ML062230239
| ML062230239 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 08/11/2006 |
| From: | Ashley D NRC/NRR/ADRO/DLR/RLRA |
| To: | AmerGen Energy Co |
| Ashley D, NRR/DLR/RLRA, 415-3191 | |
| References | |
| %dam200612 | |
| Download: ML062230239 (14) | |
Text
August 11, 2006LICENSEE:AmerGen Energy Company, LLC FACILITY:Oyster Creek Nuclear Generating Station
SUBJECT:
SUMMARY
OF A TELEPHONE CONFERENCE CALL HELD ON MARCH 8, 2006, BETWEEN THE U.S. NUCLEAR REGULATORYCOMMISSION AND AMERGEN ENERGY COMPANY, LLC, CONCERNING DRAFT REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO THE OYSTER CREEK NUCLEAR GENERATING STATION, LICENSE RENEWALAPPLICATIONThe U.S. Nuclear Regulatory Commission staff (NRC or the staff), and representatives ofAmerGen Energy Company, LLC (AmerGen), held a telephone conference call on March 8, 2006, to discuss and clarify the staff's draft request for additional information (D-RAI) concerning the Oyster Creek Nuclear Generating Station license renewal application (LRA). The conferencecall was useful in clarifying the intent of the staff's D-RAI.Enclosure 1 provides a listing of the conference call participants. Enclosure 2 contains a listingof the D-RAI 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/Donnie J. Ashley, Project ManagerLicense Renewal Branch A Division of License Renewal Office of Nuclear Reactor RegulationDocket No. 50-219
Enclosures:
As statedcc w/encls: See next page
DOCUMENT NAME: E:\Filenet\ML062230239.wpdOFFICEPM:RLRA:DLRLA:RLRA:DLRBC:RLRA:DLRNAMEDAshleyYEdmonds LLund DATE8/ 08 /067/ 31 /068/ 11 /06 Oyster Creek Nuclear Generating Station cc:
Site Vice President - Oyster Creek Nuclear Generating Station AmerGen Energy Company, LLC
P.O. Box 388 Forked River, NJ 08731Senior Vice President of Operations AmerGen Energy Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348Kathryn M. Sutton, EsquireMorgan, Lewis, & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004Kent Tosch, ChiefNew Jersey Department of Environmental Protection Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625Vice President - Licensing and Regulatory Affairs AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555Regional Administrator, Region IU.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415Mayor of Lacey Township818 West Lacey Road Forked River, NJ 08731Senior Resident InspectorU.S. Nuclear Regulatory Commission
P.O. Box 445 Forked River, NJ 08731Director - Licensing and Regulatory AffairsAmerGen Energy Company, LLC Correspondence Control
P.O. Box 160 Kennett Square, PA 19348Manager Licensing - Oyster CreekExelon Generation Company, LLC Correspondence Control
P.O. Box 160 Kennett Square, PA 19348Regulatory Assurance Manager Oyster Creek AmerGen Energy Company, LLC
P.O. Box 388 Forked River, NJ 08731Assistant General CounselAmerGen Energy Company, LLC 200 Exelon Way Kennett Square, PA 19348Ron Bellamy, Region IU.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415Correspondence Control DeskAmerGen Energy Company, LLC 200 Exelon Way, KSA 1--1 Kennett Square, PA 19348Oyster Creek Nuclear Generating StationPlant Manager AmerGen Energy Company, LLC
P.O. Box 388 Forked River, NJ 08731License Renewal ManagerExelon Generation Company, LLC 200 Exelon Way, Suite 230 Kennett Square, PA 19348 Oyster Creek Nuclear Generating Station cc:
Mr. James RossNuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708Mr. Michael P. GallagherVice President License Renewal Exelon Generation Company, LLC 200 Exelon Way, Suite 230 Kennett Square, PA 19348Mr. Christopher M. CranePresident and Chief Nuclear Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 Note to: AmerGen Energy Company, LLC, Facility: Oyster Creek Nuclear Generating Stationfrom Donnie Ashley dated August 11, 2006.
