ML060270317

2006/01/26-Oyster Creek Response to NRC Request for Additional Information, Dated December 28, 2005, Related to Plant License Renewal Application

ML060270317
Person / Time
Site:	Oyster Creek
Issue date:	01/26/2006
From:	Cowan P AmerGen Energy Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
%dam200606, -RFPFR, 2130-06-20254, TAC MC7624
Download: ML060270317 (9)

Text

AmerGen SM AmerGen Energy Company, LLC 200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.C0TrT An Exelon Company 10 CFR 50 10 CFR 51 10 CFR 54 2130-06-20254 January 26, 2006 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Oyster Creek Generating Station Facility Operating License No. DPR-16 NRC Docket No. 50-219

Subject:

Response to NRC Request for Additional Information, dated December 28, 2005, Related to Oyster Creek Generating Station License Renewal Application (TAC No. MC7624)

Reference:

"Request for Additional Information for the Review of the Oyster Creek Nuclear Generating Station, License Renewal Application (TAC No. MC7624)," dated December 28, 2005 In the referenced letter, the NRC requested additional information related to Section 2.3 of the Oyster Creek Generating Station License Renewal Application (LRA). Enclosed are the responses to this request for additional information.

If you have any questions, please contact Fred Polaski, Manager License Renewal, at 610-765-5935.

I declare under penalty of perjury that the foregoing is true and correct.Respectfully, Executed on&WaAl" 9006 PamB.na Director -Licensing

& Regulatory Affairs AmerGen Energy Company, LLC

Enclosure:

Response to 12/28/05 Request for Additional Information cc: Regional Administrator, USNRC Region I, w/o Enclosure USNRC Project Manager, NRR -License Renewal, Safety, w/Enclosure USNRC Project Manager, NRR -License Renewal, Environmental, w/o Enclosure USNRC Project Manager, NRR -Project Manager, OCGS, w/o Enclosure USNRC Senior Resident Inspector, OCGS, w/o Enclosure Bureau of Nuclear Engineering, NJDEP, w/Enclosure File No. 05040' (IN4 Enclosure Response to 12/28/05 Request for Additional Information Oyster Creek Generating Station License Renewal Application (TAC No. MC7624)RAI 2.3.3.14-1 RAI 2.3.3.23-1 RAI 2.3.3.26-1 RAI 2.3.3.27-1 RAI 2.3.3.32-1 RAI 2.3.3.35-1 RAI 2.3.3.37-1 RAI 2.3.4.3-1 1 of 8 RAI 2.3.3.14-1 License renewal drawing LR-BR-2005, Sheet 4 shows strainers located at C-7, C-8, F-7 and F-8. These strainers are shown as being within the scope of license renewal and serve a pressure boundary intended function.

However, LRA Table 2.3.3.14 does not include the component type "strainer" as a component type subject to an aging management review (AMR).Clarify if these strainers are subject to an AMR, or justify their exclusion.

Response: The strainer symbols shown on license renewal drawing LR-BR-2005, Sheet 4 at drawing coordinates C-7, C-8, F-7, and F-8 are depicting the diaphragm seal that is integral to the pressure indicator assembly.

The diaphragm seal is not specifically called out in LRA Table 2.3.3.14 since it is considered part of the "active" pressure instrument.

Diaphragm seals isolate pressure instruments from the process media while allowing the instrument to sense the process pressure.

A diaphragm, together with a fill fluid, transmits pressure from the process medium to the pressure element assembly of the instrument.

There would be no need to filter the medium prior to the diaphragm seal.Because these diaphragm seals are part of the pressure indicator assembly, which is an "active" component, they are not subject to aging management review.RAI 2.3.3.23-1 License renewal Drawing LR-SN-1 3432.19-1 for the Nitrogen Supply System at Location A-3 shows that a 3/8" line penetrates the drywell at penetration X-45. Outside the drywell, the line is identified as fulfilling an intended function according to 10 CFR 54.4(a)(1) or 10 CFR 54.4(a)(3) by being highlighted in green. Inside the drywell, the nitrogen line is not identified as fulfilling an intended function.

The line apparently supports the Neutron Monitoring System (NMS). Since the NMS is in the scope of license renewal, it is not clear whether the Nitrogen Supply System functionally supports its operation and therefore should be within the scope of license renewal. Confirm whether the 3/8" nitrogen supply line to the NMS should be excluded from the scope of license renewal.Response: The 3/8" line penetrating the drywell at penetration X-45 as shown on license renewal Drawing LR-SN-13432.19-1, drawing coordinate A-3, is the "TIP purge instrumentation reference leg piping" as described in the system boundary discussion of LRA Section 2.3.3.23 for the Nitrogen Supply System.LRA Section 2.3.3.23 states, "The Nitrogen Supply System supports the primary containment boundary intended function.

This portion of the system includes the nitrogen supply to the TIP System indexers starting from the automatic containment isolation valve and continuing to the containment penetration.

