ML12047A000

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Lr - Meetings 3
ML12047A000
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 02/15/2012
From:
Office of Nuclear Reactor Regulation
To:
Division of License Renewal
References
Download: ML12047A000 (31)


Text

Davis-BesseNPEm Resource From: CuadradoDeJesus, Samuel Sent: Wednesday, February 15, 2012 6:38 PM To: Davis-BesseNPEm Resource

Subject:

meetings 3 Attachments: 12 12 2011.pdf; DB DRAI 3 1 2 2 16-3 Tube to tubesheet welds v3 12-7-2011 to PM.DOCX; 6 16 2011.pdf; 6 16 2011 .pdf; 6 16 2011 .pdf; 6 15 2011.pdf; 6 15 2011 .pdf; Davis Besse Open Items (2).pdf; 12 8 2011.pdf; 7 12 2011.pdf; 7 12 2011 .pdf; 7 12 2011 .pdf; 7 12 2011 .pdf; Letdown cooler replacement RAI -1.docx; DB RAI AMR TRP 101 SCC -

Mintz_Min SG RAI 7-8-2011 v65 Tube-to-tubesheet Welds.docx; 7 13 2011.pdf; New DRAI from Yogen Garud on Non-Class 1 Valves 07-08 oyee.docx; July 15 2011.pdf 1

Hearing Identifier: Davis_BesseLicenseRenewal_Saf_NonPublic Email Number: 3526 Mail Envelope Properties (0046140293E11F408991442DB4FE25CA68D46402CF)

Subject:

meetings 3 Sent Date: 2/15/2012 6:37:38 PM Received Date: 2/15/2012 6:37:44 PM From: CuadradoDeJesus, Samuel Created By: Samuel.CuadradoDeJesus@nrc.gov Recipients:

"Davis-BesseNPEm Resource" <Davis-BesseNPEm.Resource@nrc.gov>

Tracking Status: None Post Office: HQCLSTR01.nrc.gov Files Size Date & Time MESSAGE 3 2/15/2012 6:37:44 PM 12 12 2011.pdf 84203 DB DRAI 3 1 2 2 16-3 Tube to tubesheet welds v3 12-7-2011 to PM.DOCX 35860 6 16 2011.pdf 81761 6 16 2011 .pdf 56341 6 16 2011 .pdf 56409 6 15 2011.pdf 58437 6 15 2011 .pdf 58530 Davis Besse Open Items (2).pdf 104746 12 8 2011.pdf 62171 7 12 2011.pdf 84786 7 12 2011 .pdf 59786 7 12 2011 .pdf 104428 7 12 2011 .pdf 105044 Letdown cooler replacement RAI -1.docx 20809 DB RAI AMR TRP 101 SCC - Mintz_Min SG RAI 7-8-2011 v65 Tube-to-tubesheet Welds.docx 22491 7 13 2011.pdf 76787 New DRAI from Yogen Garud on Non-Class 1 Valves 07-08 oyee.docx 26142 July 15 2011.pdf 66553 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

Davis-BesseHearingFile Resource

Subject:

Davis-Besse Telephone Conference Phone: 888-324-6919 Participant passcode: 20499 Location: HQ-OWFN-12B06-12p Start: Mon 12/12/2011 11:00 AM End: Mon 12/12/2011 12:00 PM Show Time As: Tentative Recurrence: (none)

Meeting Status: Not yet responded Organizer: CuadradoDeJesus, Samuel Required Attendees: Karwoski, Kenneth; Hunt, Christopher; Min, Seung; dorts@firstenergycorp.com; custerc@firstenergycorp.com; lhinkle@firstenergycorp.com; Davis-BesseHearingFile Resource Objective:

To discuss the applicants November 23, 2011, response to RAI 3.1.2.2.16-2 and new followup Draft RAI 3.1.2.2.16-3.

DB DRAI 3 1 16-3 Tube to 1

DB DRAI 3.1.2.2.16-3

Background

By letter dated November 23, 2011, the applicant responded to RAI 3.1.2.2.16-2, which addresses the extent and method of the inspections to manage cracking due to primary water stress corrosion cracking (PWSCC) of the steam generator (SG) tube-to-tubesheet welds. In its response, the applicant indicated that a gross visual inspection coupled with eddy-current inspections will be performed on the steam generator tube-to-tubesheet welds. The applicant also indicated that the inspection schedule will be concurrent with the eddy-current inspections of the SG tubes in accordance with Davis-Besse Technical Specification 5.5.8, Steam Generator (SG) Program. The applicant further indicated that at a minimum, 100% of the tubes are inspected at sequential periods of 60 effective full power months.

Issue In its review, the staff noted that it is not clear if the visual inspection of the tube-to-tubesheet welds will include the welds on the hot leg, cold leg, or both legs. The staff also needs more clarifications on the extent and methods of the inspections addressed in the applicants response.

Request

1. Clarify if the gross visual inspection will be conducted on the welds on the hot leg, cold leg, or both legs. In addition, describe the extent of the visual inspection, and clarify if the gross visual inspection will be conducted on each tube-to-tubesheet weld.
2. Clarify whether the gross visual inspection is equivalent to EVT-1, VT-1, or VT-3 inspection.

In addition, describe how the visual inspections will be coupled to the eddy-current inspections in order to detect and manage the aging effect.