SUBJECT:
SUMMARY
OF A TELEPHONE CONFERENCE CALL HELD ON MARCH 8, 2006, BETWEEN THE U.S. NUCLEAR REGULATORYCOMMISSION AND AMERGEN ENERGY COMPANY, LLC, CONCERNING DRAFT REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO THE OYSTER CREEK NUCLEAR GENERATING STATION, LICENSE RENEWALAPPLICATIONHARD COPYDLR R/F E-MAIL:JFairRWeisman AMurphy RPettis GGalletti DShum GBagchi SSmith (srs3)
SDuraiswamy YL (Renee) Li RidsNrrDlr RidsNrrDlrRlra RidsNrrDlrRlrb RidsNrrDe RidsNrrDci RidsNrreEemb RidsNrrDeEeeb RidsNrrDeEqva RidsNrrDss RidsNrrDnrl RidsOgcMailCenter RidsNrrAdes DLR Staff
CHolden RLaufer GMiller RBellamy, RI RCureton, RI JLilliendahl, RIMModes, RI MSykes, RI MYoung RidsOpaMail LIST OF PARTICIPANTS FOR TELEPHONE CONFERENCE CALLTO DISCUSS THE OYSTER CREEK NUCLEAR GENERATING STATIONLICENSE RENEWAL APPLICATIONMarch 8, 2006Participants AffiliationsDonnie AshleyU.S. Nuclear Regulatory Commission (NRC)Jai RajanNRC Andy DuBouchetNRC Rich McNallyNRC Don WarfelAmerGen Energy Company, LLC (AmerGen)
George BeckAmerGen Kevin MugglestonAmerGen Charlie MickloAmerGenENCLOSURE 1 ENCLOSURE 2DRAFT REQUESTS FOR ADDITIONAL INFORMATION (D-RAI)OYSTER CREEK NUCLEAR GENERATING STATIONLICENSE RENEWAL APPLICATIONMarch 8, 2006The U.S. Nuclear Regulatory Commission staff (NRC or the staff) and representatives ofAmerGen Energy Company, LLC (AmerGen), held a telephone conference call on March 8, 2006, to discuss and clarify the staff's draft request for additional information (D-RAI) concerning the Oyster Creek Nuclear Generating Station (OGNGS), license renewal application (LRA). The following D-RAIs were discussed during the telephone conference call.D-RAI 3.2-1In LRA Table 3.2.2.1.3 the applicant states that for stainless steel closure bolting in indoor air(external) environment there are no aging effects requiring management (AERM). The staff requests the applicant to provide the following information:a. justification for excluding loss of preload and loss of closure integrity as aging mechanisms;b. specific industry guidance for ventilation closure bolting relating to AERMs (for example, EPRI documents, published reports, operating experience etc.); andc. sizes and locations of the bolting.Discussion: The applicant understands the question and will provide a response.D-RAI 3.2-2In LRA Table 3.2.2.1.3 the applicant states that loss of material in a number of components ismanaged by the Periodic Inspection of Ventilation Systems (B.2.4) Aging Management Program. The staff requests the applicant to provide the specific tests and inspections, including frequency and methods of inspections, preventive actions, parameters monitored and inspected, detection of aging effects, acceptance criteria and operating experience in the applicant's aging management program (B.2.4) which relates to each of the following line items in the standby gas treatment system:a. change of material properties and loss of material for elastomeric door seal in anoutdoor air (external) environment (Identify the specific elastomeric material - for example, neoprene, natural rubber, chlorobutyl, etc.);b. loss of material in aluminum duct work in an external soil environment;
- c. change of material properties in elastomeric flexible connections in an outdoor air environment (Identify the specific elastomer); d. loss of material in brass piping and fitting in an outdoor air (external) environment(Identify the specific brass composition);e. loss of material in stainless steel flow elements, piping and fittings and thermowellsin an outdoor air (external) environment;f.loss of material in copper piping and fittings in an outdoor air (external) environment(Identify the specific copper composition); andg. loss of material in brass valve bodies in an outdoor air environment (Identify thespecific brass composition).Discussion: The program basis document AMP-B.2.04 contained the specific information forItems a, c, e and g. The items will be removed and the question will be revised to r ead asfollows.In LRA Table 3.2.2.1.3 the applicant states that loss of material in a number of components ismanaged by the Periodic Inspection of Ventilation Systems (B.2.4) Aging Management Program (AMP). The staff requests the applicant to provide the specific tests and inspections including frequency and methods of inspections, preventive actions, parameters monitored and inspected, detection of aging effects, acceptance criteria and operating experience in the applicant's AMP (B.2.4) which relate to each of the following line items in the standby gas treatment system:a. loss of material in aluminum duct work in an external soil environment;
