LR-N10-0316, Supplement to License Renewal Application
| ML102440675 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/26/2010 |
| From: | Davison P Public Service Enterprise Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LR-N10-0316 | |
| Download: ML102440675 (17) | |
Text
PSEG Nuclear LLC PO. Box 236, Hancocks Bridge, NJ 08038 0
PSEG Nuclear LLC AUG 26 2010 LR-N10-0316 10 CFR 50 10 CFR 51 10 CFR 54 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Salem Nuclear Generating Station, Unit No. 1 and Unit No. 2 Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272 and 50-311
Subject:
References:
Supplement to the Salem Nuclear Generating Station, Unit No. 1 and Unit No. 2 License Renewal Application
- 1. Letter from PSEG Nuclear to USNRC "Application for Renewed Operating Licenses - Salem Nuclear Generating Station, Unit No. 1 and Unit No. 2," dated August 18, 2009
- 3. Letter LR-N10-0244 from PSEG Nuclear to USNRC, responding to Various RAIs, dated July 15, 2010 PSEG Nuclear is providing this supplement to the Salem Nuclear Generating Station, Unit No. 1 and Unit No. 2 (Salem) License Renewal Application (LRA) to:
- 1. Provide corrections to the LRA that have been identified through internal project reviews and discussions with NRC license renewal staff (see Enclosure A);
- 2. Update the response to RAI B.2.1.38-01 (Reference 2) to provide clarifications requested by NRC staff in a teleconference held on July 22, 2010 (see Enclosure B);
- and,
- 3. Update the response to RAI 3.4.1-01 (Reference 3) to correct an administrative error in Table 3.1.2-4 (see Enclosure C).
This submittal has been discussed with the NRC License Renewal Project Manager for the Salem License Renewal project.
There are no other new or revised regulatory commitments contained in this letter.
If you have any questions, please contact Mr. Ali Fakhar, PSEG Manager - License Renewal, at 856-339-1646.
A-141~
Document Control Desk LR-N10-0316 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on J Z6( o Sincerely, Paul J. Davison Vice President, Operations Support PSEG Nuclear LLC AUG 26 2010
Enclosure:
A. Corrections to the Salem Unit No.1 and Unit No. 2 LRA B. Updated Response to RAI B.2.1.38-01 C. Corrected Table associated with response to RAI 3.4.1-01 cc:
Regional Administrator - USNRC Region I B. Brady, Project Manager, License Renewal - USNRC R. Ennis, Project Manager - USNRC NRC Senior Resident Inspector - Salem P. Mulligan, Manager IV, NJBNE L. Marabella, Corporate Commitment Tracking Coordinator H. Berrick, Salem Commitment Tracking Coordinator
Enclosure A LR-N10-0316 Page 1 of 7 Introduction This enclosure contains the descriptions of revisions made to correct errors or omissions identified subsequent to submittal of the License Renewal Application (LRA). For each revision the affected section, page, and paragraph of the LRA is provided and the change is described. If helpful for clarity, entire sentences or paragraphs from the LRA are provided with deleted text highlighted by strikethroughs and inserted text highlighted by bolded italics. Revisions to tables are shown by providing excerpts from the affected tables. Only the affected lines from the tables are provided.
Steam Generators Affected Section: Table 3.1.2-4 LRA Page Number: 3.1-143 Description of Change: LRA Table 3.1.2-4 addresses the aging effect and mechanism of loss of heat transfer due to fouling for the component type, Steam Generators (Tubes) in the Reactor Coolant (Internal) environment. This aging effect and mechanism for this environment on the internal side was inappropriately added to LRA Table 3.1.2-4 for the nickel alloy Steam Generator (Tubes), and is therefore deleted from LRA Table 3.1.2-4. The appropriate line items in Table 3.1.2-4 are maintained for the applicable aging effects and mechanisms. The aging effect and mechanism of loss of heat transfer due to fouling for the Steam Generators (Tubes) in the Treated Water (External) environment is correctly shown for the Salem Units 1 and 2 Steam Generators in LRA Table 3.1.2-4.
