ML061030282

Summary of Telephone Conference Call Between U.S. Nuclear Regulatory Commission Staff & Nuclear Energy Institute Re Proposed Interim Staff Guidance for License Renewal (LR-ISG) Associated with Corrosion Mark I Steel Containment Drywell Shel

ML061030282
Person / Time
Site:	PROJ0690
Issue date:	05/30/2006
From:	Linh Tran NRC/NRR/ADRO/DLR/RLRB
To:	Nuclear Energy Institute
tran, l., NRR/DLR/RLRB, 415-4103
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ML061030283	List: ML061030282
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Download: ML061030282 (8)

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May 30, 2006 ORGANIZATION: Nuclear Energy Institute (NEI)

SUMMARY

OF A TELEPHONE CONFERENCE CALL HELD ON JANUARY 31, 2006, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION (NRC) STAFF AND THE NUCLEAR ENERGY INSTITUTE The U.S. Nuclear Regulatory Commission staff (NRC or the staff) held a public telephone conference call on January 31, 2006, with NEI to discuss the proposed Interim Staff Guidance for License Renewal (LR-ISG) associated with the corrosion of the Mark I steel containment drywell shell. Members of the public participated in the call. Enclosure 1 provides a listing of the conference call participants. Enclosure 2 shows the handouts used during the telephone conference call. A summary of the discussion follows.

The staff explained its current LR-ISG process to ensure that the public participants had an understanding of the process.

C The LR-ISG process was set up to expeditiously address specific areas in the license renewal guidance documents (LRGDs) that need to be clarified or revised, and it serves as a bridge until the next LRGDs update.

C Through this process, the staff, industry, and interested members of the public may comment, or propose changes to information provided in the LRGDs.

C The staff reviews the comments or proposed changes to determine the merit of the proposed changes.

C The LR-ISG process also allows for interaction with stakeholders during the development of the LR-ISG.

C Once a proposed LR-ISG is developed, it is published in a Federal Register Notice requesting comments.

C Public involvement is an important part of this process. The process gives the public opportunities to obtain information and to comment on the proposed LR-ISG.

The staff has identified the potential need for an LR-ISG addressing corrosion of the Mark I steel containment drywell shell. The current Generic Aging Lessons Learned (GALL) Report (NUREG-1801, Revision 1) does not provide sufficient guidance when the drywell shell is surrounded by a concrete structure with a narrow distance between the steel shell and the surrounding concrete, inhibiting visual inspection. Past operating experience in Mark I steel containments indicates that when water is discovered in the bottom outside areas of the drywell (including those in the sand-pocket area), the most likely cause would be the water seeping through the space between the drywell shell and the shield concrete.

The staff is proposing changes to clarify its license renewal guidance documents (LRGDs).

Specifically, the staff is proposing that further evaluation be performed, including root cause analysis. Also, the staff proposes that an aging management program that would detect and monitor corrosion when the potential for corrosion is indicated in the inaccessible areas of the drywell, be established.

In its review of license renewal applications, if leakage through the seal has been found as the cause of the corrosion on outside surfaces of the drywell shell, the staff has been requesting applicants to bring the refueling seal within the scope of license renewal. Some applicants claim that, as the seal is required only during refueling activities, it does not have to be within the scope of license renewal. However, the staff believes that if seal leakage causes corrosion, the non-safety related component can impair the capability of primary containment to mitigate the consequences of an accident, and should be brought into the scope of license renewal, pursuant to 10 CFR 54.4(a)(2). If the leakage through the seal has been found not to be the cause of the corrosion, the staff requested that further evaluation be performed, including root cause analysis and an aging management program that would detect and monitor corrosion.

NEI acknowledged this issue and indicated that this issue is plant-specific and should be evaluated on a case-by-case basis, and not be applied to the industry as a whole. The staff reiterated that this issue applies only to nuclear power plants with the Mark I steel containment drywell shell design. This is a generic issue that deals with the corrosion of the Mark I steel containment drywell shell. NEI requested to meet with the staff to further discuss this issue.

