ML070600447: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(StriderTol Bot change)
 
(One intermediate revision by the same user not shown)
Line 15: Line 15:


=Text=
=Text=
{{#Wiki_filter:NRC Inspection Question - Resolution Log1 1-8PM lR21 Outage - NRC Ins teq. by LFerdas '.Kaufman
{{#Wiki_filter:NRC Inspection Question - Resolution Log1 1-8PM lR21 Outage - NRC Ins iection Question Log teq. by   Assignee  Due              Question                      Response            2esoived locurnenls provided LFerdas   (andasamy 31-Oct Insure that Tech Eva1for repairs This action is captured in 'ORC        ief. IR 546049 wlilos            5 reviewed by PORC                the 1R21 Reg.               cheduled Assurance Actions Log       or Nov 4 at items 6, 14, and 16.         200
'.Kaufman iection Question Log Assignee (andasamy wlilos hintenz ramburro Due 31-Oct 240ct 1 -NOV Question Insure that Tech Eva1 for repairs 5 reviewed by PORC Ioes the fact that there is no urb in the trench area affect the ;AMA analysis as part of LRA loes the fact that there is no urb in the trench area affect the :urrent Licensing basis Response This action is captured in the 1R21 Reg. Assurance Actions Log items 6, 14, and 16. Although the Level 2 PRA took some credit for the curb probabilistically, it is not significant enough to markedly change LERF or the conclusions of the SAMA analysis.
                      '.Kaufman hintenz  240ct  Ioes the fact that there is no    Although the Level 2       JRC        inswer provided by T.
IR is being written as a measure to make the appropriate changes to the Level 2 PRA. Also, if there are any further questions in this area Greg Krueger in Corporate Risk Assessment would be the contact point.
urb in the trench area affect the PRA took some credit for eviewing      2uintenz IR 550022
He will provide support for any further discussions on this topic, and we can arrange for that support as needed. 2esoived 'ORC cheduled or Nov 4 at 200 JRC eviewing locurnenls provided ief. IR 546049 inswer provided by T. 2uintenz IR 550022 K/Engr/l R21 Drywell/NRClnsp NRC Inspection Question - Resolution Log1 1-8PM Due 29-Oct em i 5 - Question will we change any LRA commitments previously made as a result of 1 R21 issues; How will we implement or document any plan changes.(Have we addressed the need for a more formal response machanism to this question Le. submittal?
                                                  ;AMA analysis as part of LRA      the curb probabilistically, it is not significant enough to markedly change LERF or the conclusions of the SAMA analysis. IR is being written as a measure to make the appropriate changes to the Level 2 PRA. Also, if there are any further questions in this area Greg Krueger in Corporate Risk Assessment would be the contact point. He will provide support for any further discussions on this topic, and we can arrange for that support as needed.
Which of the July 8,06 commitmtents have we met this outage?) Date 6-Oct 6-OCt teq. by '.Kaufman LFerdas Assignee Juintenz copy of the Tech Eva1 for the repairs/disposition of identified Response The License Renewal Team will evaluate whether any License Renewal commitments need to be changed or added as a result of inspections performed or new operating experience identified during 1R21. For example, the effects of water on the inside of the drywell shell will be reassessed to determine if additional aging management activities, programs or commitments are needed. AmerGen will make this determination and submit any such information to the NRC. We plan to submit a letter, supplementing the LRA with any updates that are needed to aging management programs, activities and commitments related to the wetted drywell shell internal surface, by early Provided Copy 10/29/06 - ,. , . . lesolved IRC ?viewing 'es Iocuments provided 'ech Eva1 A21 527W06 -ech Eva1 A2152754-09 WEngr/l R21 Drywell/NRClnsp I. Due 10/30/06 NRC Inspection Question - Resolution Log1 1-8PM Question Provide copies of Work order (or AWA, ECR, procedure or vendor instructions) on how to install caulk NRC asked to review the structural monitoring report from our walkdown - visual inspection by S.Markos and D.Fiorello What is the service life of the caulk? Should address service life - how long it will last and perform as needed - and specify a replacement schedule based on that conclusion - May need to say that we will perform visuals and structurally monitor to prove it is okay long term if lab results are non-conclusive for service life question What YO of the concrete can we estimate is underwater or saturated with water?
                      '.Kaufman ramburro  1-NOV loes the fact that there is no urb in the trench area affect the
What is the ph of the water - did 'we analyze for any trace of Date 6-Oct Oct .7-0ct !7-oct !7-0ct corrosion - did it show any 'ferrous traces - NRC wants to lsee data ZG-. by 4. Ferdas '.Kaufman
:urrent Licensing basis K/Engr/l R21Drywell/NRClnsp
-. O'Hara -. OHara LChaudary Assignee 3aY Tamburro Hallenbeck I See item IO Response Provided Copy 10/30/06 Part of Tech Eva1 Qualified to environmental conditions of DBA. Is conditionally monitored every outage Structures Monitoring Program. by ER-OC-450, Mike Ade, S&L performed calculation Ray answered that samples indicated corrosion has stopped - follow up - NRC wants to review data. Clarifying memo from Chemistry for initial sample out of trench in Bay 5 with Ph identified.
lesolved RC ?viewing es rovide IRC calc IRC ?viewing Iocurnents provided LCR 06-00879 AWAS -ech Eva1 A21 52754-05
\2152754-06 L? 152754-05 jturctural - Mike Adel 421 52754-06 WEngr/l R21 DrywelllNRClnsp NRC Inspection Question - Resolution Log? 1-8PM Why can't we keep track of all our inventory of water so we could quantify amount that may be in concrete area?
Did we try a test to pour water down the inside wall of the liner to see where it goes ( during SD water runs down wall but during Ops, leaks go to trough through piping) Need to rule out possibility that water running down wall is a source of water that could go between gap and liner - How are we sure? Why didn't we do this type of test? Can we calculate how much water might be in this mass of concrete Will the tech eval include assessment that worst spot for corrosion is at water-air interface, where the cut-out is? Justify in tech eval Why did we choose bays 5 and 17 in 1986, when the worst corrosion is suspected at bays ' and 13 - why not look at those? Where do bays 5 and 17 rank compared to others for "catalysi potential at the surface for corrosion Same as 16 :m k 12 - 14 16 - 17 Rate 7-Oct - :7-Oct !7-oct 27-oct 27-OCt :eq. by LChaudary
.. O'Hara VRC S .C hauda y T. O'Hara Assignee :ay Lay Due Question Response Calculate volume for Item 9 Repairs to prevent water entering concrete at interface to shell Close to Item 9 In attachment to Tech Eval, Barry Gordon Pete Tamburro, in eval for UT Documents provided I ?s - see ITech Eva1 A2152754-05 WEngr/l R21 DtywelVNRCInsp Date 27-0ct 27-Oct Req. by T. O'Hara S.Chaudary Time 930 930 Assignee NRC Inspection Question - Resolution Log1 1-8PM Question I If shell is breached at the bottom, would out Type A leak test identify that?
Does the grout / caulk addition affect this answer, or was it included as an assumption during review? What are the C02 and 02 levels in the water found in the trench as this would affect corrosion and what effect do these values have on our corrosion estimates (NRC commented that cracks develop from tension in concrete and they could carry 02 through cracks to liner Response Shirk add to Tech Eva1 Artz - need to address in Tech Eva1 iesolved )pen until JRC .eviews rech Eva1 )ocurnetits provided K/Engr/l R21 Drywell/NRClnsp
,. .- k NRC Inspection Question - Resolution Log1 1-8PM Date 27-Oct Time 930 Req. by T. O'Hara Assignee Quintenz Due Question I Now that there is a new environment to consider, we ma) need to address the need to re- do the aging management program based on what we found in 1R21- we assume sumps and piping function as designed -will there be a new commitment to inspect regularly?
NRC raised concern on 10CFR 54.13 accuracy ofinformation - Did we only consider 5 years history in all aging management programs?lf the LRA is based on design and operating experience, why didn't out our LRA include assessment of this history of water in the DW liner area? [Resolved Documents provided I Response requires each license renewal applicant to "notify the Commission of information identified by the applicant as having, for the regulated activity, a significant implication for