Due to the revision discussed above, LRA Table 3.1.2-4 is revised as follows:
Enclosure A LR-N10-0316 Page 2 of 7 Table 3.1.2-4 Steam Generators Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Notes Type Function Requiring Programs Vol. 2 Item Item Management S2 t G M te m Gen9rat a-T-t NiQek -Alo Reactor CWoolan Reuto of
-0HoatPA Steafm Generator Tube
.~tm I
fe--fe
-9..U-Ste~am Gene~ratr HtoA Tmnsfei N~e-~o Rator Coolant Reduction of Hea;t W;;te.-Gheme (hp4em~aI4T~F
Enclosure A LR-N110-0316 Page 3 of 7 Safety Injection System Affected Section: 3.2.2.1.3 LRA Page Number(s): 3.2-4 Paragraph: Aging Effects Requiring Management Description of Change: The LRA incorrectly included the aging effect and mechanism of loss of material due to erosion for the restricting orifices in the Safety Injection System. These restricting orifices are not in service continuously, in contrast to the event and operating conditions as described in the Licensee Event Report (LER) 50-275/94-023. The main function of the orifices in this system is to protect the safety injection pumps during surveillance testing that includes periods of high and low flow. These pumps are operated during surveillance testing and periodic refilling of the safety injection accumulators, which is typically a few hours every three months.
The list of aging effects on LRA page 3.2-4 for the Safety Injection System is revised to delete the aging effect and mechanism as shown below.
Aging Effects Requiring Management Less of Mate Fial/Erocion Chemical & Volume Control System Affected Section: 3.3.2.1.2 LRA Page Number(s): 3.3-5 Paragraph: Aging Effects Requiring Management Description of Change: The LRA incorrectly included the aging effect and mechanism of loss of material due to erosion for the restricting orifices in the Chemical & Volume Control System.
These restricting orifices are not in service continuously, in contrast to the event and operating conditions as described in the Licensee Event Report (LER) 50-275/94-023. The main function of the orifices is to protect the charging pumps during surveillance testing. These pumps are operated during surveillance testing and when the positive displacement pump is out of service for maintenance, which is typically a few hours every three months.
The list of aging effects on LRA page 3.3-5 for the Chemical & Volume Control System is revised to delete the aging effect and mechanism as shown below.
Aging Effects Requiring Management L0 of 1MPtr;,;!Ero on
Enclosure A LR-N10-0316 Page 4 of 7 Affected Section: 3.2.2.2.6 LRA Page Number(s): 3.2-9 Paragraph: Loss of Material due to Erosion Description of Change: The LRA incorrectly included the aging effect and mechanism of loss of material due to erosion for the restricting orifices in the Safety Injection System and Chemical
& Volume Control System. These restricting orifices are not in service continuously, in contrast to the event and operating conditions as described in the Licensee Event Report (LER) 50-275/94-023. The main function of the orifices is to protect the pumps during surveillance testing.
Section 3.2.2.2.6 is revised as shown below:
Item Number 3.2.1-12 is not applicable to Salem. Salom will implomont the Water Chemistry program, 1.2.1.2, to manage the loss of material duo tor*oin,, in. the stainless steel charging pump mFini floW rocirculation orifice fin the Che-micl Volumo Control Syteom. The high-pressure charging pumps are not used for normal charging flow, unless the positive displacement pump is out of service for maintenance. The positive displacement pump does not ha,-e flew through utilize the recirculation orifices. Therefore, an inspection of the orifices is not warranted to manage the aging effect of erosion on the mini-flow recirculation orifices. The Water heffmitry' p*roramn i6 described in Apperndix B.
The Safety Injection System also has mini-flow recirculation orifices, but they only have flow going through them a few hours every quarter for surveillance testing.
Therefore, an inspection of the orifices is not warranted to manage the aging effect of erosion on these restricting orifices.
Affected Section: 3.2, 3.3 LRA Page Number(s): 3.2-16, 3.2-48, 3.2-53, 3.3-135, 3.3-141 Paragraph: Table 3.2.1, Table 3.2.2-3, Table 3.3.2-2 Description of Change: Due to the revisions discussed above, Table 3.2.1, Table 3.2.2-3, and Table 3.3.2-2 are revised as shown below. Included in this revision is the deletion of Water Chemistry Program for this aging effect.
Enclosure A LR-N10-0316 Page 5 of 7 Table 3.2.1 Summary of Aging Management Evaluations for the Engineered Safety Features Item Component Aging Aging Further Discussion Number Effect/Mechanism Management Evaluation Programs Recommended 3.2.1-12 Stainless steel high-Loss of material A plant-specific Yes, plant-Not Applicable.
pressure safety due to erosion aging specific injection (charging) management The WateItr Chemistry program, 9.2.1.2, will pump miniflow orifice program is to be be u..s.d to manage the loss of material du, o exposed to treated evaluated for to eroi in th tainle stool high-borated water erosion of the pressure charging pump.Min*
-flQo...
orifice due to rcfirfice.
exposed to troatod extended use of borated wator en'ironment.
the centrifugal HPSI pump for See Subsection 3.2.2.2.6.
normal charging.
