RA-08-008, Commitment Clarifications Related to the Aging Management Program for the Drywell Shell, Associated with Amergen'S License Renewal Application

From kanterella
(Redirected from ML080160540)
Jump to navigation Jump to search

Commitment Clarifications Related to the Aging Management Program for the Drywell Shell, Associated with Amergen'S License Renewal Application
ML080160540
Person / Time
Site: Oyster Creek
Issue date: 01/14/2008
From: Gallagher M
AmerGen Energy Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-08-008, TAC MC7624
Download: ML080160540 (3)


Text

Amer4,)GSM Michael P.GallagheT, PE Telephone 610.765.5958 An Exelon Company Vice President www.exeloncorp.com License Renewal Projects michaelp.gallagher@exeloncorp.com AmerGen 10 CFR 50 200 Exelon Way 10 CFR 51 KSA/2-E 10 CFR 54 Kennett Square, PA 19348 RA-08-008 January 14, 2008 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:

Commitment Clarifications Related to the Aging Management Program for the Oyster Creek Drywell Shell, Associated with AmerGen's License Renewal Application (TAC No. MC7624)

Reference:

Initial Decision from the Atomic Safety and Licensing Board (ASLB)

Associated with Oyster Creek Nuclear Generating Station License Renewal Proceeding, dated December 20, 2007 (LBP-07-17)

The ASLB conducted a hearing on September 24 and 25, 2007, on a single contention related to AmerGen Energy Company LLC's (AmerGen's) application for a renewed operating license for the Oyster Creek Nuclear Generating Station (Oyster Creek). The ASLB issued its "Initial Decision," referenced above, in December 2007.

In its decision, and as discussed at the hearing, the ASLB acknowledged that AmerGen intends to perform periodic inspection of the drywell sand bed drains for blockage. The ASLB recommended, however, that AmerGen include this inspection among its docketed commitments. Therefore, as indicated in the Enclosure to this letter, AmerGen makes this.

commitment, which is now Commitment # 22 within the ASME Section XI, Subsection IWE Program.

Although not discussed in the referenced Initial Decision, the ASLB requested at the hearing that AmerGen clarify details related to its existing commitment to perform a modern three-dimensional (3D) structural analysis of the Oyster Creek drywell shell. AmerGen will confirm that the safety factors calculated by the new 3D analysis meet or exceed the safety factors specified by the ASME Code (i.e., greater than or equal to 2.0 for the refueling load case and 1.67 for the post-accident load case). As previously specified in Commitment # 18 of the IWE Program, failure to meet required limits would cause AmerGen to notify the NRC in accordance with 10 CFR Part 50. This clarification of AmerGen's IWE Program Commitment is also reflected in the Enclosure.

W-//

-4 January 14, 2008 Page 2 of 2 Also as previously stated in Commitment #18 of the IWE Program, AmerGen is including sensitivity analyses as part of its 3D structural analysis. These sensitivity analyses will use, as input, conservative thickness estimates for areas between UT thickness measurement locations, thereby producing a conservative assessment of the performance capability of the drywell shell.

After the 3D structural analysis is finalized, which will be prior to the period of extended operation, AmerGen will submit to the NRC Staff a summary of the 3D analysis. This will confirm AmerGen's completion of the 3D analysis.

Finally, in order to eliminate any confusion as to whether AmerGen will, under any circumstance, apply a strippable coating to the reactor cavity liner prior to filling it with water-an issue that was resolved in the Initial Decision-AmerGen is clarifying Commitment #2 of the ASME Section XI, Subsection IWE Program. This clarification, along with the 'other clarifications discussed in this letter, is shown in the Enclosure.

These clarifications will be included in the License Renewal UFSAR update.

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 /- -00 __"_ _

Michael P. Gallagher Vice President, License Renewal AmerGen Energy Company, LLC

Enclosure:

Excerpt from License Renewal Containment IWE Program Commitments cc: Regional Administrator, USNRC Region I USNRC Project Manager, NRR - License Renewal, Safety Atomic Safety and Licensing'Board (Copy to each Judge)

USNRC Project Manager, NRR - License Renewal, Environmental USNRC Project Manager, NRR - Project Manager, OCGS USNRC Senior Resident Inspector, OCGS Bureau of Nuclear Engineering, NJDEP File No. 05040

9" Enclosure - Excerpt from License Renewal Containment IWE Program Commitments The following License Renewal Commitment List Table A.5 excerpt displays the modifications to Commitments 2 and 18, and the addition of Commitment 22 associated with the ASME Section XI, Subsection IWE Program (Item 27), as described in the above letter. Bold font is used to highlight new information in the table. Refer to AmerGen letter 2130-07-20464, dated February 15, 2007, for the most recent previous submittal containing the full listing of ASME Section XI Subsection IWE Program commitments.

UFSAR ITEM NUMBER COMMITMENT SUPPLEMENT ENHANCEMENT OR SOURCE LOCATION IMPLEMENTATION (LRA APP. A) SCHEDULE

2. A strippable coating will be applied to the reactor A.1.27 Prior to filling the Section cavity liner to prevent water intrusion into the gap reactor cavity with B.1.27 between the drywell shield wall and the drywell shell water during periods when the reactor cavity is flooded.
18. AmerGen will perform a 3-D finite element structural Prior to the period of analysis of the primary containment drywell shell using extended operation modern methods and current drywell shell thickness

)ASME Section data to better quantify the margin that exists above the

27) SCode required minimum for buckling. The analysis will include sensitivity studies to determine the degree to which uncertainties in the size of thinned areas affect Code margins. If the analysis determines that the drywell shell does not meet Code-specified safety factors (i.e., 2.0 for the refueling load case and 1.67 for the post-accident load case), the NRC will be notified in accordance with 10 CFR 50 requirements.
22. Verify that the sand bed drain lines are clear Every other refueling from obstruction. outage