ML14148A388

Summary of Telephone Conference Call Held on May 19, 2014, Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC Concerning Draft Request for Additional Information, Set 28, Pertaining to the Byron Station and Br

ML14148A388
Person / Time
Site:	Byron, Braidwood
Issue date:	06/05/2014
From:	Robinson L License Renewal Projects Branch 1
To:	Exelon Generation Co
Robinson L, 415-4115
References
TAC MF1879, TAC MF1880, TAC MF1881, TAC MF1882
Download: ML14148A388 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 5, 2014 LICENSEE: Exelon Generation Company, LLC FACILITY: Byron Station, Units 1 and 2 Braidwood Station, Units 1 and 2

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON MAY 19, 2014, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND EXELON GENERATION COMPANY, LLC CONCERNING DRAFT REQUEST FOR ADDITIONAL INFORMATION, SET 28, PERTAINING TO THE BYRON STATION AND BRAIDWOOD STATION, LICENSE RENEWAL APPLICATION (TAC NOS. MF1879, MF1880, MF1881, MF1882)

The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Exelon Generation Company, LLC (Exelon or the applicant), held a telephone conference call on May 19, 2014, to discuss and clarify the staffs draft request for additional information (DRAI),

Set 28, concerning the Byron Station, Units 1 and 2, and the Braidwood Station, Units 1 and 2, license renewal application. The telephone conference call was useful in clarifying the intent of the staffs DRAIs. provides a listing of the participants, and Enclosure 2 contains a listing of the DRAIs discussed with the applicant, including a brief description on the status of the items.

The applicant had an opportunity to comment on this summary.

/RA/

Lindsay Robinson, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-454, 50-455, 50-456, and 50-457

Enclosures:

1. List of Participants

2. List of Draft Request for Additional Information cc w/encls: Listserv

ML14148A388 *concurred via email OFFICE LA:RPB2:DLR PM: RPB1:DLR BC:RPB1:DLR PM:RPB1:DLR NAME IKing LRobinson YDiazSanabria LRobinson DATE 6/3/14 6/4/14 6/5/14 6/5/14

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON MAY 19, 2014, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND EXELON GENERATION COMPANY, LLC CONCERNING DRAFT REQUEST FOR ADDITIONAL INFORMATION, SET 28, PERTAINING TO THE BYRON STATION AND BRAIDWOOD STATION, LICENSE RENEWAL APPLICATION (TAC NOS. MF1879, MF1880, MF1881, MF1882)

DISTRIBUTION EMAIL:

PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsOgcMailCenter RidsNrrPMByron Resource RidsNrrPMBraidwood Resource LRobinson DMcIntyre, OPA EDuncan, RIII JBenjamin, RIII AGarmoe, RIII JMcGhee, RIII JRobbins, RIII VMitlyng, RIII PChandrathil, RIII

TELEPHONE CONFERENCE CALL BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS May 19, 2014 PARTICIPANTS AFFILIATIONS Lindsay Robinson U.S. Nuclear Regulatory Commission (NRC)

William Holston NRC John Hufnagel Exelon Generating Company, LLC (Exelon)

Al Fulvio Exelon Don Warfel Exelon Albert Piha Exelon Casey Muggleston Exelon Paul Cervenka Exelon Ralph Wolen Exelon Don Brindle Exelon ENCLOSURE 1

DRAFT REQUEST FOR ADDITIONAL INFORMATION BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION May 19, 2014 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Exelon Generation Company, LLC (Exelon or the applicant), held a telephone conference call on May 19, 2014, to discuss and clarify the following draft request for additional information (DRAI),

Set 28, concerning the Byron Station, Units 1 and 2, and the Braidwood Station, Units 1 and 2, license renewal application (LRA).

DRAI 3.0.3-2b Applicability:

Byron Station (Byron) and Braidwood Station (Braidwood), all units

Background:

1. The response to request for additional information (RAI) 3.0.3-2a Request (2) dated May 5, 2014, states that a secondary purpose of the coating installed on the internal surfaces of the acid and caustic supply components was to protect the base metal from the relatively slow corrosion expected due to the environment the equipment would have been exposed to had the system been put in service.

1. The response to RAI 3.0.3-2a Request (4) states that the diesel oil storage tanks are designed such that coating debris will not cause flow blockage of downstream components because the suction lines for the fuel oil transfer pumps are located greater than a foot above the bottom of the tanks and the tank bottoms are sloped such that any debris would accumulate away from the suction line for the fuel oil transfer pumps. In addition, it states that a review of the results of completed tank inspections indicates that significant coating peeling, delamination, blistering, rusting, or unacceptable cracking and flaking have not occurred.

2. The response to RAI 3.0.3-2a Request (8) included changes to license renewal application (LRA) Sections A.2.1.11, A.2.1.18, B.2.1.11, and B.2.1.18 to address acceptance criteria and followup inspections when coating inspections reveal peeling and delamination and other indications.

3. The response to RAI 3.0.3-2a Request (1) states that the safety injection pump oil system includes an oil filter that removes debris and particulate prior to the oil reaching the bearings and the differential pressure across the oil filter is monitored during quarterly surveillances of the pumps.

4. The response to RAI 3.0.3-2 dated January 13, 2014, states that coating inspections for the foam concentrate tanks are performed every 15 years during replacement of the internal bladder.

ENCLOSURE 2

5. The response to RAI 3.0.3-2a Request (7) discussed qualifications of the individual who will approve post-inspection reports for coatings and the key information that will be included in the reports.

