ML051100470
| ML051100470 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/19/2005 |
| From: | Grecheck E Dominion Nuclear Connecticut |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 05-147 | |
| Download: ML051100470 (19) | |
Text
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borninion A p r i l 19, 2005 United States Nuclear Regulatory Commission Serial No.:
05-147 Attention: Document Control Desk LR/DEA:
RO Washington, DC 20555-0001 Docket Nos. : 50-336/423 License Nos.: DPR-65 N PF-49 DOMINION NUCLEAR CONNECTICUT, INC.
MILLSTONE POWER STATION UNITS 2 AND 3 LICENSE RENEWAL - COMMENTS ON THE SER WITH OPEN ITEMS In a letter dated February 24, 2005, the NRC provided Dominion Nuclear Connecticut, Inc. (DNC) the Safety Evaluation Report (SER) with Open Items for license renewal of Millstone Power Station, Units 2 and 3.
In the transmittal letter with the SER with Open Items, the NRC staff described their plans to review the format of the SER to further improve the content, while incorporating comments and responses. To that end, DNC has reviewed the SER with Open Items for consistency with the License Renewal Applications (LRAs),
LRA supplements, and subsequent information provided in response to NRC requests for additional information. Dominions comments are limited to items that, if not resolved for consistency with the License Renewal Applications, are considered to have implications on the bases of the conclusions presented in the SER.
Should you have any questions regarding this
- letter, please contact Mr. William D. Corbin, Director, Nuclear Engineering, Dominion Resources Services, Inc., at (804) 273-2365.
Very truly yours, E. S. Grecheck Vice President - Nuclear Support Services
Attachment:
Comments on SER with Open Items Commitments made in this letter:
None
SN: 05-147 Docket Nos.: 50-336/423
Subject:
Comments on SER with Open Items COMMONWEALTH OF VIRGINIA 1
1 COUNTY OF HENRICO 1
The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Eugene S. Grecheck, who is the Vice President -
Nuclear Support Services, of Dominion Nuclear Connecticut, Inc. He has affirmed before me that he is duly authorized to execute and file the forgoing document in benalf of that Company, and that the statements in the document are true and correct to the best of his knowledge, information, and belief.
Acknowledged before me this 19 cM? day of &$&
, 2005.
My Commission Expires: (%ui.ud
&.h-1 Notary Public (SEAL)
cc:
U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406-1415 Mr. V. Nerses Senior Project Manager, Millstone Unit 2 U.S. Nuclear Regulatory Commission One White Flint North 1 1555 Rockville Pike Mail Stop 8C2 Rockville, MD 20852-2738 Mr. G. F. Wunder Project Manager, Millstone Unit 3 U.S. Nuclear Regulatory Commission One White Flint North 1 1555 Rockville Pike Mail Stop 8B1A Rockville, MD 20852-2738 Mr. J. H. Eads Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 11 F1 Rockville. MD 20852-2738 Mr. S. M. Schneider NRC Senior Resident Inspector Millstone Power Station Honorable Wayne L. Fraser First Selectman P.O. Box 519 Niantic, CT 06357-051 9 Serial No.05-147 Docket Nos.: 50-336/423 Comments on SER with Open Items Page 2 of 4 Mr. Stephen Page Central VT PSC 77 Grove Street Rutland, VT 06701 Honorable Andrea Stillman CT State Senate 5 Coolidge Court Waterford, CT 06385 Mr. Denny Galloway Supervising Radiation Control Physicist State of Connecticut - DEP Division of Radiation 79 Elm Street Hartford, CT 06106-5127 Honorable Christopher Dodd US Senate 100 Great Meadow Road Wethersfield, CT 06109 Ms. Catherine Maw Governors Eastern Office P.O. Box 1007 171 Salem Turnpike Norwich, CT 06360-1 007 Mr. William Meinert MMWEC P.O. Box 426 Ludlow, MA 01056-0426 Honorable Elizabeth Ritter CT House of Representatives 24 Old Mill Road Quaker Hill, CT 06375 Honorable Ed Jutila CT House of Representatives 23 Brainard Road Niantic, CT 06357
