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Category:CORRESPONDENCE-LETTERS
MONTHYEARML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML20210G8351999-07-29029 July 1999 Final Response to FOIA Request for Documents.Records in App a Encl & Will Be Available in PDR ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20209B2081999-06-29029 June 1999 Discusses Closure of Response to RAI Re GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity. Rvid,Version 2 Issued as Result of Review of Responses.Info Should Be Reviewed & Comments Submitted by 990901 ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML18068A5831999-05-0303 May 1999 Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432 ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20217A8191999-04-29029 April 1999 Forwards Listed Matls Related to Palisades Plant June 1999 Initial License Exam ML20206E8271999-04-28028 April 1999 Forwards Palisades Plant Annual Radiological Environ Operating Rept for 1998. There Were No Reportable Events During This Period ML20207B4661999-04-23023 April 1999 Forwards Copy of Final Exercise Rept for Biennial Radiological Emergency Preparedness Exercise Conducted on 981201 for Palisades Npp.No Deficiencies Noted.Seven New Arcas Identified ML18066A4531999-04-0707 April 1999 Forwards ITS Pages 3.1.4-2 & 3.1.4-8,revising Completion Time for Action D.1,as Requested by NRC 990406 Telcon,Per TS Change Request Submitted 980126.Change Submitted Does Not Alter Conclusions of No Signficant Hazards Considerations ML18066A4481999-04-0202 April 1999 Responds to Violations Noted in Insp Rept 50-255/98-06. Corrective Actions:Nuclear Performance Assessment Dept Has Reviewed Observations & Agrees That Field Observations by Qualified Personnel Are Important Aspect of Program ML18066A4471999-03-30030 March 1999 Confirms Completion of Util Review of Design Engineering Contractor Cable Ampacity Evaluation.Evaluation Available at Plant for NRC Review ML18066A4411999-03-30030 March 1999 Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review ML18066A4441999-03-26026 March 1999 Submits Certification of Financial Assurance for Decommissioning of Palisades Nuclear Plant.Certified Rept of Status of Consumers Energy Co Decommissioning Funding & Trust Agreement Encl as Attachments 1 & 2 ML18066A4401999-03-25025 March 1999 Forwards Revised Best Estimate Fluence Evaluation Using Industry Data, Providing Justification for Using Industry Data to Determine Best Estimate Fluence.Review of Info & SE Requested ML18066A4191999-03-23023 March 1999 Forwards 1998 Annual Radioactive Effluent Release & Disposal Rept, for Palisades Plant,Providing Summary of Quantities of Radioactive Liquid & Gaseous Effluent Releases & Solid Radioactive Waste Processed During 1998 ML18066A4231999-03-22022 March 1999 Forwards Answers to 990311 Telcon Request for Addl Clarification & Revs Re ITS Section 3.4.Markups of Previously Submitted TS Pages & Revised Pages for Section 3.4 Also Encl ML20204F2091999-03-18018 March 1999 Requests That Listed TS Change Requests (Tscrs) Be Issued with Allowance That Tscrs Be Fully Implemented within Sixty Days of Issuance.Request Will Allow Time for Completion of Final Training & Procedure Changes Associated with Amend ML18066A4121999-03-18018 March 1999 Concludes That Mod to Provide Automatic Switchover of Control Room Heating,Ventilation & Air Conditioning (CRHVAC) Sys to Emergency Mode Is Not Needed to Meet Regulatory Requirements.Mod Commitment Cancelled ML18066A4141999-03-18018 March 1999 Forwards Rev 4 to COLR, Containing Limits for Fuel Cycle 14 & Future Cycles ML20204E5861999-03-16016 March 1999 Submits Current Limits of Property Insurance Maintained at Consumers Energy Co Operating Nuclear Power Plants ML18066A4131999-03-11011 March 1999 Responds to NRC 990210 Ltr Re Violations Noted in Insp Rept 50-255/98-22.Corrective Actions:Analytical Evaluation, EA-C-PAL-98-1067-01, P-50A Case to Cover Stud Evaluation, Was Submitted to NRC on 981220 ML18068A5241999-02-12012 February 1999 Resubmits Relief Request 12,with Addl Info That Includes Specific Locations Where Relief Request Would Be Applied,Per 10CFR50.55a(g)(5)(iii) ML18068A5211999-02-11011 February 1999 Informs NRC That Implementation of Formal Industry Position on Severe Accident Mgt at Palisades Plant Was Completed on 981217 ML20203F2541999-02-10010 February 1999 Informs That Beginning 990216,DE Hills Will Be Chief of Operations Branch Which Includes Operator Licensing Function 1999-09-30
