ML070600447

1R21 Outage - NRC Inspection Question Log Complied by Amergen (12 Pages)

ML070600447
Person / Time
Site:	Oyster Creek, Three Mile Island, Clinton
Issue date:	10/31/2006
From:	NRC Region 1
To:
References
Download: ML070600447 (12)

Text

NRC Inspection Question - Resolution Log1 1-8PM lR21 Outage - NRC Ins teq. by LFerdas '.Kaufman

'.Kaufman iection Question Log Assignee (andasamy wlilos hintenz ramburro Due 31-Oct 240ct 1 -NOV Question Insure that Tech Eva1 for repairs 5 reviewed by PORC Ioes the fact that there is no urb in the trench area affect the ;AMA analysis as part of LRA loes the fact that there is no urb in the trench area affect the :urrent Licensing basis Response This action is captured in the 1R21 Reg. Assurance Actions Log items 6, 14, and 16. Although the Level 2 PRA took some credit for the curb probabilistically, it is not significant enough to markedly change LERF or the conclusions of the SAMA analysis.

IR is being written as a measure to make the appropriate changes to the Level 2 PRA. Also, if there are any further questions in this area Greg Krueger in Corporate Risk Assessment would be the contact point.

He will provide support for any further discussions on this topic, and we can arrange for that support as needed. 2esoived 'ORC cheduled or Nov 4 at 200 JRC eviewing locurnenls provided ief. IR 546049 inswer provided by T. 2uintenz IR 550022 K/Engr/l R21 Drywell/NRClnsp NRC Inspection Question - Resolution Log1 1-8PM Due 29-Oct em i 5 - Question will we change any LRA commitments previously made as a result of 1 R21 issues; How will we implement or document any plan changes.(Have we addressed the need for a more formal response machanism to this question Le. submittal?

Which of the July 8,06 commitmtents have we met this outage?) Date 6-Oct 6-OCt teq. by '.Kaufman LFerdas Assignee Juintenz copy of the Tech Eva1 for the repairs/disposition of identified Response The License Renewal Team will evaluate whether any License Renewal commitments need to be changed or added as a result of inspections performed or new operating experience identified during 1R21. For example, the effects of water on the inside of the drywell shell will be reassessed to determine if additional aging management activities, programs or commitments are needed. AmerGen will make this determination and submit any such information to the NRC. We plan to submit a letter, supplementing the LRA with any updates that are needed to aging management programs, activities and commitments related to the wetted drywell shell internal surface, by early Provided Copy 10/29/06 - ,. , . . lesolved IRC ?viewing 'es Iocuments provided 'ech Eva1 A21 527W06 -ech Eva1 A2152754-09 WEngr/l R21 Drywell/NRClnsp I. Due 10/30/06 NRC Inspection Question - Resolution Log1 1-8PM Question Provide copies of Work order (or AWA, ECR, procedure or vendor instructions) on how to install caulk NRC asked to review the structural monitoring report from our walkdown - visual inspection by S.Markos and D.Fiorello What is the service life of the caulk? Should address service life - how long it will last and perform as needed - and specify a replacement schedule based on that conclusion - May need to say that we will perform visuals and structurally monitor to prove it is okay long term if lab results are non-conclusive for service life question What YO of the concrete can we estimate is underwater or saturated with water?

What is the ph of the water - did 'we analyze for any trace of Date 6-Oct Oct .7-0ct !7-oct !7-0ct corrosion - did it show any 'ferrous traces - NRC wants to lsee data ZG-. by 4. Ferdas '.Kaufman

-. O'Hara -. OHara LChaudary Assignee 3aY Tamburro Hallenbeck I See item IO Response Provided Copy 10/30/06 Part of Tech Eva1 Qualified to environmental conditions of DBA. Is conditionally monitored every outage Structures Monitoring Program. by ER-OC-450, Mike Ade, S&L performed calculation Ray answered that samples indicated corrosion has stopped - follow up - NRC wants to review data. Clarifying memo from Chemistry for initial sample out of trench in Bay 5 with Ph identified.

lesolved RC ?viewing es rovide IRC calc IRC ?viewing Iocurnents provided LCR 06-00879 AWAS -ech Eva1 A21 52754-05

\2152754-06 L? 152754-05 jturctural - Mike Adel 421 52754-06 WEngr/l R21 DrywelllNRClnsp NRC Inspection Question - Resolution Log? 1-8PM Why can't we keep track of all our inventory of water so we could quantify amount that may be in concrete area?

