ML050060167

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Summary of Telephone Conference Held on December 15, 2004, Between the U.S. Nuclear Regulatory Commission and Nuclear Management Company, LLC Concerning Draft Requests for Additional Information Pertaining to the Point Beach, Units 1 & 2...
ML050060167
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 12/16/2004
From: Morgan M
NRC/NRR/DRIP/RLEP
To:
Division of Regulatory Improvement Programs
Morgan M, NRR/NRC/DRIP/RLEP, 415-2232
References
Download: ML050060167 (10)


Text

December 16, 2004 LICENSEE: Nuclear Management Company, LLC FACILITY: Point Beach Nuclear Plant, Units 1 and 2

SUBJECT:

SUMMARY

OF TELEPHONE CONFERENCE HELD ON DECEMBER 15, 2004, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND NUCLEAR MANAGEMENT COMPANY, LLC, CONCERNING DRAFT REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO THE POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION The U.S. Nuclear Regulatory Commission staff (the staff) and representatives of Nuclear Management Company, LLC (NMC) held a telephone conference on December 15, 2004, to discuss and clarify the staffs draft requests for additional information (D-RAIs) concerning the Point Beach Nuclear Plant, Units 1 and 2, license renewal application. The conference call was useful in clarifying the intent of the staffs D-RAIs. provides a listing of the meeting participants. Enclosure 2 contains a listing of the D-RAIs discussed with the applicant, including a brief description on the status of the items.

The applicant had an opportunity to comment on this summary.

/RA/

Michael J. Morgan, Project Manager License Renewal Section A License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos. 50-266 and 50-301

Enclosures:

As stated cc w/encls: See next page

ML050060167 DOCUMENT NAME: E:\Filenet\ML050060167.wpd OFFICE PM:RLEP SC:RLEP NAME MMorgan SLee DATE 12/22/04 12/22/04 Point Beach Nuclear Plant, Units 1 and 2 cc:

Jonathan Rogoff, Esq. Mr. Jeffrey Kitsembel Vice President, Counsel & Secretary Electric Division Nuclear Management Company, LLC Public Service Commission of Wisconsin 700 First Street P.O. Box 7854 Hudson, WI 54016 Madison, WI 53707-7854 Mr. Frederick D. Kuester David Weaver President and Chief Executive Officer Nuclear Asset Manager We Generation Wisconsin Electric Power Company 231 West Michigan Street 231 West Michigan Street Milwaukee, WI 53201 Milwaukee, WI 53201 James Connolly John Paul Cowan Manager, Regulatory Affairs Executive Vice President & Chief Nuclear Point Beach Nuclear Plant Officer Nuclear Management Company, LLC Nuclear Management Company, LLC 6610 Nuclear Road 700 First Street Two Rivers, WI 54241 Hudson, WI 54016 Mr. Ken Duveneck Douglas E. Cooper Town Chairman Senior Vice President - Group Operations Town of Two Creeks Palisades Nuclear Plant 13017 State Highway 42 Nuclear Management Company, LLC Mishicot, WI 54228 27780 Blue Star Memorial Highway Covert, MI 49043 Chairman Public Service Commission Fred Emerson of Wisconsin Nuclear Energy Institute P.O. Box 7854 1776 I Street, NW., Suite 400 Madison, WI 53707-7854 Washington, DC 20006-3708 Regional Administrator, Region III Roger A. Newton U.S. Nuclear Regulatory Commission 3623 Nagawicka Shores Drive 801 Warrenville Road Hartland, WI 53029 Lisle, IL 60532-4351 James E. Knorr Resident Inspector's Office License Renewal Project U.S. Nuclear Regulatory Commission Nuclear Management Company, LLC 6612 Nuclear Road 6610 Nuclear Road Two Rivers, WI 54241 Point Beach Nuclear Plant Two Rivers, WI 54241

DISTRIBUTION: Ltr. to Licensee: Nuclear Management Company, LLC, Re: Pt. Beach Nuclear Plant, Units 1 and 2, Dated: Dece,ber 16, 2004 Adams accession no.: ML050060167 HARD COPY RLEP RF Project Manager E-MAIL:

RidsNrrDrip RidsNrrDe G. Bagchi K. Manoly W. Bateman J. Calvo R. Jenkins P. Shemanski J. Fair RidsNrrDssa RidsNrrDipm D. Thatcher R. Pettis G. Galletti C. Li M. Itzkowitz (RidsOgcMailCenter)

