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| | issue date = 07/07/2014 | | | issue date = 07/07/2014 |
| | title = Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station License Renewal Application | | | title = Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station License Renewal Application |
| | author name = Sayoc E C | | | author name = Sayoc E |
| | author affiliation = NRC/NRR/DLR/RPB1 | | | author affiliation = NRC/NRR/DLR/RPB1 |
| | addressee name = Lieb R A | | | addressee name = Lieb R |
| | addressee affiliation = FirstEnergy Nuclear Operating Co | | | addressee affiliation = FirstEnergy Nuclear Operating Co |
| | docket = 05000346 | | | docket = 05000346 |
| | license number = NPF-003 | | | license number = NPF-003 |
| | contact person = Sayoc E C, 415-4084 | | | contact person = Sayoc E, 415-4084 |
| | case reference number = TAC ME4640 | | | case reference number = TAC ME4640 |
| | document type = Letter, Request for Additional Information (RAI) | | | document type = Letter, Request for Additional Information (RAI) |
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| =Text= | | =Text= |
| {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 7, 2014 | | {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 7, 2014 Mr. Raymond A. Lieb Vice President Davis-Besse Nuclear Power Station FirstEnergy Nuclear Operating Company 5501 North State Route 2 Oak Harbor, OH 43449 |
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| Mr. Raymond A. Lieb Vice President Davis-Besse Nuclear Power Station FirstEnergy Nuclear Operating Company | |
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| 5501 North State Route 2 Oak Harbor, OH 43449 | |
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| ==SUBJECT:== | | ==SUBJECT:== |
| REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE DAVIS-BESSE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. ME4640) | | REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE DAVIS-BESSE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. ME4640) |
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| ==Dear Mr. Lieb:== | | ==Dear Mr. Lieb:== |
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| By letter dated August 27, 2010, FirstEnergy Nuclear Operating Company submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 for renewal of Operating License NPF-3 for the Davis-Besse Nuclear Power Station. The staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing this application in accordance with the guidance in NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants." During its review, the staff has identified areas where additional information is needed to complete the review. The staff's requests for additional information are included in the enclosure. Further requests for additional information may be issued in the future. | | By letter dated August 27, 2010, FirstEnergy Nuclear Operating Company submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 for renewal of Operating License NPF-3 for the Davis-Besse Nuclear Power Station. The staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing this application in accordance with the guidance in NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants. During its review, the staff has identified areas where additional information is needed to complete the review. The staffs requests for additional information are included in the enclosure. Further requests for additional information may be issued in the future. |
| | | Items in the enclosure were discussed with Cliff Custer, of your staff, and a mutually agreeable date for the response is July 30, 2014. If you have any questions, please contact me by telephone at 301-415-4084 or by e-mail at Emmanuel.Sayoc@nrc.gov Sincerely, |
| Items in the enclosure were discussed with Cliff Custer, of your staff, and a mutually agreeable date for the response is July 30, 2014. If you have any questions, please contact me by telephone at 301-415-4084 or by e-mail at Emmanuel.Sayoc@nrc.gov | | /RA/ |
| | | Emmanuel Sayoc, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-346 |
| Sincerely, | |
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| /RA/ Emmanuel Sayoc, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation
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| Docket No. 50-346 | |
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| ==Enclosure:== | | ==Enclosure:== |
| As stated
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| cc w/encl: Listserv | | As stated cc w/encl: Listserv |
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| ML14178A962 *concurred via email OFFICE LA:DLR/RPB2* PM:DLR/RPB1 BC:DLR/RPB1 PM:DLR/RPB1 NAME IKing ESayoc YDiaz-Sanabria ESayoc DATE 7/1/14 7/7/14 7/7/14 7/7/14 | | ML14178A962 *concurred via email OFFICE LA:DLR/RPB2* PM:DLR/RPB1 BC:DLR/RPB1 PM:DLR/RPB1 NAME IKing ESayoc YDiaz-Sanabria ESayoc DATE 7/1/14 7/7/14 7/7/14 7/7/14 |
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| ==SUBJECT:== | | ==SUBJECT:== |
| REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE DAVIS-BESSE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. ME4640) | | REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE DAVIS-BESSE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. ME4640) |
| | | DISTRIBUTION: |
| DISTRIBUTION | | HARD COPY: |
| : HARD COPY: DLR R/F E-MAIL: PUBLIC RidsNrrDlrResource
| | DLR R/F E-MAIL: |
| | | PUBLIC RidsNrrDlrResource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRer1 Resource RidsNrrDlrRer2 Resource RidsNrrDlrRerb Resource RidsNrrDlrRpob Resource RidsNrrDciCvib Resource RidsNrrDciCpnb Resource RidsNrrDciCsgb Resource RidsNrrDraAfpb Resource RidsNrrDraApla Resource RidsNrrDeEmcb Resource RidsNrrDeEeeb Resource RidsNrrDssSrxb Resource RidsNrrDssSbpb Resource RidsNrrDssScvb Resource RidsOgcMailCenter Resource RidsNrrPMDavisBesse Resource |
| RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRer1 Resource | | ------------- |
| | | E. Keegan B. Harris (OGC) |
| RidsNrrDlrRer2 Resource
| | C. Kanatas(OGC) |
| | E. Brown J. Uribe |
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| RidsNrrDlrRerb Resource
| | DAVIS-BESSE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION SUPPLEMENTAL REQUESTS FOR ADDITIONAL INFORMATION RAI 3.0.3-3a |
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| RidsNrrDlrRpob Resource RidsNrrDciCvib Resource RidsNrrDciCpnb Resource RidsNrrDciCsgb Resource RidsNrrDraAfpb Resource RidsNrrDraApla Resource
| | ==Background:== |
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| RidsNrrDeEmcb Resource RidsNrrDeEeeb Resource RidsNrrDssSrxb Resource
| | The response to request for additional information (RAI) 3.0.3-3 dated January 31, 2014, states that a representative sample of internally coated piping components consisting of at least 73 1-foot axial length circumferential segments of piping or 50 percent of the total length of each coating material and environment combination will be inspected. |
| | Issue: |
| | The staff has concluded that inspection locations should be selected based on susceptibility to degradation and consequences of failure in addition to potential problems identified during prior inspections, and known service life history. The RAI response did not address this aspect of selecting coating inspection locations. In addition, it does not state the length of piping that will be examined if geometric limitations impede access to the entire internal circumference of any piping segment. |
| | Request: |
| | : 1. State the criteria for selecting a representative sample of internally coated piping and piping components. |
| | : 2. State the length of piping that will be examined if geometric limitations impede access to the entire internal circumference of any piping segment. |
| | RAI 3.0.3-3b |
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| RidsNrrDssSbpb Resource RidsNrrDssScvb Resource
| | ==Background:== |
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| RidsOgcMailCenter Resource RidsNrrPMDavisBesse Resource
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| -------------
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| E. Keegan B. Harris (OGC)
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| C. Kanatas(OGC)
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| E. Brown J. Uribe ENCLOSURE DAVIS-BESSE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION SUPPLEMENTAL REQUESTS FOR ADDITIONAL INFORMATION
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| RAI 3.0.3-3a | | The response to RAI 3.0.3-3 states that adhesion testing should be conducted to ensure that the blister is completely surrounded by sound coating bonded to the surface. It also states that locations where access to the interior of components is permitted, adhesion testing should be conducted for coated areas that are determined to be suspect, deficient, or degraded as directed by the coatings program owner. |
| | Issue: |
| | By adding the premise should to the testing requirements criteria, the staff believes the threshold for performing adhesion testing is not clearly defined and may lead to ambiguity. |
| | Furthermore, LRA Section A.1.44 provides the UFSAR supplement for the Service Level III Coatings and Linings Monitoring Program. The staff noted that there are no requirements in the UFSAR supplement to conduct adhesion testing for coated surfaces determined to not meet the acceptance criteria. Draft LR-ISG-2013-01, Table 3.0-1 states, [f]or coated surfaces determined to not meet the acceptance criteria, physical testing is performed where physically possible (i.e., sufficient room to conduct testing). The test consists of destructive or nondestructive adhesion testing using ASTM International Standards endorsed in RG 1.54, Service Level I, II, and III Protective Coatings Applied to Nuclear Plants. |
| | ENCLOSURE |
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| ===Background===
| | Request: |
| : The response to request for additional information (RAI) 3.0.3-3 dated January 31, 2014, states that a representative sample of internally coated piping components consisting of at least 73 1-foot axial length circumferential segments of piping or 50 percent of the total length of each coating material and environment combination will be inspected. | | : 1. Confirm that adhesion testing shall be conducted in accordance with the guidance established in LR-ISG-2013-01. Otherwise, provide adequate justification if another methodology is to be used in lieu of the guidance developed by the staff. The response should clearly define why the alternate methodology meets or exceeds the guidance established in LR-ISG-2013-01. |
| Issue: The staff has concluded that inspection locations should be selected based on susceptibility to degradation and consequences of failure in addition to potential problems identified during prior inspections, and known service life history. The RAI response did not address this aspect of selecting coating inspection locations. In addition, it does not state the length of piping that will be examined if geometric limitations impede access to the entire internal circumference of any piping segment.
