ML043650006
| ML043650006 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 12/27/2004 |
| From: | Le N NRC/NRR/DRIP/RLEP |
| To: | Spina J Nine Mile Point |
| Le N. B., NRR/DRIP/RLEP, 415-1458 | |
| References | |
| TAC MC3272, TAC MC3273 | |
| Download: ML043650006 (8) | |
Text
December 27, 2004 Mr. James A. Spina Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093
SUBJECT:
REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. MC3272 AND MC3273)
Dear Mr. Spina:
By letter dated May 26, 2004, Constellation Energy Group Inc., submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54), to renew the operating licenses for the Nine Mile Point Nuclear Station (NMP), Units 1 and 2, for review by the U.S. Nuclear Regulatory Commission (NRC). The NRC staff is reviewing the information contained in the license renewal application (LRA) and has identified, in the enclosure, areas where additional information is needed to complete the review.
Based on discussions with Mr. Peter Mazzaferro of your staff, a mutually agreeable date for your response is within 30 days from the date of this letter. If you have any questions regarding this letter or if circumstances result in your need to revise the response date, please contact me at 301-415-1458 or by e-mail at nbl@nrc.gov.
Sincerely,
/RA/
N. B. (Tommy) Le, Senior Project Manager License Renewal Section A License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos.: 50-220 and 50-410
Enclosure:
As stated cc w/encl: See next page
ML043650006 DISTRIBUTION: See next page Document Name: E:\\Filenet\\ML043650006.wpd OFFICE RLEP:PM RLEP:SC-A NAME N. Le S. Lee DATE 12/23/04 12/27/04
DISTRIBUTION: Ltr. To J. Spina, Re: Nine Mile Nuclear Station, Units 1 and 2 Dated: December 27, 2004 Accession No.: ML043650006 HARD COPY RLEP RF N. Le (PM)
E-MAIL:
RidsNrrDrip RidsNrrDe G. Bagchi K. Manoly W. Bateman J. Calvo R. Jenkins P. Shemanski PY Chen RidsNrrDssa RidsNrrDipm D. Thatcher R. Pettis C. Li M. Itzkowitz (RidsOgcMailCenter)
T. Smith M. Lemoncelli M. Mayfield A. Murphy S. Smith (srs3)
S. Duraiswamy Y. L. (Renee) Li RLEP Staff C. Holden R. Laufer P. Tam B. Fuller, RI E. Knutson, RI J. Trapp, RI T. Mensah OPA
ATTACHMENT NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2 (NMP1 and NMP2)
LICENSE RENEWAL APPLICATION (LRA)
REQUEST FOR ADDITIONAL INFORMATION (RAI)
RELATED TO:
Section 3.3 - Aging Management of Auxiliary Systems Section 3.3 - Aging Management of Auxiliary Systems General RAIs RAI 3.3.2-1 In the LRA, the applicant credited an aging management program (AMP), System Walkdown Program, to manage the aging effects of cracking and loss of material for non safety-related (NSR) piping, fittings, and equipment for all 24 subsystems of NMP1 and NMP2 Auxiliary Systems. The applicant further stated that the System Walkdown Program will manage the aging effects for the above NSR components that are made from any material and exposed to any water environments (e.g., Demineralized Untreated Water, Treated Water or steam with various temperatures, Raw Water, etc.). However, the System Walkdown Program uses only visual inspections to identify the above aging effects. Please provide additional information to fully explain under what conditions, what sizes of cracks may occur, and what can be identified visually in those 24 subsystems. The staff does not consider leakage detection alone as an adequate AMP because the component has already degraded significantly when it leaks.
Please provide justification for NMPs conclusion that Ultra-sound Testing (UT) or Eddy Current Testing (ECT) methods are not necessary for detecting cracking aging effects.
RAI 3.3.2-2 For those 24 subsystems mentioned in RAI 3.3.2-1 above, the staff also finds that for the same component exposed to the same or similar environment with the same identified aging effects, one subsystem credits one AMP while the other uses two or three AMPs. For example, the NMP1 Hydrogen Water Chemistry System uses just the System Walkdown Program, while the NMP2 Process Sampling System uses Water Chemistry Control Program in addition to the System Walkdown Program, and the Reactor Water Cleanup Systems in both NMP1 and NMP2 credit three AMPs for each system. Please provide additional information to explain the above discrepancy.
RAI 3.3.2-3 For several auxiliary subsystems identified in the LRA, the applicant stated that various components of these subsystems are made from copper alloys (Zinc less than or equal to 15%)
and exposed to demineralized untreated water. For these components, the applicant has identified that its aging effects require no management program in order to maintain its pressure boundary integrity; and therefore, no AMPs are credited. Since demineralized water is not treated with corrosion inhibitors and thus is not chemically treated to remove or add oxygen, please provide additional information to justify NMPs conclusion that components of NMP1 and NMP2 auxiliary subsystems require no AMP to manage its aging effects.
ATTACHMENT In LRA Table 3.3.2.B-10 for NMP2 Diesel Generator Building Ventilation System, the applicant identified the loss of material aging effect for the Unit Cooler. The applicant also stated that components of the Unit Cooler are made from copper alloy (Zinc less than or equal to 15%),
and exposed to raw water. Since raw water is also an untreated water, and thus is not chemically treated to remove or add oxygen. Please provide information to compare and explain the discrepancy between the loss of material aging effect that had been identified for the Unit Cooler with the above case for the NMP1 and NMP2 auxiliary subsystems, with its components are also made from copper alloy (Zinc less than or equal to 15%), the same material found in the Unit Cooler, and exposed to demineralized untreated water; but with no identified aging effects that require an AMP.
