LR-N09-0140, Supplement to Response to Request for Additional Information Regarding Request for Examinations and Tests of Snubbers

Supplement to Response to Request for Additional Information Regarding Request for Examinations and Tests of Snubbers

ML091940397
Person / Time
Site:	Hope Creek
Issue date:	06/25/2009
From:	Keenan J Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LR-N09-0140
Download: ML091940397 (4)

Text

PSEG Nuclear LLC P.O. Box 236, HancocksBridge,.NJ 08038-0236 0 PSEG Nuclear L.L. C.

10 CFR 50.55a LR-N09-0140 June 25, 2009 U.S. Nuclear Regulatory Commission

• ATTN:.Document Control Desk Washington, DC .20555-0001 Hope Creek Generating Station Facility.Operating License No. NPF-57 NRC .Docket'No. 50-354

Subject:

Supplement to Response to.Request for Additional Information Regarding Relief Request for 'Examinations and Tests of Snubbers

References:

1) Letterfrom George P. 'Barnes (PSEG NucleariLLC) to USNRC, "Relief Request forThird Interval Inservice Inspection -Program for

'Examinations and Tests.of-Snubbers and Associated License Amendment Request," -dated July.30, .2008

2) Letter from Jeffrie Keenan (PSEG Nuclear LLC) to USNRC, "Response to Request for Additional Information Regarding Relief Request for

'Examinations and Tests of Snubbers,"' dated -June -11, 2009 In-Reference 1, -PSEG-Nuclear.LLC (PSEG) submitted relief request HC-13R-04 and-an

.associated license amendment request-for Hope Creek Generating Station (HCGS)

'related.to examinations and 'tests for snubbers. 'The relief request proposed an

alternative 'to-the requirements -of the-American Society of 'Mechanical Engineers (ASME) Code for Operation and Maintenance of NuclearPower.Plants for snubber operational readiness testing. In Reference 2,-PSEG provided additional information concerning-the relief request.

Attachment 1 to this .letter .provides clarifications .to the information provided -in Reference 2.

There .are no'commitments contained in-this letter.

Dqk7

4i

,LR-N09-0140 June 25, 2009 Page2 Should you have any questions regarding this submittal, please contact Mr. Paul Duke at 856-339-1466.

Sincerely, Manager - Licensing PSEG Nuclear.LLC Attachment

1. Supplement to Response to Request for Additional Information cc: S. Collins, Regional Administrator.-NRC Region I R. Ennis, Project Manager-- USNRC NRC Senior Resident Inspector- Hope Creek

-P. Mulligan, Manager IV, NJBNE LR-N09-0140

'Page 1 of 2 SUPPLEMENT TO RESPONSE TO REQUEST-FOR ADDITIONAL INFORMATION RELATED TO RELIEF REQUEST HC-13R-.04 FORTHIRD TEN-YEAR INSERVICE INSPECTION INTERVAL HOPE CREEK GENERATING :STATION DOCKET NO. 50-354

!By letter dated July 30, 2008, as supplemented by letters dated January 30, :and February 6, 2009 (Agencywide Documents Access and Management System (ADAMS)

Accession Nos. ML082200316, ML090490674, and ML090560538 respectively), PSEG Nuclear LLC (PSEG or the licensee) submitted relief request HC-13R-04 and an associated license amendment request-for Hope Creek Generating Station (HCGS) related to examinations and tests for snubbers. With respect to relief request HC-13R-04, PSEG -requested relief from certain requirements specified in the American Society of Mechanical Engineers Boiler (ASME) Code for Operation.and Maintenance of Nuclear Power Plants (OM)-for thethird inservice inspection (ISI) interval at HCGS.

!By letter dated June 11, 2009 PSEG.provided :additional information concerning the

-reliefrequest. In response -to a request from the NRC staff, the following information is

-provided as clarifications to information contained 'in the June 11, .2009 letter.

1. In Response to RAI # 1.b, second paragraph, fourth line, PSEG states that "The most recent series of tests conducted during RF15 in the'sping of 2009 resulted in 55 acceptable tests, and no unacceptable tests on :snubbers." Whereas in

-response to RAI#41.c, first paragraph, PSEG-states that "There have -been eight

-testcampaigns successfully completed using the.sample plan described in Technical Specification Surveillance Requirement 47.5.e.2 (similar-to-the 37 sample plan from ISTD)."

Please clarify the number of snubbers tested or sample plan used (37.snubber

-plan or-different 55 plan) during -RF15,at Hope Creek.

Response

-Hope Creek tested .:55snubbers during -RF1"5, in anticipation of implementing the proposed .alternative during RF16. -There were no operational readiness test failures amongthe 55 snubbers tested. Upon authorization of the proposed alternative, PSEG plansto extend the test interval to two .cycles (i.e., -bypass a test campaign -at RF16), -based on the successfully completed test campaigns

.during RF!.3, RF14 .and RF15.

The'RF 15-total consisted .of 37 snubbers to -satisfy current-Technical Specification (TS) Surveillance 'Requirement-4-.7:5.:e.2; -15 .additional snubbers to satisfy OM N-15,Table .1, Column A; :two-non-TS -snubbers; and a :snubber found LR-N09-0140 Page.2 of.2 to have an empty fluid reservoir (described in the response to RAI l.a in PSEG's letter dated June 11,2009).

2. InResponse-to RAI#1.:b, second paragraph, eighth line, PSEG statesthat

"'During -the past .eight fuel cycles, visual examinations have been conducted in

,accordance with the -schedule specified in HCGS Technical Specification Table 47.5-:1 (similar-to Table ISTD-4252-1) on all accessible and inaccessible snubbers." Whereas in response to RAI # 5, fourth line, it states that "PSEG will continue to perform approximately half of the visual examinations during each fuel cycle (accessible/inaccessible)."

Please verify the difference in these statements. Table ISTD-4252-1 allows the, licensee-to skip the visual examination-based on snubbers' performance. Please

-explain and verify, if PSEG is planning to use a different approach (half of the visual examination of snubbers during each -cycle) for visual examination than as required by ISTD Table-4252-1.

-Response PSEG currently performsthe HCGS accessible-and inaccessible.snubber visual

-examinations during alternating refueling outages. This results in approximately

-one half of-the snubber population -being examined -each -refueling outage. Visual examinations Will be performed in accordance with the requirements ofTable ISTD-4252-1 of Subsection ISTOD. However, when Table ISTD-4252-:1 permits the-examination interval to be extended -to:two-fuel cycles, :PSEG -plans-to continue-the current practice of performing visual examinations on the accessible

-and inaccessible snubbers during alternating refueling outages.

.3. PSEG's RAI response indicates that TS23/4.7.5 is still being used for snubber examination -and testing at Hope Creek, -which was authorized via Relief Request HC-1-3R-02 for-its :third 10-year interval.-program.

When -is -PSEG planning to convert-Hope Creek's third year interval program to ISTD to make use of requirements~as-specified in Code Case OMN-15?

Response PSEG plans to adoptSubsection ISTD -upon -implementation of-the license

.-amendment -adding .Limitin.g Condition for Operation (LCO) -3.0.8-and relocating TS 3/47 .5-tothe HCGS-Technical Requirements Manual (TRM). Upon

-implementation of the license amendment, PSEG will -make appropriate changes

• to-the'TRM reflecting -adoption of Subsection ISTD.