ML083230096
| ML083230096 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/20/2008 |
| From: | Geoffrey Miller Plant Licensing Branch 1 |
| To: | Chernoff H Plant Licensing Branch 1 |
| Miller G, NRR/DORL, 415-2481 | |
| References | |
| TAC MD9781 | |
| Download: ML083230096 (4) | |
Text
November 20, 2008 MEMORANDUM TO: Harold K. Chernoff, Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM:
G. Edward Miller, Project Manager /ra/
Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
SEABROOK STATION, UNIT NO. 1, DRAFT REQUEST FOR ADDITIONAL INFORMATION (TAC NO. MD9781)
The attached draft request for information (RAI) was transmitted on November 20, 2008, to Mr. Michael OKeefe of FPL Energy Seabrook, LLC (FPLE). This information was transmitted to facilitate an upcoming conference call in order to clarify the licensee=s relief request for the Seabrook Station, Unit No. 1 (Seabrook), dated September 30, 2008.
The proposed alternative would revise the Seabrook Inservice Inspection requirements for the pressurizer welded attachments and their associated supports.
The draft request for additional information (RAI) was sent to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. Additionally, review of the draft RAI would allow Seabrook to determine and agree upon a schedule to respond to the RAI. This memorandum and the attachment do not convey or represent an NRC staff position regarding the licensees request.
Docket No. 50-443
Enclosure:
Draft RAI
November 20, 2008 MEMORANDUM TO: Harold K. Chernoff, Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM:
G. Edward Miller, Project Manager /ra/
Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
SEABROOK STATION, UNIT NO. 1, DRAFT REQUEST FOR ADDITIONAL INFORMATION (TAC NO. MD9781)
The attached draft request for information (RAI) was transmitted on November 20, 2008, to Mr. Michael OKeefe of FPL Energy Seabrook, LLC (FPLE). This information was transmitted to facilitate an upcoming conference call in order to clarify the licensee=s relief request for the Seabrook Station, Unit No. 1 (Seabrook), dated September 30, 2008.
The proposed alternative would revise the Seabrook Inservice Inspection requirements for the pressurizer welded attachments and their associated supports.
The draft request for additional information (RAI) was sent to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. Additionally, review of the draft RAI would allow Seabrook to determine and agree upon a schedule to respond to the RAI. This memorandum and the attachment do not convey or represent an NRC staff position regarding the licensees request.
Docket No. 50-443
Enclosure:
Draft RAI DISTRIBUTION PUBLIC RidsNrrDorlLpl1-2 MMitchell, NRR LPL I-2 Reading RidsNrrPMGMiller RidsNrrDorlDpr TMcLellan, NRR ACCESSION NO.: ML083230096 OFFICE LPLI-2/PM DCI/CVIB/BC NAME G. E. Miller M. Mitchell DATE 11/20/2008 11/14/08 OFFICIAL RECORD COPY
Enclosure DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED RELIEF REQUEST INSERVICE INSPECTION REQUIREMENTS FOR PRESSURIZER WELDED ATTACHMENTS SEABROOK STATION, UNIT NO. 1 DOCKET NO. 50-443 By letter dated September 30, 2008, FPL Energy Seabrook, LLC (FPLE) submitted an relief request for the Seabrook Station, Unit No. 1 (Seabrook). The proposed alternative would revise the Seabrook Inservice Inspection requirements for the pressurizer welded attachments and their associated supports.
The Nuclear Regulatory Commission staff has reviewed the information provided in support of the proposed relief and finds that the following information is required to complete its review:
- 1) In your submittal, you describe the access limitations presented by the shield wall surrounding the pressurizer, as well as other personnel safety considerations associated with performing a VT-3 visual examination of the mechanical connections. Please provide drawings or sketches of the support areas, integral welded attachments, and limiting configurations described in the submittal that support the impracticality of performing a VT-3 visual examination of the listed components.
- 2) For pressurizer supports, ASME Code,Section XI, Table IWF-2500-1, Examination F-A, Item F1.40 requires a VT-3 visual examination of mechanical connections back to the building structure. FPLE has proposed to perform a VT-2 visual examination for leakage in lieu of the ASME Code-required VT-3 visual examination. Since an ASME Code,Section XI, Examination Category F-A, Item F1.40 support does not contain a fluid and the support is not an integral welded attachment to the pressurizer vessel, clarify how a VT-2 visual examination for leakage would provide reasonable assurance of leak-tightness of the pressurizer vessel.
- 3) ASME Code,Section XI, Examination Category B-K, Item B10.10, for pressure vessel integral welded attachments, requires a 100% surface examination of the weld length. FPLE has proposed a VT-2 visual examination for leakage in lieu of the ASME Code-required surface examination. Operating experience with other 4 loop pressure water reactors (PWR) has shown an ability to perform best-effort examinations of their pressurizers integral welded attachments. Please clarify why accessibility to the subject components in the Seabrook Station pressurizer cubical is different from other pressurizers.
- 4) The basis for the proposed alternative was based on hardship pursuant to 10 CFR 50.55a(a)(3)(ii); however, the submittal does not provide a basis as to why the ASME Code examinations were a hardship. The basis provided is more aligned with impracticality pursuant to 10 CFR 50.55a(g)(5). Please provide a basis supporting that the ASME Code-requirement compliance would result in hardship without a compensating increase in the level of quality and safety. Justify why the proposed alternative of a VT-2 visual examination provides reasonable assurance of leak-tightness of the pressurizer vessel
- 5) Please discuss any plans to examine the subject components should they become accessible to perform the ASME Code examinations?
- 6) Have you examined comparable components that have similar service histories and operating conditions as the subject components? If so, what were the results of these examinations?