| | : 2. If the guidance in LR-ISG-2013-01 is to be used, revise the UFSAR Section A.1.44 to be consistent with the draft LR-ISG-2013-01. Otherwise, state the basis for not including the requirements for adhesion testing. |
| Request: 1. State the criteria for selecting a representative sample of internally coated piping and piping components. 2. State the length of piping that will be examined if geometric limitations impede access to the entire internal circumference of any piping segment.
| | RAI B.2.18-2 |
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| RAI 3.0.3-3b
| | ==Background:== |
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| ===Background===
| | The parameters monitored/inspected and detection of aging effects program elements of LR-ISG-2012-02 aging management program (AMP) XI.M27 recommend that internal visual inspections used to detect loss of material should be capable of detecting surface irregularities that could be indicative of wall loss below nominal pipe wall thickness due to corrosion and corrosion product deposition and that where such irregularities are detected, follow-up volumetric examinations are performed. |
| : The response to RAI 3.0.3-3 states that "adhesion testing should be conducted to ensure that the blister is completely surrounded by sound coating bonded to the surface." It also states that locations where access to the interior of components is permitted, "adhesion testing should be conducted for coated areas that are determined to be suspect, deficient, or degraded as directed by the coatings program owner."
| | The acceptance criteria program element of LR-ISG-2012-02 AMP XI.M27 states that, |
| Issue: By adding the premise "should" to the testing requirements criteria, the staff believes the threshold for performing adhesion testing is not clearly defined and may lead to ambiguity.
| | [a]dditionally, if the presence of sufficient foreign organic or inorganic material to obstruct pipe or sprinklers is detected during pipe inspections, the material is removed and its source is determined and corrected. |
| Furthermore, LRA Section A.1.44 provides the UFSAR supplement for the Service Level III Coatings and Linings Monitoring Program. The staff noted that there are no requirements in the UFSAR supplement to conduct adhesion testing for coated surfaces determined to not meet the acceptance criteria. Draft LR-ISG-2013-01, Table 3.0-1 states, "[f]or coated surfaces determined to not meet the acceptance criteria, physical testing is performed where physically possible (i.e., sufficient room to conduct testing). The test consists of destructive or nondestructive adhesion testing using ASTM International Standards endorsed in RG 1.54, "Service Level I, II, and III Protective Coatings Applied to Nuclear Plants."
| | Issue: |
| Request: 1. Confirm that adhesion testing "shall" be conducted in accordance with the guidance established in LR-ISG-2013-01. Otherwise, provide adequate justification if another methodology is to be used in lieu of the guidance developed by the staff. The response should clearly define why the alternate methodology meets or exceeds the guidance established in LR-ISG-2013-01. 2. If the guidance in LR-ISG-2013-01 is to be used, revise the UFSAR Section A.1.44 to be consistent with the draft LR-ISG-2013-01. Otherwise, state the basis for not including the requirements for adhesion testing. | | The staff noted that the changes to the Fire Water Program in Amendment No. 48, dated February 19, 2014, did not include these recommendations. |
| | Request: |
| | State the basis for not including these recommendations in the Fire Water Program, or revise the program to include these recommendations. |
| | RAI 3.0.3.4.3-01 |
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| RAI B.2.18-2
| | ==Background:== |
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| ===Background===
| | LRA Section 2.3.3.21 states that the miscellaneous liquid radwaste system satisfies the scoping criteria for 10 CFR 54.4(a)(2). License renewal drawing M-037C, Clean Liquid Radioactive Waste System, states that the clean waste receiver tanks are in-scope and have a nominal capacity of 103,000 gallons. |
| : The "parameters monitored/inspected" and "detection of aging effects" program elements of LR-ISG-2012-02 aging management program (AMP) XI.M27 recommend that internal visual inspections used to detect loss of material should be capable of detecting surface irregularities that could be indicative of wall loss below nominal pipe wall thickness due to corrosion and corrosion product deposition and that where such irregularities are detected, follow-up | | Issue: |
| | LR-ISG-2012-02, Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation, revised the scope of program program element of Generic Aging Lessons Learned (GALL) Report AMP XI.M29, Aboveground Metallic Tanks, to include certain indoor large-volume tanks (e.g., greater than 100,000 gallons) in the |
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| volumetric examinations are performed. The "acceptance criteria" program element of LR-ISG-2012-02 AMP XI.M27 states that, "[a]dditionally, if the presence of sufficient foreign organic or inorganic material to obstruct pipe or sprinklers is detected during pipe inspections, the material is removed and its source is determined and corrected."
| | scope of this program. During its review of the changes to the Aboveground Steel Tanks Program described by letter dated February 19, 2014, the staff noted that the clean waste receiver tanks may meet the revised guidance, but were not included in the scope of the program. |
| Issue: The staff noted that the changes to the Fire Water Program in Amendment No. 48, dated February 19, 2014, did not include these recommendations.
| | Request: |
| Request: State the basis for not including these recommendations in the Fire Water Program, or revise the program to include these recommendations.
| | State whether the clean waste receiver tanks should be in the scope of LR-ISG-2012-02 AMP XI.M29. If so: |
| RAI 3.0.3.4.3-01 | | : 1. Revise the program to include the clean waste receiver tanks, or |
| | : 2. State the basis for why it is not necessary to include these tanks in the scope of the Aboveground Steel Tanks Inspection Program. |
| | : 3. State whether there are other indoor tanks that should be within the scope of the Aboveground Steel Tanks Inspection Program. |
| | RAI 3.0.3.4.3-02 |
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| ===Background===
| | ==Background:== |
| : LRA Section 2.3.3.21 states that the miscellaneous liquid radwaste system satisfies the scoping criteria for 10 CFR 54.4(a)(2). License renewal drawing M-037C, "Clean Liquid Radioactive Waste System," states that the clean waste receiver tanks are in-scope and have a nominal capacity of 103,000 gallons.
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| Issue: LR-ISG-2012-02, "Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation," revised the "scope of program" program element of Generic Aging Lessons Learned (GALL) Report AMP XI.M29, "Aboveground Metallic Tanks," to include certain indoor large-volume tanks (e.g., greater than 100,000 gallons) in the scope of this program. During its review of the changes to the Aboveground Steel Tanks Program described by letter dated February 19, 2014, the staff noted that the clean waste receiver tanks may meet the revised guidance, but were not included in the scope of the program. Request: State whether the clean waste receiver tanks should be in the scope of LR-ISG-2012-02 AMP XI.M29. If so: 1. Revise the program to include the clean waste receiver tanks, or
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| : 2. State the basis for why it is not necessary to include these tanks in the scope of the Aboveground Steel Tanks Inspection Program. 3. State whether there are other indoor tanks that should be within the scope of the Aboveground Steel Tanks Inspection Program.
