ML060930255

2006/03/31-Oyster Creek, License Renewal AMP-AMR Audit Questions AMP-359, AMP-360 and AMP-362

ML060930255
Person / Time
Site:	Oyster Creek
Issue date:	03/31/2006
From:	Hufnagel J Exelon Corp
To:	Ashley D NRC/NRR/ADRO/DLR/RLRA
Shared Package
ML060600344	List: ML060890080 ML060930255 ML060940146 ML060960563 ML060960568 ML060960602 ML061030419 ML061160161
References
%dam200606, TAC MC7624
Download: ML060930255 (6)

Text

D. Ashley -Responses to three more AMP questions O-agiiT]From: <john.hufnagel

@ exeloncorp.com>

To: <djal @nrc.gov>, <rkm~nrc.gov>

Date: 03/31/2006 12:04:19 PM

Subject:

Responses to three more AMP questions Donnie & Roy, The attached three Responses (to questions AMP-359, AMP-360 and AMP-362) are provided for your review. These three were included in the 3/17/06 e-mail from Donnie Ashley to George Beck. It was agreed they would be addressed in the Q & A database since they originate from the Audit.Note that we are busy finalizing responses to the last seven database questions, related to the drywell, and expect to get those to you early next week to facilitate completion of your review and Audit report. If you have any questions, please contact me. Thanks.-John.<>

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Thank You.CC: <donald.warfel

@exeloncorp.com>, <George.Beck@exeloncorp.com>,<fred.polaski

@ exeloncorp.com>

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Creation Date: From: Responses to three more AMP questions 03/31/2006 12:03:48 PM<john.hufnagel

@exeloncorp.com>

Created By: john.hufnagel

@exeloncorD.com Recipients nrc.gov OWGWPOO1.HQGWDOO1 DJA1 (D. Ashley)nrc.gov TWGWPO01.HQGWDO01 RKM (Roy Mathew)exeloncorp.com fred.polaski CC George.Beck CC donald.warfel CC Post Office OWGWPOO1.HQGWDO01 TWGWPOO1.HQGWDOO1 Files Size MESSAGE 1591 TEXT.htm 2434 Q & A Database Response AMP-362.pdf Q & A Database Response AMP-360.pdf Q & A Database Response AMP-359.pdf Mime.822 256074 Route nrc.gov nrc.gov exeloncorp.com Date & Time 31 March, 2006 12:03:48 PM 61063 58797 61821 Options Expiration Date: Priority: Reply Requested:

Return Notification:

Concealed

Subject:

Security: None Standard No None No Standard NR CInformation RequestFo Item No Date Received:

Source AMP-359 3/16/2006 AMP Audit Topic: Status: Open Lubricating Oil Analysis Program -FRCT (AMP B.1.39)Document

References:

NRC Representative Davis, Jim AmerGen (Took Issue): Beck, Chip Ouestion This question was received from Donnie Ashley, NRC Project Manager on 3/14/06 as a draft RAI. On 3/16/06 it was agreed that it would be addressed in the Q&A database since it originates from the audit (Roy Matthew).

Subsequently included in 3/17/06 email from Donnie Ashley to George Beck The Lubricating Oil Analysis Program -FRCT (OCGS AMP B.1.39) takes exception to the GALL Report requirement to monitor flash point.The basis provided for exceptions to GALL, Element 3 (Parameters Monitored or Inspected) is not valid since the Flash Point of an industrial lubricant is an important test to determine if light-end hydrocarbons are getting into the oil through seal leaks or other means. It is an effective way to monitor seal performance in light end hydrocarbon compressors.

Low Flash Points pose a safety hazard in the event of component failure that can generate heat above the flash point of the oil, such as bearing failure.Please justify the reason for not monitoring the flash point of lubricating oil at the FRCT and why this exception is acceptable to manage the effects of aging for which it is credited.Assigned To: Beck, Chip Response: The Lubricating Oil Analysis Program -FRCT (PBD-AMP-1.39) will be revised to include measurement of flash point.(This is consistent with PBD-AMP-B.2.02 Lubricating Oil Monitoring Activities)

LRCR #: 292 LRA A.5 Commitment

1. IR#: Approvals:

NRC Information Request FormlPrepared By: Beck, Chip 3/30/2006 Reviewed By: Muggleston, Kevin 3/30/2006 Approved By: Warfel, Don 3/30/2006 NRC Acceptance (Date):

NR CIntformation RequestFom Item No Date Received:

Source AMP-360 3/17/2006 Topic: Status: Open PBD-AMP-B.2.2 Lubricating Oil Monitoring Activities Document

References:

NRC Representative Davis, Jim AmerGen (Tookl Issue): Beck, Chip Question This question was received in an email from Donnie Ashley, NRC Project Manager, to George Beck, dated 3/17/06.PBD-AMP-B.2.2, 'Lubricating Oil Monitoring Activities," Element 3 states that oil analysis guidelines will be enhanced to include measurement of flash point for diesel engine lubricating oil. This is a new enhancement based on the reconciliation of this aging management program from the draft January 2005 NUREG-1800, Rev. I to the approved September 2005 NUREG-1 801, Rev. 1. This enhancement is not identified in OCGS LRA B.2.2. Is the LRA supplemented to reflect this?Assigned To: Beck, Chip Response: This enhancement is addressed in the 'Summary of Reconciliation of OC LRA to September 2005 Revision 1 NUREG-1800 and NUREG-1801" transmitted to the NRC on March 30, 2006 (Letter No.2130-06-20293).

This is an addition to the LRA Table A.5 License Renewal Commitment List Item No. 38.LRCR #: LRA A.5 Commitment

1. 38 IR#: Approvals:

Prepared By: Beck, Chip 3/30/2006 ReviewedBy:

Getz, Stu 3/30/2006 Approved By: Warfel, Don 3/30/2006 NRC Acceptance (Date):

INRC Information Request FormlItem No Date Received:

Source AMP-362 3/17/2006 AMP Audit Topic: Status: Open PBD-AMP-B.1.21 Aboveground Outdoor Tanks Document

References:

NRCRepresentative Davis, Jim AmerGen (Took Issue): Beck, Chip Question This question was received in an email from Donnie Ashley, NRC Project Manager, to George Beck, dated 3/17/06.PBD -AMP- B.1.21, -Aboveground Outdoor Tanks," identifies an exception to NUREG-1801 for element 5 (The program utilizes tank inspections every 5 years in place of system walkdowns each outage). This exception is not identified in OCGS LRA B1.12. Is the LRA supplemented to reflect this? What is the basis for this exception?

why this exception is acceptable to manage the effects of aging for which it is credited.Assigned To: Micklo, Charles Response: The technical justification for the exception to NUREG-1801 is provided in the response to Item No.AMP-148. LRCR 231 was written to correct Exelon's documentation.

The exception identified does not change any commitment stated in LRA Appendix A. The exception is included in the Question and Answer database, item AMP-148 and in the PBD-AMP-B.1.21 document that have been provided to the NRC. An LRA supplement is not required.LRCR #: 231 LRA A.5 Commitment

1. IR#: 376714.04.05 Approvals:

Prepared By: Micklo, Charles 3/30/2006 ReviewedBy:

Muggleston, Kevin 3/30/2006 Approved By: Warfel, Don 3/30/6006 NRCAcceptance (Date):