ML063450192

Request for Additional Information Amendment Request to Implement TSTF-449

ML063450192
Person / Time
Site:	Salem
Issue date:	12/20/2006
From:	Stewart Bailey NRC/NRR/ADRO/DORL/LPLI-2
To:	Levis W Public Service Enterprise Group
Bailey S N,NRR/DLPM,415-1321
References
TAC MD1193
Download: ML063450192 (5)

Text

December 20, 2006 Mr. William Levis Senior Vice President & Chief Nuclear Officer PSEG Nuclear LLC - X09 Post Office Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

SALEM NUCLEAR GENERATING STATION, UNIT NO. 2, REQUEST FOR ADDITIONAL INFORMATION RE: AMENDMENT REQUEST TO IMPLEMENT TSTF-449 (TAC NO. MD1193)

Dear Mr. Levis:

By letter dated April 6, 2006, PSEG Nuclear LLC (PSEG), the licensee for the Salem Nuclear Generating Station, Unit No. 2, requested a license amendment to change the existing steam generator tube surveillance program to one that is consistent with the program proposed by the Technical Specification Task Force (TSTF) Traveler TSTF-449. The Nuclear Regulatory Commission (NRC) staff has determined that responses to the questions in the enclosure to this letter are necessary in order for the staff to complete its review. The enclosure was sent via e-mail to PSEG on June 27, 2006, to see whether the questions were understandable, whether the regulatory bases were clear, and whether the information was already docketed.

PSEG indicated that no clarifications were needed. The NRC staff agreed that PSEGs response would be submitted after the NRC approved a license amendment to allow the use of the W* methodology at Salem, Unit No. 2. The NRC approved the W* amendment on September 28, 2006. Please provide a response to the enclosed questions within 30 days of the date of this letter in order to allow the NRC staff to complete a timely review of the amendment. This request was discussed with Mr. James Mallon of your staff on December 12, 2006. If you have questions about this request, 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:

Request for Additional Information cc w/encl: See next page

OFFICE LPL1-2/PM LPL1-2/LA CSGB/BC LPL1-2/BC NAME SBailey CRaynor A. Hiser HChernoff DATE 12/15/06 12/15/06 6/21/06 12/20/06

• by memo Salem Nuclear Generating Station, Unit No. 2 cc:

Mr. Dennis Winchester Township Clerk Vice President - Nuclear Assessment Lower Alloways Creek Township PSEG Nuclear Municipal Building, P.O. Box 157 P.O. Box 236 Hancocks Bridge, NJ 08038 Hancocks Bridge, NJ 08038 Mr. Paul Bauldauf, P.E., Asst. Director Mr. Thomas P. Joyce Radiation Protection Programs Site Vice President - Salem NJ Department of Environmental PSEG Nuclear Protection and Energy P.O. Box 236 CN 415 Hancocks Bridge, NJ 08038 Trenton, NJ 08625-0415 Mr. George H. Gellrich Mr. Brian Beam Plant Support Manager Board of Public Utilities PSEG Nuclear 2 Gateway Center, Tenth Floor P.O. Box 236 Newark, NJ 07102 Hancocks Bridge, NJ 08038 Regional Administrator, Region I Mr. Carl J. Fricker U.S. Nuclear Regulatory Commission Plant Manager - Salem 475 Allendale Road PSEG Nuclear - N21 King of Prussia, PA 19406 P.O. Box 236 Hancocks Bridge, NJ 08038 Senior Resident Inspector Salem Nuclear Generating Station Mr. James Mallon U.S. Nuclear Regulatory Commission Manager - Licensing Drawer 0509 200 Exelon Way, KSA 3-E Hancocks Bridge, NJ 08038 Kennett Square, PA 19348 Mr. Steven Mannon Manager - Regulatory Assurance P.O. Box 236 Hancocks Bridge, NJ 08038 Jeffrie J. Keenan, Esquire PSEG Nuclear - N21 P.O. Box 236 Hancocks Bridge, NJ 08038

REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT TO IMPLEMENT TSTF-449 SALEM NUCLEAR GENERATING STATION, UNIT NO. 2 DOCKET NO. 50-311 On March 21, 2006, PSEG Nuclear LLC (PSEG), the licensee for the Salem Nuclear Generating Station (Salem), Unit No. 2, requested relief from certain requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code),

Section XI, for the inservice inspection (ISI) of Class 1 and Class 2 components. PSEG stated that it had conducted examinations as part of the Second Ten-Year Interval ISI Program to the extent practical; however, coverage for certain weld examinations was less than required by the Code. The Nuclear Regulatory Commission (NRC) staff has determined that responses to the following questions are necessary in order for the staff to complete its review:

By letter dated April 6, 2006 (ML061560393), PSEG Nuclear LLC (PSEG, the licensee) requested a license amendment for Salem Generating Station (Salem), Unit No. 2, to replace the existing steam generator (SG) tube surveillance program with the program being proposed by the Technical Specification Task Force (TSTF) Traveler TSTF-449, Revision 4. The proposed change revises the Technical Specifications (TS) definitions of Identified Leakage (TS 1.19) and Pressure Boundary Leakage, (TS 1.21) as well as the TS and Associated Bases for Specifications 3/4.4.6, Steam Generator (SG) Tube Integrity, and 3/4.4.7.2, Operational Leakage. The change also adds Specifications 6.8.4.i, Steam Generator (SG)

Program, and 6.9.1.10, Steam Generator Tube Inspection Report.

In order to complete the review, the staff needs the additional information requested below:

1. Proposed TS 6.8.4.i, Steam Generator (SG) Program, lists WEXTEX expanded region inspection methodology (W* Methodology) as an alternative repair option (TS 6.8.4.i.c.1). An associated note indicates the details of the W* methodology will be incorporated into the TS if the amendment is approved by the NRC.

The NRC cannot approve the TS as written because they do not include the details for the W* alternative repair criteria. Please provide modified TS and Bases pages that include the details necessary for implementing the W* criteria (e.g., tube inspection, tube repair criteria, and reporting requirements).

2. Attachment 3 of your submittal is a regulatory commitment to implement the Steam Generator Program in accordance with NEI 97-06 at the same time the TSTF-449 amendment is implemented. It is the staffs understanding that each plant already implements the NEI 97-06 guidelines, whether or not it has received an amendment to adopt the TSTF-449 steam generator tube integrity program. Please confirm the staffs understanding that NEI 97-06 is currently implemented at Salem Unit No. 2.

Enclosure

3. The sixth paragraph of Insert 4, proposed Bases Section 3/4.4.6, Steam Generator (SG) Tube Integrity, discusses the structural integrity performance criterion. Although similar to the corresponding paragraph in TSTF-449, it adds the following sentence:

The determination of whether thermal loads are primary or secondary loads is based on the ASME definition in which secondary loads are self-limiting and will not cause failure under single load application.

Since the TSTF-449 wording explains that, for circumferential cracking, the classification of loads as primary or secondary will be evaluated on a case-by-case basis, the intent of the added statement above is unclear. Please discuss the reason for adding this statement.

4. The proposed Bases Section 3/4.4.7.2, Operational Leakage, Insert 5, omits applicable safety analysis information that is in your current TS Bases and consistent with TSTF-449. Please discuss why this information was deleted from your Bases.

5. In Action b listed under proposed TS 3.4.7.2, the requirements are to reduce the leakage rate to within limits within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN during within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

(Emphasis added by the staff.) Please discuss your plans to correct this apparent typographical error.

6. In the proposed Index, pages V and XII list the title of 3/4.4.6 as Steam Generators (SG) Tube Integrity. The staff notes that the singular form, Steam Generator (SG)

Tube Integrity, is actually the title for these sections.