Honorable Robert Simmons US Congress 2 Courthouse Square Norwich, CT 06360 Mr. Thomas Wagner Town of Waterford Town Planner 15 Rope Ferry Road Waterford, CT 06385 Dr. Edward L. Wilds Director, Division of Radiation State of Connecticut - DEP 79 Elm Street Hartford, CT 06106-5127 Chairman Donald Downes DPUC 10 Franklin Square New Britain, CT 06051 Honorable Dennis L. Popp Chairman - Council of Governments Municipal Building 295 Meridian Street Groton, CT 06340 Chief Murray J. Pendleton Director of Emergency Management 41 Avery Lane Waterford, CT 06385-2806 Honorable Richard Blumenthal Attorney General 55 Elm Street Hartford, CT 06106-1774 Mr. John Markowicz Co-Chairman - NEAC 9 Susan Terrace Waterford, CT 06385 Serial No.05-147 Docket Nos.: 50-336/423 Comments on SER with Open Items Page 3 of 4 Mr. Evan Woolacott Co-Chairman - NEAC 128 Terrys Plain Road Simsbury, CT 06070 Honorable M. Jodi Rell Governor State Capitol HartFord, CT 06106 Mr. Mark Powers 4 Round Rock Road Niantic, CT 06357 Mr. Jay Levin 23 Worthington Road New London, CT 06320 Mr. Jim Butler Executive Director - Council of Governments 8 Connecticut Avenue Norwich, CT 06360 Mr. Bill Palomba Executive Director, DPUC 10 Franklin Square New Britain, CT 06051 Honorable Ernest Hewett CT House of Representatives 29 Colman Street New London, CT 06320 Honorable Terry Backer CT House of Representatives Legislative Office Building Room 21 02 Hartford, CT 061 06 Honorable Kevin DelGobbo CT House of Representatives 83 Meadow Street Naugautuck, CT 06770
Serial No.05-147 Docket Nos.: 50-336/423 Comments on SER with Open Items Page 4 of 4 Honorable Thomas Herlihy CT Senate 12 Riverwalk Simsbury, CT 06089 Honorable Cathy Cook CT Senate, 1 8'h District 43 Pequot Avenue Mystic, CT 06355 Mr. Edward Mann Office of Senator Dodd Putnam Park 100 Great Meadow Road Wethersfield, CT 06109 Chairperson Pam Katz CT Siting Council 10 Franklin Square New Britain, CT 06051 Mr. Ken Decko CBlA 350 Church Street Hartford, CT 061 03 Honorable Paul Eccard First Selectman Town of Waterford 15 Rope Ferry Road Waterford, CT 06385 Mr. Richard Brown City Manager New London City Hall 181 State Street New London, CT 06320 Honorable Jane G. Glover Mayor, New London New London City Hall 181 State Street New London, CT 06320
Serial No.: 05-147 Docket Nos.: 50-336/423 Comments on SER with Open Items Attachment, Page 1 of 14 Attachment Comments on SER with Open Items Millstone Power Station Units 2 & 3
Serial No.: 05-147 Docket Nos.: 50-336/423 Comments on SER with Open Items Attachment, Page 2 of 14 Comments on SER with Open Items for Millstone Power Station Units 2 and 3 License Renewal Applications Comment # 1 Table 3.0.3-1 Page 3-9 1 line of the table Add XI.M3 to the GALL AMP(s) applicable to the Inservice Inspection Program: Systems, Components And Supports (B2.1.18). This GALL AMP is addressed by the program and is discussed in LRA Section B2.1.18.
Comment # 2 Section 3.0.3.1. l Page 3-1 1 1 st paragraph:
Add with Boraflex panels following Since the applicant did not credit spent fuel racks in the last sentence. This change makes the SER consistent with LRA Section B2.1.2.
Comment # 3 Section 3.0.3.1.2 Page 3-1 1 1 st paragraph:
Replace tracking with loss of material in the second sentence.
As identified in Section B2.1.3, the Boric Acid Program manages the aging effect of loss of material.
Serial No.: 05-147 Docket Nos.: 50-336/423 Comments on SER with Open Items Attachment, Page 3 of 14 Comment # 4 Section 3.0.3.1.2 Page 3-1 4 1 st partial paragraph:
Replace For all other nickel-based with For other susceptible nickel-based in the third sentence and all with susceptible in the sixth sentence. The program description in the SER should be consistent with the program description in LRA Section B2.1.3.
Comment # 5 Section 3.0.3.1.2 Page 3-1 4 1 St partial paragraph:
Add the words surge nozzle and the pressurizer following However, Millstone Unit 3 does have nickel-based alloy welds attaching the safe ends to the pressurizer in the fifth sentence.
This provides and accurate description of the weld locations and is consistent with the response to RAI 3.1.3-3B.
Comment # 6 Section 3.0.3.1.4 Page 3-23 Detection of Aging Effects Add Typically, prior to The tubesheet in Millstone Unit 2 SGs is inspected in the third sentence. This revision makes the program element description consistent with the response to RAI B2.1.22-2 in letter dated January 15, 2005 (Serial No. 04-720A).
