ML070330565

Request for Additional Information, Amendment Request Steam Generator Tube Integrity, Salem Nuclear Generating Station. Unit No. 2

ML070330565
Person / Time
Site:	Salem
Issue date:	02/05/2007
From:	Richard Ennis NRC/NRR/ADRO/DORL/LPLI-2
To:	Levis W Public Service Enterprise Group
Ennis R, NRR/DORL, 415-1420
References
TAC MD1193
Download: ML070330565 (7)

Text

February 5, 2007 Mr. William Levis Senior Vice President & Chief Nuclear Officer PSEG Nuclear LLC - N09 Post Office Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION, AMENDMENT REQUEST RE: STEAM GENERATOR TUBE INTEGRITY, SALEM NUCLEAR GENERATING STATION, UNIT NO. 2 (TAC NO. MD1193)

Dear Mr. Levis:

By letter dated April 6, 2006, as supplemented on January 19, 2007, PSEG Nuclear LLC submitted an amendment request for Salem Nuclear Generating Station, Unit No. 2. The proposed amendment would revise the Technical Specifications (TSs) related to steam generator tube integrity. The proposed changes are based on Nuclear Regulatory Commission (NRC)-approved Revision 4 to TS Task Force (TSTF) Standard TS Change Traveler 449 (TSTF-449), Steam Generator Tube Integrity.

The NRC staff is reviewing your submittal and has determined that additional information is needed to complete its review. The specific questions are found in the enclosed request for additional information.

In order to complete our timely review of your amendment request, we require your response within 30 days from the date of this letter. If you cannot respond within 30 days, please inform us in writing why you cannot respond and provide an alternate response date.

W. Levis Please note that if you do not respond to this letter within 30 days or provide an acceptable alternate date in writing, we may reject your application for amendment under the provisions of Title 10 of the Code of Federal Regulations, Section 2.108. If you have any questions, I can be reached at (301) 415-1420.

Sincerely,

/RA/

Richard B. Ennis, 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

ML070330565 *via email OFFICE LPL1-2/PM LPL1-2/LA CSGB/BC LPL1-2/BC NAME REnnis CRaynor* AHiser* HChernoff DATE 2/05/07 2/05/07 2/02/07 2/05/07 Salem Nuclear Generating Station, Unit Nos. 1 and 2 cc:

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

REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED LICENSE AMENDMENT STEAM GENERATOR TUBE INTEGRITY SALEM NUCLEAR GENERATING STATION, UNIT NO. 2 DOCKET NO. 50-311 By letter dated April 6, 2006, as supplemented on January 19, 2007, PSEG Nuclear LLC submitted an amendment request for Salem Nuclear Generating Station (Salem), Unit No. 2.

The proposed amendment would revise the Technical Specifications (TSs) related to steam generator (SG) tube integrity. The proposed changes are based on Nuclear Regulatory Commission (NRC)-approved Revision 4 to TS Task Force (TSTF) Standard TS Change Traveler 449 (TSTF-449), Steam Generator Tube Integrity.

The NRC staff is reviewing your submittal and has determined that additional information is needed to complete its review. The specific information requested is addressed below.

1. With respect to incorporation of the W* methodology for tube repair and inspection within the tubesheet region in proposed TSs 6.8.4.i.c.1 and 6.8.4.i.d, please address the following:

a. The first paragraph of proposed TS 6.8.4.i.c.1 states that the excluded portion of the tube defined by W* is ONLY applicable to Westinghouse installed steam generators, Amendment 256. This presumably is intended to distinguish between the currently-installed SGs and future replacements, but it does so indirectly. Please discuss your plans to either remove this statement or to modify your proposal to address the issue directly. For example, state that the alternate repair criteria apply only to the Westinghouse Model 51 SGs with mill annealed Alloy 600 tubing expanded into the tubesheet using the Westinghouse explosive tube expansion (WEXTEX) process, or provide separate TS sections on repair and inspection provisions for each type of SG.

b. The second paragraph of proposed TS 6.8.4.i.c.1 addresses provisions for both inspection and repair. Since this is the repair criteria section, the requirement for 100 percent inspection of the inservice tubes for the entire hot leg tubesheet W*

distance, should be located under proposed TS 6.8.4.i.d, Provisions for SG tube inspections. Please discuss your plans to modify your proposal to relocate this part of the proposal. For example, consider adding a TS 6.8.4.i.d.4 as follows:

Enclosure

4. When the W* methodology has been implemented, inspect 100 percent of the inservice tubes for the entire hot-leg tubesheet W* distance with the objective of detecting flaws that may satisfy the applicable tube repair criteria of TS 6.8.4.i.c.1 every 24 effective full power months or one refueling outage (whichever is less).