Did we try a test to pour water down the inside wall of the liner to see where it goes ( during SD water runs down wall but during Ops, leaks go to trough through piping) Need to rule out possibility that water running down wall is a source of water that could go between gap and liner - How are we sure? Why didn't we do this type of test? Can we calculate how much water might be in this mass of concrete Will the tech eval include assessment that worst spot for corrosion is at water-air interface, where the cut-out is? Justify in tech eval Why did we choose bays 5 and 17 in 1986, when the worst corrosion is suspected at bays ' and 13 - why not look at those? Where do bays 5 and 17 rank compared to others for "catalysi potential at the surface for corrosion Same as 16 :m k 12 - 14 16 - 17 Rate 7-Oct - :7-Oct !7-oct 27-oct 27-OCt :eq. by LChaudary

.. O'Hara VRC S .C hauda y T. O'Hara Assignee :ay Lay Due Question Response Calculate volume for Item 9 Repairs to prevent water entering concrete at interface to shell Close to Item 9 In attachment to Tech Eval, Barry Gordon Pete Tamburro, in eval for UT Documents provided I ?s - see ITech Eva1 A2152754-05 WEngr/l R21 DtywelVNRCInsp Date 27-0ct 27-Oct Req. by T. O'Hara S.Chaudary Time 930 930 Assignee NRC Inspection Question - Resolution Log1 1-8PM Question I If shell is breached at the bottom, would out Type A leak test identify that?

Does the grout / caulk addition affect this answer, or was it included as an assumption during review? What are the C02 and 02 levels in the water found in the trench as this would affect corrosion and what effect do these values have on our corrosion estimates (NRC commented that cracks develop from tension in concrete and they could carry 02 through cracks to liner Response Shirk add to Tech Eva1 Artz - need to address in Tech Eva1 iesolved )pen until JRC .eviews rech Eva1 )ocurnetits provided K/Engr/l R21 Drywell/NRClnsp

,. .- k NRC Inspection Question - Resolution Log1 1-8PM Date 27-Oct Time 930 Req. by T. O'Hara Assignee Quintenz Due Question I Now that there is a new environment to consider, we ma) need to address the need to re- do the aging management program based on what we found in 1R21- we assume sumps and piping function as designed -will there be a new commitment to inspect regularly?

NRC raised concern on 10CFR 54.13 accuracy ofinformation - Did we only consider 5 years history in all aging management programs?lf the LRA is based on design and operating experience, why didn't out our LRA include assessment of this history of water in the DW liner area? [Resolved Documents provided I Response requires each license renewal applicant to "notify the Commission of information identified by the applicant as having, for the regulated activity, a significant implication for

public health and safety or common defense and security." After reviewins the evaluation of the impact of water found in the bay #5 inspection trench in the drywell floor, Exelon has determined that 54.13(b) does not apply. The evaluation, as documented in AIR A2152754 Eva1 06 and Eva1 09, has determined that the drywell structural integrit) is maintained and the drywell continues to meet all of its design basis requirements.

WEngrll R21 DrywelllNRClnsp NRC Inspection Question - Resolution Log1 1-8PM Due 30-013 em 1 21 - 23 25 26 - Question Confirm that we have a commitment to perform UT Testing of wall thickness in trenches 5 and 17 every outage as part of the monitoring program. When will we UT trench area next? (Engr. responded next outage) - need to confirm. NRC is expecting that there will be more UT inspections planned to prove no corrosion is active(at least 3 times, with the third time being post POE) (related to Item 4). Do we have plans to do more inspections for this purpose? Will we be able to supply NRC with a white paper - a high level - single page or summary of what we found, what we did to fix it and why we think this is okay - by end of Friday Will we add any visual or other testing of the trenchltrough to the forced outage schedule?