Page 1 of 1

Davis-BesseHearingFile Resource

Subject:

Davis-Besse Conference call on TLAA Location: HQ-OWFN-11B06-12p Start: Thu 6/16/2011 1:00 PM End: Thu 6/16/2011 2:00 PM Show Time As: Tentative Recurrence: (none)

Meeting Status: Not yet responded Organizer: CuadradoDeJesus, Samuel Required Attendees: Medoff, James; Min, Seung; dorts@firstenergycorp.com; Ng, Ching; Sydnor, Christopher Optional Attendees: yogen garud; Chopra, Omesh K.

Resources: HQ-OWFN-09B02-12p; HQ-OWFN-09B06-12p; HQ-OWFN-11B02-12p Phone Number: 877-917-9488 Participant passcode: 60937 We will be having a conference call with Davis Besse to discuss TLAA issues and RV internal issues.

1

Davis-BesseHearingFile Resource

Subject:

Davis-Besse Conference call on TLAA Location: HQ-OWFN-11B06-12p Start: Thu 6/16/2011 1:00 PM End: Thu 6/16/2011 2:00 PM Show Time As: Tentative Recurrence: (none)

Meeting Status: Not yet responded Organizer: CuadradoDeJesus, Samuel Required Attendees: Medoff, James; Min, Seung; dorts@firstenergycorp.com; Ng, Ching Resources: HQ-OWFN-09B02-12p; HQ-OWFN-09B06-12p; HQ-OWFN-11B02-12p Phone Number and passcode coming soon 1

Davis-BesseHearingFile Resource

Subject:

Davis-Besse Conference call on TLAA Location: HQ-OWFN-11B06-12p Start: Thu 6/16/2011 1:00 PM End: Thu 6/16/2011 2:00 PM Show Time As: Tentative Recurrence: (none)

Meeting Status: Not yet responded Organizer: CuadradoDeJesus, Samuel Required Attendees: Medoff, James; Min, Seung; dorts@firstenergycorp.com; Ng, Ching; Sydnor, Christopher Resources: HQ-OWFN-09B02-12p; HQ-OWFN-09B06-12p; HQ-OWFN-11B02-12p; HQ-OWFN-11B06-12p Phone Number and passcode coming soon 1

Davis-BesseHearingFile Resource

Subject:

Davis Besse teleconference call Location: HQ-OWFN-09B02-12p Start: Wed 6/15/2011 9:00 AM End: Wed 6/15/2011 10:30 AM Show Time As: Tentative Recurrence: (none)

Meeting Status: Not yet responded Organizer: CuadradoDeJesus, Samuel Required Attendees: Davidson, Evan; Min, Seung; Todd Mintz; 'custerc@firstenergycorp.com' Resources: HQ-OWFN-11B02-12p; HQ-OWFN-11B06-12p; HQ-OWFN-10B06-12p; HQ-OWFN-09B06-12p; HQ-OWFN-08B06-12p; HQ-OWFN-08B02-12p; HQ-OWFN-07B06-12p; HQ-OWFN-07B04-25p; HQ-OWFN-07B02-12p; HQ-OWFN-06B06-10p Phone number: 888-603-7027 Participant passcode: 28093 1

Davis-BesseHearingFile Resource

Subject:

Davis Besse teleconference call Location: HQ-OWFN-09B02-12p Start: Wed 6/15/2011 9:00 AM End: Wed 6/15/2011 10:30 AM Show Time As: Tentative Recurrence: (none)

Meeting Status: Not yet responded Organizer: CuadradoDeJesus, Samuel Required Attendees: Davidson, Evan; Min, Seung; Todd Mintz; custerc@firstenergycorp.com Resources: HQ-OWFN-11B02-12p; HQ-OWFN-11B06-12p; HQ-OWFN-10B06-12p; HQ-OWFN-09B06-12p; HQ-OWFN-08B06-12p; HQ-OWFN-08B02-12p; HQ-OWFN-07B06-12p; HQ-OWFN-07B04-25p; HQ-OWFN-07B02-12p; HQ-OWFN-06B06-10p Ill send the passcode and phone # soon.

1

Davis Besse Open Items (7)

Possible Status of the OI by Next February OI Description Step/Status 2012 Containment Shield Building Crack: (BLehman) The NRC is currently looking closely at this BLehman will Open Item issue. There is currently limited data; therefore an NRC position has not been established draft an RAI on pending the review of the evaluation when completed by the licensee and further internal December discussions. The staff is waiting for the applicant to gather more information on the impact and magnitude of the crack before issuing an RAI. The applicant is still submitting information to the NRC. DLR staff will draft an RAI based on the information provided by the applicant.

1 Class 1 valves: (OYee) In response to a staff RAI the applicant identified 12 large bore Class The applicant Open Item 1 valves (i.e., valves with nominal pipe sizes in excess of 4-inches NPS) that should have to provide received CUF or fatigue analyses(It) in accordance with the design codes. The applicant analyses for couldn't find the required Class 1 valves analyses. The staff the staff's can't close this issue until the fatigue evaluation is done and submitted for review. review by May 31, 2012 N

2

Intake Canal Degradation: (BLehman) During Preventive Maintenance inspections in 2007 it RAI response Open Item was discovered that the north embankment of the safety-related portion of the intake canal had received Oct settled. It is unclear to the staff that the degradation of the embankment has been adequately 31, 2011. A addressed and that the possible aging effects will be properly managed during the PEO. teleconference with RIII was held on Nov 7 2011. Staff is waiting for additional information to be provided by Nov 11 2011.