public health and safety or common defense and security." After reviewins the evaluation of the impact of water found in the bay #5 inspection trench in the drywell floor, Exelon has determined that 54.13(b) does not apply. The evaluation, as documented in AIR A2152754 Eva1 06 and Eva1 09, has determined that the drywell structural integrit) is maintained and the drywell continues to meet all of its design basis requirements.
NRC Inspection Question - Resolution Log11-8PM em i  Date          teq. by  Assignee  Due              Question                      Response          lesolved Iocuments provided
WEngrll R21 DrywelllNRClnsp NRC Inspection Question - Resolution Log1 1-8PM Due 30-013 em 1 21 - 23 25 26 - Question Confirm that we have a commitment to perform UT Testing of wall thickness in trenches 5 and 17 every outage as part of the monitoring program. When will we UT trench area next? (Engr. responded next outage) - need to confirm. NRC is expecting that there will be more UT inspections planned to prove no corrosion is active(at least 3 times, with the third time being post POE) (related to Item 4). Do we have plans to do more inspections for this purpose? Will we be able to supply NRC with a white paper - a high level - single page or summary of what we found, what we did to fix it and why we think this is okay - by end of Friday Will we add any visual or other testing of the trenchltrough to the forced outage schedule?
- 4  6-Oct          '.Kaufman Juintenz 29-Oct will we change any LRA            The License Renewal        IRC commitments previously made      Team will evaluate        ?viewing as a result of 1R21 issues; How  whether any License will we implement or document    Renewal commitments any plan changes.(Have we        need to be changed or addressed the need for a more    added as a result of formal response machanism to      inspections performed or this question Le. submittal?      new operating Which of the July 8,06            experience identified commitmtents have we met this    during 1R21. For outage?)                          example, the effects of water on the inside of the drywell shell will be reassessed to determine if additional aging management activities, programs or commitments are needed. AmerGen will make this determination and submit any such information to the NRC.
NRC requests list of all IRs and assignments for both commitments and from "new" DW water issue, that need closure prior to start up. Request for our submittal of DW related commitments Time )30 )30 - 130 - 130 - i30 ieq. by -. O'Hara 2.Kaufman AFerdas r. O'Hara r. O'Hara Assignee taY .ambert hintenz IMoved to item 21 Response ER-OC-450 Draft provided No, covered by existing program List provided
We plan to submit a letter, supplementing the LRA with any updates that are needed to aging management programs, activities and commitments related to the wetted drywell shell internal surface, by early 5  6-OCt          LFerdas                                                      Provided Copy 10/29/06 'es        'ech Eva1A21527W06 copy of the Tech Eva1for the                                          -ech Eva1A2152754-09 repairs/disposition of identified WEngr/l R21Drywell/NRClnsp
!esofved 'es 'es 'es )ocuments provided )we copy of procedure to IRC )raft of white paper WEngdl R21 DrywelllNRClnsp Item d Date Time Req. by 27 28 30-Oct 830 T. O'Hara 29 NRC Inspection Question - Resolution Log1 1-8PM Assignee Ray Response Resolved TE - UT (May need to adjust wording in tech eval to say that with the known minimal corrosion rate, applied to the next 20 minimum years, we would be okay ) NRC to review tech Eva1 Documents provided I I IR - I 1 Due 30-Oct WEngr/l R21 DryweWNRClnsp Question Added to item 21 NRC needs clarification on whether corrosion is actually arrested - they were told in submittals and ACRS that it was but data suggests othewise - need to review data with inspectors to clarify Added to item 20 NRC Inspection Question - Resolution Log1 1-8PM Due - em i Question At the ACRS meeting, there may have been a statement made by Exelon the corrosion has been "arrested" Confirm if possible.
 