- b. loss of material in brass piping and fitting in an outdoor air (external) environment(Identify the specific brass composition); andc. loss of material in copper piping and fittings in an outdoor air (external) environment(Identify the specific copper composition).Discussion: The applicant understands the revised question and will provide a response.D-RAI 3.2-3In LRA Table 3.2.2.1.3 the applicant has identified no AERMs for plexiglass duct work in aninternal and external indoor air environment. The staff requests the applicant to discuss its current maintenance practices for plexiglass in this environment as well as vendor recommendations in this regard. In addition, the staff requests the applicant to identify the specific composition of this plexiglass material and its operating experience at the OCNGS.Discussion: The applicant understands the question and will provide a response. D-RAI 3.4-1In Table 3.4.2.1.2 the applicant states that loss of material of buried aluminum piping andfittings in an external soil environment will be managed by the Buried Piping InspectionProgram (B.126). The staff requests the applicant to provide the following information regarding the management of the aging effects:a.specific alloy composition of the piping and fittings, and the basis for identifying theaging effect in the specific external soil environment;b. identify the type of loss of material which is expected to occur (pitting, cracking,general corrosion etc.);c.operating experience with this material in this environment; and d.type of external coatings and wrappings which will be used and the preventivemeasures to keep them in place.Discussion: Based on discussions, the reviewer withdrew the (a) section of the questionreferenced above. Revise the question to read as follows:D-RAI 3.4-1In Table 3.4.2.1.2 the applicant states that loss of material of buried aluminum piping andfittings in an external soil environment will be managed by the Buried Piping InspectionProgram (B.126). The staff requests the applicant to provide the following information regarding the management of the aging effects:a. identify the type of loss of material which is expected to occur (pitting, cracking,general corrosion etc.);b.operating experience with this material in this environment; and c.type of external coatings and wrappings which will be used and the preventive.Discussion: The applicant understands the revised question and will provide a response.D-RAI 3.4-2In Table 3.4.2.1.2 of the LRA the applicant states that loss of material of aluminum tanks in anair (internal and external) and external soil environments will be managed by the AbovegroundOutdoor Tanks Program (B1.21). The staff requests the applicant to provide the following information relative to the tanks:a.specific alloy composition of the tank material; b.description of the tank supports; c.aging management of the sealant or coatings on the tank bottom, if any;d.operating experience with the tanks; e.function of the tanks and any other material in contact with its internal and externalsurfaces, such as expansion joints, piping connections etc.; andf.specific tests, wall thickness measurements and inspections which assure that theleak tightness of the tanks is maintained in the internal and external outdoor air and soil environments.Discussion: Revise the question to read as follows: In Table 3.4.2.1.2 of the LRA the applicant states that loss of material of aluminum tanks in anair (internal and external) and external soil environments will be managed by the AbovegroundOutdoor Tanks Program (B1.21). The staff requests the applicant to provide the following information relative to the tanks:a.specific alloy composition of the tank material; b.description of the tank supports; c.aging management of the sealant or coatings on the tank bottom, if any; d.operating experience with the tanks; e.purpose of the tanks (including a description of the services performed) and anyother material in contact with its internal and external surfaces, such as expansion joints, piping connections etc.; andf.specific tests, wall thickness measurements and inspections which assure that theleak tightness of the tanks is maintained in the internal and external outdoor air and soil environments.Discussion: The applicant understands the revised question and will provide a response.D-RAI 3.4-3In LRA Table 3.4.2.1.2 the applicant states that loss of material in stainless steel tanks ininternal and external outdoor air environments is managed by the Aboveground Outdoor Tanks Program (B.1.21). The staff requests the applicant to provide the following additional information:a.description of the tanks including supports and other connecting piping; b.specific tests and inspections (including wall thickness measurements) in theAboveground Outdoor Tanks Program (B.1.21), which are performed relative to these tanks to assure structural integrity; andc.operating history of these tanks. Discussion: The applicant understands the question and will provide a response.D-RAI 3.4-4In LRA Table 3.4.2.1.3 the applicant states that carbon and low alloy steel piping and fittings incontainment atmosphere (external) have no aging effects. According to the applicant, the aging effect in NUREG-1801 for this component, material and environment combination is notapplicable (Note I). The applicant cites a previous staff evaluation in which the staff had concluded that loss of material is not an aging effect for carbon steel components in a containment nitrogen environment, because of negligible amounts of