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML18068A5831999-05-0303 May 1999 Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432 ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20217A8191999-04-29029 April 1999 Forwards Listed Matls Related to Palisades Plant June 1999 Initial License Exam ML20206E8271999-04-28028 April 1999 Forwards Palisades Plant Annual Radiological Environ Operating Rept for 1998. There Were No Reportable Events During This Period ML20207B4661999-04-23023 April 1999 Forwards Copy of Final Exercise Rept for Biennial Radiological Emergency Preparedness Exercise Conducted on 981201 for Palisades Npp.No Deficiencies Noted.Seven New Arcas Identified ML18066A4531999-04-0707 April 1999 Forwards ITS Pages 3.1.4-2 & 3.1.4-8,revising Completion Time for Action D.1,as Requested by NRC 990406 Telcon,Per TS Change Request Submitted 980126.Change Submitted Does Not Alter Conclusions of No Signficant Hazards Considerations ML18066A4481999-04-0202 April 1999 Responds to Violations Noted in Insp Rept 50-255/98-06. Corrective Actions:Nuclear Performance Assessment Dept Has Reviewed Observations & Agrees That Field Observations by Qualified Personnel Are Important Aspect of Program ML18066A4471999-03-30030 March 1999 Confirms Completion of Util Review of Design Engineering Contractor Cable Ampacity Evaluation.Evaluation Available at Plant for NRC Review ML18066A4411999-03-30030 March 1999 Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review ML18066A4441999-03-26026 March 1999 Submits Certification of Financial Assurance for Decommissioning of Palisades Nuclear Plant.Certified Rept of Status of Consumers Energy Co Decommissioning Funding & Trust Agreement Encl as Attachments 1 & 2 ML18066A4401999-03-25025 March 1999 Forwards Revised Best Estimate Fluence Evaluation Using Industry Data, Providing Justification for Using Industry Data to Determine Best Estimate Fluence.Review of Info & SE Requested ML18066A4191999-03-23023 March 1999 Forwards 1998 Annual Radioactive Effluent Release & Disposal Rept, for Palisades Plant,Providing Summary of Quantities of Radioactive Liquid & Gaseous Effluent Releases & Solid Radioactive Waste Processed During 1998 ML18066A4231999-03-22022 March 1999 Forwards Answers to 990311 Telcon Request for Addl Clarification & Revs Re ITS Section 3.4.Markups of Previously Submitted TS Pages & Revised Pages for Section 3.4 Also Encl ML20204F2091999-03-18018 March 1999 Requests That Listed TS Change Requests (Tscrs) Be Issued with Allowance That Tscrs Be Fully Implemented within Sixty Days of Issuance.Request Will Allow Time for Completion of Final Training & Procedure Changes Associated with Amend ML18066A4141999-03-18018 March 1999 Forwards Rev 4 to COLR, Containing Limits for Fuel Cycle 14 & Future Cycles ML18066A4121999-03-18018 March 1999 Concludes That Mod to Provide Automatic Switchover of Control Room Heating,Ventilation & Air Conditioning (CRHVAC) Sys to Emergency Mode Is Not Needed to Meet Regulatory Requirements.Mod Commitment Cancelled ML20204E5861999-03-16016 March 1999 Submits Current Limits of Property Insurance Maintained at Consumers Energy Co Operating Nuclear Power Plants ML18066A4131999-03-11011 March 1999 Responds to NRC 990210 Ltr Re Violations Noted in Insp Rept 50-255/98-22.Corrective Actions:Analytical Evaluation, EA-C-PAL-98-1067-01, P-50A Case to Cover Stud Evaluation, Was Submitted to NRC on 981220 ML18068A5241999-02-12012 February 1999 Resubmits Relief Request 12,with Addl Info That Includes Specific Locations Where Relief Request Would Be Applied,Per 10CFR50.55a(g)(5)(iii) ML18068A5211999-02-11011 February 