Did we say that in any correspondence?(LRA) 30 - Date Io-oct - Time 500 - - ieq by I'Hara A& ig nee luintenz Response AmerGen has reviewed the July 22, 2005 Oyster Creek License Renewal Application (LRA), the April 7,2006 response to NRC RAls on Drywell corrosion (AmerGen Letter 21 30-06-202289), the June 20,2006 letter forwarding supplemental information to NRC following the June 1, 2006 public meeting on drywell corrosion (AmerGen Letter 21 30- 06-20353), the June 23, 2006 submittal that provided the NRC Staff with an update to Appendix A of the LRA following all the Audits (AmerGen letter 21 30-06 203%), and the transcripts from the October 3,2006 ACRS Subcommittee meeting.
I .
Based on review of these documents, AmerGen concludes that within these written documents and also as part of the oral comments made at the October 3rd ACRS Subcommittee meeting, 1- -~ !esolved ~ ~~ ~ Iocuments provided-WEngr/l R21 DrywelVNRClnsp 
NRC Inspection Question - Resolution Log1 1-8PM Date          ZG-.by    Assignee      Due                Question                      Response          lesolved Iocurnents provided 6-Oct          4. Ferdas            10/30/06Provide copies of Work order (or    Provided Copy 10/30/06    RC      LCR 06-00879 AWAS AWA, ECR, procedure or vendor                                  ?viewing -ech Eva1A2152754-05 instructions) on how to install caulk 6-Oct          '.Kaufman                      NRC asked to review the            Part of Tech Eva1        es      \2152754-06 structural monitoring report from our walkdown - visual inspection by S.Markos and D.Fiorello
.- Due NRC Inspection Question - Resolution Log1 1-8PM Question Do we know we have identified the source of the water? Do we know we have stopped it? Can we prove it? Do we intend to tesi repairs? Do we know how long leakage path was there? Does TDR address bottle discovery?
        .7-0ct          -.O'Hara 3aY                What is the service life of the      Qualified to                       L?152754-05 caulk? Should address service      environmental conditions life - how long it will last and    of DBA. Is conditionally perform as needed - and specify    monitored every outage a replacement schedule based        by ER-OC-450, on that conclusion - May need to    Structures Monitoring say that we will perform visuals    Program.
Does the design bases assume no leakage to liner area?
and structurally monitor to prove it is okay long term if lab results are non-conclusive for service life question
Do we hav any documents that say it's okay to be wet? Did we consider possibility of external sources of water? When water was identified back in around 1994, what corrective actions did we plan to resolcve issue? Did we do them? Cancel them? Do we intend to submit report to ASLB? Are lawyers looking at it? When will we decide? qesolved Response Documents provided In Tech Eva1 and ECR In Tech Eva1 In Tech Eva1 DRAFT Respose under review in ArnerGen In tech eval - Tech eval only addresses operability - it is not a submittal -would become part of mandatory disclosure.
        !7-oct          -. OHara  Tamburro            What YOof the concrete can we      Mike Ade, S&L              rovide  jturctural - Mike Adel Hallenbeck          estimate is underwater or          performed calculation    IRC calc saturated with water?
WEngr/l R21 DrywelVNRClnsp 
        !7-0ct          LChaudary                      What is the ph of the water - did  Ray answered that        IRC      42152754-06
... 'tern - 36 37 Due Date ;o-oct 'l-oct ~ Question Sand bed drains were uncloggec this outage - what frequency will they be checked? Future surveillance plan to ensure drains are open and operable? - Time - 500 - 30 teq. by 'inney :erdas Assignee luintenz NRC Inspection Question - Resolution Log1 1-8PM NRC wants copy of completed work package that repaired clogged drains. Want to see visual inspection report of drains Response The future surveillance plan for the sand bed drains will be determined after our review of the I R21 operating experience.
                                                      'we analyze for any trace of        samples indicated        ?viewing corrosion - did it show any        corrosion has stopped -
Any further commitments relative to sand bed drain surveillance to ensure they are open and operable will be considered in our formal submittal discusseed in Item ##4. Work order number R2088495 printout provided with CREM to Mark Ferdas 11/2/06 0830 Meeting ?esolved Iocuments provided WEngrll R21 DrywelllNRClnsp 
                                                      'ferroustraces - NRC wants to       follow up - NRC wants to lsee data                            review data.
..- a NRC Inspection Question - Resolution Log1 1-8PM Date mz- Time 130 ?eq. by Assignee Due Question s there any OE on containments hat have been demolished that ;hows effects of wetted liner and mrosion in embedded regions? Response iesolved Documents provided I The EPRl Structural Tools document references the use of the Shippingport experience with concrete, but does not reference experience with embedded steel.
Clarifying memo from Chemistry for initial sample out of trench in Bay 5 with Ph identified.
In discussions with Fred Polaski, License Renewal Manager he was not aware of any specific operating experience from decommissioned plants which has been used.
I See item I O WEngr/l R21DrywelllNRClnsp
We are using the NRC GALL for our work and there may be some experienced factored into it, but that is not known at this time. K/Engr/l R21 DrywelVNRCInsp}}
 