Enclosure A LR-N1O-0316 Page 6 of 7 Table 3.2.2-3 Safetv Iniection System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Notes Type Function Requiring Programs Vol. 2 Item Item Management Restricting GOr ThrQ#tI Stainless Steol Treated Berated Wattr Loss of.Material/Eroson Water 4---1-4 3s21-4P Rertricting OrF Thr-ttle StanleAss ;Stoo Treated Borated Water Loss of Mhateri;al/Erosion W;Ah C4D-14 3
E,6 4eAd}
__h8~itF 1
V Plant Specific Notes:
6 NU REG-80 iRol eriffies a plant 5snncifiG
-ir'l...^ *_^
"r:__^
i.....
¢:A--
^-1 A I~l.L.^
t"l-^
^.-
r]riJrit*IIFL I Ilt-i.2IIt-~
I IrIItJ IrILLJLIt:Iit]II LII:JUI:JlII :11 iii ~.xiiur '.j Iul:IItLI~ uI..uI1,I:
VI I IV I I*
I VV I V*V tr
,i l,
l T h e O n li HU
.ff d*
__W aro ucoci ;Eo m:anago the aging OTTOC(s) appiicaboio toI GiGcmpnPGent type, matoral, ana A-nvi F-MRIAnm!ent RB Roiatiln v
v v
Thhl* 2 9__-9 C~h~mir~Rl R1 VnlIJmA t~nntrol 5~v~tAm Component Intended Material Environment Aging Effect Aging NUREG-1801 Table 1 Item Notes Type Function Requiring Management Vol. 2 Item Management Progrrams RstriGting Orfi Th#Stainle Ste Treated BeratAd Water Loss of WMtrialrErosion Watee V D-1-4 211:2 Plant Specific Notes:
rNi K1D1 1mr2-!
n IO
ý n'r -feen nn n
-nwinr "T-L _
tAI--Z=--
!--L--_
rrr u, n tn nrnnr-]
iF I U%
n n
m lfn it' nM 1 TnnE I
G nn
- TT*GP I
applicable to this com*o**et typo, material, anrd..n.ironm
.t combinatin.
Enclosure A LR-N1 0-0316 Page 7 of 7 Time-Limited Aging Analyses Affected Section: Table 4.1-1, Section 4.3, Section 4.3.2, Appendix A (Section A.4.3.2)
LRA Page Numbers: 4-4, 4-22, 4-32, 4-33, A-40, and A-41 Paragraphs: All Description of Change: In discussions with the Staff, and upon further review, there are no Time-Limited Aging Analyses (TLAAs) associated with the Salem Pressurizer Safety Valves and Pilot-Operated Relief Valves since the design analyses associated with these valves do not meet all of the criteria listed in 10 CFR 54.3(a); therefore, they are not defined as TLAAs. As part of the detailed TLAA documentation search, Salem found Westinghouse design specifications for component cycles associated with the valves. These design specifications do not consider the effects of aging of the valves, and would not have normally been considered as TLAAs, because they do not meet Criterion 2 listed in 10 CFR 54.3(a), (i.e., the analyses do not consider age-related degradation effects). The LRA conservatively identified these analyses as TLAAs, evaluated the projected number of cycles associated with the valves' operations, and dispositioned the TLAAs as "Validation, 10 CFR 54.21 (c)(1)(i)". Therefore, the applicable sections are deleted to remove the analyses associated with the valves as TLAAs. LRA Sections 4.3.2 and A.4.3.2 are deleted. As a result of deleting these TLAAs, the line item associated with the Pressurizer Safety Valves and Pilot-Operated Relief Valves Fatigue Analyses listed in LRA Table 4.1-1, 'Time-Limited Aging Analyses Applicable to Salem" is deleted. Also, in Section 4.3, page 4-22, the second bulleted line item, Pressurizer Safety Valves and Pilot-Operated Relief Valves Fatigue Analyses, is deleted.
4.3.2 Pressurizer Safety Valve and Pilot-Operated Relief Valve Fatigue Analyses This section is deleted.
A.4.3.2 Pressurizer Safety Valve and Pilot-Operated Relief Valve Fatigue Analyses This section is deleted.
