ML100082195
| ML100082195 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 01/07/2010 |
| From: | Harris B License Renewal Projects Branch 1 |
| To: | License Renewal Projects Branch 1 |
| References | |
| Download: ML100082195 (8) | |
Text
January 7, 2010 MEMORANDUM TO: File FROM: Brian K. Harris, Project Manager /RA/
Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation
SUBJECT:
DOCKETING OF NOVEMBER 12, 2009 NRC TELECONFERENCE NOTES PERTAINING TO THE LICENSE RENEWAL OF THE DUANE ARNOLD ENRGY CENTER This Memorandum makes the following enclosed correspondence publicly available:
NRC License Renewal Teleconference - November 12, 2009
Enclosures:
As stated
ML100082195 OFFICE PM:RPB2:DLR NAME BHarris DATE 1/07/10
Memorandum File, from B. Harris dated, January 7, 2010
SUBJECT:
DOCKETING OF NOVEMBER 12, 2009 NRC TELECONFERENCE NOTES PERTAINING TO THE LICENSE RENEWAL OF THE DUANE ARNOLD ENRGY CENTER HARD COPY:
DLR R/F
Summary of Discussion with NRC Date 11/12/2009 Time 10:30 CST Location: Telephone Participants:
NRC* DAEC Brian Harris Ken Putnam Juan Uribe Curt Bock Cliffird Doutt Ken Chew Meena Khanna Mike Fairchild Seung Min John VanSickel Naeem Iqbal Mike Fetzer Emma Wong Bill Bryant Thomas Morgan Clara Rushworth Daniele Oudinot Bob Vincent Topic: Miscellaneous license renewal questions from NRC review of LRA and RAI responses
References:
As noted in summary Main Points of Discussion:
Fire Protection - Partition between computer room and control room The 1981 NRC SER on fire protection discussed a planned modification to add a one-hour rated glass partition between the computer room and the control room. DAEC's response to RAI 2.3.3.11-4 in letter dated 9/3/09 did not address this glass partition. DAEC explained that the glass partition had not been installed, but a wall constructed of metal studs covered with gypsum board was installed instead. This gypsum wall is described in the RAI response. NRC requested clarification whether or not this wall is one-hour fire rated. DAEC confirmed that it is.
NRC requested that this clarification be docketed.
ACTION: DAEC to clarify response to previous RAI to indicate that subject wall is one-hour fire rated. Clarification is to be included in letter responding to AMR RAIs.
Boral in spent fuel racks Discussion centered on an anticipated DAEC commitment to perform blackness testing on PaR racks. DAEC requested a sample of commitment language that NRC has found acceptable.
NRC indicated that a commitment similar to Vogtle's is desired, but with more specific language to indicate that neutron attenuation testing is the primary test to be performed. NRC was not aware of anyone performing in situ testing of Boral that could help define acceptable test methodology, but suggested that recent test experience at Palisades be considered as the DAEC method is developed.
ACTION: DAEC to provide draft commitment language to NRC for review before new commitment is docketed.
Stoplogs LRA Table 3.5.2-5 lists steel stoplogs as a component type, and the response to RAI 2.4.2-1 in letter of 10/1/09 indicates that treated wood stoplogs are also used. NRC requested a list showing where stop logs of each type were used. DAEC agreed to include the list of stop log locations in this conference call summary. The list is as follows:
DAEC FLOOD CONTROL STOPLOGS DOOR BUILDING TYPE 225 - Access Control Reactor Building Timber -Treated 239 - RR Airlock (large) Reactor Building Timber -Treated 124 - N. Rollup Turbine Building Timber -Treated 154 - N. TB to Yard Turbine Building Timber -Treated 137 - S. TB Rollup Turbine Building Timber -Treated 136 - Stairwell 14 to Yard Turbine Building Timber -Treated 421 - Battery Corridor to Admin Control Building Timber -Treated Bldg
- 805 - LLRSP Low Level Radwaste Storage Steel and Processing (LLRSP)
- 806 - LLRSP Storage area LLRSP Steel
- 846 - LLRSP Stairwell #4 LLRSP Steel 500 - Pump House Entry Pump House Timber -Treated 243 - Offgas to Yard Recombiner Building Timber -Treated
- Steel stoplogs are only used for flood barriers at the Low Level Radwaste Storage and Processing Building (LLRSP) which is not required for safe-shutdown.