The staff and NEI agreed to schedule a follow-up public meeting to further discuss this issue.

The staff also provided answers to questions from the public who participated in the telephone conference call. The majority of questions from the public were related to the design and operation of the drywell. The staff explained that the public will have an opportunity to provide comments on the proposed LR-ISG once it is developed, since it will be published in a Federal Register Notice, requesting comments.

/RA/

Linh N. Tran, Project Manager License Renewal Branch B Division of License Renewal Office of Nuclear Reactor Regulation Project No. 690

Enclosures:

1. List of Participants

2. Meeting Handouts cc w/encls: See next page The staff is proposing changes to clarify its license renewal guidance documents (LRGDs).

Specifically, the staff is proposing that further evaluation be performed, including root cause analysis. Also, the staff proposes that an aging management program that would detect and monitor corrosion when the potential for corrosion is indicated in the inaccessible areas of the drywell, be established.

In its review of license renewal applications, if leakage through the seal has been found as the cause of the corrosion on outside surfaces of the drywell shell, the staff has been requesting applicants to bring the refueling seal within the scope of license renewal. Some applicants claim that, as the seal is required only during refueling activities, it does not have to be within the scope of license renewal. However, the staff believes that if seal leakage causes corrosion, the non-safety related component can impair the capability of primary containment to mitigate the consequences of an accident, and should be brought into the scope of license renewal, pursuant to 10 CFR 54.4(a)(2). If the leakage through the seal has been found not to be the cause of the corrosion, the staff requested that further evaluation be performed, including root cause analysis and an aging management program that would detect and monitor corrosion.

NEI acknowledged this issue and indicated that this issue is plant-specific and should be evaluated on a case-by-case basis, and not be applied to the industry as a whole. The staff reiterated that this issue applies only to nuclear power plants with the Mark I steel containment drywell shell design. This is a generic issue that deals with the corrosion of the Mark I steel containment drywell shell. NEI requested to meet with the staff to further discuss this issue.

The staff and NEI agreed to schedule a follow-up public meeting to further discuss this issue.

The staff also provided answers to questions from the public who participated in the telephone conference call. The majority of questions from the public were related to the design and operation of the drywell. The staff explained that the public will have an opportunity to provide comments on the proposed LR-ISG once it is developed, since it will be published in a Federal Register Notice, requesting comments.

/RA/

Linh N. Tran, Project Manager License Renewal Branch B Division of License Renewal Office of Nuclear Reactor Regulation Project No. 690

Enclosures:

1. List of Participants

2. Meeting Handouts cc w/encls: See next page7 DISTRIBUTION: See next page Adams Accession Numbers: Pkg - ML061030283, Note to NEI w/encl 1 - ML061030282, Handouts (encls. 2) - ML061030285 OFFICE PM:RLRB:DLR LA:RLRA:DLR PM:RLRC:DLR OGC NLO BC:RLRB:DLR NAME LTran YEdmonds TTerry AHodgdon (w/comments)

JZimmerman DATE 05/ 26 /06 05/ 25 /06 04/ 13 /06 04/ 14 /06 05/ 30 /06 OFFICIAL RECORD COPY

Note to: Nuclear Energy Institute (NEI) from Linh N. Tran, Dated: May 30, 2006

SUMMARY

OF A TELEPHONE CONFERENCE CALL HELD ON JANUARY 31, 2006, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION (NRC) STAFF AND THE NUCLEAR ENERGY INSTITUTE ADAMS ACCESSION NUMBER: PKG: ML061030283 HARD COPY DLR R/F LTran E-MAIL JFair RWeisman AMurphy RPettis GGalletti CLi GBagchi SSmith (srs3)

SDuraiswamy YL (Renee) Li RidsNrrDlr RidsNrrDlrRlra RidsNrrDlrRlrb RidsNrrDe RidsNrrDci RidsNrreEemb RidsNrrDeEeeb RidsNrrDeEqva RidsNrrDss RidsNrrDnrl RidsOgcMailCenter RidsNrrAdes DLR Staff CJulian MModes JVora LKozak RidsOpaMail