NRC Inspection Question - Resolution Log?1-8PM Due                Question                      Response                  Documents provided
:m k  Rate        :eq. by    Assignee I
-12 7-Oct          LChaudary  :ay            Why can't we keep track of all    Calculate volume for    ?s- see ITech Eva1 A2152754-05 our inventory of water so we      Item 9 could quantify amount that may 13 :7-Oct        .. O'Hara  Lay be in concrete area?
Did we try a test to pour water    Repairs to prevent water down the inside wall of the liner  entering concrete at to see where it goes ( during SD  interface to shell water runs down wall but during Ops, leaks go to trough through piping) Need to rule out possibility that water running down wall is a source of water that could go between gap and liner - How are we sure? Why didn't we do this type of test?
-14 !7-oct         VRC                        Can we calculate how much          Close to Item 9 water might be in this mass of
- 15 27-oct        S .Chauday concrete Will the tech eval include        In attachment to Tech assessment that worst spot for    Eval, Barry Gordon corrosion is at water-air interface, where the cut-out is?
Justify in tech eval
- 16 27-OCt        T. O'Hara                  Why did we choose bays 5 and      Pete Tamburro, in eval 17 in 1986, when the worst        for UT corrosion is suspected at bays '
and 13 - why not look at those?
Where do bays 5 and 17 rank compared to others for "catalysi potential at the surface for corrosion
- 17                                          Same as 16 WEngr/l R21DtywelVNRCInsp
 
NRC Inspection Question - Resolution Log11-8PM Date 27-0ct Time Req. by 930    T. O'Hara Assignee I              Question If shell is breached at the
 
===Response===
Shirk add to Tech Eva1 iesolved )ocurnetits provided bottom, would out Type A leak test identify that? Does the grout / caulk addition affect this answer, or was it included as an assumption during review?
27-Oct  930    S.Chaudary              What are the C02 and 02 levels    Artz - need to address in )pen until in the water found in the trench  Tech Eva1                JRC as this would affect corrosion                              .eviews and what effect do these values                              rech Eva1 have on our corrosion estimates (NRC commented that cracks develop from tension in concrete and they could carry 0 2 through cracks to liner K/Engr/l R21Drywell/NRClnsp
 
NRC Inspection Question - Resolution Log11-8PM I
k  Date 27-Oct Time Req. by 930    T. O'Hara Assignee Quintenz Due                Question Now that there is a new
 