The NRC staff notes that if a paragraph 4 is added as in the above example, the first paragraph of TS 6.8.4.i.d will need to be modified to add d.4" (i.e., In addition to meeting the requirements of d.1, d.2, d.3, and d.4 below ......).

c. As currently proposed, the tube repair criteria for the region below the W*

distance in the hot-leg tubesheet region would be 40 percent of the nominal tube wall thickness. It is the NRC staffs understanding that you intend to allow tubes with flaws below the W* distance in the hot-leg region to remain in service, regardless of the size of the flaw. If this is the case, please discuss your plans to modify your proposal by adding a statement to this effect, such as, Flaws located below the W* distance may remain in service regardless of size.

d. Proposed TS 6.8.4.i.c.1 uses the term W* distance before defining it. Please discuss your plans to move the definitions to the beginning of the W*

methodology section.

e. Proposed TS 6.8.4.i.d contains a statement that excludes the part of the tube below the W* distance from the tube inspection requirement. This statement does not indicate that the exception only applies to the hot-leg region. In addition, this statement unnecessarily refers to the W* amendment number.

Please discuss your plans for removing the amendment number and clarifying that only the hot-leg region is excluded from the inspection provisions. Consider, for example, the following wording:

Provisions for SG tube inspections. Periodic SG inspections shall be performed. The number and portions ... and that may satisfy the applicable tube repair criteria. The portion of the tube within the hot-leg tubesheet region below the W* distance is excluded. The tube-to-tubesheet weld is not ...

Since these comments also apply to the third paragraph of Insert 4 to your proposed TS Bases, please provide a response that includes your plans for addressing these issues in the Bases.

2. Given that the new TS provided in TSTF-449 does not allow operation when the accident-induced leakage criteria are exceeded, please discuss your plans to omit the final sentence of proposed TS 6.9.1.10.h (reporting requirements related to application of the W* methodology). In addition, please discuss your plans to reflect this change in the TS Bases.

3. The response to question 4 in your January 19, 2007, letter refers to a paragraph that was removed from Bases section 3/4.4.7.2 (Operational Leakage). The paragraph that was removed discussed the plant accident leakage analysis, including the following:

the dosage contribution from the tube leakage will be limited to a small fraction of Part 100 limits in the event of either a steam generator tube rupture or steam line break.

The 1 GPM limit is consistent with the assumptions used in the analysis of these accidents. Bases section B 3.4.13 in TSTF-449 contains a similar discussion addressing analysis of accident-induced leakage. Since removing this information is inconsistent with TSTF-449, please discuss your plans to modify your proposal in order to restore this information to your Bases. In addition, please clarify whether Part 100 to Title 10 of the Code of Federal Regulations (10 CFR) or 10 CFR 50.67 is the appropriate reference (i.e., which of these is the currently approved design and licensing basis for Salem Unit 2).

4. The inserts proposed for TS Bases section B 3/4.4.6, Steam Generator (SG) Tube Integrity, do not include the Background, Applicable Safety Analysis, and Applicability sections. Please discuss why these sections were not included.

5. Please discuss your plans to replace service induced degradation with a flaw throughout your submittal, since the tube repair criteria in TSTF-449 describe the repair criteria in terms of flaws rather than degradation.

6. Please discuss your plans to clearly indicate throughout your submittal that the W*

methodology can only be applied to the hot-leg region.

7. Proposed TS Sections 6.8.4.i.d.2a and 6.8.4.i.d.2b use undefined abbreviations (MA and TT). Please discuss your plans to spell out the words instead of using these abbreviations. In addition, discuss your plans to remove the words original and replacement from these proposed TS sections.