System-specific RAIs for NMP1 and NMP2 RAI 3.3.2.A-3.1 In LRA Table 3.3.2.A-3 for NMP1 Compressed Air System, the applicant credited the Compressed Air Monitoring Program (CAMP) for managing the aging effects of cracking, hardening, shrinkage, and loss of strength for polymers in valves exposed to air environment.
However, the CAMP for NMP1 does not include the management of aging effects of polymer hardening, shrinkage, and loss of strength. Please provide information to justify the use of this aging management program (AMP) for managing the aging effects of polymers by providing the methods of detection, test intervals, acceptance criteria, monitoring, trending, and preventive action, or provide other acceptable AMP.
In LRA Table 3.3.2.A-1 for the NMP1 Circulating Water System, the applicant identified polymer cracking and loss of strength as aging effects for traveling screens and rakes exposed to raw water. The applicant also stated that the Open-Cycle Cooling Water System Program is used for managing the above identified aging effects. Please provide information to explain how the Open-Cycle Cooling Water System Program can manage the above identified aging effects.
RAI 3.3.2.A-4.1 In LRA Table 3.3.2.A-4 for NMP1 Containment System, the applicant credited the Preventive Maintenance Program (PMP) as an aging management program (AMP) for managing the aging effect of loss of material for valves made from carbon or low alloy steel (yield strength less than 100 ksi) and ductile/malleable cast iron, exposed to air environment. The ten-elements description of the PMP indicates that the PMP is a condition-monitoring program performed on a specific schedule with specific acceptance criteria established for each component inspection.
Please provide the following information:
(1)
For valves in NMP1 Containment System, provide information related to its inspection schedule and acceptance criteria for the inspections; and (2)
Components for NMP2 Reactor Building Closed Loop Cooling Water System are made from the same material (e.g., carbon or low alloy steel (yield strength less than 100 ksi) and ductile/malleable cast iron) and are exposed to a similar environment with similar identified aging effects. Please provide additional
ATTACHMENT information to explain and justify why the One-Time Inspection Program is used instead of the Preventive Maintenance Program.
RAI 3.3.2.B-6.1 In LRA Table 3.3.2.B-6 for NMP2 Containment Atmosphere Monitoring System, the applicant credited the System Walkdown Program for managing the aging effects of cracking and loss of material for bolting (made from martensitic, precipitation hardenable, and superfrritic stainless steels) exposed to air, moisture or wetting, with temperature equal to or greater than 140 degree F environments. Please provide information (1) to explain what sizes of crack may occur in the Containment Atmosphere Monitoring System that can be identified visually under the System Walkdown Program; and (2) to justify NMPs conclusion that it is not necessary to use the Ultra-sound Testing or Eddy current Testing methods to detect aging effects of cracking.
RAI 3.3.2.A-17.1 In LRA Table 3.3.2.B-24 for NMP2 Reactor Water Cleanup System, the applicant credited three aging management programs (AMPs), namely, BWR Reactor Water Cleanup System Program, System Walkdown Program, and Flow-Accelerated Corrosion Program, for managing the aging effects of cracking and loss of material for non safety-related (NSR) piping, fittings, and equipment exposed to five different treated water or steam environments.
In LRA Table 3.3.2.A-17 for the NMP1 Reactor Water Cleanup System, the applicant also credited the same three aging management programs (AMPs) to manage the aging effects for similar NSR piping, fittings, and equipment, but exposed only to treated water with temperature less than 140 degree F. Please provide information to explain the above discrepancy.
ATTACHMENT Nine Mile Point Nuclear Station, Unit Nos. 1 and 2 cc:
Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 126 Lycoming, NY 13093 Supervisor Town of Scriba Route 8, Box 382 Oswego, NY 13126 Mr. James R. Evans LIPA P.O. Box 129 Lycoming, NY 10393 Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Mr. Paul D. Eddy Electric Division NYS Department of Public Service Agency Building 3 Empire State Plaza Albany, NY 12223 C. Adrienne Rhodes Chairman and Executive Director State Consumer Protection Board 5 Empire State Plaza, Suite 2101 Albany, NY 12223-1556 Kathryn M. Sutton, Esquire Winston & Strawn 1400 L Street, NW Washington, DC 20005-3502 Mark J. Wetterhahn, Esquire Winston & Strawn 1400 L Street, NW Washington, DC 20005-3502 Mr. Michael J. Wallace President Nine Mile Point Nuclear Station, LLC c/o Constellation Energy Group, Inc.
750 East Pratt Street Baltimore, MD 21202 Mr. James M. Petro, Jr., Esquire Counsel Constellation Energy Group 750 East Pratt Street, 5th Floor Baltimore, MD 21202 Mr. Peter R. Smith, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Fred Emerson Nuclear Energy Institute 1776 I St., NW, Suite 400 Washington, DC 20006-3708 Mr. Mark Flaherty Manager - Fleet Licensing R.E. Ginna Nuclear Power Plant 1503 Lake Rd.
Ontario, NY 14519 Mr. M. Steven Leonard General Supervisor - Nuclear Regulatory Matters Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093
ATTACHMENT Nine Mile Point Nuclear Station, Unit Nos. 1 and 2 cc:
Mr. Peter Mazzaferro Site Project Manager - License Renewal Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093 Mr. Mike Heffley Senior Vice President and Chief Nuclear Officer Constellation Generation Group 1997 Annapolis Exchange Parkway Suite 500 Annapolis, MD 21401