ML091400471
| ML091400471 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 06/29/2005 |
| From: | - No Known Affiliation |
| To: | Office of Information Services |
| References | |
| FOIA/PA-2009-0070 | |
| Download: ML091400471 (21) | |
Text
Go Back Print New Search I Home AR Number: 00348545 Aff Fac:
Oyster AR Type:
CR Status:
COMPLETE Creek Aff Unit:
.01 Owed To:
A5330CAP Due Date:
03/02/2007 Aff System: 243 Event 06/29/2005 Date:
CR 4/D Disc Date:
06/29/2005 Level/Class:
How H02 Orig Date:
06/29/2005 Discovered:
Action Request Details MONITORING OF LEAKAGE FOR CONCERNS OF DRYWELL
Subject:
CORROSION
==
Description:==
. Originator: THOMAS E QUINTENZ Supv Contacted: John O'Rourke Condition
Description:
In a December 5, 1990, letter to the NRC Oyster Creek committed to a routine walkdown to identify changes in leakage from the sand bed drains.
In review of operator rounds, recurring tasks, and interview of knowledgeable personnel at the Oyster Creek site the is no evidence the routine walkdown is being implemented. This appears to be a commitment which needs to be verified, and if confirmed should be implemented, or a change made in the commitment.
Immediate actions taken:
Discussed this with the Primary Containment System Manager and Operations to determine if the walkdowns discussed have been completed. It was determined the walkdowns were done at some earlier years but are no longer done as part of routine activities.
Recommended Actions:
Research this commitment to determine if it is still required and take appropriate actions to assure they are completed per the commitment.
What activities, processes, or procedures were involved?
Review of regulatory correspondence during preparation of the License Renewal Application.
Why did the condition happen?
Not known at this time.
What are the consequences?
May be a missed commitment Were any procedural requirements impacted?
Not known at this time.
Were there any adverse physical conditions?
None identified List of knowledgeable individuals:
Bob Barbieri Repeat or similar condition?
Not known at this time.
Operable Basis:
The containment is fully operable and has passed all required testing currently.
Reportable Basis:
Licensing should have an activity to determine if missing this committment is reportable.
SOC Reviewed by: JOHN F MURPHY 06/30/2005 09:37:16 CDT SOC Comments:
ACIT to reg assurance for reportability.
WGE to System Manager to determine plan going forward.
Department review performed by: ROBERT J BARBIERI 07/13/2005 10:46:30 CDT Evaluation Comments:
Condition/Problem Statement:
A commitment was made to the NRC to perform periodic walkdowns to inspect for leakage. These walkdowns were performed and documented up to refueling outage 17R. No documentation exists after 1 7R.
Statement of Cause:
Up to 17R, leakage inspections were treated as a project. A project manager was assigned and specific funding was obtained for each outage.
After 17R, this no longer occurred. A specific PM should have been created to ensure that this work was performed each refueling outage.
Extent of Condition:
These inspections are only for leakage during refueling outages which could affect the drywell shell. One other associated issue is to perform a camera inspection of the drain line from the Reactor Cavity Trough, which is a major cause of leakage affecting the drywell shell. This drain line must be kept free of debris to ensure that leakage through the cavity liner drains effectively to keep water from pooling and running down the side of the drywell. A PM needs to be created to ensure that this activity is performed every refueling outage.
Evaluation of any SOC Comments:
Assign #01>
AR #: 00348545.
Aff Fac:
Oyster Creek Assign TRKG Status:
COMPLETE Type:
Priority:
Assigned Due Date:
07/15/2005 To:
Schedule Prim Grp:
ACAPALL Orig Due Ref:
Date:
Unit Sec Grp:
Condition:
Assignment Details
Subject/Description: MONITORING OF LEAKAGE FOR CONCERNS OF DRYWELL CORROSION Assignment Completion In Progress Notes:
Completion Notes:
Assign H:02 AR #.0,0348545, Aff Fac:
Oyster Creek Assign ACIT Status:
COMPLETE Type:
Priority:
Assigned U777DIF Due Date:
08/23/2005 To:
Schedule Prim Grp:
A5301RAPR Orig Due 07/15/2005 Ref:
Date:
Unit Sec Grp:
Condition:
Assig-nment Details Subject/Description: Review DW sand bed inspection issue for reportability.