LIST OF PARTICIPANTS FOR A TELEPHONE CONFERENCE CALL BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND THE NUCLEAR ENERGY INSTITUTE JANUARY 31, 2006 Participants Affiliations Pao-Tsin Kuo U.S. Nuclear Regulatory Commission (NRC)

Jacob Zimmerman NRC Kenneth Chang NRC Louise Lund NRC Hans Ashar NRC Jim Davis NRC Yoira Diaz Sanabria NRC Ram Subbaratnam NRC Amy Hull NRC Kiyoto Tanabe NRC (Foreign Assignee)

Daniel Frucher NRC Ann Hodgdon NRC Roy Mathew NRC Dan Hoang NRC Kamal Naidu NRC Stephen Hoffman NRC Linh Tran NRC Tomeka Terry NRC Cayetano Santos, Jr.

NRC/Advisory Committee on Reactor Safeguards Staff James Ross Nuclear Energy Institute (NEI)

Michael P. Gallagher Exelon Nuclear Kathryn Sutton Morgan Lewis Alex Polonsky Morgan Lewis Paul Bremer Cooper Nuclear Station Bill Victor Cooper Nuclear Station Fred Mogolesko Entergy Fred Polaski Exelon Nuclear Ken Brune Tennessee Valley Authority (TVA)

Russell Jansen TVA Joe Pairitz Monticello Madalon O'Brien Monticello Suzanne Leta New Jersey Public Interest Research Group Paul Gunter Nuclear Information and Resource Service Bill Sherman Vermont Department of Public Service Richard Webster Rutgers Environmental Law Clinic Edith Gbur Jersey Shore Nuclear Watch William Costanzo Jersey Shore Nuclear Watch Paula Gotsch Grandmothers, Mothers, and More for Energy Safety Deann Raleigh Scientech Ron Zak State of New Jersey Nancy G. Chapman Bechtel Power Corp.

Peter James Atherton Public

NUCLEAR ENERGY INSTITUTE Project No. 690 cc:

Mr. Joe Bartell U.S. Department of Energy NE-42 Washington, DC 20585 Ms. Christine S. Salembier, Commissioner State Liaison Officer Department of Public Service 112 State St., Drawer 20 Montipelier, VT 05620-2601 Mr. James Ross Nuclear Energy Institute 1776 I St., N.W., Suite 400 Washington, DC 20006-3708 Mr. Frederick W. Polaski Manager License Renewal Exelon Corporation 200 Exelon Way Kennett Square, PA 19348 Peter A. Mazzaferro Site Project Manager - License Renewal Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093 Mr. David Lochbaum Union of Concerned Scientists 1707 H St., NW, Suite 600 Washington, DC 20006-3919 Mr. Clifford I. Custer Project Manager, License Renewal FirstEnergy Nuclear Operating Company P.O. Box 4 Route 168 (Mail Stop SIM-2)

Shippingport, PA 15077 Mr. Paul Gunter, Director Reactor Watchdog Project Nuclear Information & Resource Service 6930 Carroll Avenue, Suite 340 Takoma Park, MD 20912 Mr. Hugh Jackson Public Citizen's Critical Mass Energy &

Environment Program 215 Pennsylvania Ave., SE Washington, DC 20003 Mary Olson Nuclear Information & Resource Service Southeast Office P.O. Box 7586 Asheville, NC 28802 Talmage B. Clements Manager - License Renewal Progress Energy P.O. Box 1551 Raleigh, NC 27602 Mr. Garry G. Young Manager, License Renewal Services 1448 SR 333, N-GSB-45 Russellville, AR 72802 Mr. William Crough, Manager Licensing and Regulatory Affairs Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 Patrick Burke License Renewal Project Manager Monticello Nuclear Generating Plant Nuclear Management Company, LLC 2807 West County Road 75 Monticello, MN 55362-9637 Robert A. Vincent Licensing Lead - License Renewal Project Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043