ML12042A104

Lr - DB Teleconference Summary for Your Review

ML12042A104
Person / Time
Site:	Davis Besse
Issue date:	01/18/2012
From:	Office of Nuclear Reactor Regulation
To:	Division of License Renewal
References
Download: ML12042A104 (11)

Text

Davis-BesseNPEm Resource From: CuadradoDeJesus, Samuel Sent: Wednesday, January 18, 2012 1:22 PM To: dorts@firstenergycorp.com Cc: custerc@firstenergycorp.com; Davis-BesseHearingFile Resource

Subject:

DB Teleconference Summary for your review Attachments: 7 19 2011 DB NRC Telecon Summary.docx Importance: High

Steve, Please let me know if you have any comments.

Regards, Samuel Cuadrado de Jesús Project Manager Projects Branch 1 Division of License Renewal U.S. Nuclear Regulatory Commission Phone: 301-415-2946 Samuel.CuadradoDeJesus@nrc.gov From: CuadradoDeJesus, Samuel Sent: Wednesday, January 18, 2012 1:16 PM To: Medoff, James

Subject:

DB Teleconference Summary for your review Importance: High

Jim, Can you please review and let me know if you have any comments by COB Thursday 19?

Thanks, Samuel Cuadrado de Jesús Project Manager Projects Branch 1 Division of License Renewal U.S. Nuclear Regulatory Commission Phone: 301-415-2946 Samuel.CuadradoDeJesus@nrc.gov 1

Hearing Identifier: Davis_BesseLicenseRenewal_Saf_NonPublic Email Number: 3425 Mail Envelope Properties (377CB97DD54F0F4FAAC7E9FD88BCA6D0806FD1566D)

Subject:

DB Teleconference Summary for your review Sent Date: 1/18/2012 1:22:15 PM Received Date: 1/18/2012 1:22:17 PM From: CuadradoDeJesus, Samuel Created By: Samuel.CuadradoDeJesus@nrc.gov Recipients:

"custerc@firstenergycorp.com" <custerc@firstenergycorp.com>

Tracking Status: None "Davis-BesseHearingFile Resource" <Davis-BesseHearingFile.Resource@nrc.gov>

Tracking Status: None "dorts@firstenergycorp.com" <dorts@firstenergycorp.com>

Tracking Status: None Post Office: HQCLSTR01.nrc.gov Files Size Date & Time MESSAGE 883 1/18/2012 1:22:17 PM 7 19 2011 DB NRC Telecon Summary.docx 37655 Options Priority: High Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

LICENSEE: FirstEnergy Nuclear Operating Company FACILITY: Davis-Besse

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON JULY 19, 2011 BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND FIRSTENERGY NUCLEAR OPERATING COMPANY, CONCERNING REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO THE DAVIS-BESSE, LICENSE RENEWAL APPLICATION (TAC. NO. ME4640)

The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of FirstEnergy Nuclear Operating Company (FENOC or the applicant) held a telephone conference call on July 19, 2011, to discuss and clarify the applicants responses to the staffs requests for additional information (RAIs) concerning the Davis-Besse, license renewal application. provides a listing of the participants and Enclosure 2 contains a description of the RAI responses and concerns discussed with the applicant, a brief description on the status of the items is also included.

The applicant had an opportunity to comment on this summary.

Samuel Cuadrado de Jesús License Renewal Branch, RPB1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Number:50-346

Enclosures:

1. List of Participants

2. List of Requests for Additional Information cc w/encls: See next page

DOCUMENT NAME: Insert document name and full path.

OFFICE LA:DLR PM:RPB1:DLR BC:RPB1:DLR NAME S Cuadrado de D Morey Jesús DATE / / / / / /

TELEPHONE CONFERENCE CALL DAVIS-BESSE LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS JULY 19, 2011 PARTICIPANTS AFFILIATIONS Samuel Cuadrado de Jesús U.S. Nuclear Regulatory Commission (NRC)

Ata Istar NRC Seung Min NRC Todd Mintz Cliff Custer FirstEnergy Nuclear Operating Company (FENOC)

Steve Dort FENOC Don Kosloff FENOC Trent Henline FENOC Allen McAllister FENOC Steve Osting FENOC Mark Swain FENOC Bob Smith FENOC Enclosure 1

REQUESTS FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION JULY 19, 2011 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of FirstEnergy Nuclear Operating Company (FENOC or the Applicant) held a telephone conference call on July 19, 2011, to discuss and clarify the following responses to requests for additional information (RAIs) concerning the license renewal application (LRA).

Response to RAI B.2.1-2

Background:

The applicant responded to the RAI B.2.1-1 by proposing to revise Subsection 2.1.2 of the Davis Besse Nuclear Power Station (DBNPS) Surveillance Test Procedure DB-PF-03009, Revision 06, "Containment Vessel and Shielding Building Visual Inspection." Revised Subsection 2.1.2 shall state "Personnel who performed general visual examinations of the exterior surface of the Containment vessel and the interior and exterior surfaces of the Shielding Building shall meet the requirements for a general visual examiner in accordance with Nuclear Operating Procedure NOP-CC-5708, Written Practice for the Qualification and Certification of Nondestructive Examination Personnel."