A,,Assignment Completion In Progress 7/15/05-WVS: Extended due date from 7/15/05 to 8/19/05.
Notes:
This event is not reportable. Currently there does not appear to be any specific commitment to inspect the sandbed region drains for water leakage during power operation. However, a commitment does exist (see Section 3.8.2.8 of the UFSAR) to take corrective actions if water leakage is discovered during power operation. Given that commitment, it appears reasonable to expect that some activity would exist for assessing and determining when those corrective actions are required including specific
criteria for the amount of leakage, trending of data and thresholds for further evaluation.
The original commitment cited in this AR Description has been changed over the years through a continual exchange of correspondence with the NRC.
Item (7) listed below appears to serve as the source of our current commitment to the Drywell Corrosion Monitoring Program (clarified by GPUN on December 15, 1995). This commitment was added to Section 3.8.2.8 of the UFSAR in Update 10, April 1997 and is therefore part of our design basis documentation.
Background Information:
The following correspondence was located in Oyster Creek Licensing File
- 86311 and is provided here as background.
(1) GPUN letter to the NRC (C320-90-302) dated 12/5/1990 stated that the DW sand bed drains were inspected by routine walkdowns to identify any changes in leakage.
This statement was apparently not captured in any existing commitment tracking database (CTD) program and was not added to the current CTD when it was created in the mid nineties. Over the years, our inspection program concerning drywell corrosion monitoring has changed as the result of corrective actions taken to mitigate the concern with the effects of moisture in the sand bed region on drywell integrity.
(2) GPUN letter to the NRC (C321-92-2163) dated 5/26/1992 states, in part, that we commit to continue taking UT drywell measurements at refueling outages and at other outages of opportunity. Drywell thickness measurements will continue for the life of the plant. During 14R outage we
will'take UT thickness measurements in the drywell sandbed region, once we have access to the sandbed region.
After the 15R outage, we will assess the condition of the drywell be evaluating the then current UT thickness measurements and will formulate an extended inspection plan. The plan will identify measurement locations including frequency of inspection for the remaining life of the plant.
(3) NRC letter to GPUN (TAC No. M79166) dated 6/30/1992 confirmed our drywell corrosion monitoring program commitments from the May 26, 1992 letter as acceptable.
(4) GPUN letter to the NRC (C321-93-2100) dated 3/25/1993 acknowledged the NRC letter of 6/30/1992 and confirmed our commitment to inform the NRC prior to implementing any changes to the Oyster Creek drywell thickness measurement inspection program.
(5) GPUN letter to the NRC (C321-95-2235) dated 9/15/1995 provided a description of the planned. changes to the inspection program based on inspections performed during the 15R outage. With regard to the sandbed region, assessment of the UT data determined that corrosion has been arrested as a result of cleaning the area of sand and rust and coating the drywell during the 14R outage in December 1992. The inspection program for the sandbed region was to perform a visual inspection of the external epoxy coating during the 16R outage and, as a minimum, during the 18R outage (year 2000). The epoxy coating has an estimated life of 8 - 10 years which makes the current projected end of life between December 2000 and December 2002. A technical assessment of the coating will be made
based on the 18R outage inspections to determine additional (post 18R) inspection criteria.
(6) NRC letter to GPUN (TAC No. M93658) dated 11/1/1995 confirmed our changes to the drywell corrosion monitoring program commitments from the September 15, 1995 letter as acceptable, but requested an additional commitment (since water leaking from the pools above the reactor cavity has been a source of corrosion) to perform additional inspection within approximately three months after the discovery of water leakage.
(7) GPUN letter to the NRC (C321-95-2360) dated 12/15/1995 provided our commitment for the following actions should water leakage not associated with normal refueling outage activities be discovered during power operation.
(1) NRC Resident Inspector will be notified of the discovery of leakage.
(2) The source of leakage will be investigated and appropriate corrective actions taken.