Therefore, the steel stoplogs are not-in-scope of License Renewal. (Note: As discussed in the 11/12/09 teleconference, the LLRSP is in-scope only for a(3) for Fire Protection, since a fire main goes through the structure to the Reactor Building.)
DAEC clarified that steel stoplogs are only used in the Low Level Radwaste Building and do not protect equipment required for safe shutdown. The line item for steel stop logs in Table 3.5.2-5 really only includes steel bracing, brackets, etc. used to install the treated wood stoplogs.
ACTION: DAEC to clarify the component description in Table 3.5.2-5 to indicate it only includes steel support materials for wood stoplogs and not the steel stoplogs themselves. Clarification is to be included in letter responding to AMR RAIs.
NRC questioned the basis for the DAEC conclusion that wood stoplogs treated with creosote and stored indoors, as indicated in the response to RAI 2.4.2-1, has no aging effects that require management. DAEC reiterated that the subject wood timbers (cross section ~6" x
~12"), treated with creosote and stored indoors, would last well in excess of the plant life.
DAEC agreed to provide references to supporting information in this conference call summary.
Two representative references for wood treated with creosote and exposed to an outdoor weather or submerged environment (more severe than the indoor environment applicable here) are publicly available on the internet at the following locations:
- 1. A Cost-Benefit Analysis of Creosote-treated Wood vs. Non-Treated Wood Materials, page 2, Product Longevity, "Treated wood utility poles have been shown to provide useful lives of 75 years or more".
http://creosotecouncil.org/pdf/CCIII_Cost-BenefitAnalysis.pdf
- 2. Field tests of timber railroad bridge piles, page 3, Deterioration of Piles, "If timber species are kept at low temperatures and completely dry, then it could remain immune for more than a hundred years".
http://txspace.tamu.edu/handle/1969.1/1357 Reactor Water Cleanup System Prior to the conference call, several RWCU discussion items related to the DAEC responses to RAIs B3.11-1 and B.3.11-2 (letter dated 10/13/09) were identified in an email from Brian Harris to Ken Putnam dated 11/9/09. These items were discussed during the call. DAEC agreed to include summaries of the responses provided in this conference call summary. The listing of discussion items and summary responses are attached.
DAEC also indicated that the description of the BWR Reactor Water Cleanup System Program in LRA Section B.3.11 and the corresponding FSAR summary in LRA Appendix A, section 18.1.11, should be clarified to clearly indicate that the RWCU System meets the three criteria for inspection schedule A. In addition, the exception related to inspection scheduling identified in the program description is not needed and will be withdrawn. Conforming changes to reflect the withdrawal of the exception will be made to all affected sections of the LRA.
ACTION: DAEC to submit changes to LRA Sections B.3.11 and 18.1.11 (plus others as needed) to reflect the above discussion and remove the exception. Changes are to be included in letter responding to AMR RAIs.
Sealants in Primary Containment HVAC NRC noted that DAEC response to RAI 2.3.3.18-1 (letter dated 9/3/09) did not address sealants. DAEC explained that the generic responses for sealants provided in RAIs 2.3.2.6-1, 2.3.3.2-1, 2.3.3.20-1 and 2.3.3.23-1 are also applicable here.
ACTION: DAEC to amend RAI 2.3.3.18-1 response to incorporate the same generic statements for sealants that were provided in the other responses. Changes are to be included in letter responding to AMR RAIs.
Inconsistent use of terms "significant moisture" and "significant voltage" NRC noted that the DAEC response to RAI B.3.27-3 (letter dated 10/13/09) brought LRA terminology for the Appendix B program description into conformance with GALL terminology
"significant moisture," but the Appendix A description of the program also needs a change to be consistent. NRC indicated that their real intent is to have the terminology in the LRA Appendix B program description, the Appendix A FSAR description and the program basis document consistent with the terminology "significant moisture" and "significant voltage" as they appear in GALL tables and program descriptions. NRC noted that a new RAI B.3.27-7 was being processed for this matter.
