ML17192A449

Errors Identified in Response Provided to Nrg During License Renewal Application Process

ML17192A449
Person / Time
Site:	FitzPatrick
Issue date:	07/11/2017
From:	David Gudger Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
IR 2017001
Download: ML17192A449 (8)

Text

Exelon Generation ~

200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 54 10 CFR 50.9 July 11, 2017 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 James A FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRG Docket No. 50-333

Subject:

Errors Identified in Response Provided to NRG during License Renewal Application Process

References:

(1) Letter, Entergy to USNRC, "James A. FitzPatrick Nuclear Power Plant, Docket No. 50-333, License No. DPR-59, License Renewal Application," JAFP-06-0109, dated July 31, 2006.

(2) Letter, Entergy to USNRC, "Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333, License No. DPR-59 License Renewal Application, Amendment 6," JAFP-07-0021, dated February 12, 2007.

(3) Letter, Entergy to USNRC, "Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333, License No. DPR-59 License Renewal Application, Amendment 9," JAFP-07-0048, dated April 6, 2007.

(4) "Safety Evaluation Report Related to the License Renewal of James A. FitzPatrick Nuclear Power Plant," ML080250372, dated February 2008.

(5) Letter, USNRC to Exelon Generation Company, LLC, "James A.

FitzPatrick Nuclear Power Plant - Integrated Inspection Report 05000333/2017001," ML17128A109, dated May 8, 2017.

This letter provides corrections to information Entergy Nuclear Operations, Inc. (Entergy) previously submitted to the U.S. Nuclear Regulatory Commission (NRG) in letters dated July 31, 2006 (Reference 1), February 12, 2007 (Reference 2), and April 6, 2007 (Reference 3) relating to the Renewal Application for the James A. FitzPatrick Nuclear Power Plant (JAF) Facility Operating License. The information provided in the referenced letters is reflected in the License Renewal (LR) Safety Evaluation Report (SER) (Reference 4). The discrepancy between LR documentation and plant conditions

U.S. Nuclear Regulatory Commission Errors Identified in Response Provided to NRC during License Renewal Application Process July 11, 2017 Page2 was first identified by the NRC in January of 2017 during the R22 Refuel Outage and is the basis for an open Unresolved Item (URI 05000333/2017001-01 ), which is documented in the 102017 Quarterly Inspection Report (Reference 5). The original incorrect information along with the corrected response is provided in Attachment 1.

Exelon Generation Company, LLC believes that the erroneous information Entergy provided does not have a material impact on the effectiveness of the affected Aging Management Program. Specifically, the Containment lnservice Inspection (Cll) IWE Program is fully compliant with ASME Section XI requirements. This program requires augmented inspections of the interface between the drywall floor and drywell shell liner as described in IWE 1240. The augmented inspections have been completed as required during the period of extended operations. These inspections are required and performed regardless of whether a moisture barrier is installed or not.

Should you have any questions concerning this submittal, then please contact Christian Williams at 610-765-5729.

Respectfully, David T. Gudger Manager - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Attachment:

1) Summary of Incorrect and Corrected Information Provided During JAF License Renewal cc: Regional Administrator - NRC Region I NRC Senior Resident Inspector James A. FitzPatrick Nuclear Power Plant NRC Project Manager - James A. FitzPatrick Nuclear Power Plant

Attachment 1 Summary of Incorrect and Corrected Information Provided During JAF License Renewal

ATTACHMENT 1

SUMMARY

OF INCORRECT AND CORRECTED INFORMATION PROVIDED DURING JAF LICENSE RENEWAL Requested Information /

ORIGINAL INFORMATION PROVIDED CORRECTED INFORMATION Source Letter, Entergy to USNRC, James A. FitzPatrick Nuclear Power Plant, Docket No. 50-333, License No. DPR-59, License Renewal Application, JAFP-06-0109, dated July 31, 2006 (Reference 1)

JAFP-06-0109 License Renewal ISG-2006-01 Corrosion of the Mark I Steel ISG-2006-01 Corrosion of the Mark I Steel Application Technical Information Containment Drywell Shell Containment Drywell Shell (Page 2.1-17) The JAFNPP drywell steel shell and the moisture The JAFNPP drywell steel shell and the interface at barrier where the drywell shell becomes embedded the drywell steel shell and concrete floor joint are in the drywell concrete floor are inspected in inspected in accordance with the Containment accordance with the Containment Inservice Inservice Inspection (CII) IWE Program and the Inspection (CII) IWE Program and Structures Structures Monitoring Program. The exterior surface Monitoring Program. The exterior surface of the of the drywell shell at the sand cushion is effectively drywell shell at the sand cushion is effectively drained and protected from condensation or water drained and protected from condensation or water that might enter the air gap from above and that might enter the air gap from above and potentially cause corrosion. Therefore, significant potentially cause corrosion. Therefore, significant corrosion of the JAF drywell is not expected. See corrosion of the JAF drywell is not expected. See Table 3.5.1, Item 3.5.1-5.

Table 3.5.1, Item 3.5.1-5.

