RA-13-127, Commitment Change Summary Report - 2012

Commitment Change Summary Report - 2012

ML14002A264
Person / Time
Site:	Oyster Creek
Issue date:	12/23/2013
From:	Stathes G Exelon Generation Co
To:	Document Control Desk
References
NEI 99-04, RA-13-127
Download: ML14002A264 (3)

Text

NEI 99-04 RA-13-127 December 23, 2013 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Oyster Creek Nuclear GeneratkV station Renewed Facility Operating License No. DPR-16 NRC Dce No. 50-219

Subject:

Commitment Change Summary Report - 2012 Enclosed isthe Oyster Crok Nucer Genwating Station C;ommftent Change Summary Report for regulatory commrimeni s during calne year 2012. This report Is being submitted in accordance with the guidance provided by NEI M9W04.

Please contact Kathy Paez at (609) 0714671 I any ft~ infomato or assistance is eeded.

Sincerely, Garey L.Stathes Vice President Oyster Creek Nuclear Generating Staion cc: Administrator, USNRC Region I USNRC Senior Project Manager, Oyster Creek USNRC Senior Resident Inspector, Oyster Creek

The following NRC commitments tracked in the Oyster Creek Nuclear Generating Station (OCNGS) commitment-tracking database were changed during the calendar year 2012. These changes were evaluated in acoordance with Exelon Procedure LS-AA-1 10, Commit Mnagement, and determined to require NRC notification in this Commitment Change Summary Report, consistent with NEI 9.04 guidance.

12-001Q e Water System CdOMtMO and Revise CommtMt- Existing Open-Cycle Cooling Water System aging management program Is credited. The revised commitment adjusts the frequency of the Containment Spray Heat Exchanger Pedormance Testing from yearly to once every two years.

Justi -The Open-Cycle Cooling Water System aging management program curret credits the Generic Letter 89-13 Program with two additional enhancements:

• Include specifcity on inspection of heat exchangers for loss of material due to general, pitting, crevice, galvanic and mlcrobiologically influenced corrosion in the RBCCW, TBCCW and Containment Spray preventative maintenance tasks and

• Inrue volumeft Inspections for piping that has been replaced, at a mwinium of 4 aboveground locations every 4 years based on the observed and anticipated performance of the new pipe.

The initial commitment to the Generic Letter 89-13 specifies performance testing wi be completed but a frequency is not detailed. Changing the frequency of the containment Spray heat transfer testing from yearly to every 2 years following deing will extend the testing frequency adequately to ensure the health of the heat exchangers are being appropriately monitored without Inviting failures due to insufficient monitoring. This better aligns the performance testing and inspection schedules so an Increase in performance testing failures is not antic*pated.

12.-9: oen-Cc Q n MINK wmsstm OrM*= oMM rto and B Q- Existing Open-Cycle Cool"n Water System aging management program is credited. The revised commitment adjusts the frequency of the Containment Spray Heat Exchang Performance Testing from yearly to once every three years.

g- This commitment change documents a clArification to Commitment Change Tracking 12-001. The Open-Cycle Cooling Water System aging manaement program currently credits the Generic Letter 89-13 Program with two additional enhancmeents:

" Include specificity on Inspection of heat exchangers for loss of material due to general, pitting, crevice, galvanic and microblologically influenced corrosion in the RBCCW, TBCCW and Containment Spray preventative maintenance tasks and

" Include volumetric inspections for piping that has been replaced, at a minimum of 4 aboveground locations every 4 years based on the observed and anticipated performance of the new pipe.

The heat exchangers are cleaned and inspected every three years. The clean and inspect frequency is typically set based on the cleanliness of the heat exchanger at other stations in the fleet; however, Oyster Creek opens the heat exchangers on a 3 year frequency to change the tube-side anodes. These anodes protect the carbon steel heat exchanger channels from salt

water corrosion and require frequent maintenance. This provides a time to clean the heat exchanger because it is open for other work.

The initial commitment to the Generic Letter 89-13 specifies performance testing will be completed but a frequency is not detailed. Changing the frequency of the containment spray heat transfer testing from yearly to every 3 years will extend the testing frequency adequately to ensure the health of the heat exchangers are being appropriately monitored. This better aligns the performance testing and Inspection schedules so an increase in performance testing failures is not anticipated.

12;0: Tqus Inspection O nl C0 and Revised QornM * - Original commitment was to ensure a torus inspection for cleanliness is performed each outage. Revised commitment adjusts the frequency of the torus inspection to every other refueling outage combined with torus de-sludging.

J~gjffigjM - Torus underwater inspection every refuel outage was committed to in the Oyster Creek Response to the NRC Bulletin 95-02, 30 Day Response to Buletin on Torus Strainer Clogging. The response was intended to provide compensatory actions in support of a justification for continued operation during the interim period before new ECCS Suction Strainers were installed.

Subject inspections are required to be performed every refueling outage by Regulatory Guide 1.82, Rev.2, which was referred to in the Oyster Creek Response to the NRC Bulletin 95-02 mentioned above. This response invoked Regulatory Guide 1.82, Rev 2 only to the extent applicable to the Torus s .

Although Oyster Creek is not committed to Rev 4 of this Regulatory Guide, it should be noted that it no longer requires the torus Inspections to be performed every refueling outage.

The new ECCS Suction Strainers installed in 1998 used design assumptions that took into consideration actual amounts and accumulation rates for coating material, paint chips, concrete dust, iron oxide, and fibrous material. The new strainer design allowed for torus Inspection and de-sludgng to be performed every other refueling outage. Hence, torus de-sludging frequency was changed after the installation of the new strainers from IR to 2R. The concrete dust, iron oxide (sludge) assumptions were re-verified in 1R23, and determined to provide a significant margin compared to the strainer design assumptions.