3 Containment Annulus Degradation: (BLehman/ASheikh) The applicant has stated in their A Open Item RAI responses that the containment annulus area condition is ok. The staff disagrees because Teconference there's a condition report (CR-10-22660) with pictures showing the condition of the grout and between RIII the moisture barrier in the annulus area as degraded. inspector and DLR staff held on Nov 1, 2011.

Teleconference held with the applicant on 11/14/2011, Applicant to supplement RAI response by 11/22/2011 4

Operating Experience: (MHomiack) To close this issue the applicant needs to state how Followup RAI Open Item FENOC plans to address the review and incorporation of operating experience into the license to be sent on renewal aging management programs. Currently the staff finds the applicant's response Dec 12 week.

unacceptable. The staff held a meeting with NEI in October 12 in which this issue was discussed and RASB will draft a follow-up RAI before the end of November.

5 SG Tube to Tubesheet Welds PWSCC: (SMin/CHunt and KKarwoski-DCI) The applicant Follow-up RAI If RAI stated that the tube to tube sheet welds for its SGs do not have a license renewal intended issued Nov 8, response is function and therefore, are not subject to an aging management review. In response to the 2011. acceptable the staff's RAI (received 10/21/2011) the applicant stated that the SG tube-to-tubesheet welds do Applicant's issue should perform a LR intended function (provide RCPB integrity) and also described how cracking do to response be closed and PWSCC will be managed. reveived SER revised November 23. input provided The staff is by the end of reviewing the December applicant's response.

6

Letdown Cooler Replacement Frequency: (JGavula) The applicant stated that the letdown Teleconference Open Item coolers are not subject to aging management review because these components are held with the periodically replaced and evaluated as short-lived components. Since these are normally long- applicant on lived passive components subject to aging management review, the staff asked for the basis for 11/9/2011.

the replacement frequency. Applicant's supp. response received 11/23/2011.

The staff is reviewing the applicant's response 7

Fire Water Storage Tank: (JKlos/NIqbal-DRA) Staff concern is that not all applicable aging Follow-up RAI If RAI effects are identified for the fire water storage tank heat exchanger tubes. The applicant issued Nov 8, response is originally stated that the consequences of tube failure do not directly challenge the function of 2011. acceptable the the tank. in the applicant's latest response (10/21/2011) the fire water storage tank heat Applicant's issue should exchanger was removed from scope. response be closed and received SER revised 11/23/2011. input provided The staff is by the end of reviewing the December applicant's response.

8

SG shell flaw evaluations: (CSydnor-DCI) The staff requests that the applicant provide the Delayed Open Item following information concerning the subject steam generator flaws and the analytical response evaluations performed for these flaws: (1) state whether any of the surface-breaking indications received on were believed to have been caused by stress corrosion cracking, or any other service-induced November 23 aging effect (2) state for any in-service examinations performed on the flawed regions of the 2011. CSydnor steam generator shell after 1991 whether these examinations detected any increase in the flaw is reviewing dimensions, relative to the 1988 flaw dimensions and (3) state whether the subject flaws were response analyzed for emergency and faulted conditions, as required by the ASME Code and provide the analyses.

9 Thermal Sleeves: (CSydnor-DCI) The staff determined that aging of the subject thermal RAI response Open Item sleeves should be identified as a TLAA because the aging mechanism is time dependent. The received Oct staff requests that the applicant amend LRA Sections 4.1, 4.7.4, and A.2.7.4 to identify 31, 2011.

HPI/makeup thermal sleeve aging as a TLAA. Sydnor is reviewing the 10 response RAI response If RAI RV integrity CLB: (CSydnor-DCI)The staff reviewed USAR Section 5.2 and could not locate received Oct response is the CLB analysis for evaluating RV integrity under the subject PTS conditions. Furthermore, 31, 2011. acceptable the the staff found no references in LRA Section 4.8 for reports documenting the analysis of RV Sydnor is issue should integrity under these PTS conditions for the period of extended operation, based on the 52 reviewing the be closed and EFPY RTPTS values. The staff will request the applicant to (1) please state the USAR section response SER revised the summary of the CLB analysis of the subject PTS event is located, (2) if a summary of the input provided CLB analysis is not located in the USAR, please state where it can be found, and (3) Please by early provide the reports documenting the projected 52 EFPY analysis of RV integrity under the December subject PTS conditions.

11

Containment Vessel Fatigue Analyses: (ABuford) The staff requested more information to Applicant If their RAI confirm that fatigue evaluations for the containment vessel will remain valid for the period of supplement response is extended operation. After reviewing the latest RAI response a teleconference was held on response acceptable the 10/26/2011 to discuss concerns related to the applicant's documentation and origin of their received issue should fatigue waiver values. 11/8/2011. be closed and NRC staff is the input reviewing the should be response. revised in early December 12 ASME Code Case N-481 evaluation: (CNg) The applicant stated that the fracture toughness of Ching Ng and issue is the cast austenitic stainless steel is not time-dependent as the analysis used a lower bound Hiser find the resolved fracture toughness of 139 ksiin that bounds the saturated fracture toughness of the Davis- RAI response.

Besse material. The NRC staffs concern is that the applicants basis may be predicated on acceptable charpy or thermal aging data that are not up-to-date or conservative when compared to the most recent data for the state of the industry.

