ML072850049

Oyster Creek September 2007 Evidentiary Hearing - Intervenors Exhibit 41, Gpu Nuclear,Technical Functions, Safety/Environmental Determination and 50.59 Review

ML072850049
Person / Time
Site:	Oyster Creek
Issue date:	01/05/1993
From:	Jacobs D GPU Nuclear Corp
To:	NRC/SECY
SECY RAS
References
50-219-LR, AmerGen-Intervenor-41, RAS 14358
Download: ML072850049 (4)

Text

"L.NUCLEA MEULADYM COMMIsSIO Citizens Exhibits 41 Rt45 /1435S Nuclear Technical Functions Safety/Environmental Determination and 50. M1iE RAT W1ThAWH (EP-016) m a Mmvin

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• UNiT Oyster Creek PAGE I OF 22_L DOCUMENTIACTIVrYTITLE Clean and Coat Drywell Ext. in Sand Bed SE Rev. No. ,.

DOCUMENT NO. 0C-M-40295Q-010 DOC REV. NO. 0 SEW*. 40295O-01]

linaottlicartie Type of Activity Modification (Modification, procedure, test, experiment, or document)

1. Is this activityidocument listed in Section 1 or II of the matrices in Corporate Procedure (lYes EINo 1000-ADM-1291.01?

If the answer to question I is "no" stop here. (Section IV activities/documents should be reviewed on a case-by-case basis to determine if this procedure is applicable.) This pro.

cedure is not applicable and no documentation is required. If the answer is "yes" proceed to question 2.

2. Is this a new activity/document or a substantive revision to an activity/document? (See  !*Yes CNo Exhibil 3, paragraph 3, this procedure for examples of non-substantive changes)

If the answer to question 2 is "no'! stop here. This procedure is not applicable and no documentation is required. If the answer is "yes" proceed to answer all remaining questions.

These answers become the Saelty/Environmental Determination and 50.59 Review.

3. Does this activityJdocument have the potential to adversely affect nuclear safety or safe ZYes CNo plant operations?

4. Does the activity/document require revision of the systemlcomponent description in the FSAR rEYes EXNo or otherwise require revision of the Technical Specifications or any other part of the SAP?

5. Does the activity/document require revision of any procedural or operating description in rYes GNo the FSAR or otherwise require revision of the Technical Specifications or any other part of the SAR?

B. Are tests or experiments conducted which are not described in the FSAR, the Technical EYes lxNo Specifications or any other part of the SAR?

No because No tests or exueriments are conducted Documents checked:

It any of, the answers to questions 3, 4, 5 or 6 are yes. prepare a written safety evaluation on a Safety Evaluation form.

it the answers to 3. 4, 5. and 6 are no, this precludes the occurrence of an Unreviewed Safety Question or Technical Specifications change. Provide a written statement In the space provided above (attach additional sheet if necessary) to support the determination, and list the documents you checked.

7. Does this document Involve any potential Non-Nuclear environmental impact? Yes Z No

8. Are the design criteria as outlined in TMI-1 SDD-TI-000 Div. 1 or OC-SDD-000 Div. I Plant -Yes ZNo Level Criteria affected by, or do they affect the activity(document?

If yes, indicate how resolved If the answer to question 7 is yes, either redesign or provide supporting documentation which will permit Environ-mental Licensing to determine if an adverse environmental impact exists and if regulatory approval is required (Ref. 1000-ADM-1216.03). If in doubt, consult the Radiological and Environmental Controls Division or Environmental Licensing for assistance in completing the evaluation.

Signatures Date Section Manager a--iLI,'7 Responsible Technical Revie,-l . Sa L-"H4OF " '/5/=

Other Reviewer(s) .

L __ __ _ __ __ _,_

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-Tlemp( SECV-2 OCLR00022240 S /c- 0 A

DOCKETED USNRC October 1,2007 (10:45am)

OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF

SE-402950-011 Rev. 0 Page 18 of 22 3.3.11 Containment Isolation With sand removed from the sand bed area and the drywell exterior cleaned and coated, containment isolation is not affected.