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| RAI 3.0.3.4.3-02
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| ===Background===
| | The External Surfaces Monitoring Program was revised by letter dated February 19, 2014, to include inspections related to Corrosion Under Insulation (CUI). The revised Aboveground Steel Tanks Inspection Program does not include inspections related to CUI. |
| : The External Surfaces Monitoring Program was revised by letter dated February 19, 2014, to include inspections related to Corrosion Under Insulation (CUI). The revised Aboveground Steel Tanks Inspection Program does not include inspections related to CUI. During the audit, the staff noted that the Borated Water Storage Tank (BWST) is insulated, and is located in an environment which could result in stress corrosion cracking of the stainless steel tank (e.g., located within 1/2 mile of a salt treated highway, or other sources of chlorides). The response to RAI B.2.2-2 dated May 24, 2011, states that: (a) the outdoor air environment could result in an Aging Effect Requiring Management (AERM) for the BWST; (b) the polyurethane foam insulation installed on the BWST is limited to leach less than 1000 ppm chlorides; and (c) the Aboveground Steel Tanks Inspection Program was revised to manage Stress Corrosion Cracking (SCC) for the BWST. The response to RAI B.2.2-2 describes the insulation as polyurethane foam on a base coat of epoxy-polyamide with an intermediate layer of butyl rubber and a top layer of aliphatic urethane.
| | During the audit, the staff noted that the Borated Water Storage Tank (BWST) is insulated, and is located in an environment which could result in stress corrosion cracking of the stainless steel tank (e.g., located within 1/2 mile of a salt treated highway, or other sources of chlorides). The response to RAI B.2.2-2 dated May 24, 2011, states that: (a) the outdoor air environment could result in an Aging Effect Requiring Management (AERM) for the BWST; (b) the polyurethane foam insulation installed on the BWST is limited to leach less than 1000 ppm chlorides; and (c) the Aboveground Steel Tanks Inspection Program was revised to manage Stress Corrosion Cracking (SCC) for the BWST. The response to RAI B.2.2-2 describes the insulation as polyurethane foam on a base coat of epoxy-polyamide with an intermediate layer of butyl rubber and a top layer of aliphatic urethane. |
| Issue: It is not clear to the staff whether the inspections related to CUI in the External Surfaces Monitoring Program include inspections of the BWST insulation. The number and periodicity of inspections in LR-IG-2012-02 AMP XI.M29 are generally in alignment with those for LR-IG-2012-02 AMP XI.M36, "External Surfaces Monitoring of Mechanical Components;" however, the recommended inspection locations are different. | | Issue: |
| | It is not clear to the staff whether the inspections related to CUI in the External Surfaces Monitoring Program include inspections of the BWST insulation. The number and periodicity of inspections in LR-IG-2012-02 AMP XI.M29 are generally in alignment with those for LR-IG-2012-02 AMP XI.M36, External Surfaces Monitoring of Mechanical Components; however, the recommended inspection locations are different. |
| | Based on a review of Licensee Event Report No. NP-82-01, dated October 11, 1984, the staff noted that the insulation for the BWST was added a number of years after the plant was placed in service. The staff also noted that RG 1.36, Nonmetallic Thermal Insulation for Austenitic Stainless Steel, Figure 1, recommends an upper limit of chlorides and fluorides dependent on the sodium and silicate content of the insulation. The specificity of the response to RAI B.2.2-2 in relation to chloride content of the insulation is inadequate to conclude that the leachable chlorides and fluorides would not result in SCC. Given that the exterior surfaces of the tank could have been exposed to elevated levels of chlorides prior to the application of the insulation and the potential amount of leachable chloride in the insulation, the staff seeks clarification on the specific inspections and periodicity of inspections, which will be used to manage loss of |
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| Based on a review of Licensee Event Report No. NP-82-01, dated October 11, 1984, the staff noted that the insulation for the BWST was added a number of years after the plant was placed in service. The staff also noted that RG 1.36, "Nonmetallic Thermal Insulation for Austenitic Stainless Steel," Figure 1, recommends an upper limit of chlorides and fluorides dependent on the sodium and silicate content of the insulation. The specificity of the response to RAI B.2.2-2 in relation to chloride content of the insulation is inadequate to conclude that the leachable chlorides and fluorides would not result in SCC. Given that the exterior surfaces of the tank could have been exposed to elevated levels of chlorides prior to the application of the insulation and the potential amount of leachable chloride in the insulation, the staff seeks clarification on the specific inspections and periodicity of inspections, which will be used to manage loss of material due to pitting and crevice corrosion, and cracking on the exterior surfaces of the BWST. In addition, the insulation appears to be that which would be described as tightly adhering insulation. LR-IG-2012-02 AMP XI.M29 does not require removal of tightly adhering insulation unless there is evidence of damage to the moisture barrier. This might not be appropriate depending on whether pre-installation inspections of the bare metal surfaces were conducted and the plant-specific operating experience related to the integrity of the insulation's moisture
| | material due to pitting and crevice corrosion, and cracking on the exterior surfaces of the BWST. |
| | In addition, the insulation appears to be that which would be described as tightly adhering insulation. LR-IG-2012-02 AMP XI.M29 does not require removal of tightly adhering insulation unless there is evidence of damage to the moisture barrier. This might not be appropriate depending on whether pre-installation inspections of the bare metal surfaces were conducted and the plant-specific operating experience related to the integrity of the insulations moisture barrier. |
| | Request: |
| | : 1. Confirm whether the insulation installed on the BWST is considered as tightly adhering insulation and impermeable to moisture. |
| | : 2. State whether inspections of the BWST insulation will be conducted under the External Surfaces Monitoring Program. If this is the case, state the extent and periodicity of inspections, the inspection methods, and how inspection locations will be selected. If no inspections will be conducted, state the basis for why there is reasonable assurance that the BWST will perform its current licensing basis intended functions. |
| | : 3. State whether visual and surface examinations sufficient to detect loss of material due to pitting and crevice corrosion and cracking were conducted on the external surfaces of the BWST prior to installing the insulation. If they were not conducted, state the basis for why bare metal inspections would not have to be conducted prior to the period of extended operation. |
| | : 4. Provide a summary of plant-specific operating experience related to the integrity of the BWST insulation. If there have been instances of damage to the insulation such that moisture could have penetrated to the surface of the BWST, state what inspections have been conducted on the bare metal surfaces of the tank. If none were conducted, state the basis for why bare metal inspections would not have to be conducted prior to the period of extended operation. |
| | RAI 2.3.3.26-2 |
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| barrier. Request: 1. Confirm whether the insulation installed on the BWST is considered as tightly adhering insulation and impermeable to moisture. 2. State whether inspections of the BWST insulation will be conducted under the External Surfaces Monitoring Program. If this is the case, state the extent and periodicity of inspections, the inspection methods, and how inspection locations will be selected. If no inspections will be conducted, state the basis for why there is reasonable assurance that the BWST will perform its current licensing basis intended functions. 3. State whether visual and surface examinations sufficient to detect loss of material due to pitting and crevice corrosion and cracking were conducted on the external surfaces of the BWST prior to installing the insulation. If they were not conducted, state the basis for why bare metal inspections would not have to be conducted prior to the period of extended operation.
| | ==Background:== |
| : 4. Provide a summary of plant-specific operating experience related to the integrity of the BWST insulation. If there have been instances of damage to the insulation such that moisture could have penetrated to the surface of the BWST, state what inspections have been conducted on the bare metal surfaces of the tank. If none were conducted, state the basis for why bare metal inspections would not have to be conducted prior to the
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| period of extended operation.
| | By notice in the Federal Register on November 22, 2013, the NRC announced the availability of LR-ISG-2012-02, Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation. By letter dated February 19, 2014, Davis-Besse Nuclear Power Station (Davis-Besse) stated that it had reviewed LR-ISG-2012-02 and identified changes needed for the LRA to align with the updated guidance in the LR-ISG. For loss of material due to recurring internal corrosion, Davis-Besse stated that it had identified recurring internal corrosion in the service water system at the site. The response states that nondestructive examination methods, including visual examinations and ultrasonic testing, are used to detect fouling and loss of material. It also states when visual inspections are used to identify loss of material, the inspection technique is capable of detecting surface irregularities that could indicate wall loss below nominal wall thickness, and where such irregularities are detected, follow-up volumetric wall thickness examinations are performed. The response also states that the Open-Cycle Cooling Water program utilizes the corrective action program to document degradations and to evaluate corrosion rates so piping and related components are cleaned and replaced prior to loss of function. |
| RAI 2.3.3.26-2
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| ===Background===
| | Issue: |
| : By notice in the Federal Register on November 22, 2013, the NRC announced the availability of LR-ISG-2012-02, "Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation." By letter dated February 19, 2014, Davis-Besse Nuclear Power Station (Davis-Besse) stated that it had reviewed LR-ISG-2012-02 and identified changes needed for the LRA to align with the updated guidance in the LR-ISG. For loss of material due to recurring internal corrosion, Davis-Besse stated that it had identified recurring internal corrosion in the service water system at the site. The response states that nondestructive examination methods, including visual examinations and ultrasonic testing, are used to detect fouling and loss of material. It also states when visual inspections are used to identify loss of material, the inspection technique is capable of detecting surface irregularities that could indicate wall loss below nominal wall thickness, and where such irregularities are detected, follow-up volumetric wall thickness examinations are performed. The response also states that the Open-Cycle Cooling Water program utilizes the corrective action program to document degradations and to evaluate corrosion rates so piping and related components are cleaned and replaced prior to loss of function. | | LR-ISG-2012-02 added Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR), Further Evaluation Section 3.3.2.2.8, Loss of Material due to Recurring Internal Corrosion, that discusses the need for considering augmented requirements to ensure the adequate management of any recurring aging effects. This Further Evaluation section includes the following five aspects: |
| Issue: LR-ISG-2012-02 added "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants" (SRP-LR), Further Evaluation Section 3.3.2.2.8, "Loss of Material due to Recurring Internal Corrosion," that discusses the need for considering augmented requirements to ensure the adequate management of any recurring aging effects. This Further Evaluation section includes the following five aspects: 1. State why the program's examination methods will be sufficient to detect the recurring aging effect before affecting the ability of a component to perform its intended function. 2. State the basis for the adequacy of the augmented inspections. 3. State what parameters will be trended as well as the decision points where increased inspections would be implemented. 4. State how inspections of components that are not easily accessed will be conducted.