Issue:

1. Insufficient information was provided with regard to the secondary purpose of the coating in the acid and caustic supply lines in that, with the systems out of service, in-leakage of water accompanied by an abundant source of oxygen could result in significant corrosion rates at points where potential coating failures occur. Significant corrosion rates have occurred in normally dry but periodically wetted uncoated fire water systems with inadequate drainage. Although a secondary purpose of the coating was not described for the hypochlorite injection lines and the 0C auxiliary building chiller condenser at Byron, the staff has the same concern.

The staff noted that the Internal Surfaces in Miscellaneous Piping and Ducting Components updated final safety analysis report (UFSAR) Supplement and program were not revised to include key aspects related to managing loss of coating integrity as was done for the Open-Cycle Cooling Water System and Fuel Oil Chemistry programs as a result of the response to RAI 3.0.3-2a. The staff noted that these changes were not made because it was assumed that the above described internally coated components are not susceptible to the two concerns unique to coatings that results in loss of coating integrity being managed. However, if a basis cannot be established for a 10-year inspection interval (e.g., the more significant corrosion rates could result in leakage through the pressure boundary between inspections if a portion of the coating were to fail), then loss of coating integrity would need to be managed for these components.

1. Insufficient details were provided for the staff to conclude that a 10-year inspection interval for the diesel oil storage tanks is acceptable. For example: (a) even though the tank is sloped and the suction lines are a foot above the tank bottom, depending on the specific gravity of coating debris and the flow velocity, debris could be transported; (b) although corrosion is unlikely for bare metal exposed to fuel, debris and water can collect on the tank bottom and result in loss of material and the RAI response did not address design minimum wall thickness and corrosion allowances; and (c) current inspections are not necessarily an effective indicator of degradation that could occur in the period of extended operation (PEO).

2. The changes to LRA Sections A.2.1.11, A.2.1.18, B.2.1.11, and B.2.1.18 are internally inconsistent because one portion would allow degraded coatings that exhibit delamination and peeling to remain in service while an enhancement states that signs of delamination of the coating from the base metal (e.g., peeling and blistering) are not acceptable. In addition peeling, delamination, and blistering are intermixed, resulting in unclear guidance.

3. The staff has concluded that the quarterly monitoring of the differential pressure across the lubricating oil filter for the safety injection pump lubricating oil system is an important feature of managing loss of coating integrity of the internal coatings on the oil reservoirs.

However, neither the UFSAR supplement nor the Lubricating Oil Analysis program credits monitoring the differential pressure across the oil filter.

4. The Fire Water System UFSAR supplement does not include key aspects and the program does not include summary descriptions of activities associated with managing loss of coating integrity as described in RAI 3.0.3-2a Request (2).

5. Appendix B for the Open-Cycle Cooling Water, Fuel Oil Chemistry, and Fire Water System programs do not include key aspects of the post-inspection reports for coatings, as described in the response to RAI 3.0.3-2a Request (7).

Request:

1. State the basis for why a 10-year inspection interval is acceptable for the internal coatings on the acid and caustic supply and hypochlorite injection lines and the 0C auxiliary building chiller condenser at Byron when the base metal could be exposed to a potentially aggressive air-water environment should the coatings fail. In addition, depending on the outcome of the response, changes may be required to LRA Sections A.2.1.25 and B.2.1.25.

1. Provide sufficient information for the staff to conclude that neither loss of material nor coating debris would result in loss of the current licensing basis intended functions of the diesel oil storage tanks and downstream in-scope components.

2. Clarify LRA Sections A.2.1.11, A.2.1.18, B.2.1.11, and B.2.1.18 in regard to acceptability of peeling, delamination, and blistering.

3. Revise LRA Sections A.2.1.26 and B.2.1.26 to credit monitoring the differential pressure across the safety injection pump lubricating oil system oil filter.

4. Provide a similar level of detail in the Fire Water System program and UFSAR Supplement as described in the response to RAI 3.0.3-2a Request (2).

5. For the Open-Cycle Cooling Water, Fuel Oil Chemistry, and Fire Water System programs, include a summary description in the LRA of qualifications of the individual who will approve post-inspection reports for coatings and the key information that will be included in the post inspection reports. For the Fire Water System program include a summary description in the LRA of qualifications of the individual who will approve post-inspection reports for coatings.

Discussion: The applicant requested clarity on the staffs concern. Each section is discussed below.

1. The staff reviewed the Generic Aging Lessons Learned (GALL) Report and LRA definition for waste water and concluded that in-leakage to the system would have a similar environmental impact as waste water as defined in GALL Report Section IX.D (waters that are collected from equipment and floor drains). Given this, and the information the applicant provided in the response to RAI 3.0.3-2b, the staff has sufficient information to accept the applicants proposal. This question will be deleted and all subsequent Request sections will be renumbered as shown above.

2. The applicant requested clarity on the staffs concern. No edits were proposed. This question will be sent as part of the formal request titled: RAI 3.0.3-2b.

3. The applicant requested clarity on the staffs concern. No edits were proposed. This question will be sent as part of the formal request titled: RAI 3.0.3-2b.

4. The applicant requested clarity on the staffs concern. No edits were proposed. This question will be sent as part of the formal request titled: RAI 3.0.3-2b.

5. The applicant requested clarity on the staffs concern. No edits were proposed. This question will be sent as part of the formal request titled: RAI 3.0.3-2b.

6. The applicant requested clarity on the staffs concern. The applicant discussed the staffs concern regarding qualifications of the individuals approving post-inspection reports; the applicant noted that the information was provided in the response for RAI 3.0.3-2a. After further review of the response for RAI 3.0.3-2a, the staff agreed that the qualifications were provided for Open-Cycle Cooling Water and Fuel Oil Chemistry, but the qualifications were not discussed for the Fire Water System program. The question was edited to request the qualification for Fire Water System program only.

Additions to the original question are annotated with underline and deletions with strikethrough. This question will be sent as part of the formal request titled:

RAI 3.0.3-2b.