free oxygen (less than 4 percent by volume) during normal operation. The staff's concern is that due to leakage of moisture and presence of oxygen during plant shutdown, the potential for degradation of carbonsteel components cannot be ruled out over an extended period of time. Therefore, there is a need for a one-time inspection prior to the period of extended operation, unless the applicant can provide additional assurance in support of its position (for example, monitored data from the Oyster Creek containment nitrogen environment to indicate that the free oxygen levels havebeen continuously maintained below threshold levels and would continue to be maintained during the period of extended operation). The staff requests the applicant to justify its position or alternately, commit to a one-time inspection of these components prior to the period of extended operation.Discussion: The applicant understands the question and will provide a response.D-RAI 3.4-5In LRA Table 3.4.2.1.3 the applicant states that in carbon and low alloy steel piping and fittingsin a treated water environment, no Aging Effects Requiring Management (AERMs) are applicable. The applicant cites Electric Power Research Institute (EPRI) Report, 'Mechanical Tools, Appendix A', to support its position that stress-corrosion cracking (SCC) and intergranular stress-corrosion cracking (IGSCC) are not applicable aging effects for carbon steel in a treated water environment. However, staff's review of the above-mentioned EPRI document indicates that while SCC and IGSCC are not applicable for carbon steel in a treated water environment, other aging effects are applicable. These are metal fatigue, general corrosion, galvanic corrosion, microbiologically induced corrosion (MIC) and erosion/FAC. The staff's concern is that due to inadvertent ingress of contaminants and other factors (such asstagnant locations where chemical treatment may not be effective), the potential fordegradation over an extended period of time cannot be ruled out. Thus, there is a need for a one-time inspection of these components prior to the period of extended operation. The applicant requested to respond to the staff's concerns as discussed above and justify its position.Discussion: Based on discussions and the inspection described in the license renewalapplication Table 3.4.2.1.3, the reviewer withdrew the question. D-RAI 3.4-6In LRA Table 3.4.2.1.3 the applicant states that for carbon and low alloy steel valve bodies, inexternal containment air and treated water environments, there are no AERMs. The staff's concerns discussed in RAIs 3.4-4 and 3.4-5 are also applicable to carbon and low alloy steel valve bodies. The staff requests the applicant to respond to the staff's concerns as discussed above and justify its position.Discussion: This question will be renumbered and revised to remove reference to RAI 3.4-5and be sent as a formal RAI. The applicant understands the revised question and will provide aresponse.D-RAI 3.4-7In LRA Table 3.4.2.1.4 the applicant states that there are no AERMs for the following maincondenser subcomponents:a.carbon and low alloy steel main condenser shell in indoor air (external) and steam(internal) environments;b.titanium main condenser tubes in a raw salt water (internal) and steam (external)environment; andc. aluminum/bronze tubesheet in a raw salt water (internal) and steam (external)environment.The applicant further states that aging management of the main condenser is not based onanalysis of materials, environments and aging effects. Condenser integrity required to perform the post accident intended function (holdup and plate out of MSIV leakage) is continuously confirmed by normal plant operation. Therefore, the applicant contends that no traditionalaging management review or aging management is required. The staff requests the applicant to provide the following information relating to the main condenser at Oyster Creek or provide justification that this information does not apply. a.Operational and maintenance history of the main condenser, summarizing thesignificant abnormal conditions or events which may have occurred in the past. This summary should include a brief discussion of the root cause determination and evaluation of these events, if available. The staff is particularly interested in events related to fouling, insulation failure, tube ruptures or major leaks, expansion joint failures, condenser air in-leakage and condenser tube microbiologically induced corrosion.b.Discuss any concerns related to condenser capacity under power uprate conditions.Discussion: This question will be renumbered and sent as a formal RAI. The applicantunderstands the question and will provide a response. D-RAI 3.4-8In LRA Table 3.4.2.1.6 the applicant states that for carbon and low alloy steel expansion joints,flow element and thermowells, in an internal and external containment atmosphere environment, there are no AERMs. As discussed in RAI 3.4-4 above, the staff considers a one-time inspection appropriate for these components prior to the period of extended operation.