Serial No.: 05-147 Docket Nos.: 50-336/423 Comments on SER with Open Items Attachment, Page 4 of 14 Comment # 7 Section 3.0.3.1.4 Page 3-23 Detection of Aging Effects Add may following The applicant in the sixth sentence. This revision makes the program element description consistent with the program basis document.
Comment # 8 Section 3.0.3.1.4 Page 3-24 Operating Experience, 1 st paragraph:
Delete periodically in the last sentence. The response to RAI B2.1.22-2 in letter dated January 15, 2005 (Serial No. 04-720A) does not state that periodic inspection of these tubes will be performed.
Comment # 9 Section 3.0.3.2.1 Page 3-30 1 St paragraph:
Delete the paragraph that starts with the words Internal tank inspections....
This discussion on operating experience is not included in the program description in the LRA and is not appropriate to this program. Additionally, the tanks referenced are not underground tanks.
Comment # 10 Section 3.0.3.2.3 Pages 3-32 and 3-33 Summary of Technical Information, 2nd paragraph and Staff Evaluation, 2nd paragraph:
Serial No.: 05-147 Docket Nos.: 50-336/423 Comments on SER with Open Items Attachment, Page 5 of 14 Replace Revision 4, dated November 1996 with Revision 5, dated May 3, 2000.
Replace Revision 4 with Revision 5.
These changes are necessary to reference the correct guideline revision.
Comment ## 11 Sect ion 3.0.3.2.5 Page 3-40 1fuIl paragraph:
Replace using the guidance cited in with consistent with and articulated with considering the technical information and guidance contained in the first sentence. With this change the SER program description will be consistent with the LRA program description.
Comment # 12 Section 3.0.3.2.5 Page 3-43 51~ full paragraph:
Delete and will be removed in a revision to the FSAR supplement that will be forwarded in a future letter. In order to preserve the numbering of the commitments in Table A6.0-1, this commitment will be noted as complete but not removed. This is consistent with the response in the February 15, 2005 letter (Serial No. 05-047A).
Comment # 13 Section 3.0.3.2.6 Page 3-46 2nd paragraph:
Replace every 10 years with not to exceed a 10 year frequency in the last sentence. With this change the testing frequency will be consistent with Table A6.0-1, Item 7 for Unit 2 and Unit 3.
Serial No.: 05-147 Docket Nos.: 50-336/423 Comments on SER with Open Items Attachment, Page 6 of 14 Comment # 14 Sect ion 3.O.3.2.6 Page 3-47 FSAR Supplement:
Add used in instrumentation circuits at the end of the first sentence. This change corrects the title of the program being addressed in this section of the SER.
Comment # 15 Section 3.0.3.2.1 0 Page 3-62 Next to last paragraph:
Add This commitment is identified in Appendix A, Table A6.0-1 License Renewal commitments, Item 11. at the end of the paragraph. This commitment was not identified in the program section of this document.
Comment # 16 Section 3.0.3.2.12 Page 3-68 Exception Number 1 2d paragraph:
Replace use its participation in the electric power research institute materials reliability programs (EPRI MRPs) studies and activities on PWR RV internal components as the basis for determining which aging effects and mechanisms are applicable to the RV internal components and which methods of examination and frequency of examinations are needed for these components with follow the industry efforts on reactor vessel internals regarding such issues as thermal or neutron irradiation embrittlement (loss of fracture toughness), void swelling (change in dimensions), stress corrosion cracking (PWSCC and IASCC),
and loss of pre-load for baffle and former-assembly bolts and will implement the appropriate recommendations resulting from this guidance in the first sentence.
With this change the SER description of the commitment will be consistent with the LRA commitment.
Serial No.: 05-147 Docket Nos.: 50-336/423 Comments on SER with Open Items Attachment, Page 7 of 14 Comment # 17 Section 3.0.3.2.1 3 Page 3-74 Exception Number 1, 1 st paragraph:
Replace Unit 3 with Unit 2 and July 25, 2000 with November 10, 2003 in the second sentence. Replace This submittal was reviewed and approved by the with Unit 3 has received in the third sentences. With these changes the SER will accurately reflect the status of the RI-IS1 programs for both Unit 2 and Unit 3.
Comment # 18 Section 3.0.3.2.1 3 Page 3-74 Exception Number 1, 1 st paragraph:
Add and, for Unit 3 only, base metal locations at the end of the fourth sentence. With this change, the SER program description will be consistent with the LRA.