| | : 1. State why the programs examination methods will be sufficient to detect the recurring aging effect before affecting the ability of a component to perform its intended function. |
| : 5. State how leaks in any involved buried or underground components will be identified. | | : 2. State the basis for the adequacy of the augmented inspections. |
| | : 3. State what parameters will be trended as well as the decision points where increased inspections would be implemented. |
| | : 4. State how inspections of components that are not easily accessed will be conducted. |
| | : 5. State how leaks in any involved buried or underground components will be identified. |
| : 6. Although the cited letter discussed some portions of the above aspects, it did not clearly address all of the criteria discussed in the Further Evaluation section. The staff noted that the LRA included a discussion regarding the identification of wall thickness measurements in segments of service water piping that were below procedural limits, but met design requirements. However, the cited letter did not discuss whether augmented inspections would be performed to manage the recurring internal corrosion. | | : 6. Although the cited letter discussed some portions of the above aspects, it did not clearly address all of the criteria discussed in the Further Evaluation section. The staff noted that the LRA included a discussion regarding the identification of wall thickness measurements in segments of service water piping that were below procedural limits, but met design requirements. However, the cited letter did not discuss whether augmented inspections would be performed to manage the recurring internal corrosion. |
| Request: Please provide additional information that woul d clarify how FirstEnergy Nuclear Operating Company intends to meet each of the five elements of the Further Evaluation section stated above for LR-ISG-2012-02.}} | | Request: |
| | Please provide additional information that would clarify how FirstEnergy Nuclear Operating Company intends to meet each of the five elements of the Further Evaluation section stated above for LR-ISG-2012-02.}} |
Letter Sequence RAI |
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TAC:ME4640, Steam Generator Tube Integrity (Approved, Closed) |
Results
- Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval
Other: L-11-114, Drawing No. M-042B, Rev. 35, Sampling System Sh. 2 Local Grab Samples, L-11-131, Drawing No. LR-OS041A2, Revision 1, Operational Schematic Emergency Diesel Generator Systems., L-11-334, Reply to Request Additional Information for the Review of the License Renewal Application Amendment No. 21, L-12-337, Review of the Safety Evaluation Report with Open Items Related to the License Renewal, L-12-444, Submittal of Contractor Equivalent Margins Assessments for Reactor Vessel Welds (Nonproprietary Versions), L-12-456, Notification of Closure of Commitments Related to the Review of the License Renewal Application, L-13-257, Notification of Completion of a License Renewal Commitment Related to the Review of License Renewal Application TAC No. ME4640) and License Renewal Application Amendment No. 45), L-13-330, License Renewal Application Amendment No. 46 - Annual Update, L-13-341, Review of the Safety Evaluation Report Related to the License Renewal of Davis-Besse Nuclear Power Station, L-14-085, License Renewal Application (TAC No. ME4640) Amendment No. 48, L-14-206, License Renewal Application Amendment No. 50 - Annual Update, L-15-120, Notification of Completion of License Renewal Commitments Related to the Review of the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application and License Renewal Application Amendment No. 55, L-15-139, License Renewal Reactor Vessel Internals Inspection Plan, L-15-214, License Renewal Application Amendment No. 59 - Annual Update, L-15-309, License Renewal Application Amendment No. 60, L-15-310, C-CSS-099.20-069, Rev 0, Shield Building Laminar Cracking Limits., ML102450565, ML111050091, ML11110A089, ML11110A091, ML11110A092, ML11110A093, ML11110A094, ML11110A095, ML11110A105, ML11110A106, ML11110A107, ML11122A014, ML11126A017, ML11126A018, ML11126A019, ML11126A020, ML11126A021, ML11126A022, ML11126A023, ML11126A024, ML11126A025, ML11126A026, ML11126A032, ML11126A033, ML11126A034, ML11126A035, ML11126A036, ML11126A037, ML11126A038, ML11126A039, ML11126A040, ML11126A041, ML11126A042, ML11126A043... further results
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MONTHYEARML11126A0882008-01-12012 January 2008 Drawing No. LR-M041B, Revision 1, Piping & Instrument Diagram Primary Service Water System. Job Code 12501 Project stage: Other ML11126A0902008-01-15015 January 2008 Drawing No. LR-OS41A1, Revision 1, Operational Schematic Emergency Diesel Generator Systems. Project stage: Other L-11-131, Drawing No. LR-OS041A2, Revision 1, Operational Schematic Emergency Diesel Generator Systems.2008-01-15015 January 2008 Drawing No. LR-OS041A2, Revision 1, Operational Schematic Emergency Diesel Generator Systems. Project stage: Other ML11126A0682008-05-0505 May 2008 Drawing No. LR-M-037E, Revision 28, Piping & Instrument Diagram Clean Liquid Radioactive Waste System. Project stage: Other ML11126A0652008-08-0606 August 2008 Drawing No. LR-M036B, Revision 1, Piping & Instrument Diagram Component Cooling Water System. Project stage: Other ML11126A0592008-10-0909 October 2008 Drawing No. LR-M033A, Revision 1, Piping & Instrument Diagram High Pressure Injection. Project stage: Other ML11126A0632008-10-10010 October 2008 Drawing No. LR-M033B, Revision 1, Piping & Instrument Diagram Decay Heat Train 1. Project stage: Other ML11126A0702008-10-10010 October 2008 Drawing No. LR-M033C, Revision 1, Piping & Instrument Diagram Decay Heat Train 2. Project stage: Other ML11126A0742008-11-0606 November 2008 Drawing No. LR-M043, Revision 1, Piping & Instrument Diagram Auxiliary Building Chilled Water System. Project stage: Other ML11126A0832008-12-18018 December 2008 Drawing No. LR-M038C, Revision 2, Piping & Instrument Diagram Gaseous Radioactive Waste System. Job Code 12501 Project stage: Other ML11126A0712009-04-0707 April 2009 Drawing No. LR-M034, Revision 1, Piping & Instrument Diagram Emerg. Core Cooling System Ctmt. Spray & Core Flooding Systems. Project stage: Other ML11126A0892009-04-0707 April 2009 Drawing No. LR-OS002, Revision 1, Operational Schematic Makeup and Purification System. Project stage: Other ML1024505652010-08-27027 August 2010 License Renewal Application and Ohio Coastal Management Program Consistency Certification Project stage: Other ML1104500462011-02-17017 February 2011 Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station - Fire Protection Project stage: RAI ML11126A0792011-02-25025 February 2011 Drawing No. LR-M900A, Revision 0, Instrument Air System Piping Schematic. Project stage: Other ML1104205972011-02-28028 February 2011 Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station - Section 2.4 Project stage: RAI ML1106801722011-03-17017 March 2011 Request for Additional Information on the Reactor Vessel Surveillance Aging Management Program, Time-Limited Aging Analyses for Neutron Embrittlement of the Rv and Internals, and Other TLAAs for the Review of the Davis-Besse Nuclear Power S Project stage: RAI ML1107007322011-03-18018 March 2011 Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station-Section 2.2 & 2.3 Project stage: RAI L-11-078, Reply to Request for Additional Information for the Review of License Renewal Application (TAC ME4640) Amendment No. 12011-03-18018 March 2011 Reply to Request for Additional Information for the Review of License Renewal Application (TAC ME4640) Amendment No. 1 Project stage: Response to RAI ML11068A0002011-03-21021 March 2011 Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station - Section 4.7 (TAC Number ME4640) Project stage: RAI L-11-079, Reply to Request for Additional Information for the Review of the License Renewal Application2011-03-23023 March 2011 Reply to Request for Additional Information for the Review of the License Renewal Application Project stage: Response to RAI L-11-089, Reply to Request for Additional Information for the Review License Renewal Application2011-03-23023 March 2011 Reply to Request for Additional Information for the Review License Renewal Application Project stage: Response to RAI ML1108206242011-03-30030 March 2011 Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station-Section 2.1 (Tac No. ME4640) Project stage: RAI ML1109002952011-03-31031 March 2011 Safety