Enclosure B LR-N10-0316 Page 1 of 5 Note: This response is a complete replacement (response text only - Appendix A and B and License Renewal A.5 Commitment List are not repeated here) for the response to RAI B.2.1.38-01 that was provided in PSEG Letter LR-N10-0225, dated July 8, 2010.
RAI B.2.1.38-01
Background:
GALL AMP XI.E3, states that the program applies to inaccessible medium voltage cables that are exposed to significant moisture simultaneously with significant voltage. Significant moisture is defined as periodic exposures to moisture that lasts for more than a few days. GALL AMP XI.E3 also states that periodic actions are taken to prevent cables from being exposed to significant moisture. GALL AMP XI.E3 further states that inspection for water collection should be performed based on actual plant experience with water accumulation in the manhole with an inspection frequency of at least every two years.
Issue:
The applicant identified operating experience and the staff confirmed through walkdowns and operating experience review, cases of inaccessible medium voltage cable exposure to significant moisture (cable submergence in manholes/vaults) and cable support structural degradation inconsistent with GALL AMP XI.E3 (i.e., periodic actions are taken to prevent cables from being exposed to significant moisture). A review of operating experience does not provide information on in-scope inaccessible medium voltage station blackout (SBO) recovery cable testing results or manhole/vault inspections. SBO cables in-scope of license renewal including direct buried portions may also be exposed to significant moisture.
Requests:
a) Describe how SNGS LRA AMP B.2.1.38 meets GALL AMP XI.E3 for in-scope inaccessible medium voltage SBO recovery cables considering that operating history shows that in-scope inaccessible medium voltage SBO recovery cable are exposed to significant moisture (i.e.
exposure lasting more than a few days).
b) In addition, (i) describe how plant operating experience was incorporated into AMP B.2.1.38 to minimize exposure of in-scope inaccessible medium voltage SBO recovery cables to significant moisture during the period of extended operation, (ii) discuss any corrective actions taken that address submerged cable conditions identified through manhole/vault inspections, (iii) discuss cable testing/frequency and applicability that demonstrates that in-scope inaccessible medium voltage SBO recovery cables will continue to perform their intended function during the period of extended operation.
Enclosure B LR-N10-0316 Page 2 of 5 PSEG Response:
a) The Salem LRA Appendix B, Section B.2.1.38 - "Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements", is a new program that is currently in the process of being implemented at Salem. This program includes (1) testing of in-scope, inaccessible medium voltage cables subject to significant moisture and significant voltage and (2) inspection of cable manholes, including subsequent pumping of accumulated water, if required, as a preventive measure to minimize the potential exposure of in-scope cables to significant moisture. There is no direct buried medium voltage cable in-scope for license renewal.
The current plan is to take actions during the current licensing period to establish the conditions necessary to implement Salem LRA AMP B.2.1.38.
Current Licensing Period Activities Specifically, Salem will perform cable testing of the in-scope SBO recovery cables during their associated transformer outages. The first test is planned for April, 2011. The current plan is to test the in-scope SBO recovery cables periodically during their associated transformer outages. The cable test frequency may be adjusted based on data trending.
Additional discussion related to the in-scope SBO recovery cable testing is provided in response to item b(iii) below.
Plant-specific operating experience has identified cable manhole and cable pit water accumulation resulting in exposure of the in-scope SBO recovery cables to significant moisture. This condition was reported and evaluated in the Corrective Action Program.
Based on this identified operating experience and in accordance with the Corrective Action Program, Salem has commenced periodic (12 months) inspections of the in-scope SBO recovery cable manholes, and removing accumulated water as required to monitor the in-scope SBO recovery cables. The cable pits will be inspected during their associated transformer outages.
Salem LRA AMP B.2.1.38 Implementation Plan Prior to the period of extended operation, additional SBO recovery cable manhole and cable pit inspections will be performed and the frequency of inspections for accumulated water will be adjusted based on inspection results to ensure that the in-scope SBO recovery cables are not exposed to significant moisture. The maximum time between inspections will be no longer than two years, which meets the recommended frequency in GALL AMP XI.E3.
Additional discussion related to the SBO recovery cable manhole and cable pit inspections is provided in response to item b(i) below.