Table 2.4-1 Reactor Building Moisture barrier: Shelter or protection [(EN) Provide No moisture barrier exists at the interface between Components Subject to Aging shelter or protection to safety-related equipment the drywell steel shell and the drywell concrete floor.

Management Review (Page 2.4-23) (including HELB, radiation shielding and pipe whip restraint).] Support for criterion (a) (1) equipment

[(SSR): Provide structural or functional support for safety-related equipment.]

3.5.2.2.1.4 Loss of Material due to JAFNPP containment is a Mark I steel containment JAFNPP containment is a Mark I steel containment General, Pitting, and Crevice located within the reactor building. JAFNPP reactor located within the reactor building. JAFNPP reactor Corrosion (Page 3.5-7) building concrete in contact with the drywell shell is building concrete in contact with the drywell shell is designed in accordance with specification ACI 318- designed in accordance with specification ACI 318-63, Building Code Requirements for Reinforced 63, Building Code Requirements for Reinforced Concrete. The concrete meets requirements of later Concrete. The concrete meets requirements of later ACI guide ACI 201.2R-77 since both documents ACI guide ACI 201.2R-77 since both documents use Page 1 of 5

ATTACHMENT 1

SUMMARY

OF INCORRECT AND CORRECTED INFORMATION PROVIDED DURING JAF LICENSE RENEWAL use the same ASTM standards for selection, the same ASTM standards for selection, application application and testing of concrete. Concrete is and testing of concrete. Concrete is monitored for monitored for cracks under the Structures cracks under the Structures Monitoring Program.

Monitoring Program. The drywell steel shell and the The drywell steel shell and the interface at the moisture barrier where the drywell shell becomes drywell steel shell and concrete floor joint are embedded in the drywell concrete floor are inspected in accordance with the Containment inspected in accordance with the Containment Inservice Inspection - IWE Program and Structures Inservice Inspection - IWE Program and Structures Monitoring Program.

Monitoring Program.

Table 3.5.1 Structures and Item Number 3.5.1-5 Discussion: Item Number 3.5.1-5 Corrected Discussion:

Components, NUREG-1801 Vol. 1 Containment Inservice Inspection (CII) and Containment Inservice Inspection (CII) and

[Page 3.5-20] LRA TI Containment Leak Rate Program will manage this Containment Leak Rate Program will manage this aging effect. Containment inservice inspection is a aging effect. Containment inservice inspection is a plant-specific program for JAFNPP. Corrosion is not plant-specific program for JAFNPP. Corrosion is not significant for inaccessible areas (i.e., drywell steel significant for inaccessible areas (i.e., drywell steel shell). To prevent corrosion of the lower part of the shell). To prevent corrosion of the lower part of the drywell, the interior and exterior surfaces are drywell, the interior and exterior surfaces are protected from contact with the atmosphere by protected from contact with the atmosphere by complete concrete encasement. Concrete is complete concrete encasement. Concrete is designed in accordance with ACI standards and designed in accordance with ACI standards and monitored under the Structures Monitoring monitored under the Structures Monitoring Program.

Program. The drywell steel shell and the moisture The drywell steel shell and the interface at the barrier where the drywell shell becomes embedded drywell steel shell and concrete floor joint are in the drywell concrete floor are inspected in inspected in accordance with the Containment accordance with the Containment Inservice Inservice Inspection (IWE) Program and Structures Inspection (IWE) Program and Structures Monitoring Program. See Section 3.5.2.2.1.4.

Monitoring Program. See Section 3.5.2.2.1.4.

Table 3.5.2.1 Reactor Building and Structure and/or Component or Commodity: Structure and/or Component or Commodity:

Primary Containment (Page 3.5-64) Moisture Barrier Moisture Barrier Notes: E: Consistent with NUREG-1801 material, Notes: JAF does not have a moisture barrier at the environment, and aging effect but a different aging drywell shell and floor interface therefore this management program component is not applicable.

Page 2 of 5

ATTACHMENT 1

SUMMARY

OF INCORRECT AND CORRECTED INFORMATION PROVIDED DURING JAF LICENSE RENEWAL Letter, Entergy to USNRC, , Entergy Nuclear Operations, Inc. James A. FitzPatrick Nuclear Power Plant Docket No. 50-333, License No. DPR-59 License Renewal Application, Amendment 6 JAFP-07-0021, dated February 12, 2007 (Reference 2)

RAI 3.5.2-3 JAF Primary Containment Design JAF Primary Containment Design In Table 3.5.2-1 under Structure [] With regard to the inner surface of the drywell, [] With regard to the inner surface of the drywell, and/or Component or Commodity the gap seal between the concrete floor (Elevation the joint between the concrete floor (Elevation 256-Drywell shell, JAFNPP CII and 256-6) and the drywell shell is inspected for 6) and the drywell shell is inspected for Containment Leak Rate Programs functionality. There have been no discernible signs degradation. There is no significant degradation in are credited to manage the loss of of degradation in the sealant material or in the the concrete and steel surfaces in the area of the material due to general, pitting, and concrete and steel surfaces in the area of the seal. gap.