Issue:

Element 5 "Detection of Aging Effects" in GALL AMP XI.S4 recommends the implementation of periodic in-service examinations for the containment structures by applying the requirements of subsections in ASME Section XI. The associated Subsection IWE-3510.1 of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI (1995), requires that "The general Visual Examination shall be performed by, or under the direction of, a Registered Professional Engineer or other individual, knowledgeable in the requirements for design, in-service inspections, and testing of Class MC and metallic liners of Class CC components."

Request:

To comply with the ASME Code,Section XI requirement, the associated Subsection IWE-3510.1 of ASME Code,Section XI (1995) code requirement must be referenced in the new revision of the DBNPS's Nuclear Operating Procedure and/or Surveillance Test Procedure.

Discussion:

FENOC stated that, following receipt of the first RAI, procedures DB-PS-3009 (Vessel and Shield Building inspections) and NOP-CC-5708 were revised to identify code references for examiner qualifications, and that examiners are qualified in accordance with the applicable code. FENOC summarized the procedure requirements, and discussed the difficulty with including specific requirements for Davis-Besse in a procedure that applies to all FENOC Enclosure 2

plants. NRC stated that the 1995 addenda to the code is more stringent than later versions, which is why NRC wants the code section identified in the procedures. FENOC noted that NOP-CC-5708, Section 4.2.5, includes sections of the code copied directly into the procedure, and the FENOC is required by law to follow the code. NRC asked for a highlighted copy of the procedures showing the relevant sections. FENOC agreed to send the procedures by email.

Response to RAI 3.5.2.2.1.7-1

Background:

By letter dated May 2, 2011, the staff issued RAI 3.5.2.2.1.7-1 requesting that the applicant justify why the water leakage addressed in LRA Section 3.5.2.2.1.10 is not conducive to stress corrosion cracking of the stainless steel penetration sleeves and bellows. In its response dated June 3, 2011, the applicant stated that the below-grade leakage is due to a reoccurring issue of groundwater intrusion into the annulus between the containment and the shield building and a 2002 condition report identified that the two stainless steel bellows and flanges for the containment emergency sump recirculation valves had a rusty appearance. The applicant also stated that the corrective action directed sampling of the water and repairs to identify the source of the leakage. The applicant further stated that evaluation of the residue on the bellows identified that it contained calcium. In addition, the applicant stated that cracking due to stress corrosion cracking is not an applicable aging effect for these bellows because the normal temperature of these components is less than 60 °C (140 °F) and a review of plant operating experience confirmed that no other containment penetration bellows have been affected by groundwater intrusion and that cracking of penetration sleeves or bellows was not identified. In addition, the applicant stated that while cracking of penetration bellows and sleeves is not considered to be an applicable aging effect, these components are inspected by the Inservice Inspection Program - IWE.

The staff also noted that LRA Section 3.5.2.2.1.1 states that the below-grade environment at Davis-Besse is aggressive (chlorides > 500 ppm and sulfates > 1,500 ppm) and sampling results indicated a chloride content maximum value of 2,870 ppm and a sulfate content maximum value of 1,700 ppm.

Issue:

In its review, the staff noted that even though generally speaking stress corrosion cracking is not a significant concern at temperature lower than 140 F, there is a potential that evaporation of leaked ground water on the surfaces of the components may cause significant contamination with chloride or sulfate ions, which may have an adverse effect on the initiation of stress corrosion cracking of the components. Therefore, the staff found a need to further confirm whether or not the applicant identifies and performs necessary corrective actions to manage an adverse effect of ground water intrusion on stress corrosion cracking of the containment penetration components when the applicants operating experience (OE),

including OE related to the Inservice Inspection Program - IWE and 10 CFR Part 50, Appendix J Program, indicates ground water intrusion on the containment penetration components.

The staff also found a need to clarify whether or not chloride or sulfate contamination was identified in the applicants evaluation of the reside on the bellows that are addressed in the applicants response to RAI 3.5.2.2.1.7-1.

Enclosure 2

Request:

1. Describe whether or not the evaluation of the residue on the bellows, which are addressed in the applicants response to RAI 3.5.2.2.1.7-1, indicated the presence of chloride or sulfate contamination on the bellows. If data are available, describe the levels of chlorides and sulfates that were detected in the residue evaluation.

2. Confirm whether or not the applicant identifies and performs necessary corrective actions to manage an adverse effect of ground water intrusion on stress corrosion cracking of the containment penetration components when the applicants operating experience (OE), including the OE related to the Inservice Inspection Program - IWE and 10 CFR Part 50, Appendix J Program, indicates ground water intrusion on the containment penetration components.

In addition, describe what corrective actions are taken in order to control the adverse environmental effect when the applicants operating experience indicates ground water intrusion on the components.