ACTION: NRC to issue new RAI B.3.27-7.
ACTION: DAEC to expand the response to new RAI B.3.27-7 as needed to provide consistent usage of these terms in overlapping areas of all relevant documents.
Actions:
FPLE/DAEC: As noted above NRC: None Summary: N/A Disposition of Summary of Discussion with NRC:
- 1) Summary for internal use _____
- 2) Meeting summary with copy provided to NRC __X
- 3) Docketed letter related to meeting
Teleconference Call with DAEC Regarding the RWCU System Program
[NOTE: This list of questions was provided to DAEC by email on 11/9/09. DAEC Summary Responses are shown in blue]
Date: November 3, 2009 Location: O-14B10 At least, one more teleconference call is required to receive and discuss the applicants information.
In its response to RAI B.3.11-1, the applicant stated that the leaking 3 long by 3/4 Type 304 SS pipe nipple was removed and was replaced with a longer, Type 304L stainless steel nipple.
- 1) Does the description mean that the outer diameter of the pipe nipple is 3/4?
The 3/4 is the standard nominal pipe size.
- 2) Describe the configuration of the nipple in more detail including the components to which the pipe nipple is connected or welded.
The following drawing extract & discussion are provided:
In its response to RAI B.3.11-2, the applicant stated that all the Category G welds were replaced with resistant materials.
- 3) Please, state what materials were used for the replacements of piping and welds, respectively.
Piping base materials:
All piping line class CCC resistant material per the Duane Arnold Piping Class sheet and the RWCU piping isometrics ISO-CCC-003-01, ISO-CCC-006-01 and ISO-CCC-007-01 is SA312 TP316L.
Weld materials:
The weld material per Engineering Evaluation NCR 90-025 is ER308L filler wire.
In its response to RAIs B.3.11-2 and B.3.11-3, the applicant stated that the applicants Schedule for the inspection of the RWCU system outboard piping is Schedule A (no inspection recommended) in accordance with the GALL Report as the applicant completed all actions requested in NRC GL 89-10 and piping is made of material that is resistant to SCC. In contrast, the applicant stated that portions of the RWCU system outboard piping are classified as IGSCC Category D, which means non-resistant piping and welds. The foregoing statements of the applicant are in conflict with each other.
- 4) How many welds belong to the IGSCC Category D welds? Clarify why the applicant claims the applicants Schedule for the inspection is Schedule A in the RWCU System Program although the RWCU system has non-resistant welds (IGSCC Category D welds) outboard of the second isolation valves.
The number of the IGSCC Category D welds is 29 Category D welds.
The DAEC Reactor Water Cleanup System Program meets the all three of the NUREG-1801 GALL screening criteria as follows:
a) Satisfactory completion of all actions requested in NRC GL 89-10.
b) No detection of IGSCC in RWCU welds inboard of the second isolation valves (ongoing inspection in accordance with the guidance in NRC GL 88-01, and c) No detection of IGSCC in RWCU welds outboard of the second isolation valves after inspecting a minimum of 10% of the susceptible piping.
Based upon the screening criteria above, DAEC complies with NUREG-1801 GALL Schedule A requirements as followed:
Schedule A: No inspection is required for plants that meet all three criteria set forth above, or if they meet only criterion (a). Piping is made of material that is resistant to IGSCC, as described above in preventive actions.
DAEC is consistent with the Generic Letter 88-01 and therefore will not take an exception to the program.
The GL 89-10 program for DAEC was completed per letter NG-95-2546 on August 11, 1995.
- 5) In relation to RAI B.3.11-2 and the GALL-Report-recommended criteria to determine an inspection schedule, clarify whether IGSCC has been detected in the inboard and outboard portions of the RWCU system piping.