NRC requests list of all IRs and assignments for both commitments and from "new" DW water issue, that need closure prior to start up. Request for our submittal of DW related commitments Time )30 )30 - 130 - 130 - i30 ieq. by -. O'Hara 2.Kaufman AFerdas r. O'Hara r. O'Hara Assignee taY .ambert hintenz IMoved to item 21 Response ER-OC-450 Draft provided No, covered by existing program List provided

!esofved 'es 'es 'es )ocuments provided )we copy of procedure to IRC )raft of white paper WEngdl R21 DrywelllNRClnsp Item d Date Time Req. by 27 28 30-Oct 830 T. O'Hara 29 NRC Inspection Question - Resolution Log1 1-8PM Assignee Ray Response Resolved TE - UT (May need to adjust wording in tech eval to say that with the known minimal corrosion rate, applied to the next 20 minimum years, we would be okay ) NRC to review tech Eva1 Documents provided I I IR - I 1 Due 30-Oct WEngr/l R21 DryweWNRClnsp Question Added to item 21 NRC needs clarification on whether corrosion is actually arrested - they were told in submittals and ACRS that it was but data suggests othewise - need to review data with inspectors to clarify Added to item 20 NRC Inspection Question - Resolution Log1 1-8PM Due - em i Question At the ACRS meeting, there may have been a statement made by Exelon the corrosion has been "arrested" Confirm if possible.

Did we say that in any correspondence?(LRA) 30 - Date Io-oct - Time 500 - - ieq by I'Hara A& ig nee luintenz Response AmerGen has reviewed the July 22, 2005 Oyster Creek License Renewal Application (LRA), the April 7,2006 response to NRC RAls on Drywell corrosion (AmerGen Letter 21 30-06-202289), the June 20,2006 letter forwarding supplemental information to NRC following the June 1, 2006 public meeting on drywell corrosion (AmerGen Letter 21 30- 06-20353), the June 23, 2006 submittal that provided the NRC Staff with an update to Appendix A of the LRA following all the Audits (AmerGen letter 21 30-06 203%), and the transcripts from the October 3,2006 ACRS Subcommittee meeting.

Based on review of these documents, AmerGen concludes that within these written documents and also as part of the oral comments made at the October 3rd ACRS Subcommittee meeting, 1- -~ !esolved ~ ~~ ~ Iocuments provided-WEngr/l R21 DrywelVNRClnsp

.- Due NRC Inspection Question - Resolution Log1 1-8PM Question Do we know we have identified the source of the water? Do we know we have stopped it? Can we prove it? Do we intend to tesi repairs? Do we know how long leakage path was there? Does TDR address bottle discovery?

Does the design bases assume no leakage to liner area?

Do we hav any documents that say it's okay to be wet? Did we consider possibility of external sources of water? When water was identified back in around 1994, what corrective actions did we plan to resolcve issue? Did we do them? Cancel them? Do we intend to submit report to ASLB? Are lawyers looking at it? When will we decide? qesolved Response Documents provided In Tech Eva1 and ECR In Tech Eva1 In Tech Eva1 DRAFT Respose under review in ArnerGen In tech eval - Tech eval only addresses operability - it is not a submittal -would become part of mandatory disclosure.

WEngr/l R21 DrywelVNRClnsp

... 'tern - 36 37 Due Date ;o-oct 'l-oct ~ Question Sand bed drains were uncloggec this outage - what frequency will they be checked? Future surveillance plan to ensure drains are open and operable? - Time - 500 - 30 teq. by 'inney :erdas Assignee luintenz NRC Inspection Question - Resolution Log1 1-8PM NRC wants copy of completed work package that repaired clogged drains. Want to see visual inspection report of drains Response The future surveillance plan for the sand bed drains will be determined after our review of the I R21 operating experience.

Any further commitments relative to sand bed drain surveillance to ensure they are open and operable will be considered in our formal submittal discusseed in Item ##4. Work order number R2088495 printout provided with CREM to Mark Ferdas 11/2/06 0830 Meeting ?esolved Iocuments provided WEngrll R21 DrywelllNRClnsp

..- a NRC Inspection Question - Resolution Log1 1-8PM Date mz- Time 130 ?eq. by Assignee Due Question s there any OE on containments hat have been demolished that ;hows effects of wetted liner and mrosion in embedded regions? Response iesolved Documents provided I The EPRl Structural Tools document references the use of the Shippingport experience with concrete, but does not reference experience with embedded steel.

In discussions with Fred Polaski, License Renewal Manager he was not aware of any specific operating experience from decommissioned plants which has been used.

We are using the NRC GALL for our work and there may be some experienced factored into it, but that is not known at this time. K/Engr/l R21 DrywelVNRCInsp