===Response===
I
[Resolved Documents provided environment to consider, we ma)      requires each license need to address the need to re-      renewal applicant to do the aging management              "notify the program based on what we             Commission of found in 1R21-we assume              information identified by sumps and piping function as        the applicant as having, designed -will there be a new        for the commitment to inspect                regulated activity, a regularly? NRC raised concern        significant implication for on 10CFR 54.13 accuracy              public health and safety ofinformation - Did we only          or common defense and consider 5 years history in all      security." After reviewins aging management programs?lf        the evaluation of the the LRA is based on design and      impact of water found in operating experience, why didn't    the bay #5 inspection out our LRA include assessment      trench in the drywell of this history of water in the DW  floor, liner area?                         Exelon has determined that 54.13(b) does not apply. The evaluation, as documented in AIR A2152754 Eva1 06 and Eva109, has determined that the drywell structural integrit) is maintained and the drywell continues to meet all of its design basis requirements.
WEngrll R21DrywelllNRClnsp
 
NRC Inspection Question - Resolution Log11-8PM em 1        Time ieq. by    Assignee  Due                Question                     Response        !esofved )ocuments provided
-21          )30 -. O'Hara                    Confirm that we have a              ER-OC-450                      )we copy of procedure to taY commitment to perform UT                                            IRC Testing of wall thickness in trenches 5 and 17 every outage as part of the monitoring program. When will we UT trench area next? (Engr.
responded next outage) - need to confirm. NRC is expecting that there will be more UT inspections planned to prove no corrosion is active(at least 3 times, with the third time being post POE) (related to Item 4).
Do we have plans to do more inspections for this purpose?
-22          )30 2.Kaufman    .ambert        Will we be able to supply NRC       Draft provided        'es      )raft of white paper with a white paper - a high level -
single page or summary of what we found, what we did to fix it and why we think this is okay -
by end of Friday
-23 130    AFerdas                  Will we add any visual or other    No,covered by existing testing of the trenchltrough to    program the forced outage schedule?
24 130    r. O'Hara                  NRC requests list of all IRs and                          'es assignments for both commitments and from "new" DW water issue, that need
-25 i30    r. O'Hara hintenz closure prior to start up.
30-013 Request for our submittal of DW    List provided          'es
-                                            related commitments IMoved to item 21 26 WEngdl R21DrywelllNRClnsp
 
NRC Inspection Question - Resolution Log11-8PM Item d  Date  Time Req. by    Assignee  Due              Question                  Response            Resolved Documents provided 27                                          Added to item 21 28  30-Oct 830  T. O'Hara Ray      30-Oct NRC needs clarification on      TE - UT (May need to        NRC to whether corrosion is actually  adjust wording in tech      review tech arrested they were told in      eval to say that with the Eva1 submittals and ACRS that it was known minimal corrosion but data suggests othewise -    rate, applied to the next need to review data with        20 minimum years, we inspectors to clarify          would be okay )
I            I 29                                          Added to item 20                IR -                      I            1 WEngr/l R21DryweWNRClnsp
 
NRC Inspection Question - Resolution Log1 1-8PM em  i  Date Time i e q by A& ignee Due              Question                    Response
                                                                                                        -~
                                                                                                    !esolved
                                                                                                              ~ ~~ ~
Iocuments provided-
              - I'Hara 30  Io-oct  500          luintenz      At the ACRS meeting, there may  AmerGen has reviewed have been a statement made by  the July 22, 2005 Oyster Exelon the corrosion has been  Creek License Renewal "arrested" Confirm if possible. Application (LRA), the Did we say that in any          April 7,2006 response to correspondence?(LRA)            NRC RAls on Drywell corrosion (AmerGen Letter 2130-06-202289),
the June 20,2006 letter forwarding supplemental information to NRC following the June 1, 2006 public meeting on drywell corrosion (AmerGen Letter 2130-06-20353), the June 23, 2006 submittal that provided the NRC Staff with an update to Appendix A of the LRA following all the Audits (AmerGen letter 2130-06 203%), and the transcripts from the October 3,2006 ACRS Subcommittee meeting.
Based on review of these documents, AmerGen concludes that within these written documents and also as part of the oral comments made at the October 3rd ACRS Subcommittee meeting,
-            -                                                                    1-WEngr/l R21DrywelVNRClnsp
 
NRC Inspection Question - Resolution Log11-8PM Due              Question                    Response          qesolved Documents provided Do we know we have identified    In Tech Eva1 and ECR the source of the water? Do we know we have stopped it? Can we prove it? Do we intend to tesi repairs? Do we know how long leakage path was there? Does TDR address bottle discovery?
Does the design bases assume      In Tech Eva1 no leakage to liner area? Do we hav any documents that say its okay to be wet?
Did we consider possibility of    In Tech Eva1 external sources of water?
When water was identified back    DRAFT Respose under in around 1994, what corrective  review in ArnerGen actions did we plan to resolcve issue? Did we do them? Cancel them?
Do we intend to submit report to  In tech eval - Tech eval ASLB? Are lawyers looking at it?  only addresses When will we decide?              operability - it is not a submittal -would become part of mandatory disclosure.
WEngr/l R21DrywelVNRClnsp
 