As for the inboard piping:
Has been IGSCC detected in the inboard portion?
Since the implementation of GL 88-01 no IGSCC on the inboard portion of the RWCU piping has been found.
As for the outboard IGSCC-resistant piping:
Has been IGSCC detected in the outboard IGSCC-resistant piping after the piping replacement?
Previously discussed CAP010488 documented leakage from the heat affected zone weld by valve V-27-0180 as shown on the 3/4 piping detail above. This failure in 1994 was attributed to a specific fabrication deficiency that involved re-welding on each end of a short nipple that resulted in sensitization of the pipe.
This configuration was eliminated. A review for similar configurations was performed. Configurations that were deemed to be sufficiently similar to merit concern were also replaced. Welding standards for the site were revised to reduce the potential for this configuration in the future. There has been no subsequent recurrence since 1994. Given that the configuration of concern was eliminated, this operating experience does not warrant a change in inspection frequency of other piping.
Since the implementation of 88-01 no IGSCC on the outboard portion of the RWCU piping has been found.
As for the outboard non-IGSCC-resistant piping (IGSCC Categorization D welds):
Has been IGSCC detected?
No During RFO -14 and RFO-15 10% of the Category D welds were inspected during each outage. No indication of IGSCC has been observed. Inspections are no longer required since the completion of the 89-10 program per Generic Letter 88-01, Supplement 1.
When was the last inspection performed?
10% of the Category D welds were inspected during RFO-15 in 1998.
What was the examination method and extent?
UTs were performed on 10% (3 welds) of the Category D welds in RFO-14 and in RFO-15.
In its response to RAI B.3.11-3 (Part 2), the applicant also stated that DEAC does not perform augmented ISI inspections on piping outside of the second isolation valve to the inspection frequency as required by GL 88-01 and follows the guidance in BWRVIP-75. The statement suggests that the applicant performs inspections on the piping outside of the second isolation valve. The staff also noted that BWRVIP-75 recommends IGSCC Category D welds to be inspected at a frequency of 100% every 6 years.
- 6) Clarify whether the applicants program performs inspections on the IGSCC Category D welds in accordance with BWRVIP-75 in the applicants BWR RWCU System Program.
The applicant needs to revisit the LRA and RAI response.
The DAEC Reactor Water Cleanup System Program meets the all three of the NUREG-1801 GALL screening criteria as follows:
a) Satisfactory completion of all actions requested in NRC GL 89-10.
b) No detection of IGSCC in RWCU welds inboard of the second isolation valves (ongoing inspection in accordance with the guidance in NRC GL 88-01, and c) No detection of IGSCC in RWCU welds outboard of the second isolation valves after inspecting a minimum of 10% of the susceptible piping.
Based upon the screening criteria above, DAEC complies with NUREG-1801 GALL Schedule A requirements as followed:
Schedule A: No inspection is required for plants that meet all three criteria set forth above, or if they meet only criterion (a). Piping is made of material that is resistant to IGSCC, as described above in preventive actions.
DAEC is consistent with the Generic Letter 88-01 and therefore will not take an exception to the program.
The 89-10 program was completed per letter NG-95-2546 on August 11, 1995.
In its response to RAI B.3.11-3, the applicant stated the DEAC Chemistry BWRVIP Program manages the effect of stress corrosion cracking (SCC) and IGSCC on all piping in the RWCU system.
- 7) Clarify what it means by the Chemistry BWRVIP Program in terms of the programs credited in the License Renewal Application.
The aging management program is the Water Chemistry Program.
- 8) Clarify whether a one-time inspection will be performed on the RWCU system outboard piping in order to ensure that the water chemistry program is effective to manage IGSCC and IGSCC is occurring very slowly or not occurring in the RWCU system outboard piping so as not to affect the intended function of the piping.
The RWCU system outboard piping is managed by the Water Chemistry Program and the One Time Inspection Program for loss of material. Any as-found degradation is evaluated using the CAP process.
The One-Time Inspection Program selects the most susceptible components from a grouping of components with the same material and environment and inspects for the potential aging mechanisms.