Discussion:

Regarding Request #1, FENOC reviewed the condition report and relevant documentation from 2002, and stated that the leakage appeared to be groundwater intrusion due to the calcium residue, and was event-driven. Corrective action was taken to investigate, and the calcium appeared to be the result of calcium sulfate in the water. The two groundwater intrusion events described in the LRA operating experience were in the annulus area and not near any containment penetrations. The current groundwater intrusion is also not near penetrations.

Regarding Request #2, FENOC does not currently have a process for managing groundwater intrusion. Water is sampled where it is found during inspections. It appears that water leakage through walls tends to decrease over time, but not clear whether the water leakage has slowed or that it evaporates as it nears the surface, and the follow-up to that is related to any potential deterioration of any affected components.

NRC stated that they have a better understanding of the issues. FENOC clarified that, after further reading the condition report and drawing reviews, the bellows that has a flange is a vertical bellows, and the residue was found on the flange, and the vertical bellows appeared to have a rust stain color although there was no residue on the bellows. Since no source of leakage was identified, the components with residue were cleaned-up and no other corrective actions were taken. Staining of stainless steel surfaces is typically not cleaned under the Corrective Action Program. FENOC discussed the categories of corrosion in the Corrective Action Program, which are typically used for categorizing boric acid corrosion events.

NRC summarized the discussion:

Didnt check the level of chlorides Level of corrosion categorized and cleaned as necessary IWE inspections would identify degradation and initiate corrective actions Appendix J tests for local leak rates Enclosure 2

Response to RAI 3.3.2.18-1

Background

By letter dated May 2, 2011, the staff issued RAI 3.3.2.18-1 to address and evaluate the applicants operating experience described in LER 1998-002-01: the applicants operating experience indicates that the degradation of the resin beads in Purification Demineralizer number 3 resulted in releases of sulfur compounds that caused the extensive pitting of the demineralizer internal screen and the breakthrough of the resin beads to the downstream piping. In its review, the staff noted that that a release of sulfur compounds can facilitate stress corrosion cracking in stainless steel components. In RAI 3.3.2.18-1, the staff requested that the applicant describe whether or not the stainless steel components in the makeup and purification system that were previously exposed to sulfur compounds have experienced stress corrosion cracking. In addition, the applicant was requested to justify why cracking due to stress corrosion cracking is not an aging effect requiring management for the stainless steel demineralizer tanks, including internal screens, and filter housing. The staff further requested that if the piping has experienced stress corrosion cracking, the applicant should justify why the One-Time Inspection Program is adequate to manage cracking due to stress corrosion cracking of the piping rather than a program that includes periodic inspections.

In its response dated June 3, 2011 to RAI 3.3.2.18-1, the applicant stated that a review of its operating experience reveals that the stainless steel components in the makeup and purification system that were previously exposed to sulfur compounds have not experienced stress corrosion cracking. The applicant also explained that stress corrosion cracking is not an aging effect requiring management for stainless steel demineralized tanks, including internal screen, and filter housing because the temperature in this system under normal operations is below 120 °F, which is less than the SCC threshold temperature in treated water.

The applicant further stated that the LER did not identify cracking due to as an apparent cause and as corrective actions, the letdown flow path was flushed and a resin control program was instituted to prevent reoccurrence.

Request:

Describe what activities are performed in the resin control program as corrective actions to prevent the reoccurrence of demineralizer resin breakthrough to the downstream piping of the demineralizers. In addition, describe whether or not the plant-specific operating experience indicates that the resin control program has been effective to prevent resin breakthrough to the downstream piping in the makeup and purification system.

Discussion:

FENOC reviewed the causes and corrective actions from Licensee Event Report (LER) 1998-002-01. Radiation levels of 106 rads or higher causes breakdown of and damage to the resins. The number 3 demineralizer bed was over 10 years old, and had sat idle for long periods of time. The resin began to breakdown due to high radiation levels from the buildup of isotopes. The resin breakdown produced an acidic environment. Had the demineralizer been placed in service periodically, this action would have buffered the water. The Resin Control Program ensures the operation of the demineralizers is controlled to avoid resin degradation concerns, by tracking performance and in-service time of the demineralizers in the primary systems to ensure the demineralizers are changed-out prior to any resin degradation. The Resin Control Program addresses the root cause of the number 3 demineralizer resin degradation. In the past, each demineralizer could perform lithium removal for an entire 18-month fuel cycle. However, the change to a 2-year fuel cycle changed the method of Enclosure 2

operation such that one demineralizer is in-service and the other two are used for lithium removal alternately. Therefore, the demineralizers no longer sit idle for extended periods of time. Also, by procedure, the resins are changed-out every four years. Monitoring actions and responsibility for the operation and change-out of the demineralizers belongs to Chemistry and Operations. There has been no recurrence of the event.

No followup RAIs will be issued on these topics.

There was no further discussion, and the call was concluded.

Enclosure 2

SUBJECT:

Summary of Telephone Conference Call conducted on July 19, 2011 DISTRIBUTION:

HARD COPY:

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PUBLIC [or NON-PUBLIC, if applicable]

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