Evaluation Report Related to the License Renewal of Salem Nuclear Generating Station Project stage: Approval ML1108204902011-04-0505 April 2011 Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station - Batch 1 Project stage: RAI ML11110A0932011-04-15015 April 2011 Drawing No. M-037D, Rev. 21, Clean Liquid Radioactive Waste System Project stage: Other ML11110A1072011-04-15015 April 2011 Drawing No. M-045, Rev. 56, Chemical Addition Systems Project stage: Other ML11110A1062011-04-15015 April 2011 Drawing No. M-042C, Rev. 33, Sampling System Sh. 3 Project stage: Other ML11110A1052011-04-15015 April 2011 Drawing No. M-040A, Rev. 76, Reactor Coolant System Details Project stage: Other ML11110A0952011-04-15015 April 2011 Drawing No. M-039B, Rev. 18, Miscellaneous Liquid Radioactive Waste Project stage: Other ML11110A0942011-04-15015 April 2011 Drawing No. M-039A, Rev. 33, Miscellaneous Liquid Radioactive Waste Project stage: Other ML11110A0922011-04-15015 April 2011 Drawing No. M-037C, Rev. 30, Clean Liquid Radioactive Waste System Project stage: Other L-11-114, Drawing No. M-042B, Rev. 35, Sampling System Sh. 2 Local Grab Samples2011-04-15015 April 2011 Drawing No. M-042B, Rev. 35, Sampling System Sh. 2 Local Grab Samples Project stage: Other L-11-107, Reply to Request for Additional Information on Reactor Vessel Surveillance Aging Management Program & Time-Limited Aging Analyses for Neutron Embrittlement for Review of License Renewal Application & License Renewal Application...2011-04-15015 April 2011 Reply to Request for Additional Information on Reactor Vessel Surveillance Aging Management Program & Time-Limited Aging Analyses for Neutron Embrittlement for Review of License Renewal Application & License Renewal Application... Project stage: Response to RAI ML11110A0882011-04-15015 April 2011 Reply to Request for Additional Information for the Review of the License Renewal Application, Sections 2.2 & 2.3, License Renewal Application Amendment No. 3, and Revised License Renewal Project stage: Response to RAI ML11110A0912011-04-15015 April 2011 Drawing No. M-011, Rev. 61, Domestic Water System Project stage: Other ML11110A0892011-04-15015 April 2011 Drawing No. M-0060, Rev. 52, Auxiliary Feedwater System Project stage: Other ML1110500912011-04-19019 April 2011 Scoping and Screening Audit Report Regarding the Davis-Besse Nuclear Power Station License Renewal Application Project stage: Other L-11-115, Reply to Request for Additional Information for the Review of the License Renewal Application and License Renewal Application Amendment No. 42011-04-20020 April 2011 Reply to Request for Additional Information for the Review of the License Renewal Application and License Renewal Application Amendment No. 4 Project stage: Response to RAI ML1109807182011-04-20020 April 2011 Request for Additional Information for the Review of the Davis-Bessie Nuclear Power Station - Batch 2 Project stage: RAI ML11126A0362011-04-29029 April 2011 Drawing No. LR-M017D, Revision 1 Piping & Instrument Diagram, Steam Blackout Diesel Generator. Project stage: Other ML11126A0352011-04-29029 April 2011 Drawing No. LR-M017C, Revision 2, Piping & Instrument Diagram, Fuel Oil. Project stage: Other ML11126A0342011-04-29029 April 2011 Drawing No. LR-M017B, Revision 1, Piping & Instrument Diagram, Diesel Generators Air Start. Project stage: Other ML11126A0332011-04-29029 April 2011 Drawing No. LR-M016B, Revision 1, Piping & Instrument Diagram Station Fire Protection System Project stage: Other ML11126A0322011-04-29029 April 2011 Drawing No. LR-M016A, Revision 1, Piping & Instrument Diagram Station Fire Protection System Project stage: Other ML11126A0262011-04-29029 April 2011 Drawing No. LR-M010C, Revision 1, Piping & Instrument Diagram Make-up Water Treatment System Project stage: Other ML11126A0252011-04-29029 April 2011 Drawing No. LR-M010A, Revision 1, Piping & Instrument Diagram Make-Up Water Treatment System Project stage: Other ML11126A0242011-04-29029 April 2011 Drawing No. LR-M009B, Revision 1, Piping & Instrument Diagram Cooling Water System Project stage: Other ML11126A0192011-04-29029 April 2011 Drawing No. LR-M003A, Revision 1, Piping & Instrument Diagram Main Steam and Reheat System. Sheet 1 Project stage: Other ML11126A0452011-04-29029 April 2011 Drawing No. LR-M024H, Revision 1, Piping & Instrument Diagram, No. 2 Main and Auxiliary Turbine Driven Feed Pumps. Project stage: Other 2011-02-25
[Table View] |
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Category:Letter
MONTHYEARIR 05000346/20243012024-02-0202 February 2024 NRC Initial License Examination Report 05000346/2024301 IR 05000346/20230042024-01-31031 January 2024 Integrated Inspection Report 05000346/2023004 ML23313A1352024-01-17017 January 2024 Authorization and Safety Evaluation for Alternative Request RP 5 for the Fifth 10 Year Interval Inservice Testing Program ML23353A1192023-12-19019 December 2023 Operator Licensing Examination Approval Davis Besse Nuclear Power Station, January 2024 L-23-260, Corrections to the 2022 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station2023-12-0707 December 2023 Corrections to the 2022 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station L-23-243, Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-0606 December 2023 Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23338A3172023-12-0606 December 2023 Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000346/2024001 IR 05000346/20234032023-11-0202 November 2023 Security Baseline Inspection Report 05000346/2023403 ML23293A0612023-11-0101 November 2023 Letter to the Honorable Marcy Kaptur, from Chair Hanson Responds to Letter Regarding Follow Up on Concerns Raised by Union Representatives During the June Visit to the Davis-Besse Nuclear Power Plant L-23-215, Changes to Emergency Plan2023-10-19019 October 2023 Changes to Emergency Plan ML23237B4222023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Letter Regarding Order Approving Transfer of Licenses and Draft Conforming License Amendments ML23269A1242023-09-27027 September 2023 Request for Withholding Information from Public Disclosure IR 05000346/20234012023-09-13013 September 2023 Security Baseline Inspection Report 05000346/2023401 (Public) L-23-205, Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-09-12012 September 2023 Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments L-23-172, Quality Assurance Program Manual2023-08-31031 August 2023 Quality Assurance Program Manual IR 05000346/20230112023-08-30030 August 2023 Biennial Problem Identification and Resolution Inspection Report 05000346/2023011 ML23129A1722023-08-25025 August 2023 Request for Withholding Information from Public Disclosure for Beaver Valley Power Station, Units 1 and 2; Davis Besse Nuclear Power Station, Unit 1; and Perry Nuclear Power Plant, Unit 1 IR 05000346/20230052023-08-24024 August 2023 Updated Inspection Plan for Davis-Besse Nuclear Power Station (Report 05000346/2023005) L-23-188, Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-08-0707 August 2023 Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments IR 05000346/20230502023-08-0303 August 2023 Special Inspection Report 05000346/2023050 IR 05000346/20230902023-08-0101 August 2023 EA-23-002 Davis-Besse Nuclear Power Station - NRC Inspection Report No. 05000346/2023090 (Public) ML23178A2742023-08-0101 August 2023 Letter to the Honorable Marcy Kaptur from Chair Hanson Responds to Letter Regarding the License Transfer Application for the Davis-Besse Nuclear Power Station L-23-175, Submittal of Fifth Ten Year Inservice Testing Program2023-08-0101 August 2023 Submittal of Fifth Ten Year Inservice Testing Program IR 05000346/20230022023-07-27027 July 2023 Integrated Inspection Report 05000346/2023002 ML23193A7842023-07-13013 July 2023 Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000346/2023402 ML23178A2422023-06-28028 June 2023 Reassignment of the U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch III ML23160A2342023-06-13013 June 2023 Confirmation of Initial License Examination L-23-034, 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2023-06-13013 June 2023 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models IR 05000346/20235012023-06-13013 June 2023 Emergency Preparedness Biennial Exercise Inspection Report 05000346/2023501 L-23-135, Response to Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-05-31031 May 2023 Response to Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations L-23-065, Annual Financial Report2023-05-22022 May 2023 Annual Financial Report