ML061030282

01/31/2006 Summary of Telephone Conference Call Between U.S. Nuclear Regulatory Commission Staff & Nuclear Energy Institute Re Proposed Interim Staff Guidance for License Renewal (LR-ISG) Associated with Corrosion Mark I Steel Containment D

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

SUMMARY

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

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

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

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

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

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

Public involvement is an important part of this process. The process gives the publicopportunities to obtain information and to comment on the proposed LR-ISG. The staff has identified the potential need for an LR-ISG addressing corrosion of the Mark Isteel containment drywell shell. The current Generic Aging Lessons Learned (GALL) Report (NUREG-1801, Revision 1) does not provide sufficient guidance when the drywell shell issurrounded by a concrete structure with a narrow distance between the steel shell and the surrounding concrete, inhibiting visual inspection. Past operating experience in Mark I steel containments indicates that when water is discovered in the bottom outside areas of the drywell(including those in the sand-pocket area), the most likely cause would be the water seeping through the space between the drywell shell and the shield concrete. The staff is proposing changes to clarify its license renewal guidance documents (LRGDs). Specifically, the staff is proposing that further evaluation be performed, including root causeanalysis. Also, the staff proposes that an aging management program that would detect andmonitor corrosion when the potential for corrosion is indicated in the inaccessible areas of the drywell, be established.In its review of license renewal applications, if leakage through the seal has been found as thecause of the corrosion on outside surfaces of the drywell shell, the staff has been requesting applicants to bring the refueling seal within the scope of license renewal. Some applicants claim that, as the seal is required only during refueling activities, it does not have to be within the scope of license renewal. However, the staff believes that if seal leakage causes corrosion, the non-safety related component can impair the capability of primary containment to mitigatethe consequences of an accident, and should be brought into the scope of license renewal, pursuant to 10 CFR 54.4(a)(2). If the leakage through the seal has been found not to be the cause of the corrosion, the staff requested that further evaluation be performed, including rootcause analysis and an aging management program that would detect and monitor corrosion. NEI acknowledged this issue and indicated that this issue is plant-specific and should beevaluated on a case-by-case basis, and not be applied to the industry as a whole. The staff reiterated that this issue applies only to nuclear power plants with the Mark I steel containment drywell shell design. This is a generic issue that deals with the corrosion of the Mark I steel containment drywell shell. NEI requested to meet with the staff to further discuss this issue.

The staff and NEI agreed to schedule a follow-up public meeting to further discuss this issue.The staff also provided answers to questions from the public who participated in the telephoneconference call. The majority of questions from the public were related to the design and operation of the drywell. The staff explained that the public will have an opportunity to providecomments on the proposed LR-ISG once it is developed, since it will be published in a Federal Register Notice, requesting comments. /RA/Linh N. Tran, Project ManagerLicense Renewal Branch B Division of License Renewal Office of Nuclear Reactor RegulationProject No. 690

Enclosures:

1. List of Participants

2. Meeting Handoutscc w/encls: See next page The staff is proposing changes to clarify its license renewal guidance documents (LRGDs). Specifically, the staff is proposing that further evaluation be performed, including root causeanalysis. Also, the staff proposes that an aging management program that would detect andmonitor corrosion when the potential for corrosion is indicated in the inaccessible areas of the drywell, be established.In its review of license renewal applications, if leakage through the seal has been found as thecause of the corrosion on outside surfaces of the drywell shell, the staff has been requesting applicants to bring the refueling seal within the scope of license renewal. Some applicants claim that, as the seal is required only during refueling activities, it does not have to be within the scope of license renewal. However, the staff believes that if seal leakage causes corrosion, the non-safety related component can impair the capability of primary containment to mitigatethe consequences of an accident, and should be brought into the scope of license renewal, pursuant to 10 CFR 54.4(a)(2). If the leakage through the seal has been found not to be the cause of the corrosion, the staff requested that further evaluation be performed, including rootcause analysis and an aging management program that would detect and monitor corrosion. NEI acknowledged this issue and indicated that this issue is plant-specific and should beevaluated on a case-by-case basis, and not be applied to the industry as a whole. The staff reiterated that this issue applies only to nuclear power plants with the Mark I steel containment drywell shell design. This is a generic issue that deals with the corrosion of the Mark I steel containment drywell shell. NEI requested to meet with the staff to further discuss this issue.

