ML073300435
| ML073300435 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 08/17/2007 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| Download: ML073300435 (11) | |
Text
JAFNPP License Renewal Project Comment and Resolution Form License Renewal Project Report
Title:
Safety Evaluation Report With Open Items License Renewal Project Report Number: JAF Draft SER License Renewal Project Team Lead: Rick Plasse JAFNPP Reviewer: Jacque Lingenfelter Date: 8/17/07 Comment Section/Pg.# Comment Resolution No.
1 2.1.4.1.1, pg 2-7 As someone at the NRC recently pointed out, 10 CFR 50.34(a)(1) applies to all plants; but for the older plants, it refers to 10 CFR 100 guidelines.
In the second paragraph of 2.1.4.1.1, replace the third sentence ("The exposure guidelines of 10 CFR 50.34(a)(1) do not apply because the construction permit was issued before January 10, 1997.") with the following:
"For plants (including JAFNPP) with construction permits issued before January 10, 1997, 10 CFR 50.34(a)(1) refers to the guidelines of 10 CFR 100 which are included in the applicant's definition."
2 2.1.4.1.2, pg 2-8 The first full paragraph of page 2-8 is an awkward sentence. The intended meaning is not clear. Proposed changes, as shown below may or may not address the author's intention.
The applicant scoped SSCs for the 10 CFR 54.4(a)(1 ) criterion using with the LRPGs, piping and instrumentation diagrams (P&IDs) and other information sources a- with the guidance of the LRPGs in the preparation, review, verification, and approval of the scoping evaluations fei to assure adequate scoping results.
Partial paragraph at top of page 2-9, next to last sentence, last word should be LRPDs instead of LRPGs.
Indented paragraph at top of page, beginning of second line, should read 10 CFR 100 rather than 10 CFR 67; and word-"also" should be deleted.
JAFNPP License Renewal Project Comment and Resolution Form License Renewal Project Report
Title:
Safety Evaluation Report With Open Items License Renewal Project Report Number: JAF Draft SER License Renewal Project Team Lead: Rick Plasse JAFNPP Reviewer: Jacque Lingenfelter Date: 8/17/07 Comment Section/Pg.# Comment- Resolution No.
5 2.1.4.1.2, pg 2-9 As in comment 1, the discussion of 10CFR 50.34 in the last paragraph of the section needs revised. Revise the second sentence of the paragraph as follows:
Based on this review, the staff verified that 10 CFR 50.34(a)(1) docs not apply bGcauso it covcrs construction permit applications since Januar-y 10, 1997.- the JAFNPP construction permits was issued before January 10, 1997. For such plant, 10 CFR 50.34(a)(1) refers to the ,quidelines of 10 CFR 100 which are included in the applicant's definition.
6 2.1.4.2.1, pg 2-10 For clarity, revise the last paragraph of the section as follows:
As documented in the audit report, the results of the applicant's evaluation of nonsafety-related SSCs affecting safety-related SSCs were incorporated into the license renewal project report, which describes fei the 10 CFR 54.4(a)(2) review and the AMR of nonsafety-related systems and components affecting safety-related systems. These results, described in LRA Sections 2.1.1.2 and 2.3.3.14, were input to the scoping and screening process.
7 2.1.4.2.2, pgs 2-11 For clarity, revise the third sentence of paragraph (2) at the bottom of page 2-and 2-12 11 as follows:
The applicant included all nonsafety-related SSCs within the analyzed structural boundary in within the scope of license renewal aRd within the
_,_analyzed Strucual beupn*a,* in accordance with 10 CFR 54.4(a)(2).
JAFNPP License Renewal Project Comment and Resolution Form License Renewal Project Report
Title:
Safety Evaluation Report With Open Items License Renewal Project Report Number: JAF Draft SER License Renewal Project Team Lead: Rick Plasse JAFNPP Reviewer: Jacque Lingenfelter Date: 8/17/07 Comment Section/Pg.# Comment Resolution No.
8 2.1.4.3.1, pg 2-14 Third line of "Fire Protection" paragraph has incomplete sentence. Add "10 CFR 50.48." to complete.