Also included is the TIP purge instrumentation reference leg piping from the containment penetration up to and including the manual isolation valve." Inboard of the TIP purge and TIP purge instrumentation reference leg piping containment isolation valves is also discussed in the system boundary discussion of LRA Section 2.3.3.23.As stated in LRA Section 2.3.3.23, the nitrogen supply lines up to these valves are included in scope as they define the Nitrogen Supply System pressure boundary necessary to support the 2 of 8 intended function for Fire Protection.

The nitrogen piping inside the primary containment associated with the TIP system is not required to functionally support the intended functions of the Neutron Monitoring System (NMS).Furthermore, as stated in LRA Section 2.1.5.2, non-safety related systems containing air or gas are not included in the scope of license renewal for 10 CFR 54.4(a)(2) spatial interaction.

Therefore, AmerGen has concluded that the 3/8" nitrogen supply to the NMS is not in scope of license renewal.Additionally, the supports for the Nitrogen Supply System piping inside of the Primary Containment are included in scope to prevent the piping from falling and potentially impacting safety related SSCs. These supports are evaluated on a commodity level and are not included in the evaluation of the Nitrogen Supply System.RAI 2.3.3.26-1 On license renewal drawing LR-GU-3E-551-21-1000, the existing feedwater sample sink and the existing condensate sample sink are shown to be in the scope of license renewal.However, "sinks" are not listed as a component subject to an AMR. Indicate if these sinks are included within a component type that is subject to AMR. If not, justify their exclusion from an AMR.Response: The feedwater and condensate sample sinks are correctly shown on license renewal Drawing LR-GU-3E-551-21-1000 as in scope for spatial interaction (10 CFR 54.4(a)(2)).

LRA Table 2.3.3.26 for Process Sampling System components subject to aging management review and LRA Table 3.3.2.1.26 for Process Sampling System aging management evaluation should have included a component type of "Sinks", or equivalently named component, with an intended function of "Leakage Boundary." Attachment I to this Enclosure identifies the addition of "Sinks" to Tables 2.3.3.26 and 3.3.2.1.26.

For the purpose of aging management review, the sample sinks were considered to be included in the GALL structure and/or component category of piping, piping components, and piping elements.LRA Table 3.3.1 summary of aging management evaluations for the Auxiliary Systems, Item Number 3.3.1-22, further evaluation paragraph 3.3.2.2.10.1 for loss of material due to pitting and crevice corrosion, and LRA Appendix A and B for the Water Chemistry (B.1.2) and One-Time Inspection (B.1.24) Aging Management Programs are not affected by this change.RAI 2.3.3.27-1 Section 2.4.17 of the LRA states that effluents through the ventilation stack are monitored to ensure that the limits of 10 CFR 20, which apply to releases during normal operation, and the limits of 10 CFR 100, which apply to accidental releases, are not exceeded.

LRA Section 2.3.3.27 states that the stack and turbine building Radioactive Gaseous Effluents Monitoring System (RAGEMS) monitors do not support a license renewal intended function and are not included in the scope of license renewal. The above two statements appear to be contradictory.

Clarify this apparent discrepancy, and indicate if the ventilation stack radiation monitors are within the scope of license renewal.3 of 8 Response: LRA Section 2.4.17 does suggest that the radiation monitors are required to monitor accident releases, but that was not the intent. While they may be used for post-accident monitoring, the stack radiation monitors are not credited for accident mitigation and are not safety related.These radiation monitors do not have an intended function for license renewal and are therefore not in scope.RAI 2.3.3.32-1 Note 5 on license renewal Drawing LR-GE-148F444 states that the inner tube of sample cooler (at Location H-8) is evaluated with the reactor water cleanup system. However, LRA Table 2.3.3.32 does not list sample cooler (tubes) as a component subject to an AMR.Confirm that sample cooler tubes are subject to AMR. If not, justify their exclusion from an AMR.Response: The sample cooler shown on license renewal Drawing LR-GE-148F444 at drawing coordinate H-8 is a dual heat transfer coil type (tube-in-tube) with Reactor Building Closed Cooling Water (RBCCW) in the annulus between the outer and inner tubes and Reactor Water Cleanup (RWCU) water in the inner tube. Note 5 on license renewal Drawing LR-GE-1 48F444 indicates that the inner tube of the sample cooler is evaluated with the RWCU system. The inner tube is not required for leakage boundary for license renewal as it is contained by the outer tube (which is scoped and screened with the RBCCW System). As shown on LR-GE-148F444, the inner tube is colored black indicating that the inner tube is not within the scope of license renewal (for spatial interaction) and is not subject to AMR.RAI 2.3.3.35-1 LRA Table 2.3.3.25 [sic] lists the component type "strainer" with the intended function"filter" and "strainer body" with the intended function "pressure boundary".

The radiation monitor duplex strainer is indicated in parenthesis for these intended functions.