13

Refueling Canal Leakage: (BLehamn/ASheikh)Boric acid deposits had been observed over a BLehman and If the RAI large surface area of the Containment Incore Instrumentation Tunnel walls and the under- A Sheikh are response is vessel area that are indicative of refueling canal leakage. It is unclear to the staff that the reviewing the acceptable the effects of refueling cavity leakage on the containment internal concrete structures have been applicant's issue should adequately addressed and that the possible aging effects will be properly managed during the response be closed and PEO. the input should be revised by the end of November 14 Abandoned Equipment: (BRogers) The staff requested the applicant to provide details on the implementation Open Item activities performed to confirm that all abandoned equipment that at any time contained fluids, of Commitment and is in the proximity of safety-related SSCs, has been verified to be drained.The NRC staff 26 by February was unclear from the FENOC response (Commitment 26) to RAI 2.1-3 if FENOC is aware of all 15, 2011 the abandoned equipment. The applicant revised Commitment 26, to ensure that abandoned equipment is identified, and either isolated and drained or included within the scope of license renewal and subject to aging management review by February 15, 2012.

15

Davis-BesseHearingFile Resource

Subject:

Davis Besse Teleconference Phone: 888-390-0924 Participant passcode: 69867 Location: HQ-OWFN-12B06-12p Start: Thu 12/8/2011 11:00 AM End: Thu 12/8/2011 12:00 PM Show Time As: Tentative Recurrence: (none)

Meeting Status: Not yet responded Organizer: CuadradoDeJesus, Samuel Required Attendees: custerc@firstenergycorp.com; dorts@firstenergycorp.com; Hiser, Allen; Sydnor, Christopher; Yee, On; lhinkle@firstenergycorp.com; Davis-BesseHearingFile Resource Well like to have a Telephone conference to discuss FENOCs response to RAI 4.7.4-1. Specifically well like to discuss the following:

  • Revision of commitment 23: Whats the reason to remove from the commitment the replacement of the HPI/makeup nozzle thermal sleeve?
  • ISI Program: what would be the type and frequency of the inspection for the HPI/makeup nozzle thermal sleeve under the augmented ISI Program?

1

Davis-BesseHearingFile Resource

Subject:

Davis-Besse Teleconference Location: HQ-OWFN-11B02-12p Start: Tue 7/12/2011 12:30 PM End: Tue 7/12/2011 2:00 PM Show Time As: Tentative Recurrence: (none)

Meeting Status: Not yet responded Organizer: CuadradoDeJesus, Samuel Required Attendees: Pham, Bo; Homiack, Matthew; Klos, John; Bozga, John; Hunt, Christopher; Yee, On; Ng, Ching; Prinaris, Andrew; Istar, Ata; Lehman, Bryce; Sheikh, Abdul; custerc@firstenergycorp.com; 'dorts@firstenergycorp.com' Resources: HQ-OWFN-09B02-12p Below is the order in which the topics will be discussed. Well start with those who have less issues first. Let me know if you have any suggestions-Sam C.

Topic #1- Mathew Homiack and Bo

  • To discuss FENOC response to RAI B1.4-1 on operating experience.

Topic #2 - Christopher Hunt

  • During a public meeting on February 18, 2011, industry Steam Generator Task Force representatives indicated that primary side fouling of steam generator tubes is not an issue in the United States (refer to the meeting summary in ADAMS under accession number ML110670317).

In the applicants license renewal application, reduction of heat transfer of the steam generator tubes in a borated reactor coolant environment is addressed as an aging mechanism. Has there been any information gained by the industry since the February 18, 2011 meeting that would suggest that primary side loss of heat transfer has become an issue? If there is additional information, please provide it. If not, discuss your plans to withdraw the aging management review line item that deals with reduction in heat transfer of nickel alloy tubing and sleeves in a borated reactor coolant environment.

Topic #3 - FENOC

Topic #4 - On Yee and Ching Ng RAI B2.16-1 Applicant promised to update USAR table. What is the time frame?

RAI B2.16-2 Commitment No. 42 said This evaluation will be submitted to the NRC one year prior to the period of extended operation. What is the intent for the submittal?

RAI B2.16-3 Commitment No. 9, 1st bullet said When the number of accrued cycles is within 75% of the allowable cycle limit for any transient What is allowable cycle?

1

RAI 4.3-2 Part 3 states Transient 22 (now Transient 22 A1), HPI System Test, includes HPI flow through all 4 HPI nozzles for 10 seconds with RCS pressure of 2200 psig and RCS temperature of 550ºF.

Are the 4 HPI nozzles being referenced in the RAI response the ones on LR Boundary Drawing LR-M033A - FE HP3A, FE HP3B, FE HP3C and FE HP3D?

These flow elements are highlights green in the LR Boundary Drawing (Non-Class 1 Mechanical Component) - Are these the same HPI nozzles that are being referencing in LRA Section 4.3 and have a CUF value associated with them? Or are the HPI nozzles being referenced in LRA Section 4.3 (with the CUF values) the nozzle connection to the reactor coolant inlet piping?

RAI 4.3-10 Transient 25: The transient pressurizer heaters is applicable to pressurizer electric heaters but not the pressurizer or pressurizer heater elements. Clarify if and how the transient pressurizer heaters does or does not affect the fatigue of pressurizer electric heaters.