Comment # 19 Section 3.0.3.2.1 3 Page 3-80 1 full paragraph:
Delete Unit 3 from the first sentence.
Add of the LRAs following in Appendix A and for Unit 2 and Item 15 for Unit 3 following Item 14 in the second sentence. Millstone made the commitment to follow the industry nickel based alloy efforts on both Unit 2 and 3.
Serial No.: 05-147 Docket Nos.: 50-336/423 Comments on SER with Open Items Attachment, Page 8 of 14 Comment # 20 Section 3.0.3.2.1 3 Pages 3-82 and 3-83 Staff Evaluation, 2nd paragraph, 3rd paragraph, and 5h paragraph, Replace RAI B2.1.18-2 and RAI B2.1.18-1 with RAI B2.1.18-
Comment # 21 Section 3.0.3.2.1 3 Page 3-86 Summary of Technical Information, 1 st paragraph and Staff Evaluation, 1 St paragraph:
Replace be leaking through cracks with show evidence of leakage. The statement should accurately reflect the statement in the LRA.
Comment # 22 Section 3.0.3.2.1 8 Page 3-1 00 Exception 1, 2d paragraph:
Replace EPRI NP-104213 with EPRI TR-104213 in the next to the last sentence.
Comment # 23 Section 3.0.3.3.1 Page 3-1 03 Item (6), 1 st paragraph:
Delete during a seismic event or maintain its integrity for general operation in the next to the last sentence. This change will make the statement accurately reflect the statements made in the LRA.
Serial No.: 05-147 Docket Nos.: 50-336/423 Comments on SER with Open Items Attachment, Page 9 of 14 Comment # 24 Section 3.0.3.3.2 Pages 3-1 06 and 3-1 07 3rd full paragraph and 1 St full paragraph:
Replace monthly with quarterly in the sentence that starts with These conditions are observable.... Since the time of the LRA audits, evaluations of the results of the system engineer walkdowns determined that the frequency could be extended without loss of quality.
Changes to the system engineer guidelines and general condition monitoring AMP have resulted in the walkdown frequency being changed to quarterly.
Comment # 25 Section 3.0.3.3.3 Page 3-1 11 Section (6):
Delete the sentence that starts with the words Engineering evaluations determine. This statement is true only if, after entry into the corrective action program, an engineering evaluation is deemed necessary.
Comment # 26 Section 3.0.3.3.4 Page 3-1 16 1 St paragraph:
Replace structures and component supports with containment structures (personnel hatch and reactor cavity seal).
Delete components (doors and barrier penetration seals) and concrete structures in fire protection. This change will make the statement accurately reflect the components addressed in the LRA.
Penetration seals are already listed elsewhere in this same paragraph. Additionally, the Fire Protection AMP monitors the fire door seals.
Serial No.: 05-147 Docket Nos.: 50-336/423 Comments on SER with Open Items Attachment, Page 10 of 14 Comment # 27 Section 3.1 B.2.2.2 Page 3-1 79 3rd paragraph:
Delete the words, supplemented by the steam generator integrity program,.
As indicated in LRA Table 3.1.2-4, the steam generator structural integrity program is not an aging management program credited for managing loss of material for the steam generator shell.
Comment # 28 Sections 3.5A.2.1 and 35B.2.1 Pages 3-443 and 3-510
!jth paragraph and 8h paragraph:
Revise the sentence, However, the applicant stated that the localized concrete temperature in the vicinity of high energy piping containment penetrations is maintained below the threshold value by the containment penetration cooling system, which consists of a ventilation system in Unit 2 (the containment penetration cooling system described in LRA Section 2.3.3.18) and a water cooling system in Unit 3 (as part of the reactor plant component cooling system described in LRA Section 2.3.3.6). The statement should accurately reflect how insulation and the containment cooling systems work together to maintain the containment concrete temperature below the threshold value as indicated in Dominions response to RAI 2.4-3 provided by letter dated November 9, 2004 (Serial No.04-673).
Serial No.: 05-147 Docket Nos.: 50-336/423 Comments on SER with Open Items Attachment, Page 11 of 14 Comment # 29 Sections 3.5A.2.2.1 and 3.59.2.2.1 Pages 3-448 and 3-51 6 Last paragraph and 4th paragraph:
Delete the words, On the basis of interviews with the applicants technical staff, the staff determined that the environment at the time of construction was not aggressive and on the basis of subsequent testing it has remained within the limits identified in the GALL Report. Dominion did not convey information related to the below-grade environment at the time of construction for structures. Although changes at or near the site that could have affected the below-grade environment have not been identified, no groundwater chemistry evaluations were documented at the time of construction and such information was not provided to the NRC during audits with Millstone technical staff. However, groundwater testing is currently being performed and the results substantiate that the groundwater chemistry is within the limits identified in the GALL Report.