The following components were found to be within the scope of license renewal according to the boundaries given in the Oyster Creek LRA Section 2.3.3.35.

They are indicated as being within scope on the license renewal drawings and serve an intended function, but are not listed in LRA Table 2.3.3.35: a. Strainers located at F-8 and G-7 on license renewal Drawing LR-BR-2005, sheet 2 provide a pressure boundary function.b. Strainer S-3-035 in the seal well at B-3/4 on license renewal Drawing LR-BR-2005, sheet 2 provides a filtration intended function.

The seal well is included as part of the miscellaneous yard structures.

However, there is no strainer included in this system.Confirm that these components are subject to an AMR. If not, justify their exclusion from an AMR.Response: a. The strainer symbols shown on license renewal drawing LR-BR-2005, Sheet 2 at drawing coordinates F-8 and G-7 are depicting the diaphragm seal that is integral to the pressure indicator assembly.

The diaphragm seal is not specifically called out in LRA Table 2.3.3.35 4 of 8 since it is considered part of the "active" pressure instrument.

Diaphragm seals isolate pressure instruments from the process media while allowing the instrument to sense the process pressure.

A diaphragm, together with a fill fluid, transmits pressure from the process medium to the pressure element assembly of the instrument.

There would be no need to filter the medium prior to the diaphragm seal. Because these diaphragm seals are part of the pressure indicator assembly, which is an "active" component, they are not subject to aging management review.b. Seal Well strainer S-3-035 on Drawing LR-BR-2005, Sheet 2 coordinate B-3/4 is incorrectly shown as in scope. This strainer was originally the supply/suction point of the Service Water radiation monitoring system. This strainer is no longer used and was abandoned in-place following a plant modification to the Service Water radiation monitoring system. This strainer does not perform an intended function for license renewal, is not in scope, and is not subject to aging management review.RAI 2.3.3.37-1 LRA Section 2.3.3.37, (page 2.3-204, 2 nd Paragraph) states that the piping that discharges into the reactor cavity, equipment storage cavity and spent fuel pool is included in the scoping boundary for the spent fuel pool cooling system. However, license renewal Drawing LR-GE-237E756 (at Location E-9) does not highlight the piping and associated diffusers that discharge into the reactor cavity as part of scoping boundary.

Clarify this apparent discrepancy.

Response: The piping and return diffusers located within the reactor cavity are correctly shown on license renewal Drawing LR-GE-237E756 as not in scope (black). The piping up to the reactor cavity is in scope, but the piping within the reactor cavity does not perform or support a system intended function.

The intent of the discussion in LRA Section 2.3.3.37 was not to exactly define the components or portion of piping that was in scope, but rather to describe this section in general terms. The exact boundary of in scope/not in scope piping is defined by the license renewal drawing.RAI 2.3.4.3-1 Section 2.3.4.3 of the LRA states that the feedwater system is in scope under 10 CFR 54.4(a)(3) because it is relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with fire protection per 10 CFR 50.48. Most of the reactor feedwater system shown on license renewal Drawing LR-BR-2003 is colored in red indicating that it is not required for 10 CFR 50.48. It is not clear which portions of the reactor feedwater system are in scope with 10 CFR 54.4(a)(3) for fire protection functions.

Please Identify those portions of the reactor feedwater system required for 10 CFR 54.4(a)(3) that have fire protection functions.

Resronse: LRA Section 2.3.4.3 for the Feedwater System does not specifically identify the portion of the system relied upon for fire protection.

The Feedwater Control System, which is included in the Feedwater System license renewal system, is the portion relied upon for fire protection.

The Feedwater Control System is not shown on license renewal drawing LR-BR-2003 for Feedwater.

The Feedwater Control System provides a digital control function for the Feedwater System and consists of two computers with dual links to the digital controllers.

The computers contain the 5 of 8 feedwater logic software.

The Appendix R Safe Shutdown Analysis requires demonstration of adequate plant process monitoring capability to achieve and maintain safe shutdown during and following postulated fire events. The Oyster Creek safe shutdown analysis credits reactor level monitoring instrumentation, including associated control and indication circuits that are part of the Feedwater Control System.6 of 8 Attachment I (Page 1 of 2)Addition to Table 2.3.3.26 Process Sampling System Components Subject to Aging Management Review: I Component Type l Intended Function I Sinks Leakage Boundary 7 of 8 I Attachment I -Page 2 of 2 Addition to Table 3.3.2.1.26 Process Sampling System Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG- Table 1 Notes Type Function Requiring Management 1801 Vol. 2 Item_ Management Programs Item Sinks Leakage Stainless Indoor Air None None VII.J-17 3.3.1-76 A Boundary Steel (External) (AP-17)Treated Loss of One-Time VII.E4-15 3.3.1-22 A Water <1 40F Material Inspection (A-58)(Internal) (B.1.243 Water VII.E4-15 3.3.1-22 B Chemistry (A-58)(B.1 .2)8 of 8