RAI 4.3-17 RAI response for the Surge Line Piping said Global Fen is calculated by dividing the Uen by the in-air CUF, which is the same as MRP-47 LRA pg 4.3-28 and footnote 2 in table 4.3-2 said adjusted CUF is obtained by dividing the Uen by the global Fen Did one calculate the adjusted CUF first or the global Fen first? Did LRA and table 4.3-2 need to be revised?

Topic #5 - Andrew Prinaris. Ata Istar, Bryce Lehman and Abdul Sheikh RAIs B.2.25-2, 3, 4, and 6

  • Verify that leak trenches on the floor are unlined concrete
  • Verify that leakage for PH and Iron will be monitored via the SMP
  • Where does the 5 band comes from?
  • Boroscope requirements
  • UFSAR supplement for the Periodic Inspection Program 2

Davis-BesseHearingFile Resource

Subject:

Davis-Besse Teleconference Location: HQ-OWFN-11B02-12p Start: Tue 7/12/2011 12:30 PM End: Tue 7/12/2011 2:00 PM Show Time As: Tentative Recurrence: (none)

Meeting Status: Not yet responded Organizer: CuadradoDeJesus, Samuel Required Attendees: Pham, Bo; Homiack, Matthew; Klos, John; Bozga, John; Hunt, Christopher; Yee, On; Ng, Ching; Prinaris, Andrew; Istar, Ata; Lehman, Bryce; Sheikh, Abdul; custerc@firstenergycorp.com; 'dorts@firstenergycorp.com' Resources: HQ-OWFN-09B02-12p Ill send the phone # and passcode soon. Also Ill send a list of the topics and the order in which theyll be discussed. Bo I noticed youll be available only for the first half hour so you and Homiack will go first.

1

Davis-BesseHearingFile Resource

Subject:

Davis-Besse Teleconference Location: HQ-OWFN-11B02-12p Start: Tue 7/12/2011 12:30 PM End: Tue 7/12/2011 2:00 PM Show Time As: Tentative Recurrence: (none)

Meeting Status: Not yet responded Organizer: CuadradoDeJesus, Samuel Required Attendees: Pham, Bo; Homiack, Matthew; Klos, John; Bozga, John; Hunt, Christopher; Yee, On; Ng, Ching; Prinaris, Andrew; Istar, Ata; Lehman, Bryce; Sheikh, Abdul; custerc@firstenergycorp.com; 'dorts@firstenergycorp.com' Resources: HQ-OWFN-09B02-12p Toll Free Number: 888-469-0883 Participant passcode: 44351 Below is the order in which the topics will be discussed. Well start with those who have less issues first. Let me know if you have any suggestions-Sam C.

Topic #1- Mathew Homiack and Bo

  • To discuss FENOC response to RAI B1.4-1 on operating experience.

Topic #2 - Christopher Hunt

  • During a public meeting on February 18, 2011, industry Steam Generator Task Force representatives indicated that primary side fouling of steam generator tubes is not an issue in the United States (refer to the meeting summary in ADAMS under accession number ML110670317). In the applicants license renewal application, reduction of heat transfer of the steam generator tubes in a borated reactor coolant environment is addressed as an aging mechanism. Has there been any information gained by the industry since the February 18, 2011 meeting that would suggest that primary side loss of heat transfer has become an issue? If there is additional information, please provide it. If not, discuss your plans to withdraw the aging management review line item that deals with reduction in heat transfer of nickel alloy tubing and sleeves in a borated reactor coolant environment.

Topic #3 - FENOC

Topic #4 - On Yee and Ching Ng RAI B2.16-1 Applicant promised to update USAR table. What is the time frame?

RAI B2.16-2 Commitment No. 42 said This evaluation will be submitted to the NRC one year prior to the period of extended operation. What is the intent for the submittal?

1

RAI B2.16-3 Commitment No. 9, 1st bullet said When the number of accrued cycles is within 75% of the allowable cycle limit for any transient What is allowable cycle?

RAI 4.3-2 Part 3 states Transient 22 (now Transient 22 A1), HPI System Test, includes HPI flow through all 4 HPI nozzles for 10 seconds with RCS pressure of 2200 psig and RCS temperature of 550ºF.

Are the 4 HPI nozzles being referenced in the RAI response the ones on LR Boundary Drawing LR-M033A - FE HP3A, FE HP3B, FE HP3C and FE HP3D?

These flow elements are highlights green in the LR Boundary Drawing (Non-Class 1 Mechanical Component) -

Are these the same HPI nozzles that are being referencing in LRA Section 4.3 and have a CUF value associated with them? Or are the HPI nozzles being referenced in LRA Section 4.3 (with the CUF values) the nozzle connection to the reactor coolant inlet piping?

RAI 4.3-10 Transient 25: The transient pressurizer heaters is applicable to pressurizer electric heaters but not the pressurizer or pressurizer heater elements. Clarify if and how the transient pressurizer heaters does or does not affect the fatigue of pressurizer electric heaters.

RAI 4.3-17 RAI response for the Surge Line Piping said Global Fen is calculated by dividing the Uen by the in-air CUF, which is the same as MRP-47 LRA pg 4.3-28 and footnote 2 in table 4.3-2 said adjusted CUF is obtained by dividing the Uen by the global Fen Did one calculate the adjusted CUF first or the global Fen first? Did LRA and table 4.3-2 need to be revised?

