ML19240A300

Public Clarification Call with Exelon to Discuss Questions on Their Coatings and Linings of Certain Components Aging Management Program and Their Inspection of Buried and Underground Piping and Tanks Aging Management Program for SLR

ML19240A300
Person / Time
Site:	Peach Bottom
Issue date:	09/27/2019
From:	Bennett Brady NRC/NRR/DMLR/MRPB
To:	Exelon Generation Co
Brady B, NRR-DMLR 415-2981
Shared Package
ML19255F782	List: ML19238A303 ML19240A300 ML19246A145
References
EPID L-2018-RNW-0012
Download: ML19240A300 (4)

Text

September 27, 2019 U.S. Nuclear Regulatory Commission Public Meeting Summary

Title:

Public clarification call with Exelon Generation Company, LLC (Exelon) to discuss questions on their coatings and linings of certain components aging management program and their inspection of buried and underground piping and tanks aging management program for subsequent license renewal.

Date of Meeting: Wednesday, June 5, 2019 Location: Teleconference Type of Meeting: Category 1 Purpose of the Meeting(s):

To provide clarification on Exelon Generation Company, LLCs (Exelon) response to the U.S. Nuclear Regulatory Commission (NRC) requests for additional information (RAIs) on their internal coatings and linings and buried and underground piping and tanks aging management programs General Details:

The NRC staff held a public teleconference with Exelon as part of the safety review of the Peach Bottom Atomic Power Station, Units 2 and 3 subsequent license renewal application (SLRA). The meeting started at 1:30 p.m. and ended at approximately 2:15 p.m. There were two NRC staff members present in the room; one NRC staff member on the phone; and five Exelon staff members were on the phone. The meeting began with introductions of NRC staff in the room, NRC staff on the phone, and the five Exelon staff members on the phone. No members of the public announced themselves on the phone or informed the NRC staff that they participated in the teleconference.

Phone Participants Affiliations Bennett Brady Nuclear Regulatory Commission (NRC)

William Holston NRC Brian Allik NRC David Distel Exelon Generation Company, LLC (Exelon)

Michael Baker Exelon Mary Kowalski Exelon Scott Kauffman Exelon Donald B. Warfel Sr. Exelon

Summary of Meeting:

SLRA Section B.2.1.28, "Buried and Underground Piping and Tanks":

GALL-SLR Report AMP Xl.M41 recommends the following: a) One inspection for buried stainless steel in each 10-year inspection period beginning 10 years prior to the subsequent period of extended operation. This recommendation is based on all in-scope buried stainless steel being coated in accordance with the "preventive actions" program element of GALL-SLR Report AMP Xl.M41 during the inspection period. b) Additional inspections, beyond those in GALL-SLR Report Table Xl.M41-may be appropriate if exceptions are taken to Program Element 2, "preventive actions."

Summarizing their response, Exelon stated that one inspection of buried stainless steel piping will be performed in the 10-year period prior to the subsequent period of extended operation. The basis for this approach is that: (a) the percentage of buried uncoated stainless steel pipe is small relative to the overall length of buried stainless steel pipe, (b) favorable UT inspection results have been recorded, (c) resulting projection of remaining wall thickness is acceptable, (d) configuration is favorable, and (e) low soil corrosivity potential results have been demonstrated as described above. Therefore, this sample inspection quantity and frequency are appropriate. The uncoated 10-inch diameter stainless steel line will be the location for the one inspection in the 10-year period prior to the SPEO and prior to the reapplication of the pipe coating, since it represents a worst-case condition of all buried stainless-steel piping and is therefore bounding.

The NRC noted that the response does not provide docketed confirmation that all other in-scope stainless steel (not covered under Enhancement No. 7) is coated in accordance with the preventive actions program element of GALL-SLR Report AMP XI.M1.

The NRC staff also noted that the response states that one inspection of buried stainless steel piping will be performed in the 10-year period prior to the subsequent period of extended operation. GALL-SLR Report AMP XI.M41 recommends two inspections for a two-unit site.

SLRA Section B.2.1.29, "Internal Coatings/Linings for In-scope Piping, Piping Components, Heat Exchangers and Tanks:

During the NRC review of Peach Bottoms Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Aging Management Program, it was identified that the high-pressure service water side of the RHR heat exchanger water box does not appear to be coated. The staff submitted a request for additional information (RAI) asking whether the high-pressure service water carbon steel RHR heat exchanger tube side components are internally coated. Exelon had responded that during an inspection of the water box to determine if a protective coating was present, the coating was verified to be present as shown on the heat exchanger design drawing.

During the telephone conference, the NRC staff noted that SLRA Table 3.3.2-13, Emergency Service Water System, states that stainless steel with internal coating is included within the scope of the program, however, the SLRA Section B.2.1.29 does not include stainless steel. The staff may submit a second round RAI to address this question.

Public Participation:

No members of the public announced themselves on the phone or informed the NRC staff that they participated in the teleconference.

Action Items/Next Steps:

The NRC staff will consider issuing a second round of RAIs to address the above questions.

Title:

Public clarification call with Exelon Generation Company, LLC (Exelon) to discuss questions on their coatings and linings of certain components aging management program and their inspection of buried and underground piping and tanks aging management program for subsequent license renewal. Dated September 27, 2019.

DISTRIBUTION:

E-MAIL:

PUBLIC RidsNrrDmlr Resource RidsNrrPMPeach Bottom Resource Yvonne.Edmonds@nrc.gov NRR/DMLR Brian.Smith2@nrc.gov RI/DRP Bennett.Brady@nrc.gov NRR/DMLR Mitzi.Young@nrc.gov OGC David.Drucker@nrc.gov NRR/DMLR Kayla.Gamin@nrc.gov OGC Lauren.Gibson@nrc,gov, NRR/DMLR Michael.McCoppin@nrc.gov OEDO Angela.Buford@nrc.gov, NRR/DMLR Scott.Burnell@nrc.gov; HQ/OPA Steven.Bloom@nrc.gov, NRR/DMLR Diane.Screnci@nrc.gov RI/OPA David.Alley@nrc.gov, NRR/DMLR Neil.Sheehan@nrc.gov RI/OPA Eric.Oesterle@nrc.gov NRR/DMLR Darrell.Adams@nrc.gov, OCA Benjamin.Beasley@nrc.gov NRR/DMLR David.Decker@nrc.gov, OCA Meena.Khanna@nrc.gov NRR/DMLR Brice.Bickett@nrc.gov RI/ORA Joseph.Donoghue@nrc.gov NRR/DMLR Justin.Heinly@nrc.gov RI/DPR Jennifer.Tobin@nrc.gov NRR/DORL Jonathan.Greives@nrc.gov RI/DPR Justin.Heinly@nrc.gov RI/DRP Kevin.Mangan@nrc.gov RI/DRS David.Distel@exeloncorp.com Paul.Weyhmuller@exeloncorp.com John.Hilditch@exeloncorp.com Donald.Warfel@exeloncorp.com ADAMS Accession Nos:

Meeting Package:ML19255F782 Meeting Notice/Agenda:ML19154A141 Meeting Summary:ML19240A300 *concurred via email OFFICE PM:MRPB:DMLR LA:MRPB:DMLR BC:MRPB:DMLR PM:MRPB:DMLR NAME BBrady YEdmonds EOesterle BBrady DATE 9/6/19 9/9/19 9/19/19 9/27/19 OFFICE RECORD COPY