Text

NEI 99-04 RA-13-127 December 23, 2013 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Oyster Creek Nuclear GeneratkV station Renewed Facility Operating License No. DPR-16 NRC Dce No. 50-219

Subject:

Commitment Change Summary Report - 2012 Enclosed isthe Oyster Crok Nucer Genwating Station C;ommftent Change Summary Report for regulatory commrimeni s during calne year 2012. This report Is being submitted in accordance with the guidance provided by NEI M9W04.

Please contact Kathy Paez at (609) 0714671 I any ft~ infomato or assistance is eeded.

Sincerely, Garey L.Stathes Vice President Oyster Creek Nuclear Generating Staion cc: Administrator, USNRC Region I USNRC Senior Project Manager, Oyster Creek USNRC Senior Resident Inspector, Oyster Creek

The following NRC commitments tracked in the Oyster Creek Nuclear Generating Station (OCNGS) commitment-tracking database were changed during the calendar year 2012. These changes were evaluated in acoordance with Exelon Procedure LS-AA-1 10, Commit Mnagement, and determined to require NRC notification in this Commitment Change Summary Report, consistent with NEI 9.04 guidance.

12-001Q e Water System CdOMtMO and Revise CommtMt- Existing Open-Cycle Cooling Water System aging management program Is credited. The revised commitment adjusts the frequency of the Containment Spray Heat Exchanger Pedormance Testing from yearly to once every two years.

Justi -The Open-Cycle Cooling Water System aging management program curret credits the Generic Letter 89-13 Program with two additional enhancements:

• Include specifcity on inspection of heat exchangers for loss of material due to general, pitting, crevice, galvanic and mlcrobiologically influenced corrosion in the RBCCW, TBCCW and Containment Spray preventative maintenance tasks and

• Inrue volumeft Inspections for piping that has been replaced, at a mwinium of 4 aboveground locations every 4 years based on the observed and anticipated performance of the new pipe.

The initial commitment to the Generic Letter 89-13 specifies performance testing wi be completed but a frequency is not detailed. Changing the frequency of the containment Spray heat transfer testing from yearly to every 2 years following deing will extend the testing frequency adequately to ensure the health of the heat exchangers are being appropriately monitored without Inviting failures due to insufficient monitoring. This better aligns the performance testing and inspection schedules so an Increase in performance testing failures is not antic*pated.

12.-9: oen-Cc Q n MINK wmsstm OrM*= oMM rto and B Q- Existing Open-Cycle Cool"n Water System aging management program is credited. The revised commitment adjusts the frequency of the Containment Spray Heat Exchang Performance Testing from yearly to once every three years.

g- This commitment change documents a clArification to Commitment Change Tracking 12-001. The Open-Cycle Cooling Water System aging manaement program currently credits the Generic Letter 89-13 Program with two additional enhancmeents:

" Include specificity on Inspection of heat exchangers for loss of material due to general, pitting, crevice, galvanic and microblologically influenced corrosion in the RBCCW, TBCCW and Containment Spray preventative maintenance tasks and

" Include volumetric inspections for piping that has been replaced, at a minimum of 4 aboveground locations every 4 years based on the observed and anticipated performance of the new pipe.

The heat exchangers are cleaned and inspected every three years. The clean and inspect frequency is typically set based on the cleanliness of the heat exchanger at other stations in the fleet; however, Oyster Creek opens the heat exchangers on a 3 year frequency to change the tube-side anodes. These anodes protect the carbon steel heat exchanger channels from salt

water corrosion and require frequent maintenance. This provides a time to clean the heat exchanger because it is open for other work.

The initial commitment to the Generic Letter 89-13 specifies performance testing will be completed but a frequency is not detailed. Changing the frequency of the containment spray heat transfer testing from yearly to every 3 years will extend the testing frequency adequately to ensure the health of the heat exchangers are being appropriately monitored. This better aligns the performance testing and Inspection schedules so an increase in performance testing failures is not anticipated.

12;0: Tqus Inspection O nl C0 and Revised QornM * - Original commitment was to ensure a torus inspection for cleanliness is performed each outage. Revised commitment adjusts the frequency of the torus inspection to every other refueling outage combined with torus de-sludging.

J~gjffigjM - Torus underwater inspection every refuel outage was committed to in the Oyster Creek Response to the NRC Bulletin 95-02, 30 Day Response to Buletin on Torus Strainer Clogging. The response was intended to provide compensatory actions in support of a justification for continued operation during the interim period before new ECCS Suction Strainers were installed.

Subject inspections are required to be performed every refueling outage by Regulatory Guide 1.82, Rev.2, which was referred to in the Oyster Creek Response to the NRC Bulletin 95-02 mentioned above. This response invoked Regulatory Guide 1.82, Rev 2 only to the extent applicable to the Torus s .

Although Oyster Creek is not committed to Rev 4 of this Regulatory Guide, it should be noted that it no longer requires the torus Inspections to be performed every refueling outage.

The new ECCS Suction Strainers installed in 1998 used design assumptions that took into consideration actual amounts and accumulation rates for coating material, paint chips, concrete dust, iron oxide, and fibrous material. The new strainer design allowed for torus Inspection and de-sludgng to be performed every other refueling outage. Hence, torus de-sludging frequency was changed after the installation of the new strainers from IR to 2R. The concrete dust, iron oxide (sludge) assumptions were re-verified in 1R23, and determined to provide a significant margin compared to the strainer design assumptions.