Topic #5 - Andrew Prinaris. Ata Istar, Bryce Lehman and Abdul Sheikh RAIs B.2.25-2, 3, 4, and 6

  • Verify that leak trenches on the floor are unlined concrete
  • Verify that leakage for PH and Iron will be monitored via the SMP
  • Where does the 5 band comes from?
  • Boroscope requirements
  • UFSAR supplement for the Plant Specific Leak Chase Monitoring Program 2

Davis-BesseHearingFile Resource

Subject:

Davis-Besse Teleconference Location: HQ-OWFN-11B02-12p Start: Tue 7/12/2011 12:30 PM End: Tue 7/12/2011 2:00 PM Show Time As: Tentative Recurrence: (none)

Meeting Status: Not yet responded Organizer: CuadradoDeJesus, Samuel Required Attendees: Pham, Bo; Homiack, Matthew; Klos, John; Bozga, John; Hunt, Christopher; Yee, On; Ng, Ching; Prinaris, Andrew; Istar, Ata; Lehman, Bryce; Sheikh, Abdul;

'custerc@firstenergycorp.com'; 'dorts@firstenergycorp.com'; Li, Rui Optional Attendees: Karwoski, Kenneth Resources: HQ-OWFN-09B02-12p; HQ-OWFN-11B02-12p Toll Free Number: 888-469-0883 Participant passcode: 44351 Below is the order in which the topics will be discussed. Well start with those who have less issues first. Let me know if you have any suggestions-Sam C.

Topic #1- Mathew Homiack and Bo

  • To discuss FENOC response to RAI B1.4-1 on operating experience.

Topic #2 - Christopher Hunt

  • During a public meeting on February 18, 2011, industry Steam Generator Task Force representatives indicated that primary side fouling of steam generator tubes is not an issue in the United States (refer to the meeting summary in ADAMS under accession number ML110670317). In the applicants license renewal application, reduction of heat transfer of the steam generator tubes in a borated reactor coolant environment is addressed as an aging mechanism. Has there been any information gained by the industry since the February 18, 2011 meeting that would suggest that primary side loss of heat transfer has become an issue? If there is additional information, please provide it. If not, discuss your plans to withdraw the aging management review line item that deals with reduction in heat transfer of nickel alloy tubing and sleeves in a borated reactor coolant environment.

Topic #3 - FENOC

Topic #4 - On Yee and Ching Ng RAI B2.16-1 Applicant promised to update USAR table. What is the time frame?

RAI B2.16-2 Commitment No. 42 said This evaluation will be submitted to the NRC one year prior to the period of extended operation. What is the intent for the submittal?

1

RAI B2.16-3 Commitment No. 9, 1st bullet said When the number of accrued cycles is within 75% of the allowable cycle limit for any transient What is allowable cycle?

RAI 4.3-2 Part 3 states Transient 22 (now Transient 22 A1), HPI System Test, includes HPI flow through all 4 HPI nozzles for 10 seconds with RCS pressure of 2200 psig and RCS temperature of 550ºF.

Are the 4 HPI nozzles being referenced in the RAI response the ones on LR Boundary Drawing LR-M033A - FE HP3A, FE HP3B, FE HP3C and FE HP3D?

These flow elements are highlights green in the LR Boundary Drawing (Non-Class 1 Mechanical Component) -

Are these the same HPI nozzles that are being referencing in LRA Section 4.3 and have a CUF value associated with them? Or are the HPI nozzles being referenced in LRA Section 4.3 (with the CUF values) the nozzle connection to the reactor coolant inlet piping?

RAI 4.3-10 Transient 25: The transient pressurizer heaters is applicable to pressurizer electric heaters but not the pressurizer or pressurizer heater elements. Clarify if and how the transient pressurizer heaters does or does not affect the fatigue of pressurizer electric heaters.

RAI 4.3-17 RAI response for the Surge Line Piping said Global Fen is calculated by dividing the Uen by the in-air CUF, which is the same as MRP-47 LRA pg 4.3-28 and footnote 2 in table 4.3-2 said adjusted CUF is obtained by dividing the Uen by the global Fen Did one calculate the adjusted CUF first or the global Fen first? Did LRA and table 4.3-2 need to be revised?

Topic #5 - Andrew Prinaris. Ata Istar, Bryce Lehman and Abdul Sheikh RAIs B.2.25-2, 3, 4, and 6

  • Verify that leak trenches on the floor are unlined concrete
  • Verify that leakage for PH and Iron will be monitored via the SMP
  • Where does the 5 band comes from?
  • Boroscope requirements
  • UFSAR supplement for the Plant Specific Leak Chase Monitoring Program 2

RAI 2.3.3.18-3

Background

LRA Section 2.3.3.18, Makeup and Purification System, states that the letdown coolers, designated as DB-E25-1 and -2, are not subject to aging management review because these components are periodically replaced and evaluated as short-lived components. Since these are normally long-lived passive components subject to aging management review, the staff issued RAI 2.3.3.18-2 requesting the basis for the replacement frequency and the circumstances surrounding the need to replace these heat exchangers.

In its response dated June 3, 2011, Davis-Besse stated that the cooler replacement frequency is based on a qualified life from plant-specific operating experience, and is scheduled approximately every 14 years. The response also stated that the cooler design has a tendency to develop leaks after 14 to 16 years. The response further stated that the need to replace the coolers was attributed to fatigue cracking due to flow-induced vibration, and that an extent of condition review determined that the design of these coolers is unique and no other similar heat exchangers are installed at Davis-Besse.

