ML090771109
| ML090771109 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 02/23/2009 |
| From: | - No Known Affiliation |
| To: | Division of License Renewal |
| References | |
| Download: ML090771109 (8) | |
Text
1 PrairieIslandNPEm Resource From:
Eckholt, Gene F. [Gene.Eckholt@xenuclear.com]
Sent:
Monday, February 23, 2009 2:01 PM To:
Subject:
FW: Summaries of 2/3, 2/11 and 2/23 Conference Calls Attachments:
Summary of 2-3-09 Conference Call.doc; Summary of 2-11-09 conference call with NRC.doc; Summary of 2-23-09 Conference Call.doc Rick Here are the summaries for three telecons.
Gene
Hearing Identifier:
Prairie_Island_NonPublic Email Number:
944 Mail Envelope Properties (7A9B2084CC9CEC45828E829CBF20D638033F6AF3)
Subject:
FW: Summaries of 2/3, 2/11 and 2/23 Conference Calls Sent Date:
2/23/2009 2:01:17 PM Received Date:
2/23/2009 2:01:03 PM From:
Eckholt, Gene F.
Created By:
Gene.Eckholt@xenuclear.com Recipients:
"Richard Plasse" <Richard.Plasse@nrc.gov>
Tracking Status: None Post Office:
enex02.ft.nmcco.net Files Size Date & Time MESSAGE 60 2/23/2009 2:01:03 PM Summary of 2-3-09 Conference Call.doc 43584 Summary of 2-11-09 conference call with NRC.doc 32320 Summary of 2-23-09 Conference Call.doc 31808 Options Priority:
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Recipients Received:
Summary of 2/3/09 NRC - PINGP License Renewal Conference Call NRC Attendees: Rick Plasse, Bob Jackson, Erach Patel, Jim Medoff, et. al.
PINGP Attendees: Gene Eckholt, Phil Lindberg, Scott Marty, Bill O'Brien, Bill Roman, Bob Vincent Draft RAI 3.4.2-8-1 The reviewer questioned why some chrome-moly traps in plant indoor air -
uncontrolled had both the External Surfaces Monitoring and the Boric Acid Corrosion Programs assigned, but the steel and cast iron traps on pages 3.4-151 and 152, only the External Surfaces Monitoring program is assigned.
PINGP explained that plant indoor air - uncontrolled environment accounts for boric acid leakage in the Auxiliary Building. Those components in the Aux Building get both Boric acid and External Surfaces inspections, but those in the Turbine Building only get External surfaces inspections since there is no potential for boric acid leakage.
Based on this clarification the reviewer indicated that the RAI need not be issued.
Draft RAI 3.3.2-9-2 LRA Table 3.3.2-9 shows some heat exchanger tubes in an internal environment of raw water being managed with the Fire water system rather than the Open Cycle Cooling Water Program. The GALL Report recommends the Open Cycle Cooling Program. If the water supply comes from the Ultimate Heat Sink, the program should be OCCW. If not, then another program may be acceptable.
PINGP indicated that the subject heat exchangers are supplied from the Fire Water System. The Fire Water System pumps do take water from the Ultimate Heat sink, the Mississippi River, but the water is not normal cooling system water. The Fire Water System is considered the appropriate aging management program.
NRC questioned whether the heat exchangers were in the GL 89-13 program. If not, then the FWS is acceptable. If they are, then OCCW should be applied.
PINGP agreed to confirm the heat exchangers are not in the 89-13 program.
This RAI will be issued. PINGP can respond by confirming that the heat exchangers are not in the 89-13 program, and need not be covered by the OCCW Program.
Draft RAI 3.1.1-24-01 This is a duplicate of RAI 3.1.1.2-02 and will not be issued.
Draft RAI 3.3.1-33-01 LRA 3.3.2.2.12.2 states that MIC is not managed in stainless steel components exposed to a lubricating oil environment based on operating experience. OE is not sufficient justification in itself. NRC needs a technical justification.
PINGP referred to the EPRI Mechanical tools for the justification.
NRC indicated it may be acceptable to use to EPRI tools for justification, but do not simply refer to the tools. Reference alone to tools is insufficient since NRC has not formally reviewed and accepted them. Include the technical justification also. Also it may be argued that routine oil samples may reveal the presence of biological contaminants.
This RAI will be issued.
Draft RAIs 3.3.2.3-1 and 3.4.2.3-1 The LRA includes various elastomer and plastic materials in Tables 3.3.2-6, 3.3.2-7, 3.3.2-8, 3.3.2-20, and 3.3.2-21 for which no aging effect requiring management has been identified. This also applies to Table 3.4.2-3.
PINGP explained that the exterior surfaces in air are shown in LRA tables as being managed by the External Surfaces Monitoring program. The internal surfaces are shown as having no aging effects as they are not exposed to UV radiation, ozone, etc..
It was noted that PINGP has already submitted an RAI response that addresses this subject. NRC indicated that the response that has already been submitted can be used to resolve these questions, and that these two RAIs need not be issued.
Sampling for Copper in Feedwater The LRA lists several bronze and brass valves exposed to treated water in the Condensate System. The Water Chemistry Program takes an exception to GALL by stating that copper is not sampled in feedwater because PINGP is an all-ferrous plant with no copper sources. The reviewer questioned how PINGP can justify not sampling feedwater for copper when there is copper in system.
It was explained that the components are generally not in the main system, but it is possible for some water from copper-bearing components to make it to the condensate system. It was also noted that PINGP actually does sample feedwater weekly for metals including copper. The exception to GALL was noted because metal sampling is not a formal procedural requirement.
RAI will not be issued.
Total Metal Analysis of Feedwater It was questioned how often the total metal analysis was performed.
PINGP stated that analysis is performed weekly for metals including copper. The exception for copper sampling was taken for the Water chemistry Program because this analysis is not formally required by procedure. It is performed, however.
RAI will not be issued.
Hydrazine Use in Feedwater It was questioned whether hydrazine is used for pH control as well as oxygen control.
PINGP indicated that hydrazine is used for oxygen control and amine is used for pH control.
RAI will not be issued.
Draft Follow up to RAI 3.2.2.2.4.2-1 The reviewer wished to discuss the RAI response in more detail.
PINGP reviewed various GALL Table 1 items where stainless steel in borated water only uses the Water Chemistry Program without a separate One-Time Inspection for confirmation, and reiterated its position that the Water Chemistry Program should be sufficient.
A Follow up RAI will not be issued.
Draft Follow up to RAI 3.3.2.2.4.1-1 Part 2 of the RAI response indicates that the heat exchanger tubes addressed by this Further Evaluation Required item may not be selected for examination under the One-Time Inspection Program. The applicable GALL line item for the non-regenerative heat exchanger mentions eddy current testing in addition to the Water Chemistry Program and radiation monitoring of the shell side. It was questioned whether examination of other components of the same material-environment combination would be representative of the non-regenerative heat exchanger.
PINGP explained that the radiation levels in the non-regenerative heat exchangers were excessive and made disassembly for examination highly undesirable. The aging management strategy identified in the LRA is consistent with multiple previous license renewal applicants, and has been approved by NRC in multiple SERs.
The discussion was tabled by NRC.
Follow up Discussion to RAI B2.1.7-1 re: Boric Acid Residue on Ferritic Materials Concern was expressed with the response to RAI B2.1.7-1. Part B of the response implies that boric acid residue can be left on ferritic components, including the reactor vessel head, for extended periods. This is contrary to NRC expectations after the Davis-Besse event.
PINGP explained that Part B of the RAI response in the 12/5/08 letter responded directly to the NRC question, "Clarify whether the program permits PINGP to leave any boric acid residues in place, and if so, how the program assesses the impacts of boric acid residues on the structural integrity of impacted components if the residues are left in place for any period of time." It did not intend to suggest that boric acid would not be cleaned up at the first opportunity after discovery. It only meant that boric acid could remain in place for limited periods of time (e.g.,
until the next outage when access would become available) if required cleanup and corrective action (described in part A of the response) could not be completed immediately.
PINGP agreed to clarify the RAI response to remove the implication that boric acid residue could be left on the reactor vessel head or other components for extended periods.
Summary of 2/11/09 NRC - PINGP License Renewal Conference Call NRC Attendees: Rick Plasse, Bob Jackson PINGP Attendees: Gene Eckholt, Bill O'Brien, Bill Roman, Bob Vincent NRC requested clarification on a line item in Table 3.4.2-4 on page 3.4-75 for Flex Connections of stainless steel in an Outdoor Air - Sheltered environment.
The line item has Note G (environment not in GALL) but points to a GALL Table 1 line for Indoor Air - Uncontrolled. Reviewer asked what the external environment actually is.
PINGP responded that the outdoor air sheltered environment is not in GALL.
Reviewer was referred to Table 3.0-1 for the definition of the environment. The line in question is insulated and sheltered. As used in the LRA, the environments Outdoor Air - Sheltered and Indoor Air - Uncontrolled are equivalent. The humidity experienced in both environments would be the same. The LRA was confirmed to be correct as written.
PINGP understands the question and agreed to provide this clarification in a supplemental letter. RAIs will not be issued.
Summary of NRC-PINGP Conference Call on 2/23/09 NRC
Participants:
Rick Plasse, Bruce Heida PINGP
Participants:
Gene Eckholt, Scott Marty, Bob Vincent NRC requested clarification of the NSPM response to RAI 2.3.3.5-03 in a letter dated 1/15/09. The reviewer indicated that the drains from chillers would be expected to be configured to prevent control room air in-leakage, and questioned whether the drains are hard piped or open to floor drains.
PINGP responded that the air handler is in the control room envelope. The drains off the chillers are hard piped into the roof drains with no loop seals. Both the roof drains and the chiller condensate drains are in-scope for license renewal for spatial interaction. It is recognized that this configuration provides a small leak path for air in-leakage into the control room through the roof drains.
Testing in the current configuration shows that the total control room in-leakage, including the small leakage through this path, is within the in-leakage assumed in the analysis. A modification has been proposed to reroute the chiller drains to the floor drains which have a loop seal.
Based on this clarification the reviewer indicated that he had sufficient information. No further action is needed from PINGP.