Comment # 30 Sections 3.5A.2.2.2 and 3.5B.2.2.2 Pages 3-455 and 3-525 2d paragraph and last paragraph:
Delete the words, In the LRA, the applicant stated that the below-grade environment is not aggressive because the environment at the time of construction had a measured pH greater than 5.5, chlorides less than 500 ppm, and sulfates less than 1,500 ppm and subsequent testing has shown the environment has remained within these limits.
Groundwater test results at the time of construction were not provided in the LRA. Additionally, although changes at or near the site that could have affected the below-grade environment have not been identified, no groundwater chemistry evaluations were documented at the time of construction and such information was not provided to the NRC during audits with Millstone technical staff. However, groundwater testing is currently being performed and results substantiate that the groundwater chemistry is within the limits identified in the GALL Report.
Serial No.: 05-147 Docket Nos.: 50-336/423 Comments on SER with Open Items Attachment, Page 12 of 14 Comment # 31 Section 3.5A.2.2.2 Page 3-458 3rd paragraph:
Remove,...and excavated concrete has been and will continue to be monitored... from the 3rd paragraph since Dominion has not monitored excavated concrete in the past. Table A6.0-1, License Renewal Commitments, Item 21, identifies Enhancement 5 to the Structures Monitoring Program, which will ensure that inspections of inaccessible areas of below-grade concrete surfaces are performed when the areas become accessible by excavation or during maintenance or for any other reason. This will ensure future excavated concrete will be monitored, as inaccessible areas are made accessible.
Comment # 32 Section 4.2.1.I Page 4-4 4th full paragraph:
Replace the words for both Unit 2 and Unit 3 with for Unit 2.
The discussion in paragraph is applicable to Unit 2 only.
Comment # 33 Section 4.2.1.2 Page 4-5 2nd paragraph:
Replace the FITNDT value of 70 OF with 7.0 OF. With this change the value will be consistent with Unit 2 LRA Table 4.2-2, page 4-
- 12.
Comment ## 34 Section 4.2.1.2 Page 4-5 3rd paragraph:
Serial No.: 05-147 Docket Nos.: 50-336/423 Comments on SER with Open Items Attachment, Page 13 of 14 Replace in 2005 with at least two years prior to the period of extended operation in the first sentence.
With this change the SER will be consistent with the supplemental response to RAI 4.2.1-3, Unit 2 in letter dated February 8, 2005 (Serial No.05-047) and with Unit 2 LRA Table A6.0-1, Commitment 37.
Comment # 35 Section 4.7B.3.2 Page 4-58 1 st and 2d paragraphs:
These paragraphs should be revised to reflect that the requested Unit 3 LBB information was provided to the NRC in a letter dated February 8, 2005 (Serial No.: 05-047).
Comment # 36 Unit 2 Appendix A and Unit 3 Appendix A Pages A-5 and A-1 8 Item 9:
Replace the first paragraph of the schedule for this item with Prior to The Sprinkler Heads Achieving 50 Years Of Service Life. With this change, the SER will be consistent with the letter dated July 7, 2004 (Serial No.04-320).
Comment # 37 Unit 2 Appendix A and Unit 3 Appendix A Pages A-8 and A-21 Items 14 and 15:
Add A2.1.22, Steam Generator Structural Integrity in the column LRA Appendix A. The Unit 2 and Unit 3 LRA Table A6.0-1 for this commitment indicated that two programs, A2.1.18 and A2.1.22, were affected by this commitment.
Serial No.: 05-147 Docket Nos.: 50-336/423 Comments on SER with Open Items Attachment, Page 14 of 14 Comment # 38 Unit 2 Appendix A and Unit 3 Appendix A Page A-1 0 and A-23 Item 22 and 23:
Add Appropriate at the beginning of the commitment statement.
With this change the SER will be consistent with the LRA.
Comment # 39 Unit 3 Appendix A Page A-27 Item 36:
Replace the commitment description in the Commitment column with:
Complete the SAMA evaluation of the ability to manually control the Turbine Driven Auxiliary Feedwater Pump. If this SAMA is cost beneficial (i.e., can be accomplished without a hardware modification), a Severe Accident Management Guideline (SAMG) addressing this mitigation strategy will be developed. With this change the SER will have the correct Unit 3 SAMA commitment instead of referencing the Unit 2 SAMA commitment in the Unit 3 table.