The staff and NEI agreed to schedule a follow-up public meeting to further discuss this issue.The staff also provided answers to questions from the public who participated in the telephoneconference call. The majority of questions from the public were related to the design and operation of the drywell. The staff explained that the public will have an opportunity to providecomments on the proposed LR-ISG once it is developed, since it will be published in a Federal Register Notice, requesting comments. /RA/Linh N. Tran, Project ManagerLicense Renewal Branch B Division of License Renewal Office of Nuclear Reactor RegulationProject No. 690

Enclosures:

1. List of Participants

2. Meeting Handouts cc w/encls: See next page7DISTRIBUTION: See next pageAdams Accession Numbers: Pkg - ML061030283, Note to NEI w/encl 1 - ML061030282, Handouts (encls. 2) - ML061030285OFFICEPM:RLRB:DLRLA:RLRA:DLRPM:RLRC:DLROGC NLOBC:RLRB:DLRNAMELTranYEdmondsTTerryAHodgdon(w/comments)JZimmermanDATE05/ 26 /0605/ 25 /0604/ 13 /0604/ 14 /0605/ 30 /06OFFICIAL RECORD COPY Note to: Nuclear Energy Institute (NEI) from Linh N. Tran, Dated: May 30, 2006

SUMMARY

OF A TELEPHONE CONFERENCE CALL HELD ON JANUARY 31, 2006, BETWEEN THE U.S. NUCLEAR REGULATORYCOMMISSION (NRC) STAFF AND THE NUCLEAR ENERGY INSTITUTE ADAMS ACCESSION NUMBER: PKG: ML061030283HARD COPYDLR R/FLTranE-MAILJFairRWeisman AMurphy RPettis GGalletti CLi GBagchi SSmith (srs3)

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

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CJulian MModes JVora LKozak RidsOpaMail LIST OF PARTICIPANTS FOR A TELEPHONE CONFERENCE CALL BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND THE NUCLEAR ENERGY INSTITUTEJANUARY 31, 2006ParticipantsAffiliationsPao-Tsin KuoU.S. Nuclear Regulatory Commission (NRC)Jacob ZimmermanNRC Kenneth ChangNRC Louise LundNRC Hans AsharNRC Jim DavisNRC Yoira Diaz SanabriaNRC Ram SubbaratnamNRC Amy HullNRC Kiyoto TanabeNRC (Foreign Assi gnee)Daniel FrucherNRC Ann HodgdonNRC Roy MathewNRC Dan HoangNRC Kamal NaiduNRC Stephen HoffmanNRC Linh TranNRC Tomeka TerryNRC Cayetano Santos, Jr.NRC/Advisory Committee on Reactor Safeguards StaffJames RossNuclear Energy Institute (NEI)

Michael P. GallagherExelon Nuclear Kathryn SuttonMorgan Lewis Alex PolonskyMorgan Lewis Paul BremerCooper Nuclear Station Bill VictorCooper Nuclear StationFred MogoleskoEntergy Fred PolaskiExelon Nuclear Ken BruneTennessee Valley Authority (TVA)

Russell JansenTVA Joe PairitzMonticello Madalon O'BrienMonticello Suzanne LetaNew Jersey Public Interest Research Group Paul GunterNuclear Information and Resource Service Bill ShermanVermont Department of Public ServiceRichard WebsterRutgers Environmental Law Clinic Edith GburJersey Shore Nuclear Watch William CostanzoJersey Shore Nuclear Watch Paula GotschGrandmothers, Mothers, and More for Energy Safety Deann RaleighScientech Ron ZakState of New Jersey Nancy G. ChapmanBechtel Power Corp.

Peter James AthertonPublicEnclosure 1 NUCLEAR ENERGY INSTITUTE Project No. 690

cc:Mr. Joe Bartell U.S. Department of Energy NE-42 Washington, DC 20585Ms. Christine S. Salembier, CommissionerState Liaison Officer Department of Public Service 112 State St., Drawer 20 Montipelier, VT 05620-2601Mr. James RossNuclear Energy Institute 1776 I St., N.W., Suite 400 Washington, DC 20006-3708Mr. Frederick W. PolaskiManager License Renewal Exelon Corporation 200 Exelon Way Kennett Square, PA 19348Peter A. MazzaferroSite Project Manager - License Renewal Nine Mile Point Nuclear Station, LLC

P.O. Box 63 Lycoming, NY 13093Mr. David LochbaumUnion of Concerned Scientists 1707 H St., NW, Suite 600 Washington, DC 20006-3919Mr. Clifford I. CusterProject Manager, License Renewal FirstEnergy Nuclear Operating Company

P.O. Box 4 Route 168 (Mail Stop SIM-2)

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

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