During sand removal, cleaning and coating, containment isolation will not be affected. An impact analysis, Reference 3.1.5, identifies limits as to the weight of tools which may be carried or lifted above the torus, as well as the maximum heights at which they may be carried to avoid load drops that might damage the torus or its internal coating. In general, that analysis requires that tools be covered with padding while being moved across the top of the torus. These limits on tool weight, lift height, and padding thickness will be observed during cleaning and coating work. The limits are detailed in OC-MM-402950-009.

3.3.12 Materials Compatibility The drywell exterior surface will be cleaned with a water-based cleaner and coated with epoxy primer and epoxy paint. An epoxy primer will be brushed/poured into the drywell-to-concrete gap at the base of the sand bed area. An epoxy caulk may be applied over any remaining drywell-to-concrete gap that the epoxy primer did not fill. The specific materials to be used are described in OC-MM- 402950-010. These materials have been reviewed for compatibility in this application and approved for use by GPUN's Material Engineering department. The application of these materials will not increase the corrosion rate of the drywell exterior.

3.4 Licensing Basis Documents/Margin of Safety With the sand removed and the drywell exterior cleaned and coated, the margin of safety discussed in SE-000243-002 (Reference 3.1.3) is not reduced.

After the drywell exterior has been cleaned, the steel surface will be free of active corrosion cells so that corrosion will be reduced. Accordingly, it is acceptable to .clean but not coat the surface during 14R if time constraints prevent coating application. After the drywell is coated, the steel surface wiUl not be wet by any future water leaks into the sand bed, so that future corrosion will be further minimized. Whether or not the drywell surface is coated during 14R, this modification will make it more likely that the margin of safety will be maintained.

Cleaning and coating in portions of the sand bed area which are difficult to access will be performed on a best effort basis. Accordingly, some patches of the drywell exterior may be left uncleaned and/or uncoated. Possible OCLROO022257

SE-402950-011 Rev. 0 Page 19 of 22 preferential corrosion of these uncleaned/uncoated patches was evaluated.

Two conditions may exist in which patches of the drywell exterior are left uncleaned/uncoated: (1) the patches are uncleaned/uncoated while the bulk of the drywell exterior is coated or, (2) the patches are uncleaned/uncoated while the bulk of the drywell exterior is cleaned but not coated. In both cases, the bulk of the drywe]l will not be cathodic with respect to the uncleaned/uncoated patches, and therefore, galvanic cells (i.e., preferential corrosion) between the uncleaned/uncoated patches and the bulk of the drywell exterior is unlikely to exist. It is expected that the uncleaned/uncoated patches will continue to experience general corrosion, but at a reduced rate since the sand and moisture will no longer be present.

3.5 Nuclear Safety/Safe Plant Operation This modification will have no adverse effect on nuclear safety or safe plant operations. As discussed in Section 3.3.1, the safety functions of the plant systems potentially effected by this modification will not be degraded during and after sand removal, cleaning, and coating.

Sand removal, rust removal and surface preparation tools will vibrate the drywell locally in the sand bed area. Cleaning and coating will not be performed during plant operation, so that there is no potential for this vibration to initiate an inadvertent plant shutdown. Also, based on previous experience with more aggressive tools and cutting activities this vibration will not be severe enough to effect plant equipment.

3.6 Probability of Occurrence or Consequence of an Accident With sand removed and the drywell cleaned and coated in the sand bed area, the probability of occurrence of an accident is not increased.

Neither the probability of occurrence of an accident nor the consequences of an accident will be increased during sand removal, cleaning, and coating activities.

3.7 Probability of Occurrence or Consequence of Malfunction of Safety Equipment For the reasons given in Section 3.3 above, removing sand from the sand bed area and cleaning and coating the drywell steel in the sand bed area will not increase the probability of occurrence or consequence of malfunction of safety equipment.

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