ML091180329

PINGP Lr - Summary of 3-30-09 Conference Call with NRC

ML091180329
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Site:	Prairie Island
Issue date:	04/10/2009
From:	- No Known Affiliation
To:	Division of License Renewal
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1 PrairieIslandNPEm Resource From:

Eckholt, Gene F. [Gene.Eckholt@xenuclear.com]

Sent:

Friday, April 10, 2009 10:34 AM To:

Richard Plasse Cc:

Vincent, Robert

Subject:

Summary of 3-30-09 Conference Call with NRC Attachments:

Summary of 3-30-09 Conference Call with NRC.doc A summary of the 3/30/09 conference call is attached.

<<Summary of 3-30-09 Conference Call with NRC.doc>>

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Eckholt, Gene F.

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"Vincent, Robert" <Robert.Vincent@xenuclear.com>

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1 Summary of 3/30/09 NRC - PINGP License Renewal Conference Call NRC Attendees: Rick Plasse, Jim Medoff, Jim Davis, Wayne Pavinich, Bob Jackson, Allen Hiser PINGP Attendees: Gene Eckholt, Phil Lindberg, Scott Marty, Bill O'Brien, Bill Roman, Bob Vincent Summary: The purpose of the call was to discuss several follow up questions and some draft RAIs. Specific issues discussed are as follows:

B2.1.9 Closed-Cycle Cooling Water System Program Follow up Question The PINGP letter of 2/6/09 provided an exception to the performance testing recommendations of GALL. The letter of 2/26/09 revised the exception to state that periodic visual inspections will be performed on certain chillers. The reviewer felt that the periodic visual inspections should be captured as a commitment.

PINGP explained that the CCCW System Program in the LRA already contains an enhancement to perform periodic inspections of internal surfaces when those surfaces are made accessible during maintenance or surveillance. This enhancement would encompass internal inspections which relate to the chillers in question. This enhancement is captured as License Renewal Commitment #6.

The reviewer indicated that this would be sufficient to resolve his concern. No further action is needed from PINGP.

Draft RAI 3.3.2-8-1 Natural Rubber in Fuel Oil Environment The LRA indicates natural rubber is used in a fuel oil or lubricating oil environment, but natural rubber is not resistant to oil. The reviewer asked how aging of the rubber would be managed.

PINGP explained that during the AMR process, certain rubber hoses were identified as being made of natural rubber by default when the actual materials were not readily available. This was done to be conservative since the aging effects are most severe in natural rubber, but it did not acknowledge that natural rubber is generally not suitable for an oil environment. Many hoses have subsequently been confirmed to be made of synthetic materials resistant to oil environments. There are still some remaining to be confirmed.

PINGP understands the question. The RAI will be issued.

2 B2.1.19 Fuel Oil Chemistry Program Follow up Questions The LRA takes exception to the GALL recommendation for cleaning and for wall thickness measurements in the diesel generator day tanks and leakage collection tanks. The reviewer was concerned that no monitoring of tank condition was being performed and indicated that more justification was needed to support the exception.

PINGP acknowledged that the day tanks are raised and may be accessible for UT thickness testing on their bottom surfaces. It was agreed that PINGP would consider one-time UT thickness testing of day tank(s).

PINGP explained that the leakage collection tanks are very small tanks on the order of a couple of gallons, and the interiors were not accessible for inspection.

The clean leakage collection tanks collect clean fuel oil from the injectors, and return the clean oil directly to the engine fuel oil system with virtually no potential for contaminating the fuel oil system. The dirty leakage collection tanks collect drips, etc. from the engine, and the resulting dirty oil is disposed of as waste.

PINGP agreed to supplement the discussion provided in the previous RAI response [RAI B2.1.19-3 response on 12/18/08] to provide more descriptive information on the leakage collection tanks and further explain how aging effects are adequately managed.

PINGP understands the question and will provide a clarification in a supplemental letter. An RAI will not be issued.

B2.1.19 Fuel Oil Analysis Follow up question PINGP has provided a commitment to initiate annual testing of fuel oil for particulates, but GALL recommends quarterly testing. The basis for annual particulate testing appears to be that previous sediment testing has not found particulates. The reviewer indicated that annual testing may be sufficient as long as sediment testing and particulate testing show that fuel oil continues to be clean without particulates. Clarification was requested, however, to state that in the event significant sediment or particulates are detected, the annual test frequency for particulates would be increased.

PINGP understands the question and will provide a clarification in a supplemental letter. An RAI will not be issued.

Draft RAIs for Section 4.7.5 Turbine Missile Analysis TLAA LRA Section 4.7.5 indicates that the analysis of turbine rotor failure leading to turbine missiles is a TLAA. It primarily references the USAR discussion, but the USAR does not make it clear that this is a TLAA in the CLB. The USAR cites a safety evaluation for turbine valve test frequency which does not appear to apply

3 to turbine rotor failure. The USAR cites SRP Section 3.5.3 which relates to missile barriers, but does not cite the SRP section which relates to turbine rotor failure. The reviewer questioned whether the rotor failure was part of the CLB.

He questioned whether NRC had ever issued an SE specifically for the turbine rotor inspection interval under GDC 4 and the SRP; if not, that may be a basis for concluding the turbine rotor analysis is not part of the CLB, and therefore not a TLAA. He reiterated he is not challenging the PINGP CLB, but does not understand what the CLB is with regard specifically to the turbine rotor inspection frequency.

PINGP explained that when that section of the LRA was prepared, the USAR discussion was accepted at face value. In retrospect, after looking at the evaluation in more detail, the evaluation was not done for the operating license term. The probability of rotor failure is a function of the length of time the rotor is in service and not the operating license term. PINGP also questions whether this meets the definition of a TLAA, and is continuing to research the issue.

The reviewer requested that PINGP clarify whether the issue meets the definition of a TLAA. If it is concluded to be a TLAA, specific CLB information which defines the safety bases for turbine rotor failure (inspection frequency) should be provided. He recommended looking at SRP Section 3.5.1.3 guidance relating to how a probabilistic analysis of turbine rotor failure is performed for information.

PINGP understands the question and will provide a clarification in a supplemental letter. An RAI will not be issued.