R. Weisman M. Mayfield A. Murphy S. Smith (srs3)

S. Duraiswamy Y. L. (Renee) Li RLEP Staff P. Lougheed, RIII J. Strasma, RIII A. Stone, RIII H. Chernoff W. Ruland C. Marco L. Raghavan T. Mensah OPA

LIST OF PARTICIPANTS FOR TELEPHONE CONFERENCE TO DISCUSS THE POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION DECEMBER 15, 2004 Participants Affiliations J.Knorr Nuclear Management Company, LLC J.Thorgersen Nuclear Management Company, LLC T.Mielke Nuclear Management Company, LLC M.Morgan Nuclear Regulatory Commission M.Murphy Nuclear Regulatory Commission V.Rodriguez Nuclear Regulatory Commission Enclosure 1

DRAFT REQUESTS FOR ADDITIONAL INFORMATION (D-RAI)

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION December 15, 2004 The U.S. Nuclear Regulatory Commission staff (the staff) and representatives of Nuclear Management Company, LLC (NMC) held a telephone conference call on December 15, 2004, to discuss and clarify the staffs draft requests for additional information (D-RAIs) concerning the Point Beach Nuclear Plant, Units 1 and 2, license renewal application (LRA). The following D-RAIs were discussed during the telephone conference call.

Aging Management Review Program D-RAI 3.1-1 Table 3.1.2-5 identifies that aging will be managed for the SG Anti-Vibration Bars (AVBs) by the Water Chemistry Program and the Steam Generator Integrity Program for cracking due to SCC. Table 3.1.2-5 also refers to NUREG 1801, Volume 2, line item (IV.D1.2-h) and table 1 line item (3.1.1-19) which refer to loss of material associated with FAC for this line item.

Provide an explanation for the discrepancy between the aging effect identified in the license renewal application and what is identified in GALL (including the further evaluation section of the LRA) and provide any corrections. Discuss how SG secondary side inspections will be used to assess degradation in the AVBs in light of the ten elements of an AMP.

Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as a formal RAI.

D-RAI 3.1-2 Table 3.1.2-5 identifies that aging management for a number of SG secondary side components which are identified as susceptible to loss of material will be provided by both the Water Chemistry Program and Steam Generator Integrity Program. Table 3.1.2-5 also associates NUREG 1801 Volume 2 line item (IV.D1.1-c) and table 1 line item (3.1.1-02) with these components which identifies that the Inservice Inspection Program along with Water Chemistry will be used to manage aging. The further evaluation (item 3.1.2.2.2.1) associated with (3.1.1-02) for these items indicates Inservice Inspection and Water Chemistry will manage aging for these components and that the Steam Generator Integrity Program will provide all inclusive guidance for the management of Steam Generator assets. The Steam Generator Integrity Program description does not indicate that it will be used to meet the intent of the Inservice Inspection program for certain components. Clarify if the SG Integrity Program is intended to subsume the Inservice Inspection activity and manage aging of these components, why Inservice Inspection is not addressed in table 3.1.2-5 for these components and how the Steam Generator Integrity Program will manage aging for these components with particular focus being paid to addressing detection, monitoring and trending, acceptance criteria and operating experience with past secondary side inspections associated with these components.

Also address how loss of material, pitting and crevice corrosion of the shell and its components will be identified by these secondary side inspections.

Enclosure 2

SG Blowdown Piping Nozzles and Secondary Shell Penetration SG Feedwater Nozzle SG Secondary Closures SG Steam Outlet Nozzle SG Tube Bundle Wrapper and Wrapper Support System SG Tubesheet SG Upper and Lower Shell, Elliptical Head and Transition Cone Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as a formal RAI.

D-RAI 3.1-3 Table 3.1.2-5 indicates that SG Components (in contact with primary water) fabricated from stainless steel, alloy 600 and alloy 690 are susceptible to loss of material and the aging will be managed by Water Chemistry alone. Since water chemistry is a mitigative strategy and inspection is used (one time inspection at a minimum) to verify its effectiveness, provide a list of the subject sub-components and provide an explanation why water chemistry alone is sufficient to manage aging in these sub-components based on specific operating experience or past inspection results of these sub-components demonstrating the effectiveness of water chemistry.

Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as a formal RAI.

D-RAI 3.1-4 Table 3.1.2-5 indicates that the SG Divider Plate which is fabricated from alloy 600 and alloy 690 is susceptible to stress corrosion cracking and the aging will be managed by Water Chemistry alone. Since water chemistry is a mitigative strategy and inspection is used (one time inspection at a minimum) to verify its effectiveness, provide an explanation why water chemistry alone is sufficient to manage aging in these components based on specific operating experience or past inspection results that demonstrate the effectiveness of water chemistry.

Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as a formal RAI.

D-RAI 3.1-5 Clarify the SG program scope to identify those sub-components that rely on this program for aging management. Discuss the periodicity, acceptance criteria and bases for these items associated with the secondary side SG inspections for the various sub-components which rely on this program for aging management.

Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as a formal RAI.

Enclosure 2

D-RAI 3.1-6 The SG Integrity Program AMP related operating experience acknowledges the Outside Diameter Stress Corrosion Cracking (ODSCC) that was identified at Seabrook and indicates that the Point Beach Nuclear Power Plant SG tube material is thermally treated alloy 600 in Unit 1 and thermally treated Alloy 690 in Unit 2. Provide an operating experience discussion regarding inspections and results performed at Point Beach Units 1 & 2 to identify if similar tube eddy current characteristics exist as those identified at Seabrook and documented in Supplement 1 of NRC Information Notice 2002-21.

Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as a formal RAI.

Aging Management Program B2.1.7 - Buried Services Monitoring Program D-RAI B2.1.7-1 The program indicates that buried components within the program scope are coated per industry practice prior to installation. Although the AMP references industry practice what bases were used by the plant to confirm that all buried services within the program scope were required to be coated at the plant? If such documentation does not exist, how is reasonable assurance established that program components are all coated in light of the limited related operating experience.

Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as a formal RAI.

D-RAI B2.1.7-2 Related operating experience indicates that a post-indicating valve was repaired in the fire protection system which required excavation, exposing portions of the associated piping. The operating experience also indicates that the external portion of the piping showed no signs of corrosion after 14 years. Please discuss how the specific condition assessment of the piping corrosion (or lack of) was made in light of the program element that buried components are coated per industry practice; i.e., was the piping coated and was the coating removed to make this assessment?

Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as a formal RAI.

D-RAI B2.1.7-3 Since this is a new program it is understandable that there may be limited operating experience regarding inspections of opportunity which validate the limited buried component degradation.

However, the GALL indicates that inspection periodicity needs to be evaluated on a plant specific bases. With such a limited amount of experience, provide a justification why one time inspection of various in-scope components is not warranted prior to the period of extended Enclosure 2

operation to establish a sound basis for inspection frequency or to justify why inspections of opportunity will adequately manage aging in the future.

Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as a formal RAI.

Aging Management Program B2.1.22 - Tank Internal Inspection Program D-RAI B2.1.22-1 The Tank Internal Inspection Program indicates that the internal surfaces of carbon steel tanks will be periodically visually inspected and UT will be used to inspect inaccessible areas, such as the tank bottom or may be used from external surfaces. Provide a discussion regarding the periodicity and its bases for internal visual inspection and UT inspection of the tank bottoms.

Discuss the inspection scope for internal visual, UT of the tank bottom and when external UT is used, for instance; will internal visual inspection consist of 100% of the tank surface area, will the tank bottom UT consist of 100% of the bottom surface and if 100% inspection is not performed discuss the bases for a reduced inspection scope and the associated expansion criteria. Discuss how external UT examination scope will be comparable to internal visual examination scope when external UT inspection is used in lieu of internal inspection. If a sampling strategy is used in any of the above inspections provide a discussion of the sampling plan and its bases.

Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as a formal RAI.

D-RAI B2.1.22-2 Since monitoring and trending will only commence if significant wall loss is identified, how will it be possible to know the areas monitored if 100% inspection is not performed every time and how will accurate rates of degradation be determined which could be used to establish alternate inspection frequencies as outlined in the program description. The Acceptance Criteria indicates that Any degradation will be recorded and evaluated... this appears to be a form of monitoring and trending, discuss the apparent discrepancy.

Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as a formal RAI.

D-RAI B2.1.22-3 Define what is considered significant coating degradation which would lead to corrective action or significant material loss which would lead to commencement of trending. How will loss of material be measured/evaluated when visual inspection is performed to determine level of significance. Discuss how loss of material from general corrosion, pitting or underdeposit attack would be addressed relative to significant material loss and acceptance criteria.

Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as a formal RAI.

Enclosure 2

D-RAI B2.1.22-4 Based on the related operating experience, tank internal inspections of the North and South Condensate Tanks have occurred, did these inspections include UT of the tank bottoms. If the tanks bottoms were not evaluated when will the tank bottoms be evaluated and what was the justification for not evaluating the bottoms. Had these tanks ever been recoated in the life of the plant and when was the previous inspection of each of these tanks.

Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as a formal RAI.

Enclosure 2