Issue As previously noted in RAI 2.3.3.18-2, if the frequency is based on qualified life, then information should be provided to demonstrate that the coolers intended function is being maintained consistent with the current licensing basis, at the point in time immediately prior to replacement. The staff notes that in accordance with SRP-LR Section A.1.2.3.4, an aging management approach based solely on detecting component failures is not considered an effective program. The staff also notes that in accordance with USAR Section 3.9.2, and Table 3.9-2, the letdown coolers are safety-related components constructed to the ASME Code,Section III, Class 3.

In addition, the staff notes that, if the design of the cooler results in a tendency to develop leaks after14 to 16 years, then each heat exchanger would have only been replaced twice, so far, at Davis-Besse. With the relatively limited operating experience and the limited number of data points, the ability to reasonably predict the life of the coolers appears to have a large degree of uncertainty. In addition, as noted in RAI 2.3.3.18-2, previous LRAs for other sites have attributed the fatigue cracking problem in these letdown coolers to be associated with specific operational transients, and, if a similar phenomenon is occurring at Davis-Besse, then a predicted life may need to consider transients in addition to operational time.

Request

1) Provide a summary of Davis-Besses operating experience associated with the letdown coolers, including occurrences of tube leakage and past replacements for each cooler.

Consider including the circumstances how the associated leakage from the reactor coolant system into the component cooling water system was detected, and the approximate magnitude(s) of the leakage.

2) Provide a summary of any past evaluations of the cause(s) for previous tube leakage, including how leakage was determined to be from fatigue cracks due to flow-induced vibration, and the degree and extent of the cracking identified. Include information regarding the role any

operational transients may have played in causing previous tube leakage or how it was concluded that operational transients need not be considered.

3) Provide the information that determined the coolers intended function is being maintained consistent with current licensing basis, at the point in time immediately prior to replacement.

DRAFT Davis-Besse TRP 101 - Stress Corrosion Cracking RAI 3.1.2.2.16-1

Background

GALL Report, Rev. 2, item IV.D2.RP-185 recommends using GALL AMP XI.M2, Water Chemistry and a plant-specific program to manage cracking due to primary water stress corrosion cracking (PWSCC) of steam generator tube-to-tubesheet welds made of nickel alloy. GALL Report, Rev. 2, item IV.D2.RP-185 also recommends that a plant-specific program should be evaluated to confirm the effectiveness of the water chemistry program and to ensure cracking is not occurring. Consistently, SRP-LR, Rev. 2, Section 3.1.2.2.11, item 2 states that cracking due to PWSCC could occur in steam generator nickel alloy tube-to-tubesheet welds exposed to reactor coolant. The SRP-LR, Rev. 2 also states that unless the NRC has approved a redefinition of the pressure boundary in which the tube-to-tubesheet weld is no longer included, the effectiveness of the primary water chemistry program should be verified to ensure cracking is not occurring.

By contrast, the applicants AMR items for the steam generator components, which are described in LRA Table 3.1.2-4, do not clearly address how the applicant manages the cracking due to PWSCC of steam generator tube-to-tubesheet welds exposed to reactor coolant.

Issue The staff found a need to clarify how the applicant manages cracking due to PWSCC of steam generator tube-to-tubesheet welds in comparison with the GALL Report and SRP-LR.

Request

1. If the applicant plans to replace the steam generators prior to the period of extended operation, provide the following information.

(a) Describe the materials to be used for the fabrication of the new steam generator tubes, tubesheet cladding and tube-to-tubesheet welds. If any of the tubes, tubesheet cladding, and weld filler metal (if applicable) is Alloy 600 or one of its associated weld metals such the material is susceptible to PWSCC, discuss how cracking due to PWSCC of the tube-to-tubesheet welds will be managed for the period of extended operation.

If the materials are determined not to be susceptible to PWSCC, confirm whether or not the applicant will continue to evaluate the plant-specific and industry operating experience related to PWSCC of the tube-to-tubesheet welds so that necessary corrective actions will be identified and performed to adequately manage the aging effect of the components.

(b) In addition, if the operating experience indicates that the tube-to-tubesheet welds of the steam generators have experienced PWSCC and the applicant proposes a one-time inspection to manage the aging effect of the replacement tube-to-tubesheet welds, justify why the one-time inspection is adequate to manage the aging effect of the replacement components in view that Page 1 of 2

DRAFT Davis-Besse TRP 101 - Stress Corrosion Cracking the existing components to be replaced have experienced cracking due to PWSCC under the given water chemistry conditions.

2. Provide the following information regarding the aging management method that the applicant will use if the steam generators are not replaced prior to the period of extended operation.

(a) Describe the aging management method that the applicant will use to manage cracking due to PWSCC of the tube-to-tubesheet welds if the steam generators are not replaced prior to the period of extended operation. As part of the applicants response, describe the materials of the current steam generator tubes, tubesheet cladding and tube-to-tubesheet welds, and determine whether or not any of the tubes, tubesheet cladding, and weld filler metals (if applicable) is susceptible to PWSCC.