crevice corrosion. However, it was unclear to the staff how and when Operating Experience and Actions Taken to inspections were performed to Prevent Drywell Corrosion Operating Experience and Actions Taken to verify that there has been no [] The drywell shell to floor caulked seal is Prevent Drywell Corrosion observed leakage causing moisture inspected every refueling outage. A general visual [] The drywell shell to floor joint is inspected every in the vicinity of the sand cushion at examination is performed looking for cracking, refueling outage per surveillance test ST-15B and JAFNPP and no moisture has been peeling, delaminating or separation of the seal, once a period in accordance with the JAF IWE detected or is suspected on the discoloration in the caulking material, and flexibility Program. Since JAF does not have a moisture inaccessible areas of the drywell of the caulking. The caulk seal has not been barrier at the drywell shell to floor joint, augmented shell which would result in corrosion removed or replaced. examinations per ASME Section XI, IWE-1241(a) and wall and IWE-2500-1, E-C, Item Nos. E4.11 and E4.12 thinning. If conditions exist, the staff are performed once a period.

requests the applicant to address proposed license renewal interim staff guidance LR-ISG-2006-01, Plant Specific Aging Management Program for Inaccessible Areas of Boiling Water Reactor Mark 1 Steel Containment Drywell Shell, which was published in the Federal Register on May 9, 2006. Also, the staff requests the applicant to Page 3 of 5

ATTACHMENT 1

SUMMARY

OF INCORRECT AND CORRECTED INFORMATION PROVIDED DURING JAF LICENSE RENEWAL provide significant findings during the implementation of, and subsequent examinations to GL 87-05, Request for Additional Information-Assessment of Licensee Measures to Mitigate And/or Identify Potential Degradation of Mark I Drywells. pg 17 of 27 JAFP-07-0021 Attachment 1 Page 17 of 27 The referenced Sketch in this letter is not a contains a Sketch titled Primary Containment controlled plant document. The reference to a Detail which contains an arrow pointing to the CAULK SEAL with arrow should be deleted and the Drywell floor surface to shell interface at El. 256-6 Sketch should be used to represent sand cushion with the words CAULK SEAL. information only.

Letter, Entergy to USNRC, , Entergy Nuclear Operations, Inc. James A. FitzPatrick Nuclear Power Plant Docket No. 50-333, License No. DPR-59 License Renewal Application, Amendment 9 JAFP-07-0048, dated April 6, 2007. (Reference 3)

(JAFNPP AMP and AMR Database Audit Questions associated with moisture barrier.)

Audit Question #291: LR Response Revised LR Response LR Request The "Structures Monitoring Program", AMP The JAFNPP drywell does not have a moisture Section 3.5-8 AMR B.1.27.2 [Ref. LRA Table 3.5.2-1 Page 3.5-64], will barrier, therefore an AMP is not required for this Item 3.5.1 In Table 3.5.2-1 on manage aging effect of the drywell moisture barrier. component. The "Containment Leak Rate program",

page 3.5-64 of the LRA for Primary The "Containment Leak Rate program", AMP B.1.8 AMP B.1.8 [Ref. LRA Table 3.5.2-1 Page 3.5-64],

Containment Electrical Penetration [Ref. LRA Table 3.5.2-1 Page 3.5-64], will manage will manage aging effects of the Primary seals and sealant, the AMP shown aging effect of the Primary Containment Electrical Containment Electrical Penetration seals and is Containment Leak Rate. The Penetration seals and sealant. sealant.

applicant is asked to confirm that AMP CII-IWE will not be used to manage the aging of the moisture barrier.

Page 4 of 5

ATTACHMENT 1

SUMMARY

OF INCORRECT AND CORRECTED INFORMATION PROVIDED DURING JAF LICENSE RENEWAL Audit Question #294: LR Response Revised LR Response LR Request JAFNPP uses a moisture barrier to seal the joint JAFNPP does not have a moisture barrier to seal the Section 3.5-11 AMR between the containment drywell shell and drywell joint between the containment drywell shell and Item Number 3.5.1 Under the concrete floor. Moisture barrier is listed in LRA drywell concrete floor. JAFNPP does not seal the discussion column, it states that Table 3.5.2-1 as "moisture barrier". As indicated in joint, thus the Containment Inservice Inspection seals and gaskets are not included LRA Table 3.5.2-1, aging effects on the moisture (IWE) examination requirement for a moisture barrier in the Containment Inservice barrier will be managed under the "Structures does not apply. Augmented examinations of the Inspection Program at JAFNPP. Monitoring Program" (AMP B.1.27.1). The drywell floor to joint interface area are performed in One of the components for this item Structures Monitoring Program includes drywell accordance with IWE-1240 as part of the number is moisture barriers. interior inspections. Program inspections have Containment Inservice Inspection (IWE) Program.

Explain how JAFNPP seals the joint confirmed no visible evidence of water collection or between the containment drywell equipment leakage have been noted in the area of shell and the drywell concrete floor the moisture barrier caulk seal that would challenge if there is no moisture barrier. the capability of the seal. The moisture barrier was Explain why the inspection of this noted to be in good condition and capable of joint is not part of the Containment performing its design function to provide an Inservice Inspection (IWE) Program effective barrier to moisture from entering the at FitzPatrick? interface between the concrete floor and steel shell.

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