ML23124A1742023-05-17017 May 2023 Energy Harbor Fleet Vistra License Transfer - Request for Withholding Information from Public Disclosure for Commance Peak Plant, Units 1 & 2, Beaver Valley Station, Units 1 & 2, Davis Besse Station, Unit 1 and Perry Plant, Unit 1 ML23129A0112023-05-16016 May 2023 Notice of Consideration of Approval of Indirect and Direct License Transfer for Comanche Peak Plant, Units 1 & 2, Beaver Valley Station, Units 1 & 2, Davis Besse Station, Unit 1 and Perry Plant, Unit 1 (EPID L-2023-LLM-0000) (Letter) ML23131A2732023-05-15015 May 2023 Notification of NRC Supplemental Inspection 95001 and Request for Information L-23-101, Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station - 20222023-05-12012 May 2023 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station - 2022 L-23-131, Readiness for Resumption of NRC Supplemental Inspection2023-05-12012 May 2023 Readiness for Resumption of NRC Supplemental Inspection IR 05000346/20230102023-05-0909 May 2023 Commercial Grade Dedication Inspection Report 05000346/2023010 ML23123A1272023-05-0303 May 2023 Information Request to Support Upcoming Problem Identification and Resolution Inspection at Davis-Besse Nuclear Power Station IR 05000346/20230012023-05-0101 May 2023 Integrated Inspection Report 05000346/2023001 and 07200014/2022001 L-23-092, Occupational Radiation Exposure Report for Year 20222023-04-27027 April 2023 Occupational Radiation Exposure Report for Year 2022 ML23111A1972023-04-26026 April 2023 Information Meeting with Question and Answer Session to Discuss NRC 2022 End-of-Cycle Plant Performance Assessment of Davis-Besse Nuclear Power Plant Station ML23114A1062023-04-25025 April 2023 Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection CP-202300181, ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, ISFSI, Corrected Affidavit for Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-04-20020 April 2023 ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, ISFSI, Corrected Affidavit for Application for Order Consenting to Transfer of Licenses and Conforming License Amendments CP-202300157, ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, and ISFSI, Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-04-14014 April 2023 ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, and ISFSI, Application for Order Consenting to Transfer of Licenses and Conforming License Amendments ML23096A1382023-04-11011 April 2023 Review of the Spring 2022 Steam Generator Tube Inspection Report L-23-061, Submittal of the Decommissioning Funding Status Reports2023-03-31031 March 2023 Submittal of the Decommissioning Funding Status Reports L-23-037, and Perry Nuclear Power Plant - Independent Spent Fuel Storage Installation Changes, Tests, and Experiments2023-03-29029 March 2023 and Perry Nuclear Power Plant - Independent Spent Fuel Storage Installation Changes, Tests, and Experiments L-23-066, Annual Notification of Property Insurance Coverage2023-03-21021 March 2023 Annual Notification of Property Insurance Coverage ML23066A2892023-03-14014 March 2023 Request for Threshold Determination Under 10 CFR 50.80 and 10 CFR 72.50 for an Amendment to the Voting Agreement ML23066A2592023-03-14014 March 2023 Request for Withholding Information from Public Disclosure for Beaver Valley Power Station, Units 1 and 2, Davis Besse Nuclear Power Station, Unit 1, and Perry Nuclear Power Plant, Unit 1 2024-02-02
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML23338A3172023-12-0606 December 2023 Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000346/2024001 ML23193A7842023-07-13013 July 2023 Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000346/2023402 ML23131A2732023-05-15015 May 2023 Notification of NRC Supplemental Inspection 95001 and Request for Information ML23033A0322023-02-0101 February 2023 NRR E-mail Capture - Request for Additional Information for Davis-Besse's 2022 Steam Generator Inspection Report (L-2022-LRO-0115) ML22357A0302022-12-23023 December 2022 Request for Information for NRC Commercial Grade Dedication Inspection: Inspection Report 05000346/2023010 ML22266A1102022-09-23023 September 2022 NRR E-mail Capture - Davis-Besse Nuclear Power Station, Unit No. 1 - Request for Additional Information Regarding July 21, 2022, Request for Withholding Information from Public Disclosure ML22214A7042022-08-0202 August 2022 Reissue - Davis-Besse Nuclear Power Station, Unit 1 Notification of Nrc Fire Protection Team Inspection Request for Information: Inspection Report 05000346/2022011 ML22187A0992022-07-0606 July 2022 Notification of NRC Supplemental Inspection (95001) and Request for Information ML22164A8572022-06-13013 June 2022 NRR E-mail Capture - Davis-Besse Nuclear Power Station, Unit No. 1 - Request for Additional Information Regarding License Amendment Request to Revise the Emergency Plan ML22118A6862022-04-28028 April 2022 NRR E-mail Capture - Davis-Besse Nuclear Power Station, Unit No. 1 - Request for Additional Information Regarding Alternative to Extend the Steam Generator Weld Inspection Interval ML22112A1092022-04-22022 April 2022 NRR E-mail Capture - Davis-Besse Nuclear Power Station, Unit No. 1 - Request for Additional Information Regarding License Amendment Request to Revise the Design Basis for the Shield Building ML22055A0872022-02-23023 February 2022 NRR E-mail Capture - Davis-Besse Nuclear Power Station, Unit No. 1 - Request for Additional Information Regarding Relief Request RP-3 IR 05000346/20210912021-12-17017 December 2021 NRC Inspection Report (05000346/2021091) Preliminary Greater than Green Finding ML21321A3792021-11-16016 November 2021 NRR E-mail Capture - Davis-Besse Nuclear Power Station, Unit No. 1 - Request for Additional Information Regarding Alternative to Extend the Steam Generator Weld Inspection Interval ML21301A0992021-10-28028 October 2021 Draft Request for Additional Information: Proposed Alternate for Examination of Steam Generator Welds - Energy Harbor Nuclear Corp., Davis-Besse Nuclear Power Station, Unit No. 1 ML21203A3252021-07-28028 July 2021 Request for Information for an NRC Triennial Baseline Design Bases Assurance Inspection (Team): Inspection Report 05000346/2021011 ML21155A1952021-06-0404 June 2021 Information Request to Support Upcoming Problem Identification and Resolution (Pi&R) Inspection at Davis Besse Nuclear Power Station ML21041A5452021-02-10010 February 2021 NRR E-mail Capture - Davis-Besse Nuclear Power Station, Unit No. 1 - Request for Additional Information Regarding Steam Generator Tube Inspection Reports ML21007A3732021-01-0707 January 2021 NRR E-mail Capture - (External_Sender) (External) Request for Additional Information Regarding License Amendment Request to Incorporate the Applicable Standard Technical Specification 5.2.2, Unit Staff, ML21004A1442020-12-30030 December 2020 NRR E-mail Capture - Request for Additional Information Regarding License Amendment Request to Incorporate the Applicable Standard Technical Specification 5.2.2, Unit Staff ML20300A5592020-10-27027 October 2020 Notification of an NRC Biennial Licensed Operator Requalification Program Inspection and Request for Information ML20154K7642020-06-0202 June 2020 NRR E-mail Capture - Davis-Besse Nuclear Power Station, Unit No. 1 - Request for Additional Information Regarding License Amendment Request to Adopt TSTF-425 ML20133J9792020-05-14014 May 2020 Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection ML20127H8672020-05-0606 May 2020 NRR E-mail Capture - Beaver Valley, Davis-Besse, and Perry - Request for Additional Information Regarding Request for Exemptions from Part 73 Security Requalification Requirements ML20021A3162020-01-21021 January 2020 NRR E-mail Capture - Davis-Besse Nuclear Power Station - Request for Additional Information Regarding License Amendment Request to Revise Containment Leakage Rate Testing ML19192A2222019-07-18018 July 2019 Request for Additional Information Regarding Application for Order Consenting to Transfer of Licenses and Conforming License Amendments ML19179A1382019-06-28028 June 2019 NRR E-mail Capture - Davis-Besse - Request for Additional Information Regarding the Decommissioning Quality Assurance Program ML19164A1532019-06-13013 June 2019 NRR E-mail Capture - Davis-Besse Nuclear Power Station - Request for Additional Information Regarding License Amendment Request for Post-Shutdown Emergency Plan ML19162A3922019-06-11011 June 2019 NRR E-mail Capture - Davis-Besse Nuclear Power Station - Request for Additional Information Regarding License Amendment Request for Permanently Defueled