1999 Informs NRC That Implementation of Formal Industry Position on Severe Accident Mgt at Palisades Plant Was Completed on 981217 ML18066A4051999-02-10010 February 1999 Requests Copy of Consumers Energy (Palisades) Formal Response to RAI Dtd 990512 (USI A-46) ML18066A3921999-01-29029 January 1999 Forwards Licensee Interpretation of TS Requirements for Performance of SRs as Applied to Instrumentation Channel Calibr.Ltr Established No New Commitments ML18066A3891999-01-28028 January 1999 Submits Response to Concern Expressed in Insp Rept 50-255/98-06 Re Whether Palisades ISI Program Was Being Conducted IAW Applicable Requirements 1999-09-30
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A CMS Energy Company November 26, 1997 U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555 DOCKET 50-255 -LICENSE DPR-20 PALISADES PLANT 111oma* t:. Bordlae Manager Licensing ANNUAL REPORT OF CHANGES IN ECCS MODELS PER 1 OCFR50.46 Palisades is required to submit an annual report of changes in Emergency Core Cooling System (ECCS) Models in accordance with 1 OCFR50.46(a)(3)(ii).
Attachment 1 of this letter transmits that report and contains both the Small Break Loss of Coolant Accident (SBLOCA) and Large Break Loss of Coolant Accident (LBLOCA) evaluation model information.
This report covers the period from May 1996 to May 1997. Attachment 2 to this letter is a summary of correspondence between Consumers Energy, Siemens Power Corporation (SPC) and the NRC since June 1995 regarding the Palisades LOCA evaluation models. Included in this summary are additional correspondence
- regarding errors and concerns with the SPC LBLOCA methodology which the NRC raised late in 1996. Attachment 2 is provided to serve as a baseline of the Palisades reports made over the previous two years and provide a clear foundation for future reports to NRC. Attachment 2 is not a required portion of the annual report of changes.
SUMMARY
OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.
Thomas C. Berdine *Manager, licensin*g-
CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector
-Palisades Attacnments
.-----r--97,12010134 971126 f"'*
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1 R _, . -* . -* -Palisades Nuclear Plant
- 27780 Blue Star Memorial Highway
- Fax: 616 764 2490 ATTACHMENT 1 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 ANNUAL REPORT OF CHANGES IN ECCS MODELS PER 1 OCFRS0.46 2 Pages ANNUAL REPORT OF CHANGES IN ECCS MODELS PER 10CFR50.46 ABB-CE SBLOCA ECCS EVALUATION
SUMMARY
Asea Brown Boveri-Combustion Engineering (ABB-CE) performed a reanalysis of the Small Break Loss of Coolant Accident (SBLOCA) design basis for Palisades using Palisades plant-specific input data in ABB-GE's NRG-approved 1977 ECCS Evaluation Model. The previous SBLOCA analysis, which was documented in the Palisades FSAR, was an analysis for another plant that had been determined to be applicable to the Palisades design by ABB-CE. The results of the reanalysis demonstrated conformance to the ECCS performance acceptance criteria of 1 OCFR50.46(b).
A significant change was noted in that the predicted peak clad temperature of 1992°F was 52°F higher than the previous analysis results. This predicted temperature increase was the result of using Palisades specific data and not the result of a change to or an error in the ABB-CE SBLOCA evaluation model, or an error in the application of the model to the Palisades Plant. Palisades reported this change in the calculated peak fuel cladding temperature in a notification to the NRC dated January 15, 1997. EXEM PWR LARGE BREAK LOCA MODEL FOR PALISADES The EXEM PWR Large Break Loss of Coolant Accident (LBLOCA) Evaluation Model is used to assess large break loss of coolant accidents in PWRs. The Evaluation Model consists of four primary computer codes: RELAP4 to compute the system and hot channel response; RFPAC to compute the containment pressures, reflood rates, and axial shape factors; TOODEE2 to calculate the hot rod heatup; and RODEX2 to determine the rod conditions at the start of the transient.