9 2.1.5.2.2, pg 2-26 Partial paragraph at top of page, sentence ending with "for use in the license database." should say "for use in the LRIS database."
10 2.1.5.3.1, pg 2-26 Next to last sentence of first paragraph of section, remove the word "mirror" from example. Mirror insulation may not be common to all structures but insulation will be.
11 2.1.5.3.2, pg 2-27 End of last'sentence of first paragraph of section, replace "each system" with "major structural groups and for bulk commodities."
12 2.1.6, pg 2-29 August 10, 2006 date for RAIs not correct (LRA submitted on 8/1/06). Actual date unknown.
JAFNPP License Renewal Project Comment and Resolution Form License Renewal Project Report
Title:
Safety Evaluation Report With Open Items License Renewal Project Report Number: JAF Draft SER License Renewal Project Team Lead: Rick Plasse JAFNPP Reviewer: Jacque Lingenfelter Date: 8/17/07 Comment No. SectionlPg.# Comment Resolution 13 Section 2.3.1, pgs Near the end of SER section 2.3.1, a list of CRD component types from LRA 2-34 and 2-35, Table 2.3.3-14-3 and a list of RCS component types from LRA Table 2.3.3 and 2 are presented. These lists are of nonsafety-related components affecting Section 2.3.3.14R.3 safety-related per 54.4(a)(2), and do not represent all component types of the pg 2-108 CRD or RCS systems.
The list of component types presented in SER section 2.3.1.3 lists reactor coolant pressure boundary components including the main CRD and RCS system components (outside the vessel) with intended functions other than 54.4(a)(2). This list comes from LRA Table 2.3.1-3.
Itwould make more sense to combine the two lists near the end of section 2.3.1, with the list in 2.3.1.3. This would be consistent with the similar combined lists for the non-class 1 systems (e.g., for RHR in 2.3.2.1.1)
The "Staff Evaluation" and "Conclusion" paragraphs at the end of section 2.3.1, should be deleted, or at least revised to point to sections 2.3.1.1 through 2.3.1.3. This will parallel the structure of the LRA where section 2.3.1 presents an overview, and sections 2.3.1.1 through 2.3.1.3 present the actual component lists.
If the lists are moved as suggested, the relevant section numbers for the CRD and reactor coolant system in the list of system following the Conclusion section 2.3.3.14R.3, should be changed from 2.3.1 to 2.3.1.3.
JAFNPP License Renewal Project Comment and Resolution Form License Renewal Project Report
Title:
Safety Evaluation Report With Open Items License Renewal Project Report Number: JAF Draft SER License Renewal Project Team Lead: Rick Plasse JAFNPP Reviewer: Jacque Lingenfelter Date: 8/17/07 Comment Section/Pg.#- Comment Resolution 14 Various Do search and replace - replace "to An AMR" with "to an AMR" Replace "FAF-" with "JAF-"
JAFNPP License Renewal Project Comment and Resolution Form License Renewal Project Report
Title:
Safety Evaluation Report With Open Items License Renewal Project Report Number: JAF Draft SER License Renewal Project Team Lead: Rick Plasse JAFNPP Reviewer: Ted Ivy_
Date:
Comment No. Section/Pg.# Comment Resolution 3.2.1/3-205 In the third paragraph it says In LRA Tables 3.3.2-14-1 to 4. Tables 3.3.2 15 2 and 3 are RCS systems not ESF systems. This is not consistent with sections 3.2 thru 3.4 which split up the (a)(2) systems based on where they are described in GALL.
3.2.2.1.3/3-218 The heading for this section doesn't match the aging mechanisms discussed 16 in the paragraphs below.
17 3.2.2.3/3-234 Typo in first paragraph Table 3.3.2-14-1 through 3.3.2-14-14 should be 3.3.2-14-4 not 14 which is mentioned later.
18 3.4/3-331 In this section it lists MS, turbine generator auxiliaries, and main condenser as separate bulleted systems when only the condensate storage system is specifically described in section 3.4. These systems are part of (a)(2) which is mentioned in the next bullet.
19 3.4.1/3-331 The condensate storage system is not in the bulleted list nor is table 3.4.2-1 mentioned with the (a)(2) tables that are described here.
20 3.4.2.2.6/3-349 In the second paragraph there is a statement of "but a note '"401" was added to indicate" which implies the note was not there originally. Change wording to "but a note "401" is included to indicate".
21 3.4.2.2.7(3)/3-352 In the first paragraph it states "However, for those line items in Table 3.3.2-14-18 where this Table 3.4.1 line item". The table 3.3.2-14-18 should be 3.3.2-14-26 to agree with previous sentence and the LRA.
JAFNPP License Renewal Project Comment and Resolution Form License Renewal Project Report
Title:
Safety Evaluation Report With Open Items License Renewal Project Report Number: JAF Draft SER License Renewal Project Team Lead: Rick Plasse JAFNPP Reviewer: Reza Ahrabli Date: 8/20/2007 Comment No. Section/Pg.# Comment Resolution a) The last paragraph states in part: "Based on its a) "are" should be changes to "is" to make the 22 2.4.1.2/2-120 review, the staff finds the applicant's response to paragraph to read as follows: "Based on its RAI 2.4.1-5 acceptable. The staff's concern review, the staff finds the applicant's response to described in RAI 2.4.1-5 are resolved." RAI 2.4.1-5 acceptable. The staff's concern described in RAI 2.4.1-5 is resolved."
b) The last paragraph discusses RAI 2.4.1-5 and b) Suggest to split the last paragraph into two 2.4.1-6 without any space the two different separate paragraphs; one for RAI 2.4.1-5 and discussions. other for 2.4.1-6 discussion.
2.4.4.2/2-130 4 th paragraph states in part: "In RAI 2.4.4-1 F dated In 4 th paragraph, "RAI 2.4.4-1 F" should be 23 January 12, 2007, the staff stated that LRA changed to "RAI 2.4.4-1" Section 2.4.4 includes review of bulk commodities such as structural components or commodities that support intended functions of in-scope SSCs."
Could not find RAI 2.4.4-1 F.
24 3.5.2.1.5/3- No space between "3.5.2.1.5" "Loss of Material Due Please provide a space between "3.5.2.1.5" and 377 to Abrasion, Cavitation" in the title. "Loss of Material Due to Abrasion, Cavitation" in the title.
JAFNPP License Renewal Project Comment and Resolution Form License Renewal Project Report
Title:
Safety Evaluation Report With Open Items License Renewal Project Report Number: JAF Draft SER License Renewal Project Team Lead: Rick Plasse JAFNPP Reviewer: Reza Ahrabli Date: 8/20/2007 Comment No. Section/Pg.# Comment Resolution 3.5.2.2.1/3- There is an extra space at the beginning of the 3 rd Please delete the extra space at the beginning of 25 384 paragraph between which states in part:" The staff the 3 rd paragraph to read as follow: "The staff found these aging effects not applicable to the Mark found these aging effects not applicable to the I freestanding steel containment. The listed possible Mark I freestanding steel containment. The listed aging effects apply to concrete elements of PWR possible aging effects apply to concrete elements containments and concrete BWR containments." of PWR containments and concrete BWR containments."
3.5.2.2.1/3- The word "applicant states" in beginning of the 3 rd Suggest revising the beginning sentence of the 26 387 paragraph should be changed to "applicant 3 rd paragraph to read (in part): "In its response, describes" the applicant describes that for JAFNPP, the sand cushion area at the ... enter the air gap.
3.5.2.2.1/3- Extra parenthesis exists in 5 th paragraph which Please delete the extra parenthesis in 5th 27 387 states in part: "Any leakage through the bellows paragraph after word "system".
assembly is directed to a drain system ((inner bellows to the Drywell Equipment Drain Sump, outer bellows to the "B"Condensate Storage Tank),
where ... event of a bellows failure."
28 3.5.2.2.1/3- The 3 rd sentence in 2 nd paragraph states (in part): "As Suggest changing the 3 rd sentence in 2 nd paragraph (in 390 stated in LRA Section 3.5.2.2.1.7... do not exist. part) from "As stated in LRA Section 3.5.2.2.1.7... do not exist." to (in part) "As described in LRA ... do not The referenced statement is not literally stated in LRA exist."
section 3.5.2.2.1.7, but it is described in there.
JAFNPP License Renewal Project Comment and Resolution Form License Renewal Project Report
Title:
Safety Evaluation Report With Open Items License Renewal Project Report Number: JAF Draft SER License Renewal Project Team Lead: Rick Plasse JAFNPP Reviewer: Reza Ahrabli Date: 8/20/2007 Comment Section/Pg.# Comment Resolution No.
3.5.2.2.2/3- The first part of lst paragraph states (in part): "The Please revise "Class 1" to "Class I"in first part of 29 396 applicant states that .... for Groups 1-3 and 5-9 Class 1 1 st paragraph to read as follow (in part): "The structures. The JAFNPP Class I structures are founded applicant states that .... for Groups 1-3 and 5-9
... settlement. The staff finds acceptable ... to JAFNPP Class I structures. The JAFNPP Class Istructures Class 1 structures." are founded ... settlement. The staff finds acceptable ... to JAFNPP Class I structures."
JAFNPP License Renewal Project Comment and Resolution Form License Renewal Project Report
Title:
Safety Evaluation Report With Open Items License Renewal Project Report Number: JAF Draft SER License Renewal Project Team Lead: Rick Plasse JAFNPP Reviewer: Roger B. Rucker Date: 8/6/07 Comment No. Section/Pg.# Comment Resolution 30 3.0.3.2.13/3-83 The response from the applicant on the MEB program has a typo. The following sentence has repetitive words. "The 115kV bus at JAFNPP is energized from two 115kV from two 115kV transmission lines as shown in UFSAR Figure 8.3-2."
31 Table 3.6-1/3-416 The line items associated with med. voltage cables and fuse holders (metallic clamp) state that the evaluation is not consistent with GALL.
Neither of these items was subject to AMR. Section 3.6.2.3.1 states that the aging effects are not applicable, because these commodities were screened out. How can this be an inconsistency?
32 3.6.2.3.2/3-430 In the discussion about the applicant response associated with bolted electrical connections, the SER contains JAF maintenance procedure numbers. Should these be deleted? Also, this information was provided in response to AUDIT Item 296. How can this information be used in the SER, if it was not provided in a letter? Letter JAFP-07-0019 provided the requested information for Item 296, which did not include any of the information associated with maintenance procedures.
JAFNPP License Renewal Project Comment and Resolution Form License Renewal Project Report
Title:
Safety Evaluation Report With Open Items License Renewal Project Report Number: JAF Draft SER License Renewal Project Team Lead: Rick Plasse JAFNPP Reviewer: Roger B. Rucker Date: 8/6/07 Comment No. Section/Pg.# Comment Resolution 33 3.6.2.3.2/3-435 & 436 In the discussion for the 115 kV oil-filled cable the SER states that the Oil Analysis Program (3.0.3.2.14) will manage the lube oil portion of the cable system, and it will test the electrical insulating oil.. The description in Section 3.0.3.2.14 does not address the electrical insulating oil.
The SER states that the Periodic Surveillance and Preventive Maintenance Program (3.0.3.3.4) will include maintenance as described in the vendor tech manual, but then adds some very detailed requirements, some of which will have to be performed weekly. Also, one of these items is to perform torque checks on the connections, which is not a good method to inspect for loose connections. Section 3.0.3.3.4 does not address the 115 kV oil-filled cable system.
34 3.0.3.3.6/3-154 In the bolted cable program discussion for element 4, the next to the last sentence of the B.1.34 text is missing a word. "The technical basis for the sample selected is to be documented. Inspection methods may include thermography, contact resistance testing, or other appropriate methods including visual inspection based on plant configuration and industry guidance.".