The Salem LRA AMP B.2.1.38 meets GALL AMP XI.E3 for the in-scope SBO recovery cables because prior to the period of extended operation, cable tests will be periodically performed (not to exceed ten years) and, prior to the period of extended operation, the frequency of inspections for accumulated water will be established (not to exceed two years) based on inspection results to ensure that the in-scope SBO recovery cables are not exposed to significant moisture during the period of extended operation.
Enclosure B LR-N10-0316 Page 3 of 5 The Salem LRA Appendix A, Section A.2.1 38 and Appendix B, Section B.2.1.38 are revised as a result of the clarification described above, as shown in Enclosure A of this letter. The Salem LRA Table A.5 Commitment List, line item 38, is revised as a result of the clarification described above, as shown in Enclosure B of this letter.
b) Additional questions:
(i) The Salem LRA AMP B.2.1.38 is a new program that meets GALL AMP XI.E3. GALL AMP XI.E3 states, in part, "in this aging management program, periodic actions are taken to prevent cables from being exposed to significant moisture, such as inspecting for water collection in cable manholes, and draining water, as needed."
Current Licensing Period Activities Specifically, there are eight (8) manholes and thirteen (13) cable pits where in-scope medium voltage SBO recovery cables can be inspected for water submergence. SBO recovery manhole inspections were conducted in March, 2010. The manhole inspections identified submerged cables and were subsequently dewatered. This condition was reported and evaluated in the Corrective Action Program. The cable pits will be inspected during their associated transformer outages. The next transformer outage is scheduled in April, 2011.
As a result of this operating experience, actions have been initiated to establish recurring tasks to open, inspect, and dewater SBO recovery cable manholes and cable pits, as required to monitor the in-scope SBO recovery cables. The switchyard cable manhole configuration enables the cable condition to be assessed as a result of rain or other event driven occurrences as directed by station procedures (e.g. hurricane, tropical storm, or coastal flooding warning issued for the site area will prompt the inspection and assessment of the cable manholes / pits for accumulated water). Results of the inspections and dewatering activities will be monitored to ensure that the in-scope SBO recovery cables are not exposed to significant moisture. Trending and characterizing the water intrusion rate allow for adjustments to the SBO recovery cable manhole and cable pit inspection freqUen y (not to exceed two years) in accordance with the Corrective Action Program.
Salem LRA AMP B.2.1.38 Implementation Plan The current licensing period activities and lessons learned will be used to implement the Salem LRA AMP B.2.1.38, Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, prior to the period of extended operation.
Specifically, prior to the period of extended operation, additional SBO recovery cable manhole and cable pit inspections will be performed and the frequency of inspections for accumulated water will be adjusted based on inspection results to ensure that the in-scope SBO recovery cables are not exposed to significant moisture. The maximum time between inspections will be no longer than two years, which meets the recommended frequency in GALL AMP XI.E3.
Enclosure B LR-N10-0316 Page 4 of 5 This description demonstrates how plant operating experience was incorporated into Salem LRA AMP B.2.1.38 to minimize exposure of in-scope inaccessible medium voltage cables to significant moisture during the period of extended operation.
(ii) In March 2010, all eight (8) manholes containing inaccessible medium voltage SBO recovery cables were inspected for accumulated water.
The manhole inspections identified submerged cables. The manholes were dewatered.
This condition was reported and evaluated in the Corrective Action Program. The current plan is to provide drainage for in-scope medium voltage SBO recovery cable manholes.
No cable defects or conditions adverse to quality were observed for any cables within these manholes, thus no corrective actions are required regarding the cables.
No concrete related issues or conditions adverse to quality were observed within the manholes, thus no corrective actions are required regarding the manhole structure.
The cover and cover support steel for Manhole MH-1 and MH-1A were found rusted.
There was no structural degradation. The conditions were reported in the Corrective Action Program. Repairs to the cover and cover support steel are planned for May 2011.
(iii) As stated in Salem LRA Appendix B, Section B.2.1.38, all "in scope, non-EQ, inaccessible medium voltage cables subject to significant moisture and voltage will be tested as part of this aging management program. These medium voltage cables will be tested using a proven test for detecting deterioration of the insulation system due to wetting, such as power factor, partial discharge, or polarization index, as described in EPRI TR-103834-P1-2, or other testing that is state-of-the-art at the time the test is performed. Cable testing will be performed at least once every ten years. The first tests will be completed prior to the period of the extended operation." This includes the in-scope inaccessible medium voltage SBO recovery cables.
Current Licensing Period Activities Operating experience shows that there have been no in-scope inaccessible medium voltage cable failures at Salem. Salem is planning to perform tan-delta cable testing.