(3) An evaluation of the impact of the leakage on drywell structural integrity will be performed to ensure sufficient margin is maintained for operation to the next scheduled drywell inspection.
(4) In the unexpected event that the evaluation of the impact of the leakage on drywell structural integrity does not ensure sufficient structural margin will be maintained for operation to the next scheduled outage, an additional drywell inspection will be performed within approximately three months after discovery of the water leakage.
(8) NRC letter to GPUN (TAC No. M92688) dated 2/15/1996 confirmed our commitment as stated in the December 15, 1995 letter as acceptable.
Completion Notes:
A~ssign #: 03 AR #: 00348545 Aff Fac:
Oyster Creek Assign ACIT Status:
COMPLETE Type:
Priority:
Assigned U777RJB Due Date:
10/26/2005 To:
Schedule Prim Grp:
A5330NESTE Orig Due 10/26/2005 Ref:
Date:
Unit Sec Grp:
Condition:
ý,Assignment Details Subject/Description: Create 2 new PM's to ensure inspections are performed eac h refueling outage to inspect key areas for leakage from the Reactor Cavity. One PM will be to perform w alkdowns to inspect for leakage. The other will be t o perform a camera inspection of the cavity trough d rain line prior to and during each refueling outage.
Assignment Completion In Progress Closeout comments: Two PIMS Evals were created and assigned to Notes:
the PM coordinator. They are A2014243, E80 and E81, which request new PM's to perform the required inspections. These evals were prepared in accordan6e with procedure MA-MA-716-009.
Completion Notes:
Assign #: 04 A R #:"00348545"ý Aff Fac:
Oyster Creek Assign CA Status:
COMPLETE Type:
Priority:
Assigned U999FGA Due Date:
11/28/2005 To:
Schedule Prim Grp:
A5340WC Orig Due 11/28/2005
Ref:
Date:
Unit Sec Grp:
A5340CAP Condition:
Assignm nt-De'tails7 Subject/Description: PM coordinator to create"2 new PM tasks from assignment # 3.
Contact system manager for any questions.
AAssignmentCompletion.-.
In Progress Notes:
- COMPLETE FOLLOWING STEPS PRIOR TO COMPLETION OF ASSIGNMENT****
- 1. Prior to start of work on the completion of any CA, ensure you have reviewed the associated CR, investigation, this assignment, and if necessary contact the originator to ensure a complete understanding of the requested action.
- 2. Implement the requested actions. (e.g. Procedure should be implemented not submitted for change)
- 3. Document completion of action by completing each field in the following form or marking NA.
- 4. Additional guidance is provided by:
Clicking Here Record of Extensions None, there were no extensions.
Note: Record the date, justification and approval received for each extension Document Corrective Action and the Resolution:
IR 348545 documented that In a December 5, 1990, letter to theNRC Oyster Creek committed to a routine walkdown to identify changes in leakage from the sand bed drains. In review of operator rounds, recurring tasks, and interview of knowledgeable personnel at the Oyster Creek site the is
no evidence the routine walkdown is being implemented. This appears to be a commitment which needs to be verified, and if confirmed should be implemented, or a change made in the commitment.
Discussed this with the Primary Containment System Manager and Operations to determine if the walkdowns discussed have been completed. It was determined the walkdowns were done at some earlier years but are no longer done as part of routine activities. A Corrective action was made to generate two new PMs to insure the inspections are made during refuel outagesPer procedure MA-MA-716-009 "Preventative Maintenance Work Order Process" PIMs Evals A2014243.80 and A2014243.81 were made to Work Management to create the shells for the PMs.
Eval A2014243.80 will perform inspections during refuel outages to check for leakage from the reactor cavity.
Eval a2014243.81 will perform camera inspections of the reactor cavity drain line both before and during the refuel outage. This drain line is a major factor in minimizing leakage, which effects drywell corrosion rate.
The PM shell was generated by the PM Coordinator. PM 18703M were generated for eval A2014243.81. PM 18704M was generated for eval A2014243.80. Per Procedure MA-MA-716-009 requirements the evals were reassigned to Maintenance Planning to develop the PMs. New Passport CA 348545-5 was made to track development of the PMs to completion.
