ML061010644

Email Fwd: Additional follow-up Questions for Audit Q&A Database (PA)

ML061010644
Person / Time
Site:	Oyster Creek
Issue date:	03/17/2006
From:	Ashley D NRC/NRR/ADRO/DLR/RLRA
To:	Beck G, Hufnagel J Exelon Corp
References
%dam200606, TAC MC7624
Download: ML061010644 (4)

Text

D. Ashley - Fwd: Additional follow-up questions for Audit Q&A database Page 1 From:

D. Ashley To:

George Beck; John Hufnagel Date:

03/17/2006 6:50:59 AM

Subject:

Fwd: Additional follow-up questions for Audit Q&A database John, George-Attached are the subject questions from the Audit Team Leader.

He requests that you add to the Q&A Database and include in your next update for ADAMS addition.

regards, Donnie Ashley NRR/DL R/RLRA Oyster Creek License Renewal Project Manger 301-415-3191 djal @ nrc.gov

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Fwd: Additional follow-up questions for Audit Q&A database 03/17/2006 6:50:59 AM D. Ashley DJA1 @nrc.gov Recipients exeloncorp.com 6:51:1C AM George.Beck (George Beck) john.hufnagel (John Hufnagel)

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I D. Ashley - Additional follow-up questions Page 1 l From:

To:

Date:

Subject:

Roy Mathew D. Ashley 03/16/2006 4:12:06 PM Additional follow-up questions Donnie: see attached file. Please forward this to the applicant. Thanks, Roy CC:

James Davis

ID. Ashley -_Audit tearn followup questions.wpd u

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.w Page 1 Audit team follow-up questions: James Davis, NRC

1.

The Lubricating Oil Analysis Program - FRCT (OCGS AMP B.1.39) takes exception to the GALL Report requirement to monitor flash point..

The basis provided for exceptions to GALL, Element 3 (Parameters Monitored or Inspected) is not valid since the Flash Point of an industrial lubricant is an important test to determine if light-end hydrocarbons are getting into the oil through seal leaks or other means. It is an effective way to monitor seal performance in light end hydro-carbon compressors. Low Flash Points pose a safety hazard in the event of component failure that can generate heat above the flash point of the oil, such as bearing failure.

Please justify the reason for not monitoring the flash point of lubricating oil at the FRCT and why this exception is acceptable to manage the effects of aging for which it is credited.

2.

PBD-AMP-B.2.2, "Lubricating Oil Monitoring Activities," Element 3 states that oil analysis guidelines will be enhanced to include measurement of flash point for diesel engine lubricating oil. This is a new enhancement based on the reconciliation of this aging management program from the draft January 2005 NUREG-1 800, Rev. 1 to the approved September 2005 NUREG-1801, Rev. 1. This enhancement is not identified in OCGS LRA B.2.2.

Is the LRA supplemented to reflect this?

3.

PBD -AMP-B.1.12, "Bolting Integrity" identifies an enhancement to NUREG-1801 for elements 1, 2, and 7. This enhancement is not identified in OCGS LRA B1.12. Is the LRA supplemented to reflect this?

4.

PBD -AMP-B.1.21, "Aboveground Outdoor Tanks," identifies an exception to NUREG-1801 for element 5 (The program utilizes tank inspections every 5 years in place of system walkdowns each outage). This exception is not identified in OCGS LRA B1.12.

Is the LRA supplemented to reflect this? What is the basis for this exception?

why this exception is acceptable to manage the effects of aging for which it is credited.

L.-

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