NRC Inspection Question - Resolution Log11-8PM
  'tern  Date Time teq. by  Assignee Due              Question
                                                                              ~
Response          ?esolved Iocuments provided
  -  36 ;o-oct 500    'inney luintenz        Sand bed drains were uncloggec    The future surveillance this outage - what frequency will  plan for the sand bed they be checked? Future            drains will be determined surveillance plan to ensure        after our review of the drains are open and operable?      IR21 operating experience. Any further commitments relative to sand bed drain surveillance to ensure they are open and operable will be considered in our formal submittal discusseed in Item ##4.
37 'l-oct 30    :erdas                NRC wants copy of completed        Work order number work package that repaired        R2088495 printout clogged drains. Want to see        provided with CREM to visual inspection report of drains Mark Ferdas 11/2/06 0830 Meeting WEngrll R21DrywelllNRClnsp
 
a NRC Inspection Question - Resolution Log11-8PM Date mz- 130 Time ?eq. by Assignee Due              Question s there any OE on containments
 
===Response===
The EPRl Structural I
iesolved Documents provided hat have been demolished that    Tools document
                                                ;hows effects of wetted liner and references the use of the mrosion in embedded regions?      Shippingport experience with concrete, but does not reference experience with embedded steel. In discussions with Fred Polaski, License Renewal Manager he was not aware of any specific operating experience from decommissioned plants which has been used.
We are using the NRC GALL for our work and there may be some experienced factored into it, but that is not known at this time.
K/Engr/l R21DrywelVNRCInsp}}

Latest revision as of 19:38, 13 March 2020

1R21 Outage - NRC Inspection Question Log Complied by Amergen (12 Pages)
ML070600447
Person / Time
Site: Oyster Creek, Three Mile Island, Clinton
Issue date: 10/31/2006
From:
NRC Region 1
To:
References
Download: ML070600447 (12)


Text

NRC Inspection Question - Resolution Log1 1-8PM lR21 Outage - NRC Ins iection Question Log teq. by Assignee Due Question Response 2esoived locurnenls provided LFerdas (andasamy 31-Oct Insure that Tech Eva1for repairs This action is captured in 'ORC ief. IR 546049 wlilos 5 reviewed by PORC the 1R21 Reg. cheduled Assurance Actions Log or Nov 4 at items 6, 14, and 16. 200

'.Kaufman hintenz 240ct Ioes the fact that there is no Although the Level 2 JRC inswer provided by T.

urb in the trench area affect the PRA took some credit for eviewing 2uintenz IR 550022

AMA analysis as part of LRA the curb probabilistically, it is not significant enough to markedly change LERF or the conclusions of the SAMA analysis. IR is being written as a measure to make the appropriate changes to the Level 2 PRA. Also, if there are any further questions in this area Greg Krueger in Corporate Risk Assessment would be the contact point. He will provide support for any further discussions on this topic, and we can arrange for that support as needed.

'.Kaufman ramburro 1-NOV loes the fact that there is no urb in the trench area affect the

urrent Licensing basis K/Engr/l R21Drywell/NRClnsp

NRC Inspection Question - Resolution Log11-8PM em i Date teq. by Assignee Due Question Response lesolved Iocuments provided

- 4 6-Oct '.Kaufman Juintenz 29-Oct will we change any LRA The License Renewal IRC commitments previously made Team will evaluate ?viewing as a result of 1R21 issues; How whether any License will we implement or document Renewal commitments any plan changes.(Have we need to be changed or addressed the need for a more added as a result of formal response machanism to inspections performed or this question Le. submittal? new operating Which of the July 8,06 experience identified commitmtents have we met this during 1R21. For outage?) example, the effects of water on the inside of the drywell shell will be reassessed to determine if additional aging management activities, programs or commitments are needed. AmerGen will make this determination and submit any such information to the NRC.

We plan to submit a letter, supplementing the LRA with any updates that are needed to aging management programs, activities and commitments related to the wetted drywell shell internal surface, by early 5 6-OCt LFerdas Provided Copy 10/29/06 'es 'ech Eva1A21527W06 copy of the Tech Eva1for the -ech Eva1A2152754-09 repairs/disposition of identified WEngr/l R21Drywell/NRClnsp

I .

