The implementation of the Non-EQ Electrical Commodities Condition Monitoring Program provides reasonable assurance that aging effects will be managed such that the electrical commodities within the scope of this program will continue to perform their intended functions consistent with the current licensing bases for the period of extended operation.
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