ML053110080

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Response to Generic Letter 2004-01, Requirements for Steam Generator Tube Inspections
ML053110080
Person / Time
Site: Salem PSEG icon.png
Issue date: 11/28/2005
From: Stewart Bailey
Plant Licensing Branch III-2
To: Levis W
Public Service Enterprise Group
Bailey S N
References
GL-04-001, TAC MC4848
Download: ML053110080 (7)


Text

November 28, 2005 Mr. William Levis Senior Vice President & Chief Nuclear Officer PSEG Nuclear LLC - X04 Post Office Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

SALEM NUCLEAR GENERATING STATION, UNIT NO. 2 - RESPONSE TO GENERIC LETTER 2004-01, REQUIREMENTS FOR STEAM GENERATOR TUBE INSPECTIONS (TAC NO. MC4848)

Dear Mr. Levis:

On August 30, 2004, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2004-01, Requirements For Steam Generator Tube Inspections. The purpose of GL 2004-01 was to obtain information that would enable the NRC staff to determine whether licensees steam generator (SG) tube inspection programs comply with the existing tube inspection requirements (the plant technical specifications, in conjunction with Appendix B to Part 50 of Title 10 of the Code of Federal Regulations).

By letter dated October 29, 2004, PSEG Nuclear, LLC (PSEG) responded to GL 2004-01 for Salem Nuclear Generating Station (Salem), Unit Nos. 1 and 2. The staffs review of your response to the GL did not identify any concerns with the inspection practices employed at Salem, Unit No. 1. The staff, therefore, concluded that your SG tube inspection practices for Salem, Unit No. 1 are in compliance with the existing tube inspection requirements. By letter dated June 30, 2004, the NRC staff closed out its review of GL 2004-01 for Salem, Unit No. 1.

For Salem, Unit No. 2, PSEG determined that the tube inspection practices were not consistent with the NRCs position with respect to inspections within the hot-leg tubesheet, and this issue was entered into the corrective action process. By letter dated June 23, 2005, PSEG committed to submit a license amendment request to remove the inconsistency. This license amendment request was submitted by letter dated September 21, 2005, and is currently under staff review. As discussed in the enclosed evaluation, the NRC staff concludes that your overall response to GL 2004-01 is acceptable. This completes the staffs efforts under TAC MC4848.

W. Levis If you have any questions regarding this matter, please contact me at (301) 415-1321.

Sincerely,

/RA/

Stewart N. Bailey, Senior Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-311

Enclosure:

As stated cc w/encl: See next page

W. Levis If you have any questions regarding this matter, please contact me at (301) 415-1321.

Sincerely,

/RA/

Stewart N. Bailey, Senior Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-311

Enclosure:

As stated cc w/encl: See next page Distribution:

Public PKlein LLund MBanerjee CRaynor DRoberts LPLI-2/RF MYoder SBailey ECobey ADAMS Accession No.: ML053110080

  • Memo provided; no substantive changes made.

Office NRR/LPLI-2/PM NRR/LPLI-2/LA EMCB/SC*

NRR/LPLI-2/BC Name SBailey CRaynor LLund DRoberts Date 11/17/05 11/15/05 07/28/2005 11/28/05 OFFICIAL COPY

Salem Nuclear Generating Station, Unit No. 2 cc:

Mr. Michael Gallagher Vice President - Eng/Tech Support PSEG Nuclear P.O. Box 236 Hancocks Bridge, NJ 08038 Mr. Dennis Winchester Vice President - Nuclear Assessment PSEG Nuclear P.O. Box 236 Hancocks Bridge, NJ 08038 Mr. Thomas P. Joyce Site Vice President - Salem PSEG Nuclear P.O. Box 236 Hancocks Bridge, NJ 08038 Mr. Darin Benyak Director - Regulatory Assurance PSEG Nuclear - N21 P.O. Box 236 Hancocks Bridge, NJ 08038 Mr. George H. Gellrich Plant Support Manager PSEG Nuclear P.O. Box 236 Hancocks Bridge, NJ 08038 Jeffrie J. Keenan, Esquire PSEG Nuclear - N21 P.O. Box 236 Hancocks Bridge, NJ 08038 Lower Alloways Creek Township c/o Mary O. Henderson, Clerk Municipal Building, P.O. Box 157 Hancocks Bridge, NJ 08038 Dr. Jill Lipoti, Asst. Director Radiation Protection Programs NJ Department of Environmental Protection and Energy CN 415 Trenton, NJ 08625-0415 Mr. Brian Beam Board of Public Utilities 2 Gateway Center, Tenth Floor Newark, NJ 07102 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspector Salem Nuclear Generating Station U.S. Nuclear Regulatory Commission Drawer 0509 Hancocks Bridge, NJ 08038 Mr. Carl J. Fricker Plant Manager PSEG Nuclear - N21 P.O. Box 236 Hancocks Bridge, NJ 08038

Enclosure EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RESPONSE TO NRC GENERIC LETTER 2004-01 PSEG NUCLEAR LLC SALEM NUCLEAR GENERATING STATION, UNIT NO. 2 DOCKET NO. 50-311 On August 30, 2004, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2004-01, Requirements For Steam Generator Tube Inspections. The purpose of GL 2004-01 was to obtain information that would enable the NRC staff to determine whether licensees steam generator (SG) tube inspection programs comply with the existing tube inspection requirements the plant Technical Specifications (TSs) in conjunction with Appendix B to Title 10 of the Code of Federal Regulations (10 CFR) Part 50.

Licensees who concluded that their SG tube inspections have not been or are not being performed consistent with the NRCs position on the requirements in the TSs, in conjunction with Appendix B of 10 CFR Part 50, were requested to submit a safety assessment. As part of this safety assessment, licensees were to address whether their safety bases for limiting inspections within the tubesheet constitutes a change to the method of evaluation for establishing the structural and leakage integrity of the tube-to-tubesheet joint. The NRC staff requested this information since it was expected that licensees safety bases relied on a mechanical expansion joint rather than the tube-to-tubesheet weld. Since the original tube-to-tubesheet joint was most likely designed by demonstrating that the stresses in the tube, weld, and tubesheet satisfy the allowable stress values in Section III of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), or other similar standard, the staff questioned whether the safety basis for limiting inspections relied on demonstrating that the expansion joint satisfied some criteria (e.g., minimum tube pullout load criteria, allowable leakage) beyond those specified in Section III of the ASME Code.

By letter dated October 29, 2004, (Agencywide Documents Access and Management System (ADAMS) Accession Number ML043140237) as supplemented by letter dated June 23, 2005, (ML051880061) PSEG Nuclear LLC (PSEG), the licensee for Salem Nuclear Generating Station, Unit No. 2, submitted a response to GL 2004-01. In the response, PSEG concluded that the safety basis used to support the tube inspection practices does not constitute a change to the method of evaluation. The safety basis, used to support a conclusion that flaws located a certain distance below the top of the tubesheet do not have any safety implications, relies on a mechanical interference fit between the tube and the tubesheet for establishing the tube-to-tubesheet joint (i.e., forming the reactor coolant pressure boundary). However, for many plants (if not all), the original design of the SG gave no credit for this interference fit since the weld between the tube and the tubesheet ensured the integrity of the tube-to-tubesheet joint. In fact, the design rules (Section III of the ASME Code) do not address the use of an interference fit for maintaining pressure boundary integrity.

Although PSEG did not provide the basis for its conclusion that the safety assessment does not constitute a change in the method of evaluation, the NRC staff concludes that PSEGs overall response to GL 2004-01 is acceptable. This conclusion is based on PSEG acknowledging that the tube inspection practices were not consistent with the NRC staff position, and entering this issue into the plants corrective action program.

In the June 23, 2005, response to the NRC staffs request for additional information, PSEG committed to submit a license amendment request to remove the inconsistency. This license amendment request was submitted by letter dated September 21, 2005, and is currently being reviewed by the NRC staff.

Principal Contributor: P. Klein Date: November 28, 2005