The current plan is to test the SBO recovery cable every three years during the Station Power Transformer outages. Testing will continue to be conducted periodically to trend and characterize the SBO recovery cable insulation condition. The first in-scope SBO recovery cable tests are planned for April, 2011. The cable test frequency may be adjusted based on data trending in accordance with the Corrective Action Program.
Salem LRA AMP B.2.1.38 Implementation Plan The current licensing period activities and lessons learned will be used to implement the Salem LRA AMP B.2.1.38, Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, prior to the period of extended
Enclosure B LR-N10-0316 Page 5 of 5 operation. Specifically, the cable test frequency may be adjusted based on data trending, however, not to exceed ten years.
This discussion demonstrates how the cable testing/frequency will provide reasonable assurance that the intended functions of inaccessible medium-voltage cables that are not subject to the environmental qualification requirements of 10 CFR 50.49 and are exposed to adverse localized environments caused by moisture will be maintained consistent with the current licensing basis through the period of extended operation.
Enclosure C LR-N10-0316 Page 1 of 3 Note: The response to RAI 3.4.1-01 was provided to NRC in PSEG Letter LR-N10-0244, dated July 15, 2010. Table 3.1.2-4 was provided as part of the response; however, information was "cut off' at the right edge of the table in that response. Therefore, the entire response is provided again here, with the corrected Table 3.1.2-4 included. All other information remains unchanged.
RAI 3.4.1 -01
Background:
The SRP-LR, Table 3.4-1, item 16, states that stainless steel piping, piping components, piping elements, tanks, and heat exchanger components exposed to treated water are subject to loss of material due to pitting and crevice corrosion. The GALL Report, under item VIII.B1 -4, recommends managing the aging effect using the Water Chemistry and One-Time Inspection Programs.
Issue:
The Salem Nuclear Generating Station LRA Table 3.1.2-4 indicates that stainless steel steam generator tube support plates exposed to treated water greater than 140 OF can undergo loss of material due to pitting and crevice corrosion, and the Steam Generator Tube Integrity and Water Chemistry Programs will be used to manage this aging effect. The AMR line items cite generic note E, indicating that they are consistent with the GALL Report item for material, environment and aging effect, but a different aging management program is credited. The LRA references Table 3.4.1, item 3.4.1-16 and GALL Report item VIII.B1-4 for consistency with the GALL Report. However, GALL Report item VIII.B1-4 recommends managing the aging effect using the Water Chemistry Program augmented by the One-Time Inspection Program to verify the effectiveness of the chemistry control program.
Request:
Clarify how the AMR line items in LRA Table 3.1.2-4 for tube support plates loss of material due to pitting and crevice corrosion are consistent with the GALL Report item VIII.B1-4 for piping, piping components, and piping elements and provide a basis for the adequacy of the Steam Generator Tube Integrity Program to verify the effectiveness of the Water Chemistry Program for these components.
PSEG Response:
Salem selected GALL Report item VIII.B1-4 (piping, piping components, and piping elements) since the stainless steel component type Steam Generators (Tube Support Plates) was subjected to the treated water > 140°F environment, and therefore considered this material, environment, and aging effects combination most closely aligned to this item number. Salem had substituted the Steam Generator Tube Integrity aging management program (Salem LRA Appendix B, Section B.2.1.10) for the One-Time Inspection aging management program (Salem LRA Appendix B, Section B.2.1.20) in Table 3.1.2-4, "Steam Generators", since this aging management program inspects the Steam Generator tube support plates during refueling
Enclosure C LR-N10-0316 Page 2 of 3 outages. However, to be consistent with the GALL Report item VIII.B1 -4, Salem will use the One-Time Inspection aging management program for inspections of the Steam Generator tube support plates to verify the effectiveness of the Salem Water Chemistry aging management program (Salem LRA Appendix B, Section B.2.1.2).
LRA Table 3.1.2-4, Page 3.1-143, "Steam Generators", is revised as follows:
Enclosure C LR-N10-0316 Page 3 of 3 Table 3.1.2-4 Steam Generators Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Notes Type Function Requiring Programs Vol. 2 Item Item Management Steam Generators Structural Support Stainless Steel Treated Water Loss of Material/Pitting Steam Generator Tubh VIII.B1-4 3.4.1-16 (Tube Support (External) > 140 F and Crevice Corrosion ltegi4ty C
Plates)
One-Time Inspection