ML091180329
| ML091180329 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 04/10/2009 |
| From: | - No Known Affiliation |
| To: | Division of License Renewal |
| References | |
| Download: ML091180329 (5) | |
Text
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.docA summary of the 3/30/09 conference call is attached.
<<Summary of 3-30-09 Conference Call with NRC.doc>>
Hearing Identifier: Prairie_Island_NonPublic Email Number: 1007 Mail Envelope Properties (7A9B2084CC9CEC45828E829CBF20D638033F6C0E)
Subject:
Summary of 3-30-09 Conference Call with NRC Sent Date: 4/10/2009 10:34:25 AM Received Date: 4/10/2009 10:34:33 AM From: Eckholt, Gene F.
Created By: Gene.Eckholt@xenuclear.com Recipients: "Vincent, Robert" <Robert.Vincent@xenuclear.com>
Tracking Status: None "Richard Plasse" <Richard.Plasse@nrc.gov>
Tracking Status: None Post Office: enex02.ft.nmcco.net
Files Size Date & Time MESSAGE 114 4/10/2009 10:34:33 AM Summary of 3-30-09 Conference Call with NRC.doc 38976 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:
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 Lindber g, 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 ex ception 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 inspecti ons 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 R ubber in Fuel Oil Environment
The LRA indicates natural rubber is us ed in a fuel oil or lubricating oil environment, but natural rubber is not resist ant to oil. The reviewer asked how aging of the rubber would be managed.
PINGP explained that during the AMR process, ce rtain rubber hoses were identified as being made of natural rubber by default when the actual materials were not readily available. This wa s 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 t he day tanks are raised and may be accessible for UT thickness testing on their bottom surf aces. 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 interi ors were not accessible for inspection.
The clean leakage collection tanks collect cl ean fuel oil from t he 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 t he engine, and the resulting dirty o il is disposed of as waste.
PINGP agreed to supplement the discussi on 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 init iate annual testing of fuel oil for particulates, but GALL recommends quarte rly testing. The basis for annual particulate testing appears to be that prev ious sediment testing has not found particulates. The reviewer indicated that annual testing may be sufficient as long as sediment testing and particulate testi ng show that fuel oil continues to be clean without particulates.
Clarification was requested, how ever, to state that in the event significant sediment or part iculates 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 turbi ne 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 te st 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 LR A 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 ro tor 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 ro tor failure is performed for information.
PINGP understands the question and will provide a clarification in a supplemental letter. An RAI will not be issued.