Note: Restate the requested action and clearly document the implementation of the Corrective Action to the requirements of LS-AA-125.
"That which is not documented is not done."
Document any changes to the intent of the original Actions (Include appropriate Department Head Approval):
There were no changes to the original intent of this CA.
Note: Document any deviation from the specific action and document the name of the Senior Manager/Director that authorized the deviation.
Document additional assignment determined during evaluation:
New Passport CA 348545-5 was made to track development of the PMs to completion (see above).
Note: Do not close to a promise -CA Type Assignments can only be closed to another CA Type Assignment on a CR.
Quality Signoff: Name: Ron Baran & Frank Aller Date: 11/22/2005 Note: Document the name of the person who is accountable for the completion of this assignment DOCUMENT ADDITIONAL DETAILS HERE:
Completion Notes:
Assign #: 05 AR #.,00348545 Aff Fac:
Oyster Creek Assign CA Status:
COMPLETE Type:
Priority:
Assigned U777RJB Due Date:
08/28/2006 To:
Schedule Prim Grp:
A5330NESTE Orig Due 04/01/2006 Ref:
Date:
Unit Sec Grp:
Condition:
A ssignm~ent Details
Subject/Description: Develop PMs 18703M & 18704M to inspect the DW liner A nsignmn-t Co6m pletion.
In Progress
- COMPLETE FOLLOWING STEPS PRIOR TO COMPLETION Notes:
OF ASSIGNMENT****
- 1. Prior to start of work on the completion of any CA, ensure you have reviewed the associated CR, investigation, this assignment, and if necessary contact the originator to ensure a complete understanding of the requested action.
- 2. Implement the requested actions. (e.g. Procedure should be implemented not submitted for change)
- 3. Document completion of action by completing each field in the following form or marking NA.
- 4. Additional guidance is provided by clicking here..:
Clicking Here Record of Extensions: (Note: Record the date, justification and approval received for each extension)
- 1. Please change the due date to 7/30/06. I have worked exclusively on the Tritium project and License Renewal for the last three weeks. The PM's have been created, but the planning needs to be done.
Extension request approved by S. Hutchins per telecom. J. Arvin 3/31/2006 Original Message -----
From: Hutchins, Steven P Sent: Wednesday, July 19, 2006 11:23 AM To: Barbieri, Robert J Cc: Frank, James E
Subject:
RE: Due Date Extensions Agreed.
Original Message -----
From: Barbieri, Robert J Sent: Wednesday, July 19, 2006 11:16 AM To: Hutchins, Steven P Cc: Frank, James E
Subject:
Due Date Extensions
- Steve, This is to request due date extensions for the following:
- 2. 348545 This task is to develop two PM's related to Drywell corrosion due to leakage. The 2 PM's have already been created and planned for 1 R2 1. However, they need some modifications to capture the license renewal commitments, as well as some details as to inspection locations.
Tom Quintenz has agreed to help with this task and submit the paperwork to revise the PM's.
current due date: 7/26/06 Proposed Due Date: 8/27/06 Document Corrective Action: (Note: Restate the requested action)
Develop PM's 18703M and 18704M to inspect the drywell liner.
Document the Resolution: (Note: Clearly document the implementation of the Corrective Action to the requirements of LS-AA-125 Attachment 3.
"That which is not documented is not done.")
PMs 18703M and 18704M have been developed to perform inspections to identify and mitigate leakage onto the drywell shell during refueling outages. Also, work orders R2088493 and R2088495 have been planned for 1R21. However, work order R2088495 needs to be revised to contain the correct scope of work. Two AR Evals have been assigned to planning to make the required changes. An assignment was made to planning for these changes. The assignment is 348545, assignment 07, and is due 9/15/06.
Document any changes to the intent of the original Actions (Include appropriate Department Head Approval): (Note: Document any deviation from the specific action and document the name of the Senior
Manager/Director that authorized the deviation)
NA Document additional assignment determined during evaluation:
(Note(s):
Do not close to a promise - CA Type Assignments can only be closed to another CA Type Assignment on a CR) 348545, 07 Quality Signoff: (Note: Document the name of the person who is accountable for the completion of this assignment.)
