ML19246A145

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Clarification Call to Discuss Exelon'S Response to NRC Requests for Additional Information (RAI) 3.3.2.1.1-1
ML19246A145
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 09/27/2019
From: Bennett Brady
Division of Materials and License Renewal
To:
Brady B.NRR-DMLR 415-2981
Shared Package
ML19255F782 List:
References
EPID L-2018-RNW-0012
Download: ML19246A145 (4)


Text

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

Title:

Clarification call to discuss Exelons response to NRC requests for additional Information (RAI) 3.3.2.1.1-1 Date of Meeting: Wednesday, May 15, 2019 Location: Teleconference Type of Meeting: Category 1 Purpose of the Meeting(s):

To provide clarification on Exelon Generation Company, LLCs (Exelon) response to requests for additional information (RAIs) related to the potential for cracking due to stress corrosion cracking (SCC) for copper alloy with greater than 15 percent zinc components exposed to air, condensation, raw water, and waste water.

General Details:

The U.S. Nuclear Regulatory Commission (NRC) staff held a public teleconference with Exelon as part of the safety review of Peach Bottom Atomic Power Station, Units 2 and 3 subsequent license renewal application (SLRA). The meeting started at 11:00 a.m. and ended at approximately 11:47 a.m. There were two NRC staff members present in the room and four Exelon staff members were on the phone. The meeting began with introductions of NRC staff in the room, and the four Exelon staff 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 David Distel Exelon Generation Company, LLC (Exelon)

Paul Weyhmuller Exelon Mark Miller Exelon Donald B. Warfel Sr. Exelon

Summary of Meeting:

The NRC staff discussed three issues that were not clarified in the applicants RAI response:

1. In RAI 3.3.2.1.1-1, the staff asked that the applicant state the basis for why cracking due to SCC is not cited as an aging effect requiring management for copper alloy with greater than 15 percent zinc components exposed to air indoor uncontrolled, airdry, air outdoor, condensation, treated water, raw water, or waste water.

The May 2, 2019 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML19122A289), response to RAI 3.3.2.1.1-1 from Exelon states that, cracking due to SCC is not cited as an aging effect requiring management for copper alloy with greater than 15 percent zinc components in the environment of air - indoor, uncontrolled. The response provided a basis for this position citing NUREG-2221, Technical Bases for Changes in the Subsequent License Renewal Guidance Documents NUREG-2191 and NUREG-2192, Table 3-2 SRP-SLR Chapter 2, Scoping and Screening, Differences from SRP-LR, Revision 2 and Their Technical Bases, The staff explained that the GALL-SLR Report and SRP-SLR do not recommend that aging effects be managed for packing, gaskets, seals, and O-rings. However, potential aging effects due to degraded (leaking) packing, gaskets, seals, and O-rings should be evaluated to be consistent with the GALL-SLR Report.

The response did not provide a technical basis for why cracking due to SCC is not cited as an aging effect requiring management for copper alloy with greater than 15 percent zinc components exposed to an environment of air - indoor, uncontrolled.

2. Also, the RAI response lacks sufficient clarity on whether ammonia or ammonium compounds are or could be present. For five of the environments (i.e., air indoor-uncontrolled, air-outdoor, air-dry, treated water, waste water) cited in the response to RAI 3.3.2.1.1-1, the response states in part that, ammonia or ammonium compounds are not assumed to be present. The NRC requests that the applicant definitively state whether ammonia or ammonium compounds are or could be present in the following environments: air indoor-uncontrolled, air-outdoor, air-dry, treated water, waste water.
3. The first portion of the response to RAI 3.3.2.1.1-1 states that cracking of copper alloy with greater than 15 percent zinc is cited for insulated components exposed to condensation in the chilled water system and domestic water system because the insulation is assumed to contain contaminants that could leach out onto the copper alloy component due to moisture under the insulation.

The general discussion associated with the condensation environment states in part, cracking due to SCC is not cited as an aging effect requiring management for copper alloy with greater than 15 percent zinc components in this environment of condensation.

The staff recognizes that the first statement is related to insulated components exposed to condensation and the second statement is probably related to all other components exposed to condensation. However, response to RAI 3.3.2.1.1-1 has conflicting statements. Please clarify the conflicting comments cited above.

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 three questions.

SUBJECT:

Clarification Call to Discuss Exelons Response to NRC Request For Additional Information (RAI) 3.3.2.1.1 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: ML19246A145 *concurred via email OFFICE PM:MRPB:DMLR LA:MRPB:DMLR BC:MRPB:DMLR PM:MRPB:DMLR NAME B Brady SLent EOesterle B Brady DATE 9/6/19 9/5/19 9/19/19 9/27/19 OFFICE RECORD COPY