Technical Specifications ML19143A0732019-05-29029 May 2019 FENOC Fleet - Beaver Valley, Units 1 and 2; Davis-Besse, Unit 1, Perry, Unit 1 - Supplemental Information Needed for Acceptance of Requested Licensing Action; Application for Order Consenting to License Transfer and Conforming Amendments ML18305B0192018-11-0101 November 2018 18 Davis-Besse Nuclear Power Station - Notification of an NRC Biennial Licensed Operator Requalification Program Inspection and Request for Information(Rdb) ML18201A4122018-07-19019 July 2018 NRR E-mail Capture - Davis-Besse - Request for Additional Information Regarding License Amendment Request to Adopt NFPA 805 ML18190A4902018-07-0909 July 2018 Request for Information for an NRC Triennial Baseline Design Bases Assurance Inspection (Team), Inspection Report 05000346/2018011 (DRP-DXB) ML18102B0852018-04-12012 April 2018 NRR E-mail Capture - Follow-up Request for Additional Information (RAI) FENOC FLEET-- Exemption Request for a Physical Barrier Requirement for Beaver ML18043A0102018-02-0909 February 2018 NRR E-mail Capture - FENOC--MG0010-MG0011, MG-0012, MG0013-- Request for Additional Information (RAI) - Exemption Request Security Barrier in Physical Plans ML17355A3722017-12-21021 December 2017 NRR E-mail Capture - Davis-Besse Nuclear Power Station, Unit No. 1 - Request for Additional Information Regarding License Amendment Request to Adopt NFPA 805 ML17303B1582017-11-0707 November 2017 FENOC-Beaver Valley Power Station, Units 1 and 2, Davis-Besse Nuclear Power Station, Unit 1, Perry Nuclear Power Plant Unit 1 - Generic Letter 2016-01, Request for Supplemental Information ML17257A1402017-09-14014 September 2017 NRR E-mail Capture - Davis-Besse Nuclear Power Station, Unit No. 1 - Request for Additional Information Regarding License Amendment Request to Adopt NFPA 805 ML17135A3612017-05-12012 May 2017 Information Request for NRC Triennial Evaluations of Changes, Tests, and Experiments (50.59) Baseline Inspection 05000346/2017010 (Jvb) ML17129A4112017-05-0909 May 2017 Request for Additional Information Regarding Evaluation Submitted in Response to License Renewal Commitment No. 54 ML17100A1732017-04-19019 April 2017 Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Associated Standard 805 ML16364A2792017-01-23023 January 2017 Request for Additional Information Regarding License Renewal Commitment No. 42 ML16355A0352016-12-19019 December 2016 Ltr 12/19/16 Davis-Besse Nuclear Power Station, Unit 1 - Information Request for an NRC Post-Approval Site Inspection for License Renewal 05000346/2017009 (Bxj) ML16256A0662016-10-18018 October 2016 Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Associated Standard 805 ML16196A0152016-07-22022 July 2016 Request for Additional Information Regarding Amendment Request to Revise Emergency Action Level Scheme L-16-122, Completion of Required Action by NRC Order EA-12-051, Reliable Spent Fuel Pool Instrumentation2016-06-24024 June 2016 Completion of Required Action by NRC Order EA-12-051, Reliable Spent Fuel Pool Instrumentation ML16060A0122016-02-29029 February 2016 FENOC - Email RAI to Licensee Regarding LAR for Changes to TS 5.3.1 CAC Nos. MF7118, MF7119, and MF7120 ML16047A1452016-02-22022 February 2016 Supplemental Information Needed for Acceptance of License Amendment Request to Adopt National Fire Protection Associated Standard 805 ML16019A3972016-01-20020 January 2016 Request for Additional Information Related to Amendment Request for Emergency Diesel Generator Minimum Voltage Surveillance Requirements ML15222A1792015-09-21021 September 2015 Request for Additional Information Related to Amendment Request for Emergency Diesel Generator Minimum Voltage Surveillance Requirements (TAC No. MF6060)(L-15-117) 2023-07-13
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Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 7, 2014 Mr. Raymond A. Lieb Vice President Davis-Besse Nuclear Power Station FirstEnergy Nuclear Operating Company 5501 North State Route 2 Oak Harbor, OH 43449
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE DAVIS-BESSE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. ME4640)
Dear Mr. Lieb:
By letter dated August 27, 2010, FirstEnergy Nuclear Operating Company submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 for renewal of Operating License NPF-3 for the Davis-Besse Nuclear Power Station. The staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing this application in accordance with the guidance in NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants. During its review, the staff has identified areas where additional information is needed to complete the review. The staffs requests for additional information are included in the enclosure. Further requests for additional information may be issued in the future.
Items in the enclosure were discussed with Cliff Custer, of your staff, and a mutually agreeable date for the response is July 30, 2014. If you have any questions, please contact me by telephone at 301-415-4084 or by e-mail at Emmanuel.Sayoc@nrc.gov Sincerely,
/RA/
Emmanuel Sayoc, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-346
Enclosure:
As stated cc w/encl: Listserv
ML14178A962 *concurred via email OFFICE LA:DLR/RPB2* PM:DLR/RPB1 BC:DLR/RPB1 PM:DLR/RPB1 NAME IKing ESayoc YDiaz-Sanabria ESayoc DATE 7/1/14 7/7/14 7/7/14 7/7/14
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE DAVIS-BESSE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. ME4640)
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E. Keegan B. Harris (OGC)
C. Kanatas(OGC)
E. Brown J. Uribe
DAVIS-BESSE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION SUPPLEMENTAL REQUESTS FOR ADDITIONAL INFORMATION RAI 3.0.3-3a
Background:
The response to request for additional information (RAI) 3.0.3-3 dated January 31, 2014, states that a representative sample of internally coated piping components consisting of at least 73 1-foot axial length circumferential segments of piping or 50 percent of the total length of each coating material and environment combination will be inspected.
Issue:
The staff has concluded that inspection locations should be selected based on susceptibility to degradation and consequences of failure in addition to potential problems identified during prior inspections, and known service life history. The RAI response did not address this aspect of selecting coating inspection locations. In addition, it does not state the length of piping that will be examined if geometric limitations impede access to the entire internal circumference of any piping segment.
Request:
- 1. State the criteria for selecting a representative sample of internally coated piping and piping components.
- 2. State the length of piping that will be examined if geometric limitations impede access to the entire internal circumference of any piping segment.
RAI 3.0.3-3b
Background:
The response to RAI 3.0.3-3 states that adhesion testing should be conducted to ensure that the blister is completely surrounded by sound coating bonded to the surface. It also states that locations where access to the interior of components is permitted, adhesion testing should be conducted for coated areas that are determined to be suspect, deficient, or degraded as directed by the coatings program owner.
Issue:
By adding the premise should to the testing requirements criteria, the staff believes the threshold for performing adhesion testing is not clearly defined and may lead to ambiguity.
Furthermore, LRA Section A.1.44 provides the UFSAR supplement for the Service Level III Coatings and Linings Monitoring Program. The staff noted that there are no requirements in the UFSAR supplement to conduct adhesion testing for coated surfaces determined to not meet the acceptance criteria. Draft LR-ISG-2013-01, Table 3.0-1 states, [f]or coated surfaces determined to not meet the acceptance criteria, physical testing is performed where physically possible (i.e., sufficient room to conduct testing). The test consists of destructive or nondestructive adhesion testing using ASTM International Standards endorsed in RG 1.54, Service Level I, II, and III Protective Coatings Applied to Nuclear Plants.
ENCLOSURE
Request:
- 1. Confirm that adhesion testing shall be conducted in accordance with the guidance established in LR-ISG-2013-01. Otherwise, provide adequate justification if another methodology is to be used in lieu of the guidance developed by the staff. The response should clearly define why the alternate methodology meets or exceeds the guidance established in LR-ISG-2013-01.