With the exception of the TOODEE2 code, there were no model or correlation changes made. The changes to the TOODEE2 code are described below. TOODEE2 The FCTF reflood correlation was modified such that a linear interpolation of reflood heat transfer coefficients is used between effective reflood rates of 1.0 to 1. 77 in/sec. This is an interim model update approved by the NRC for use until SPC receives approval for updates to the TOODEE2 code submitted to the NRC in December 1996. 1 Peak Cladding Temperature Impact Due to Changes The Palisades Cycle 13 LBLOCA analysis of record utilized the TOODEE2 interim model -----=:__
update. The Peak Cladding Temperature (PCT) predicted for Cycle 13 with the interim FCTF model was 1892°F. The PCT predicted (not submitted to NRC; used only to assess PCT change) for Cycle 13 with the 1991 FCTF model (model the NRC determined to be unacceptable) was 1862°F. Thus, an increase of 30°F is associated with the TOODEE2 model change. The Palisades Cycle 13 LBLOCA analysis was affected by the TOODEE2 interim model update, even though the PCT of 1862°F predicted without the interim model update occurred at a time when the effective reflood rate was greater than 1.77 in/sec. Use of the interim 'FCTF model results in lower heat transfer coefficients than the 1991 FCTF model when the effective reflood rate becomes less than 1. 77 in/sec. The effect is that elevations high in the core experience higher cladding temperatures with the interim model as the reflood rate reduces below 1. 77 in/sec. Depending on plant specific operating conditions and the particular axial shape being analyzed (particularly top skewed shapes), the PCT may occur on a node farther downstream from the peak powered node and at a later time in the transient than with the previous 1991 FCTF model. With the previous 1991 model, the PCT typically occurred on the peak powered node, which was also the ruptured node. With the interim model, and for top skewed axial shapes, the PCT occurs downstream of the peak powered node and at a time after the effective reflood rate has gone below 1. 77 . in/sec. Use of Dougall-Rohsenow Correlation The PCT temperature predicted during this reporting period was calculated using an interim update to the TOODEE2 code and, consequently, was not referenced back to the originally-approved 1986 EM model. Future use of the Dougall-Rohsenow correlation is
- addressed in the topical report (EXEM/PWR Large Break LOCA ECCS Model Updates, XN-NF-82-20(P), Revision 1, Supplement
- 6) submitted to the NRC by the following quoted statement from page 1-2 of the topical report: "In the event that the 1996 reflood model combined with other changes could significantly reduce the peak cladding temperature (PCT) compared with the 1986 model, the conservatism of the Dougall-Rohsenow correlation must be addressed.
To do this, SPC will limit the reduction of conservatism by applying a conservative multiplier to the 1996 FCTF reflood heat transfer coefficient for that reactor. The multiplier will be determined and reported on a plant-specific basis until a revision to the Dougall-Rohsenow correlation in the SPC model is approved." 2 ATTACHMENT 2 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255
SUMMARY
OF CORRESPONDENCE WITH NRC REGARDING PALISADES LOCA ECCS EVALUATION MODELS June 1995 to September 1997 3 Pages
of Correspondence with NRC Regarding Palisades LOCA ECCS Evaluation Models June 16, 1995 -CPCo Letter to NRC, "Notification of Significant Change to ECC Calculation".
Due to new fuel enrichment of reload batch 'P', a reanalysis of the Palisades LBLOCA was performed for cycle 12 and a change of >50°F in PCT was calculated.
The calculated peak clad temperature (PCT) changed from 2192°F to 2095°F. May 29, 1996 -SPC letter to NRC, "Annual Reporting of Changes and Errors in ECCS Evaluation Models". Summary of minor changes and errors in SPC LOCA evaluation models for the period of March 1995 to May 1996. October 11, 1996 -NRC letter to CPCo, "1 OCFR50.46 LBLOCA Evaluation Model For -Palisades Plant (TAC No M96355)." This letter requests assessment of the impact of SPC LBLOCA evaluation model errors and changes ensuring compliance with 1 OCFR50.46.