NRC Inspection Question - Resolution Log1 1-8PM Date ZG-.by Assignee Due Question Response lesolved Iocurnents provided 6-Oct 4. Ferdas 10/30/06Provide copies of Work order (or Provided Copy 10/30/06 RC LCR 06-00879 AWAS AWA, ECR, procedure or vendor ?viewing -ech Eva1A2152754-05 instructions) on how to install caulk 6-Oct '.Kaufman NRC asked to review the Part of Tech Eva1 es \2152754-06 structural monitoring report from our walkdown - visual inspection by S.Markos and D.Fiorello

.7-0ct -.O'Hara 3aY What is the service life of the Qualified to L?152754-05 caulk? Should address service environmental conditions life - how long it will last and of DBA. Is conditionally perform as needed - and specify monitored every outage a replacement schedule based by ER-OC-450, on that conclusion - May need to Structures Monitoring say that we will perform visuals Program.

and structurally monitor to prove it is okay long term if lab results are non-conclusive for service life question

!7-oct -. OHara Tamburro What YOof the concrete can we Mike Ade, S&L rovide jturctural - Mike Adel Hallenbeck estimate is underwater or performed calculation IRC calc saturated with water?

!7-0ct LChaudary What is the ph of the water - did Ray answered that IRC 42152754-06

'we analyze for any trace of samples indicated ?viewing corrosion - did it show any corrosion has stopped -

'ferroustraces - NRC wants to follow up - NRC wants to lsee data review data.

Clarifying memo from Chemistry for initial sample out of trench in Bay 5 with Ph identified.

I See item I O WEngr/l R21DrywelllNRClnsp

NRC Inspection Question - Resolution Log?1-8PM Due Question Response Documents provided

m k Rate :eq. by Assignee I

-12 7-Oct LChaudary :ay Why can't we keep track of all Calculate volume for ?s- see ITech Eva1 A2152754-05 our inventory of water so we Item 9 could quantify amount that may 13 :7-Oct .. O'Hara Lay be in concrete area?

Did we try a test to pour water Repairs to prevent water down the inside wall of the liner entering concrete at to see where it goes ( during SD interface to shell water runs down wall but during Ops, leaks go to trough through piping) Need to rule out possibility that water running down wall is a source of water that could go between gap and liner - How are we sure? Why didn't we do this type of test?

-14 !7-oct VRC Can we calculate how much Close to Item 9 water might be in this mass of

- 15 27-oct S .Chauday concrete Will the tech eval include In attachment to Tech assessment that worst spot for Eval, Barry Gordon corrosion is at water-air interface, where the cut-out is?

Justify in tech eval

- 16 27-OCt T. O'Hara Why did we choose bays 5 and Pete Tamburro, in eval 17 in 1986, when the worst for UT corrosion is suspected at bays '

and 13 - why not look at those?

Where do bays 5 and 17 rank compared to others for "catalysi potential at the surface for corrosion

- 17 Same as 16 WEngr/l R21DtywelVNRCInsp

NRC Inspection Question - Resolution Log11-8PM Date 27-0ct Time Req. by 930 T. O'Hara Assignee I Question If shell is breached at the

Response

Shirk add to Tech Eva1 iesolved )ocurnetits provided bottom, would out Type A leak test identify that? Does the grout / caulk addition affect this answer, or was it included as an assumption during review?

27-Oct 930 S.Chaudary What are the C02 and 02 levels Artz - need to address in )pen until in the water found in the trench Tech Eva1 JRC as this would affect corrosion .eviews and what effect do these values rech Eva1 have on our corrosion estimates (NRC commented that cracks develop from tension in concrete and they could carry 0 2 through cracks to liner K/Engr/l R21Drywell/NRClnsp

NRC Inspection Question - Resolution Log11-8PM I

k Date 27-Oct Time Req. by 930 T. O'Hara Assignee Quintenz Due Question Now that there is a new

Response

I

[Resolved Documents provided environment to consider, we ma) requires each license need to address the need to re- renewal applicant to do the aging management "notify the program based on what we Commission of found in 1R21-we assume information identified by sumps and piping function as the applicant as having, designed -will there be a new for the commitment to inspect regulated activity, a regularly? NRC raised concern significant implication for on 10CFR 54.13 accuracy public health and safety ofinformation - Did we only or common defense and consider 5 years history in all security." After reviewins aging management programs?lf the evaluation of the the LRA is based on design and impact of water found in operating experience, why didn't the bay #5 inspection out our LRA include assessment trench in the drywell of this history of water in the DW floor, liner area? Exelon has determined that 54.13(b) does not apply. The evaluation, as documented in AIR A2152754 Eva1 06 and Eva109, has determined that the drywell structural integrit) is maintained and the drywell continues to meet all of its design basis requirements.

WEngrll R21DrywelllNRClnsp

NRC Inspection Question - Resolution Log11-8PM em 1 Time ieq. by Assignee Due Question Response !esofved )ocuments provided

-21 )30 -. O'Hara Confirm that we have a ER-OC-450 )we copy of procedure to taY commitment to perform UT IRC Testing of wall thickness in trenches 5 and 17 every outage as part of the monitoring program. When will we UT trench area next? (Engr.

responded next outage) - need to confirm. NRC is expecting that there will be more UT inspections planned to prove no corrosion is active(at least 3 times, with the third time being post POE) (related to Item 4).