- 2. If the guidance in LR-ISG-2013-01 is to be used, revise the UFSAR Section A.1.44 to be consistent with the draft LR-ISG-2013-01. Otherwise, state the basis for not including the requirements for adhesion testing.
RAI B.2.18-2
Background:
The parameters monitored/inspected and detection of aging effects program elements of LR-ISG-2012-02 aging management program (AMP) XI.M27 recommend that internal visual inspections used to detect loss of material should be capable of detecting surface irregularities that could be indicative of wall loss below nominal pipe wall thickness due to corrosion and corrosion product deposition and that where such irregularities are detected, follow-up volumetric examinations are performed.
The acceptance criteria program element of LR-ISG-2012-02 AMP XI.M27 states that,
[a]dditionally, if the presence of sufficient foreign organic or inorganic material to obstruct pipe or sprinklers is detected during pipe inspections, the material is removed and its source is determined and corrected.
Issue:
The staff noted that the changes to the Fire Water Program in Amendment No. 48, dated February 19, 2014, did not include these recommendations.
Request:
State the basis for not including these recommendations in the Fire Water Program, or revise the program to include these recommendations.
RAI 3.0.3.4.3-01
Background:
LRA Section 2.3.3.21 states that the miscellaneous liquid radwaste system satisfies the scoping criteria for 10 CFR 54.4(a)(2). License renewal drawing M-037C, Clean Liquid Radioactive Waste System, states that the clean waste receiver tanks are in-scope and have a nominal capacity of 103,000 gallons.
Issue:
LR-ISG-2012-02, Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation, revised the scope of program program element of Generic Aging Lessons Learned (GALL) Report AMP XI.M29, Aboveground Metallic Tanks, to include certain indoor large-volume tanks (e.g., greater than 100,000 gallons) in the
scope of this program. During its review of the changes to the Aboveground Steel Tanks Program described by letter dated February 19, 2014, the staff noted that the clean waste receiver tanks may meet the revised guidance, but were not included in the scope of the program.
Request:
State whether the clean waste receiver tanks should be in the scope of LR-ISG-2012-02 AMP XI.M29. If so:
- 1. Revise the program to include the clean waste receiver tanks, or
- 2. State the basis for why it is not necessary to include these tanks in the scope of the Aboveground Steel Tanks Inspection Program.
- 3. State whether there are other indoor tanks that should be within the scope of the Aboveground Steel Tanks Inspection Program.
RAI 3.0.3.4.3-02
Background:
The External Surfaces Monitoring Program was revised by letter dated February 19, 2014, to include inspections related to Corrosion Under Insulation (CUI). The revised Aboveground Steel Tanks Inspection Program does not include inspections related to CUI.
During the audit, the staff noted that the Borated Water Storage Tank (BWST) is insulated, and is located in an environment which could result in stress corrosion cracking of the stainless steel tank (e.g., located within 1/2 mile of a salt treated highway, or other sources of chlorides). The response to RAI B.2.2-2 dated May 24, 2011, states that: (a) the outdoor air environment could result in an Aging Effect Requiring Management (AERM) for the BWST; (b) the polyurethane foam insulation installed on the BWST is limited to leach less than 1000 ppm chlorides; and (c) the Aboveground Steel Tanks Inspection Program was revised to manage Stress Corrosion Cracking (SCC) for the BWST. The response to RAI B.2.2-2 describes the insulation as polyurethane foam on a base coat of epoxy-polyamide with an intermediate layer of butyl rubber and a top layer of aliphatic urethane.
Issue:
It is not clear to the staff whether the inspections related to CUI in the External Surfaces Monitoring Program include inspections of the BWST insulation. The number and periodicity of inspections in LR-IG-2012-02 AMP XI.M29 are generally in alignment with those for LR-IG-2012-02 AMP XI.M36, External Surfaces Monitoring of Mechanical Components; however, the recommended inspection locations are different.
Based on a review of Licensee Event Report No. NP-82-01, dated October 11, 1984, the staff noted that the insulation for the BWST was added a number of years after the plant was placed in service. The staff also noted that RG 1.36, Nonmetallic Thermal Insulation for Austenitic Stainless Steel, Figure 1, recommends an upper limit of chlorides and fluorides dependent on the sodium and silicate content of the insulation. The specificity of the response to RAI B.2.2-2 in relation to chloride content of the insulation is inadequate to conclude that the leachable chlorides and fluorides would not result in SCC. Given that the exterior surfaces of the tank could have been exposed to elevated levels of chlorides prior to the application of the insulation and the potential amount of leachable chloride in the insulation, the staff seeks clarification on the specific inspections and periodicity of inspections, which will be used to manage loss of
material due to pitting and crevice corrosion, and cracking on the exterior surfaces of the BWST.
In addition, the insulation appears to be that which would be described as tightly adhering insulation. LR-IG-2012-02 AMP XI.M29 does not require removal of tightly adhering insulation unless there is evidence of damage to the moisture barrier. This might not be appropriate depending on whether pre-installation inspections of the bare metal surfaces were conducted and the plant-specific operating experience related to the integrity of the insulations moisture barrier.
Request:
- 1. Confirm whether the insulation installed on the BWST is considered as tightly adhering insulation and impermeable to moisture.
- 2. State whether inspections of the BWST insulation will be conducted under the External Surfaces Monitoring Program. If this is the case, state the extent and periodicity of inspections, the inspection methods, and how inspection locations will be selected. If no inspections will be conducted, state the basis for why there is reasonable assurance that the BWST will perform its current licensing basis intended functions.
- 3. State whether visual and surface examinations sufficient to detect loss of material due to pitting and crevice corrosion and cracking were conducted on the external surfaces of the BWST prior to installing the insulation. If they were not conducted, state the basis for why bare metal inspections would not have to be conducted prior to the period of extended operation.
- 4. Provide a summary of plant-specific operating experience related to the integrity of the BWST insulation. If there have been instances of damage to the insulation such that moisture could have penetrated to the surface of the BWST, state what inspections have been conducted on the bare metal surfaces of the tank. If none were conducted, state the basis for why bare metal inspections would not have to be conducted prior to the period of extended operation.
RAI 2.3.3.26-2
Background:
By notice in the Federal Register on November 22, 2013, the NRC announced the availability of LR-ISG-2012-02, Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation. By letter dated February 19, 2014, Davis-Besse Nuclear Power Station (Davis-Besse) stated that it had reviewed LR-ISG-2012-02 and identified changes needed for the LRA to align with the updated guidance in the LR-ISG. For loss of material due to recurring internal corrosion, Davis-Besse stated that it had identified recurring internal corrosion in the service water system at the site. The response states that nondestructive examination methods, including visual examinations and ultrasonic testing, are used to detect fouling and loss of material. It also states when visual inspections are used to identify loss of material, the inspection technique is capable of detecting surface irregularities that could indicate wall loss below nominal wall thickness, and where such irregularities are detected, follow-up volumetric wall thickness examinations are performed. The response also states that the Open-Cycle Cooling Water program utilizes the corrective action program to document degradations and to evaluate corrosion rates so piping and related components are cleaned and replaced prior to loss of function.
Issue:
LR-ISG-2012-02 added Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR), Further Evaluation Section 3.3.2.2.8, Loss of Material due to Recurring Internal Corrosion, that discusses the need for considering augmented requirements to ensure the adequate management of any recurring aging effects. This Further Evaluation section includes the following five aspects:
- 1. State why the programs examination methods will be sufficient to detect the recurring aging effect before affecting the ability of a component to perform its intended function.
- 2. State the basis for the adequacy of the augmented inspections.
- 3. State what parameters will be trended as well as the decision points where increased inspections would be implemented.
- 4. State how inspections of components that are not easily accessed will be conducted.
- 5. State how leaks in any involved buried or underground components will be identified.
- 6. Although the cited letter discussed some portions of the above aspects, it did not clearly address all of the criteria discussed in the Further Evaluation section. The staff noted that the LRA included a discussion regarding the identification of wall thickness measurements in segments of service water piping that were below procedural limits, but met design requirements. However, the cited letter did not discuss whether augmented inspections would be performed to manage the recurring internal corrosion.
Request:
Please provide additional information that would clarify how FirstEnergy Nuclear Operating Company intends to meet each of the five elements of the Further Evaluation section stated above for LR-ISG-2012-02.