Also requests CPCo to attend a public meeting at NRC headquarters on 10/16/96.
October 24, 1996 -CPCo Letter to NRC, "1 OCFR50.46 LBLOCA Evaluation Model for Palisades Plant". Summary of initial conclusions and justification that current LBLOCA analyses are conservative with respect to the SPC LBLOCA model errors and LBLOCA analyses for Palisades plant. Presents a summary of conference calls and meetings held between SPC, CPCo and NRC in October of 1996. This letter was requested by NRC at a meeting in Washington on 10/16/96.
November 5, 1996 -NRC letter to CPCo (et al), "Meeting on the 1 OCFR50.46 LBLOCA Evaluation Model Error and Changes (TAC No M96355)." This--letter summarizes the referenced
_meeting held at the request of NRC staff in Washington on 10/16/96.
November 22, 1996 -CPCo Letter to NRC, "Clarification of October 24, 1996 Response to NRC Request for Assessment".
1 Q
of Correspondence with NRC Regarding Palisades LOCA ECCS Evaluation Models This letter clarifies a statement made during the October 16, 1996 presentation at NRG and subsequently submitted in the October 24, 1996 letter. December 13, 1996 -NRG letter to CPCo, "Palisades Plant -1 OCFR50.46 LBLOCA Evaluation Model (TAC M96355)".
In this letter, NRG requests additional information regarding Palisades LBLOCA methodology and current analysis which will permit the staff to determine if the application of the corrected 1991 model for Palisades is consistent with the database on which the SPC reflood heat transfer coefficient correlation is based. January 15, 1997 -CPCo Letter to NRG, "Notification Under 1 OCFR50.46 of Change in ECCS Calculation Results".
Report of recently performed Palisades plant specific SBLOCA model. This was the first Palisades plant specific SBLOCA ECCS evaluation.
PCT of 1992°F was calculated which was 52°F higher than the previous analysis (which had been performed for another plant but deemed applicable to Palisades).
January 20, 1997 -CPCo Letter to NRG, "Notification Under 1 OCFR50.46-of Change in ECCS Calculation Results".
This reported an error in the Palisades LBLOCA model discovered by SPC in May of 1995 which was not reported by SPC to Palisades until December 1996. The error resulted in an over prediction in PCT of 104°F. With the errors corrected, the PCT of cycle 12 was 1991°F versus 2095°F previously reported on June 16, 1995. April 9, 1997 -Consumers Letter to NRG, "Response to NRG Request for Additional Information Regarding 1 OCFR50.46 LBLOCA Evaluation Model" Consumers Energy responses to eight additional questions regarding our Cycle 13 LBLOCA evaluation model which were raised by NRG (NRC letter dated December 13, 1996) while reviewing SPC LBLOCA methodology.
April 30, 1997 -Consumers-Letter to NRG, "Notification Under 10CFR50.46 of Change in ECCS Calculation Results".
- This reported a reduction in analyzed PCT of greater than 50°F for the fuel cycle 13 Palisades LBLOCA analysis.
The LBLOCA analysis for fuel cycle 13 predicted a PCT of 1892°F which constituted a 99°F reduction from the cycle 12 predicted PCT of 1991°F. This reduction was not due to errors in analysis models but rather to 2
$ummary of Correspondence with NRC Regarding Palisades LOCA ECCS Evaluation Models changes in SPC LBLOCA methodology and input assumptions specific to Palisades cycle 13 operation.
June 19, 1997 -NRG letter to Consumers, "Information Regarding Open Technical Issues Related to SPC's 10CFR50.46 LBLOCA Evaluation Model." This letter is a NRG summary of open technical issues associated with recent audit of SPC and regulatory requirements pertaining to the computer codes used to perform LOCA analyses.
September 2, 1997 -SPC Letter to NRG, "96/97 Annual Reporting of Changes and Errors in ECCS Evaluation Models". A description of the minor changes and errors in the SPC LOCA evaluation models for the period May 1996 to May 1997. 3