If the materials are determined not to be susceptible to PWSCC, confirm whether or not the applicant will continue to evaluate the plant-specific and industry operating experience related to PWSCC of the tube-to-tubesheet welds so that necessary corrective actions will be identified and performed to adequately manage the aging effect of the components.

(b) In addition, if the operating experience indicates that the tube-to-tubesheet welds have experienced PWSCC and the applicant proposes a one-time inspection to manage the aging effect of the tube-to-tubesheet welds, justify why the one-time inspection is adequate to manage the aging effect of the components that have already experienced cracking due to PWSCC under the given water chemistry conditions.

Page 2 of 2

Davis-BesseHearingFile Resource

Subject:

DB Teleconference Location: HQ-OWFN-11B02-12p Start: Wed 7/13/2011 10:30 AM End: Wed 7/13/2011 11:30 AM Show Time As: Tentative Recurrence: (none)

Meeting Status: Not yet responded Organizer: CuadradoDeJesus, Samuel Required Attendees: 'custerc@firstenergycorp.com'; Min, Seung; Todd Mintz; Gavula, James;

'dorts@firstenergycorp.com' Resources: HQ-OWFN-11B06-12p Letdown DB RAI AMR r replacement 101 SCC - Min 1

DRAI 4.3.2.3.2-X or 4.3.3.2-X (Ching to decide on the SER section and number for issuing this RAI)

Background:

LRA Section 4.3.2.3.2 discusses fatigue of Class 1 (Class A) valves of the reactor coolant pressure boundary (RCPB). It states that a review of Davis-Besse quality assurance records was performed, which resulted in identifying stress reports of record for tweleve Class 1 valves with four inch or greater diameter, however no associated fatigue analyses were identified. LRA Section 4.3.2.3.2 also states that valve bodies were considered robust compared to the piping system in which they were located and fatigue of the attached piping was understood to bound the fatigue of the valve bodies. Therefore, LRA Table 4.1-1 states that fatigue of Class 1 valves is not a TLAA. The staff reviewed the applicants USAR to identify the Comment [OYee1]: USAR or UFSAR?

applicable design Code of record for these valves, but could not ascertain the applicable design Comment [OYee2]: Specific documents?

code(s). CLB is very broad and general.

Do you mean USAR?

However, the staff noted that the Davis-Besse USAR Table 5.2-1 states that relief valves and pressurizer safety valves were designed to ASME draft pump and valve Code, Nov. 1968 Edition, loop isolation valves and other valves were designed to ASME Section III, 1971 Edition or later, pressurizer pilot-operated relief isolation valve designed to ASME Section III 1974 Edition with Addenda through Summer 1976, and pressurizer spray line isolation valve designed to ASME Section III, 1986 Edition. The staff noted that valves designed to these Codes, and having larger than 4 in. nominal pipe size, are to meet the requirements of NB-3530 through NB-3550 (or Article 4 of 1968 Edition of Draft Pump and Valve Code), and that adequacy of the valves for cyclic conditions is verified in accordance with Subsection NB-3553 (or Sub-article 454 of 1968 edition of draft pump and valve Code), which requires fatigue usage It to be less than 1.0. It was unclear to the staff why the fatigue analyses of Class 1 valves were not performed as required by the design Code of record and, as such, why the Class 1 valves are identified in the LRA as not requiring fatigue TLAA for the extended period of operation. Comment [OYee3]: Is all of this needed?

Was all of this asked in RAI 4.1-1?

By letter dated May 2, 2011, the staff issued RAI 4.1-1 (ML111170204) requesting the applicant If it was I would suggest deleting it because it to identify the applicable design codes for Class 1 valves, justify why the fatigue analyses were does not add any value. You can just reference the previous RAI.

not required or why these analyses were not included in the LRA as TLAAs.

By teleconference dated June 16, 2011 the staff discussed the absence of TLAA for Class 1 fatigue valves in relation to the above issued RAI 4.1-1 and noted that the USAR refers to a few Class 2/3 valves as being analyzed for Class 1. The applicant stated that the handling of the Class 2 and 3 valves that were analyzed to Class 1 design criteria was addressed in LRA Section 4.3.2.3.2 but stated that it will address both these valve sets, as part of its RAI 4.1-1 response,. The staff agreed to time extension for this response from the applicant. Comment [OYee4]: Can we say this?

Issue: In light of the issues discussed in RAI 4.1-1 and similar issues with Class 2/3 valves treated as Class 1 for design analysis, the staff requires additional information. Comment [OYee5]: This is just repeating the request.

Request: Justify the bases for concluding that the LRA does not need to identify any TLAAs for Comment [OYee6]: This is repeating the the Davis Besse Class 2 and 3 valves that were analyzed to Class 1 design requirements. issue.

Davis-BesseHearingFile Resource

Subject:

Davis-Besse Teleconference on DRAI-Class 2/3 valves treated as Class 1 for design analysis Location: HQ-OWFN-11B02-12p Start: Fri 7/15/2011 1:00 PM End: Fri 7/15/2011 2:00 PM Show Time As: Tentative Recurrence: (none)

Meeting Status: Not yet responded Organizer: CuadradoDeJesus, Samuel Required Attendees: 'custerc@firstenergycorp.com'; 'dorts@firstenergycorp.com'; Medoff, James; yogen garud Resources: HQ-OWFN-11B06-12p; HQ-OWFN-09B02-12p; HQ-OWFN-09B06-12p New DRAI Yogen Garud o 1