Do we have plans to do more inspections for this purpose?

-22 )30 2.Kaufman .ambert Will we be able to supply NRC Draft provided 'es )raft of white paper with a white paper - a high level -

single page or summary of what we found, what we did to fix it and why we think this is okay -

by end of Friday

-23 130 AFerdas Will we add any visual or other No,covered by existing testing of the trenchltrough to program the forced outage schedule?

24 130 r. O'Hara NRC requests list of all IRs and 'es assignments for both commitments and from "new" DW water issue, that need

-25 i30 r. O'Hara hintenz closure prior to start up.30-013 Request for our submittal of DW List provided 'es

- related commitments IMoved to item 21 26 WEngdl R21DrywelllNRClnsp

NRC Inspection Question - Resolution Log11-8PM Item d Date Time Req. by Assignee Due Question Response Resolved Documents provided 27 Added to item 21 28 30-Oct 830 T. O'Hara Ray 30-Oct NRC needs clarification on TE - UT (May need to NRC to whether corrosion is actually adjust wording in tech review tech arrested they were told in eval to say that with the Eva1 submittals and ACRS that it was known minimal corrosion but data suggests othewise - rate, applied to the next need to review data with 20 minimum years, we inspectors to clarify would be okay )

I I 29 Added to item 20 IR - I 1 WEngr/l R21DryweWNRClnsp

NRC Inspection Question - Resolution Log1 1-8PM em i Date Time i e q by A& ignee Due Question Response

-~

!esolved

~ ~~ ~

Iocuments provided-

- I'Hara 30 Io-oct 500 luintenz At the ACRS meeting, there may AmerGen has reviewed have been a statement made by the July 22, 2005 Oyster Exelon the corrosion has been Creek License Renewal "arrested" Confirm if possible. Application (LRA), the Did we say that in any April 7,2006 response to correspondence?(LRA) NRC RAls on Drywell corrosion (AmerGen Letter 2130-06-202289),

the June 20,2006 letter forwarding supplemental information to NRC following the June 1, 2006 public meeting on drywell corrosion (AmerGen Letter 2130-06-20353), the June 23, 2006 submittal that provided the NRC Staff with an update to Appendix A of the LRA following all the Audits (AmerGen letter 2130-06 203%), and the transcripts from the October 3,2006 ACRS Subcommittee meeting.

Based on review of these documents, AmerGen concludes that within these written documents and also as part of the oral comments made at the October 3rd ACRS Subcommittee meeting,

- - 1-WEngr/l R21DrywelVNRClnsp

NRC Inspection Question - Resolution Log11-8PM Due Question Response qesolved Documents provided Do we know we have identified In Tech Eva1 and ECR the source of the water? Do we know we have stopped it? Can we prove it? Do we intend to tesi repairs? Do we know how long leakage path was there? Does TDR address bottle discovery?

Does the design bases assume In Tech Eva1 no leakage to liner area? Do we hav any documents that say its okay to be wet?

Did we consider possibility of In Tech Eva1 external sources of water?

When water was identified back DRAFT Respose under in around 1994, what corrective review in ArnerGen actions did we plan to resolcve issue? Did we do them? Cancel them?

Do we intend to submit report to In tech eval - Tech eval ASLB? Are lawyers looking at it? only addresses When will we decide? operability - it is not a submittal -would become part of mandatory disclosure.

WEngr/l R21DrywelVNRClnsp

NRC Inspection Question - Resolution Log11-8PM

'tern Date Time teq. by Assignee Due Question

~

Response ?esolved Iocuments provided

- 36 ;o-oct 500 'inney luintenz Sand bed drains were uncloggec The future surveillance this outage - what frequency will plan for the sand bed they be checked? Future drains will be determined surveillance plan to ensure after our review of the drains are open and operable? IR21 operating experience. Any further commitments relative to sand bed drain surveillance to ensure they are open and operable will be considered in our formal submittal discusseed in Item ##4.

37 'l-oct 30 :erdas NRC wants copy of completed Work order number work package that repaired R2088495 printout clogged drains. Want to see provided with CREM to visual inspection report of drains Mark Ferdas 11/2/06 0830 Meeting WEngrll R21DrywelllNRClnsp

a NRC Inspection Question - Resolution Log11-8PM Date mz- 130 Time ?eq. by Assignee Due Question s there any OE on containments

Response

The EPRl Structural I

iesolved Documents provided hat have been demolished that Tools document

hows effects of wetted liner and references the use of the mrosion in embedded regions? Shippingport experience with concrete, but does not reference experience with embedded steel. In discussions with Fred Polaski, License Renewal Manager he was not aware of any specific operating experience from decommissioned plants which has been used.

We are using the NRC GALL for our work and there may be some experienced factored into it, but that is not known at this time.

K/Engr/l R21DrywelVNRCInsp