Name: R. Barbieri Date: 8/28/06 Document Additional Details here: NA Please revise due date.
This task is to develop two PM's related to Drywell corrosion due to leakage. The 2 PM's have already been created and planned for I R2 1.
However, they need some modifications to capture the license renewal commitments, as well as some details as to inspection locations. Tom Quintenz has agreed to help with this task and submit the paperwork to revise the PM's. Please change the due date to 8/27/06.
Completion Notes:
Assign #0 06 "AR" #: 003448545 5
Aff Fac:
Oyster Creek Assign ACIT Status:
COMPLETE Type:
Priority:
Assigned UOOOBP5 Due Date:
03/02/2007 To:
Schedule Prim Grp:
A5330NESTS Orig Due 09/30/2006 Ref:
Date:
Unit Sec Grp:
Condition:
Assignment Details Subject/Description:
Initiate eval for recurring task during operation Inititate an eval to create a recurring task for inspection for leakage during power operation in accordance with the commitment documented in the letter from the NRC dated February 15, 1996. This recurring task should check for leakage and if leakage is found provide direction for what actions are to -be taken. This should reference the commitment, and should be placed into commitment tracking with the Regulatory Assurance Dept.
Assignment Completion, In Progress Notes:
Activity
Description:
Initiate an eval to create a recurring task for inspection for leakage during power operation in accordance with the commitment documented in the letter from the NRC dated February 15, 1996. This recurring task should check for leakage and if leakage is found provide direction for what actions are to be taken. This should reference the commitment, and should be placed into commitment tracking with the Regulatory Assurance Dept.
Activity Completion: 2/27/07 Prepared by: BrookePorras, SM Completion Notes: PM18705M (AR A2143031) has already been created for this task on 05/06. Close IR.
Completion Notes:
- ,Assig H 0 AR #: 00348545, Aff Fac:
Oyster Creek Assign CA Status:.
COMPLETE Type:
Priority:
Assigned U777RCY Due Date:
09/15/2006 To:
Schedule Prim Grp:
A5325PLN Orig Due 09/15/2006 Ref:
Date:
Unit Sec Grp:
Condition:
_Assignment Details Subject/Description: Revise work order R2088495 Revise WO R2088495 for 1R21 to incorporate work scope identified in AR A2127016, Eval 1.
Please also incorporate contents of AR A2133631, Eval 4 for license renewal commitments. These requirements should also be incorporated into the Library copy.
Assignment Completion.
In Progress
- COMPLETE FOLLOWING STEPS PRIOR TO COMPLETION Notes:
OF ASSIGNMENT****
- 1. Prior to start of work on the completion of any CA, ensure you have reviewed the associated CR, investigation, this assignment, and if necessary contact the originator to ensure a complete understanding of the requested action.
- 2. Implement the requested actions. (e.g. Procedure should be implemented not submitted for change)
- 3. Document completion of action by completing each field in the following form or marking NA.
- 4. Additional guidance is provided by clicking here..:
Clicking Here Record of Extensions: (Note: Record the date, justification and approval received for each extension)
N/A Document Corrective Action: (Note: Restate the requested action)
Revise WO R2088495 for 1R21 to incorporate work scope identified
in AR A2127016, Eval 1. Please also incorporate contents of AR A2133631, Eval 4 for license renewal commitments.
These requirements should also be incorporated into the Library copy.
Document the Resolution: (Note: Clearly document the implementation of the Corrective Action to the requirements of LS-AA-125 Attachment 3.
"That which is not documented is not done.")
Revised WO R2088495 as requested Document any changes to the intent of the original Actions (Include appropriate Department Head Approval): (Note: Document any deviation from the specific action and document the name of the Senior Manager/Director that authorized the deviation)
N/A Document additional assignment determined during evaluation:
(Note(s):
Do not close to a promise - CA Type Assignments canonly be closed to another CA Type Assignment on a CR)
N/A Quality Signoff: (Note: Document the name of the person who is accountable for the completion of this assignment.)