The staff requests the applicant to respond to the staff's above concerns as they relate to the Main Steam System and justify its position.Discussion: This question will be renumbered and sent as a formal RAI. The applicantunderstands the question and will provide a response.D-RAI 3.4-9In LRA Table 3.4.2.1.6 the applicant states that for carbon and low alloy steel piping and fittingsand valve bodies in internal and external containment air and internal treated water environments, the applicant has identified no AERMs. As discussed in RAIs 3.4-4 and 3.4-5 above, the staff considers a one-time inspection appropriate for these components prior to the period of extended operation. The staff requests the applicant to respond to the staff's concerns as they relate to the Main Steam System and justify its position.Discussion: This question will be renumbered, revised to remove reference to RAI 3.4-5 andbe sent as a formal RAI. The applicant understands the revised question and will provide aresponse.D-RAI 4.7.1-1The staff requests the applicant to discuss any major repairs, modifications or replacementsdone in the past which affected the original design basis of the reactor building, turbine and heater bay cranes at OCNGS. Also, identify any lifts at or in excess of the capacity of these cranes which have occurred in the past.Discussion: The applicant understands the question and will provide a response.D-RAI 4.7.1-2The staff requests the applicant to discuss the operational history of the three cranes within thescope of license renewal.Discussion: The applicant understands the question and will provide a response.D-RAI B.2.1-1The staff requests the applicant to discuss any aging mechanisms for the piping supportmaterials in the containment air environment. In addition, provide the bases for identifying these aging mechanisms or identifying no aging mechanism for the environment/material combination. Discussion: The applicant understands the question and will provide a response. D-RAI B.2.1-2It is stated in the LRA that flow tests are conducted with air rather than water. The staff'sconcern is that since the reaction forces on the supports and the spray nozzles are substantiallyless with air flow versus water flow, the periodic flow tests simply assure that there is no clogging of the spray nozzles, but do not test the structural integrity of the spra y system underactual operating conditions. The staff is concerned that the piping supports and nozzles may not be able to withstand the forces exerted during accident conditions when water is turned on and potentially result in a failure of the spray system. The staff requests the applicant toprovide justification to assure that the structural integrity of the system under accidentconditions will be maintained during the period of extended operation.Discussion: The applicant understands the question and will provide a response.D-RAI B.2.4-1In LRA Section B.2.4 of Appendix B, the applicant states that existing ventilation systemperiodic preventive maintenance activities will be enhanced as follows:"Instrument piping and valves, restricting orifices and flow elements, thermowells andStandby Gas Treatment System ducts exposed to soil will be added to the scope of theplant implementation documents."The staff requests the applicant to provide a listing of the line items in the AMR Tables of theLRA which would be within the scope of this AMP, and it would be credited.Discussion: The applicant understands the question and will provide a response.D-RAI B.2.4-2In LRA Section B.2.4 of Appendix B, the applicant states that existing ventilation systemperiodic preventive maintenance activities will be enhanced as follows:"Specific guidance for identification of applicable aging effects will be added topreventive maintenance documents." The information in the LRA suggests that the identification of the aging effects is currentlybased on qualitative acceptance criteria. The staff requests the applicant to discuss the enhancements in more detail to indicate whether or not any aging effects would be identified on the basis of quantitative acceptance criteria such as, durometer reading limits for identificationof aging effects in elastomers etc.Discussion: The applicant understands the question and will provide a response.