ML052020434
| ML052020434 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/21/2005 |
| From: | Hartz L Dominion Nuclear Connecticut |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 05-454 | |
| Download: ML052020434 (12) | |
Text
Dominion Nuclear Connecticut, Inc.
~ l i l l ~ ~ o t i c Power Srarion
\\\\'.i[~,t tord, (11. 00385 l:"p' Iwt-!, Ko.1d July 21, 2005 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 k
Y borninion Serial No.:
05-454 LWDWL RO Docket Nos.:
50-336 License Nos.: DPR-65 50-423 NPF-49 DOMINION NUCLEAR CONNECTICUT, INC. (DNC)
MILLSTONE POWER STATION UNITS 2 AND 3 ADDITIONAL INFORMATION IN SUPPORT OF LICENSE RENEWAL APPLICATIONS In an e-mail sent to DNC on July 15, 2005, and in a subsequent telephone conference call the same day, the Nuclear Regulatory Commission staff asked for additional information regarding the requested exception to NUREG-I 801,Section XI.M26, "Fire Protection." The exception pertains to the gaseous fire suppression systems (Halon and Carbon Dioxide). Attachment 1 to this letter provides the response to this request.
Should you have any questions regarding this letter, please contact Mr. William D.
Corbin, Director, Nuclear Engineering, Dominion Resources Services, Inc., 5000 Dominion Blvd., Glen Allen, VA, 23060.
Very truly yours, L.N. Hartz W
Vice President - Nuclear Engineering : Responses to Request for Additional Information Regarding Gaseous Fire Suppression Systems Commitments made in this letter: None
Serial No.05-454 Docket Nos.: 50-3361423 Additional Information in Support of License Renewal Applications Page 2 of 4 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 11 555 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 11 555 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 11 555 Rockville Pike Mail Stop 1 IF1 Rockville, MD 20852-2738 Mr. S. M. Schneider NRC Senior Resident Inspector Millstone Power Station 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 061 09 Ms. Catherine Man<
Governors Eastern Office P.O. Box 1007 171 Salem Turnpike Norwich, CT 06360-1 007 Mr. Joseph Roy MMWEC P.O. Box426 Ludlow, MA 01 056-0426 Honorable Elizabeth Ritter CT House of Representatives 24 Old Mill Road Quaker Hill, CT 06375 Honorable Wayne L. Fraser First Selectman P.O. Box 519 Niantic, CT 06357-051 9
Serial No.05-454 Docket Nos.: 50-3361423 Additional Information in Support of License Renewal Applications Page 3 of 4 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 061 06-1 774 Mr. John Markowicz Co-Chairman - NEAC 9 Susan Terrace Waterford, CT 06385 Mr. Evan Woolacott Co-Chairman - NEAC 128 Terrys Plain Road Simsbury, CT 06070 Honorable M. Jodi Rell Govern or 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 Bui Id i ng Room 21 02 Hartford, CT 06106
Serial No.05-454 Docket Nos.: 50-336/423 Additional Information in Support of License Renewal Applications Page 4 of 4 Honorable Kevin DelGobbo CT House of Representatives 83 Meadow Street Naugautuck, CT 06770 Honorable Thomas Herlihy CT Senate 12 Riverwalk Simsbury, CT 06089 Honorable Cathy Cook CT Senate, 18'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 06103 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 Hal; 181 State Street New London, CT 06320
SN: 05-454 Docket Nos.: 50-336/423
Subject:
Additional Information in Support of License Renewal Applications COMMONWEALTH OF VIRGINIA
)
)
COUNTY OF HENRICO 1
The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Leslie N. Hartz, who is the Vice President - Nuclear Engineering, of Dominion Nuclear Connecticut, Inc. She has affirmed before me that she is duly authorized to execute and file the forgoing document in behalf of that Company, and that the statements in the document are true and correct to the best of her knowledge, information, and belief.
A Acknowledged before me this J / ?T day of
,2005.
(/
My Commission Expires:
V Notar$ Public (SEAL)
Serial No.05-454 Docket Nos.: 50-3361423 Additional Information in Support of License Renewal Applications Response to Request for Additional Information Regarding Gaseous Fire Suppression Systems Millstone Power Station Units 2 and 3 Dominion Nuclear Connecticut, Inc.
Serial No.05-454 Docket Nos.: 50-336/423 Additional Information in Support of License Renewal Applications / Page 1 of 6 Request for Additional Information - Aging Management for Fire Protection Gaseous Suppression Systems:
The following are the contents of an e-mail received from the staff on July 15, 2005:
The following is brief summary of the staffs issue with the Millstone exception for the C02 and Halon Fire Suppression Systems AMP.
Operating experience indicates that trend of degradation, such as leaks, general corrosion, and biofouling may occur in the system due to external and internal exposure of piping and fittings and other components. Therefore, such components may require corrective actions.
The purpose of the AMP is to manage the effects of aging prior to the loss of the intended function. NUREG-I 801, Generic Aging Lessons Learned (GALL) Report provide staff approved AMPS to manage or monitor the aging of SSCs that are subject to an AMR.
The staff determined that the external and internal environments have aging effects associated with metallic components. On this basis, the staff finds that the aging management guidance for the C02 and Halon fire suppression systems included in GALL AMP XI.M26, Fire Protection, is applicable and the exception is therefore not acceptable.
The staff has approved relaxations (example from biannually to 18 months) to the GALL requirements with respect to the inspection interval to test the CO2IHalon fire suppression systems at several other plants. The staff will consider such relaxations for Millstone, after evaluating Millstone specific details.
Dominion Response:
The aging management reviews for the Halon and C02 gaseous fire suppression systems concluded that there were no aging effects requiring management for the components exposed to a gas or air environment, which comprise the internal and external environments for the Halon and C02 system components located indoors.
Therefore, an exception to the NUREG-1801,Section XI.M26 Fire Protection AMP was documented in the Millstone LRA Appendix B, Section B2.1.10, that the NUREG-1801 aging management activities associated with the gaseous suppression systems were not required for Millstone. Dominion reviews of plant and industry operating experience did not reveal any concerns for aging-related degradation of these components. In addition, as noted in NUREG-1801,Section XI.M26, the operating
Serial No.05-454 Docket Nos.: 50-3361423 Additional Information in Support of License Renewal Applications I Page 2 of 6 experience review performed during preparation of NUREG-I 801 also did not identify corrosion concerns with these components.
However, DNC understands that the staff does not consider the AMP exception to be acceptable. Therefore, DNC is supplementing its License Renewal Applications (LRAs) for Millstone Units 2 and 3 to remove the exception related to aging management of the Halon and C02 systems. As a result, loss of material for the carbon steel piping, valves, and odorizers will be managed through the Fire Protection Aging Management Program (AMP). There are no aging effects identified for carbon steel in a gas environment, or for the stainless steel discharge nozzles in an air environment, since these material and environment combinations do not result in applicable aging effects.
An additional exception related to frequency of performance of the periodic visual and function tests will be taken for the Halon and C02 systems, since the Millstone Fire Protection Program performs some of these tests on a 12 or 18-month frequency and the NUREG-I801 Fire Protection Aging Management Program (AMP) identifies a six month frequency.
The Unit 2 and Unit 3 LRAs, Appendix B, Section B2.1.10, page B-37, Program Descriptions are being supplemented to remove the third paragraph as it is no longer valid.
The Unit 2 and Unit 3 LRAs, Appendix B, Section B2.1.10, page B-37, are being supplemented to delete the current Exception 1 and replace it with a new Exception 1 which reads as follows:
Exception 1 : XI.M26 - Aging Management of the Halon and Carbon Dioxide Systems NUREG-I 801 recommends that periodic visual inspection and function tests of the Halon and C02 fire suppression systems be performed at least once every six months to detect degradation in the system. Per the Millstone Unit 3 Current Licensing Basis (CLB), the Technical Requirements Manual (TRM) requires functional tests of the Unit 3 Halon and CO2 systems to be performed at a 12-month and 18-month frequency, respectively. In addition, (not required by the TRM) comprehensive system walkdown inspections are performed by the system engineer on an annual basis. Plant operating experience has demonstrated that this frequency is adequate to maintain the intended function of these systems.
Program Elements Affected:
0 Parameters Monitoredllnspected - The functional tests of the Unit 3 Halon and C02 systems are performed at a 12-month and 18-month frequency respectively, and comprehensive system engineer walkdown inspections are performed on an
Serial No.05-454 Docket Nos.: 50-336/423 Additional Information in Support of License Renewal Applications / Page 3 of 6 annual basis, to demonstrate that the systems are capable of performing their intended function.
0 Detection of Aging Effects - The functional tests of the Unit 3 Halon and C02 systems are performed at a 12-month and 18-month frequency respectively, and comprehensive system engineer wal kdown inspections are performed on an annual basis, to demonstrate that the systems are capable of performing their intended function.
Unit 3 utilizes C02 fire suppression in twelve areas of the plant. Nine of these areas contain equipment that is safety related or important to safety and are monitored and tested in accordance with the Unit 3 Technical Requirements Manual (TRM). According to the plant's CLB, the remaining three areas (i.e., the Normal Switchgear Area, the Auxiliary Boiler Enclosure Fuel Oil Pump Pit, and the Alternator/Exciter Bearing and Casing Enclosure) do not require functional tests. They do not protect any safety related equipment or equipment that is important to safety. Therefore, an exception to NUREG-1801,Section XI.M26, is being taken and is provided as Exception 2 below.
Although functional testing of the C02 systems in these three areas is not required, aging management of these three C02 systems is still being accomplished by the Fire Protection Program AMP, through the use of comprehensive system engineer walkdowns, on an annual basis. These walkdowns visually inspect for degradation of the system and any noticeable degradation is reported using the Corrective Action Program.
The Millstone Unit 2 and Unit 3 LRAs, Appendix B, Section B2.1.10, page B-38, is being supplemented to add new Exception 2 as follows:
Exception 2: XI.M26 - Aging Management of the Halon and Carbon Dioxide Systems NUREG-I801 recommends that periodic visual inspection and function test of the Halon and C02 fire suppression systems be performed at least once every six months to detect degradation in the system. In lieu of a functional test of the Unit 3 Normal Switchgear Area, the Auxiliary Boiler Enclosure Fuel Oil Pump Pit, and the Alternator/Exciter Bearing and Casing Enclosure C02 systems, comprehensive system engineer walkdowns are conducted on an annual basis. These walkdowns visually verify that degradation of the system is not occurring. Any noticeable degradation is addressed using the Corrective Action Program.
Program Elements Affected:
0 Parameters Monitored/lnspected - Comprehensive system walkdowns are conducted by the system engineer, on an annual basis, to detect system degradation. These walkdowns visually inspect for corrosion and other signs of
Serial No.05-454 Docket Nos.: 50-336/423 Additional Information in Support of License Renewal Applications / Page 4 of 6 degradation. Any degradation is then addressed through the Corrective Action Program.
Detection of Aging Effects - Comprehensive system engineer walkdowns are conducted on an annual basis, to detect system degradation. These walkdowns visually inspect for signs of age-related degradation, such as corrosion. Any degradation is then addressed through the Corrective Action Program.
0 Monitoring and Trending - Comprehensive system engineer walkdowns are conducted on an annual basis, to detect system degradation. Any degradation is addressed through the Corrective Action Program.
The Millstone Unit 2 LRA Tables 3.3.2-31 and 3.3.2-32, and the Millstone Unit 3 Tables 3.3.2-36 and 3.3.2-37, are being supplemented for the affected Halon and C02 fire suppression systems as shown on the remaining pages of this response.
Serial No.05-454 Docket Nos.: 50-336/423 Additional Information in Support of License Renewal Applications Attachment /Page 5 of 6 Notes correspond to the notes in Millstone Unit 2 LRA Section 3.3 tables.
Serial No.05-454 Docket Nos.: 50-3361423 Additional Information in Support of License Renewal Applications Attachment /Page 6 of 6 Component Type IFunction(s)) Material I
Environment I
Management I
Programs
\\Volume 2 Item/
Item I Notes Pipe IPB ICarbon Steel I(E) Air
]Loss of Material
/Fire Protection Program IVII.I.1-b 13.3.1-05 IA,2 (I) Air Loss of Material Fire Protection Program Vll.H.2.3-a 3.3.1-05 A,2 (I) Gas None None G
Nozzles SP Stainless (E) Air None None G
Steel (I) Air None None G
Valves PB Carbon Steel (E) Air Loss of Material Fire Protection Program VII.I.1-b 3.3.1-05 A,2 (I) Air Loss of Material Fire Protection Program Vll.H.2.3-a 3.3.1-05 A,2 (I) Gas None None G
Notes correspond to the notes in Millstone Unit 3 LRA Section 3.3 tables.
1 Unit 3 LRA 1 I
I I
I I
I I
/Stainless l(E) Air I None I None IG I
(I) Air None None G
Steel PB Carbon Steel (E) Air Loss of Material Fire Protection Program VII.I.1-b 3.3.1-05 A,2 I
I I
I I
I (I) Air LOSS of Material
]Fire Protection Program IVll.H.2.3-a 13.3.1-05 IA,2 1
I I
I I
I I(1) Gas INone
]None IG I
I I
I I
I PB ICarbon Steel I(E) Air ILosS of Material jFire Protection Program
/VII.I.l-b 13.3.1-05 IA,2 1
(I) Air Loss of Material Fire Protection Program Vll.H.2.3-a 3.3.1-05 A,2 (I) Gas None None G
I to the notes in Millstone Unit 3 LRA Section 3.3 tables.