Name: Robert Yarnes Date: 9/05/06 Document Additional Details here:
Completion Notes:
Assign #:l08 Aff Fac:
Oyster Creek Assign ACIT Status:
COMPLETE Type:
Priority:
Assigned U777RJB Due Date:
09/13/2006 To:
Schedule Prim Grp:
Orig Due 09/13/2006 Ref:
Date:
Unit Sec Grp:
Condition:
Assignment Details-Subject/Description: Evaluate impact of water found in bottles Evaluate the impact of the leakage on the drywell structural integrity to ensure sufficient structural margin is maintained for operation to the next scheduled drywell inspection AXSSinment Completion In Progress Based on a December 15, 1995 letter from GPUN to NRC, the Notes:
following commitments were made:
If, during power operation leakage is discovered, we will:
- 1. Notify NRC Resident
- 2. Investigate source of leakage and corrective actions will be taken
- 3. Evaluate the impact of leakage on DW structural integrity, to ensure sufficient structural margin is maintained for operation to the next scheduled DW inspection.
- 4. If effects on structural integrity do not ensure adequate margin to operate to next outage, we will perform additional DW inspections within approximately 3 months after discovery of water leakage.
During preparation for NRC AMP Inspection for long term operation
and license renewal, OC self identified that on line inspections weren't occurring since around 2000.
This was entered in the CAP system as a deficiency under IR 348545 by the License Renewal team. The letters between NRC and GPUN were reviewed and the above summary of known commitments is accurate, as stated in the Dec 15, 1995 letter.
PMs were put in place to start doing quarterly "at power" monitoring (PM 18705M), to perform an, outage monitoring and assessment plan(PM18704M),
and to look at the condition of the trough prior to and during the refueling process (PM1 8703M). These PMs are currently in place.
In March12006, an informal walk-down was performed by the system engineer to assess our current program, as a part of NRC inspection readiness for a license renewal AMP inspection. Presence of water was found in 3 of 5
bottles (Approximately 15 gallons) and was documented in IR 470325.
Further inspection indicated that there was no active leak. There were no signs of water on the floor or drywell wall and there was no observed flow of water through the tubing.
Based on review of past inspection reports, and known lack of a PM to.
empty the bottles, it is likely that this water was from the previous 3 refueling outages. The bottles were emptied as a means of ongoing monitoring to verify that an active leak was not present and to confirm that the most likely source was from past outage activities. Since March 2006, there have been 5 inspections of the bottles contents (Not all formally documented) and no new water has been found in the bottles.
Tubing to the bottles was inspected for active flow and none was found.
Therefore, we are in compliance with the following commitments:
- 1. NRC is aware of current condition
- 2. ID source of leakage: based on ongoing inspections - there is no active leakage. A sample of residual water left in bottle after emptying, showed no activity levels, which provides further indication that there is not an active leak. This suggests that the water collected in the past during refueling outages is most likely due to condensation collecting on steel surfaces, as the entire plant cooled down during shut down.
- 3. Based on the above indicators that there is no current active leak when the plant is at power, and the minimal amount of water collected over a
long period of time, it is unlikely that this has contributed to any appreciable drywell corrosion. The amount of water (15 gallons maximum) that was found is insignificant when compared to the amount of water found in the mid 1980's when sand bed corrosion was initially found (Hundreds of gallons). In addition, the conditions of the Drywell vessel during operation are at elevated temperature (Greater than 140 degrees). This would dry remaining small amounts of moisture that could collect on the surface of the Drywell vessel. Expected corrosion rates for these conditions are less than a mil per year, which has been verified by ongoing inspections of the Drywell vessel, as recently as 2004 (20R).
Based on Engineering Judgment, structural margin is maintained until the next inspection (1 R21).
- 4. Since adequate margin is maintained, no inspection is required until 1 R2 1.
References:
- September 15, 1995-Letter from GPUN to NRC
- November 1, 1995 letter from NRC to GPUN
- December 15, 1995 letter from GPUN to NRC A peer review of this evaluation has been performed by P. Tamburro.
Completion Notes: