ML101060155

Request for Additional Information for the Review of the Hope Creek Generating Station License Renewal Application Identified During the Audit

ML101060155
Person / Time
Site:	Hope Creek
Issue date:	05/14/2010
From:	Ashley D License Renewal Projects Branch 1
To:	Joyce T Public Service Enterprise Group
Brady B NRR/DLR/RPB1, 415-2981
References
TAC ME1832
Download: ML101060155 (14)

Text

May 14, 2010 Mr. Thomas Joyce President and Chief Nuclear Officer PSEG Nuclear LLC P.O. Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE HOPE CREEK GENERATING STATION LICENSE RENEWAL APPLICATION IDENTIFIED DURING THE AUDIT (TAC NO ME1832)

Dear Mr. Joyce By letter dated August 18, 2009, as supplemented by letter dated January 23, 2009, Public Service Enterprise Group Nuclear, LLC, submitted an application pursuant to Title 10 of the Code of Federal Regulation Part 54 (10 CFR Part 54) for renewal of Operating License No.

NPF-57 for the Hope Creek Generating Station. The staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) completed its aging management program consistency audit on February 19, 2010 and has identified, in the enclosure, areas where additional information is needed to complete the review. Further requests for additional information may be issued in the future.

Items in the enclosure were discussed with John Hufnagel and other members of your staff, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me by telephone at 301-415-3191 or by e-mail at donnie.ashley@nrc.gov.

Sincerely,

/RA/ B. Brady for Donnie J. Ashley, Sr. Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-354

Enclosure:

As stated cc w/encl: See next page

ML101060155 OFFICE PM:DLR:RPB1 LA:DLR BC:DLR:RPB1 PM:DLR:RPB1 NAME D. Ashley I. King B. Pham D. Ashley (B. Brady for)

DATE 04/26/10 05/10/10 05/14/10 05/14/10

Letter to T. Joyce from D. Ashley dated May 14, 2010

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE HOPE CREEK GENERATING STATION LICENSE RENEWAL APPLICATION IDENTIFIED DURING THE AUDIT (TAC NO ME1832)

DISTRIBUTION:

HARD COPY:

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Hope Creek Generating Station cc:

Mr. Robert Braun Senior Vice President Nuclear PSEG Nuclear LLC One Alloway Creek Neck Road Hancocks Bridge, NJ 08038 Mr. Brian Booth Director Nuclear Oversight PSEG Nuclear P.O. Box 236 Hancocks Bridge, NJ 08038 Mr. John Perry Station Vice President - Hope Creek PSEG Nuclear P.O. Box 236 Hancocks Bridge, NJ 08038 Mr. Larry Wagner Plant Manager - Hope Creek PSEG Nuclear LLC One Alloway Creek Neck Road Hancocks Bridge, NJ 08038 Mr. Michael Gallagher Vice President - License Renewal Projects Exelon Nuclear LLC 200 Exelon Way Kennett Square, PA 19348 Mr. Jeffrie J. Keenan, Esquire Manager - Licensing PSEG Nuclear LLC One Alloway Creek Neck Road Hancocks Bridge, NJ 08038 Mr. Gregory Sosson Director Corporate Engineering PSEG Nuclear LLC One Alloway Creek Neck Road Hancocks Bridge, NJ 08038 Mr. Michael Gaffney Manager - Hope Creek Regulatory Assurance PSEG Nuclear LLC One Alloway Creek Neck Road Hancocks Bridge, NJ 08038 Mr. Ali Fakhar Manager, License Renewal PSEG Nuclear LLC One Alloway Creek Neck Road Hancocks Bridge, NJ 08038 Township Clerk Lower Alloways Creek Township Municipal Building, P.O. Box 157 Hancocks Bridge, NJ 08038 Mr. Paul Bauldauf, P.E., 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 Mr. Paul Davison Vice President, Operations Support PSEG Nuclear LLC One Alloway Creek Neck Road Hancocks Bridge, NJ 08038

Hope Creek Generating Station cc:

Ms. Christine Neely Director - Regulator Affairs PSEG Nuclear LLC One Alloway Creek Neck Road Hancocks Bridge, NJ 08038 Senior Resident Inspector Hope Creek Generating Station U.S. Nuclear Regulatory Commission Drawer 0509 Hancocks Bridge, NJ 08038 Mr. Earl R. Gage Salem County Administrator Administration Building 94 Market Street Salem, NJ 08079

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE HOPE CREEK GENERATING STATION LICENSE RENEWAL APPLICATION IDENTIFIED DURING THE AUDIT (TAC NO ME1832)

RAI B.2.1.1-01

Background:

GALL AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD, Program Element 4, Detection of Aging Effects, states that components are examined and tested as specified in Tables IWB-2500-1, IWC-2500-1, and IWD-2500-1, respectively, for Class 1, 2, and 3 components. However, license renewal application (LRA) Section B.2.1.1 states that the Hope Creek Generating Station (HCGS) ASME Section XI program includes a risk-informed inservice inspection (RI-ISI) program used to determine the inspection locations, inspection frequency, and inspection techniques for Class 1 Category B-F and B-J, and Class 2 Category C-F-1 and C-F-2 welds.

Issue:

RI-ISI and other alternatives to ASME Code Section XI specifications are approved for only the current 10-year ISI interval in accordance with 10 CFR 50.55a. There is no assurance that such alternatives, if requested, would be approved for future ISI intervals; such alternatives are not approved as part of license renewal in accordance with 10 CFR 54; and the plants current 10-year ISI interval does not overlap with the period of extended operation. Because the current 10-year ISI interval does not continue into the period of extended operation, the staff needs clarification with regard to discussion of RI-ISI and other alternatives to ASME Code Section XI specifications in the Program Description for LRA Appendix B.2.1.1.

Request:

Revise the LRA to delete discussion of RI-ISI and other alternatives to the requirements of ASME Code Section XI, Subsections IWB, IWC, and IWD; or clarify why such alternatives are being discussed in the LRAs Program Description for the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD program.

RAI B.2.1.3-01

Background:

GALL AMP XI.M3, Reactor Head Closure Studs, Program Element 4, Detection of Aging Effects, states that, examination category B-G-1 for pressure-retaining bolting greater than 2 inches diameter in reactor vessels specifiessurface and volumetric examination of studs when removed.

Issue:

Based on its review of the HCGS Reactor Head Closure Studs program, the staff has determined that only volumetric examinations are provided for studs when removed from the reactor flange.

In addition, the staff noted that HCGS LRA Section B.2.1.3 states that the program is based on the examination and inspection requirements specified in the 1998 edition of ASME Code Section XI, including the 2000 addenda. However, LRA Section B.2.1.1 (ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD) states that HCGSs current ISI program plan is based on the 2001 edition of ASME Code Section XI, through the 2003 addenda.

Requests:

a)

Explain why this is not identified as an exception to the GALL Reports recommendations or identify it as an exception to the GALL Report.

b)

Justify why volumetric examination (only) of reactor head closure studs when removed provides adequate detection of the aging effects for which the Reactor Head Closure Stud program is credited.

c)

Clarify what ASME Code Section XI edition and addenda are referenced in the current HCGS Reactor Head Closure Studs Program.

RAI B.2.1.12-01

Background:

Generic Aging Lessons Learned (GALL) aging management program (AMP) XI.M18, Bolting Integrity, Program Element 1, Scope of Program, states that the program covers bolting within the scope of license renewal, including 1) safety-related bolting, 2) bolting for nuclear steam supply system component supports, 3) bolting for other pressure retaining components, including non-safety-related bolting, and 4) structural bolting (actual measured yield strength 150 ksi). Program Element 2, Preventive Actions, states that selection of bolting material and use of lubricants and sealants is in accordance with the guidelines of EPRI NP-5769 and the additional recommendations in NUREG-1339, and that bolting replacement activities include proper torquing and application of appropriate preload based on EPRI documents.

Both the LRA and the program basis document for HCGS AMP B.2.1.12 indicate that aging effects for component support bolting and structural bolting are managed by AMPs different from the Bolting Integrity program, such as the Structures Monitoring program, the Inspection of Overhead Heavy Load and Light Load (Relating to Refueling) Handling Systems, the ASME Section XI, Subsection IWF program, the External Surfaces Monitoring program, or the Periodic Inspection program.

Issue:

It is not clear to the staff why the use of AMPs that are different from the Bolting Integrity program for managing the aging effects of bolts in scope of license renewal was not identified as an exception to Element 1 of the Bolting Integrity program. Also, it is not clear how the other credited AMPs, which are primarily inspection programs, would implement all of the elements of the Bolting Integrity program, especially Element 2, which includes recommendations related to procurement, replacement activities, and requirements for and implementation of proper torquing, that normally are not included within the scope of an inspection program.

Requests:

a)

Explain why use of other programs to manage the aging effects of component support and structural bolting was not identified as an exception to GALL AMP XI.M18, Element 1.

b)

Explain how you ensure that other AMPs credited for aging management of component support and structural bolting include all recommendations for aging management of bolting in GALL AMP XI.M18. Include sufficient information for the staff to determine whether and how the preventive actions in GALL AMP XI.M18, Element 2, are included in the other credited AMPs.

RAI B.2.1.17-01

Background:

GALL AMP XI.M26, Element 3, Parameters Monitored or Inspected states:

The periodic visual inspection and function test is performed at least once every six months to examine the signs of degradation of the halon/CO2 fire suppression system.

Material conditions that may affect the performance of the system, such as corrosion, mechanical damage, or damage to dampers, are observed during these tests.

HCGS LRA Appendix B2.1.17 takes an exception to GALL AMP XI.M26, and states:

NUREG-1801 recommends visual inspection and functional testing of the Halon and Carbon Dioxide fire suppression systems at least once every six months. The Halon and Carbon Dioxide fire suppression systems currently undergo functional testing every refueling cycle (18-months).

Issue:

It is not clear if the exception only applies to functional testing.

Request:

Clarify that the exception only applies to functional testing, and that the HCGS Fire Protection Program performs visual inspections at least once every six months to examine the signs of degradation of the halon/CO2 fire suppression system. If a visual inspection is not performed once every six months, please justify why this is not an exception to GALL AMP XI.M26.

RAI B.2.1.17-02

Background:

GALL AMP XI.M26, Element 4, Detection of Aging Effects states:

Visual inspections of the halon/CO2 fire suppression system detect any sign of added degradation, such as corrosion, mechanical damage, or damage to dampers. The periodic function test and inspection performed at least once every six months detects degradation of the halon/CO2 fire suppression system before the loss of the component intended function.

GALL AMP XI.M26, Element 6, Acceptance Criteria states:

Also, any signs of corrosion and mechanical damage of the halon/CO2 fire suppression system are not acceptable.

Program Basis Document, SH-PBD-AMP-XI.M26, under section 3.4.f, states:

The Fire protection aging management program directs Halon fire suppression system surveillance that verifies storage tank weight at least every six months. The manual Halon fire suppression system piping and nozzles are verified to be clear and not blocked every refueling cycle. During the inspections, adverse conditions are required to be reported for corrective action evaluation. Procedures HC.FP-SV.KC-0066 (F) and HC.FP-ST.KC-0048 (F) are referenced.

The program directs low-pressure Carbon Dioxide fire suppression system surveillance that verifies the valves are properly aligned at least every 31 days. System operability is verified at least once per refueling outage by verifying the system valves and associated ventilation dampers actuate automatically in response to a simulated actuation signal. A flow test is made to verify flow from each carbon dioxide nozzle and no blockage is observed. Any adverse conditions are required to be reported in the corrective action program. Procedures HC.FP-ST.KC-0021 (F) are referenced.

Issue:

Procedure HC.FP-ST.KC-0021 (F) verifies the operation of the total flooding CO2 system at least every 18 months. However, there is no visual inspection activity to check for degradation such as corrosion or mechanical damage. Acceptance criteria as identified in the procedure do not address corrosion.

Request:

Clarify how this is considered consistent with GALL AMP XI.M26. If it is not consistent, justify why this is not an exception or an enhancement.

RAI B.2.1.28-01

Background:

GALL Report (NUREG-1801), AMP XI.S1, ASME Section XI, Subsection IWE, Program Element 10, states that implementation of ASME Section XI, Subsection IWE, in accordance with 10 CFR 50.55a, is a necessary element of aging management for steel components of steel and concrete containments through the period of extended operation.

Issue:

Program Element 10 for the HCGS ASME Section XI, Subsection IWE AMP describes water leakage during the 2009 refueling outage from the seal rupture drain line penetration J13 sleeve which is located in the drywell air gap region. Water may be trapped between the concrete and drywell steel below the J13 penetration sleeve since it is located approximately eight feet above the drywell lower air gap drains. This could potentially corrode the drywell steel containment and impact its integrity.

Request:

The applicant is requested to provide the following:

1. Plans for determining the root cause for the water leak. The plan should include the details and timing to complete different activities.

2. Explain why the water did not travel below the penetration sleeve J13 and exit from the drywell lower air gap drains located approximately 8 feet below.

3. Plans to perform nondestructive examinations of the drywell area below the penetration sleeve J13 to demonstrate that water is not trapped in the two inch annular space between the drywell and the concrete shield wall.

4. Plans to quantify the effects of water leakage on the drywell, including volumetric examination, detailed engineering analysis and evaluations of the drywell.

The staff needs the above information to confirm that the effects of aging of the containment pressure boundary metal will be adequately managed so that its intended function will be maintained consistent with the current licensing basis for the period of extended operation as required by 10 CFR 54.21(a)(3).

RAI B.2.1.28-02

Background:

GALL Report (NUREG-1801), AMP XI.S1, ASME Section XI, Subsection IWE, Program Element 10 states that implementation of ASME Section XI, Subsection IWE, in accordance with 10 CFR 50.55a, is a necessary element of aging management for steel components of steel and concrete containments through the period of extended operation.

Issue:

Program Element 10 of the HCGS ASME Section XI, Subsection IWE AMP describes general corrosion and pitting of the torus shell and deficiencies in the interior coatings identified in 2004 by underwater inspections performed by divers as part of the IWE inspection program. The cleaning and underwater coating repair of the affected areas was completed during the subsequent outage. However, the LRA and program basis document do not provide sufficient information for the staff to evaluate and make an assessment regarding the impact of these deficiencies.

Request:

The applicant is requested to provide following additional details of underwater inspections performed during 2004:

1. Maximum depth of degradation due to corrosion.

2. Corrosion allowance thickness incorporated in the original design of the torus.

3. General condition of the coating applied to the inside surface of the torus.

4. Normal design life of Amercoat 90 coating applied to the inside surface of the torus.

RAI B.2.1.29-01

Background:

GALL Program XI.M18, Bolting Integrity states that GALL Program XI.S3, ASME Section XI, Subsection IWF manages inspection of safety related bolting. Salem Generating Station and HCGS document SH-PBD-AMP-XI.M18 states that the Bolting Integrity aging management program follows information as delineated in NUREG-1339, published EPRI NP-5769 guidelines, and industry recommendations.

Issue:

EPRI NP-5769, EPRI TR-104213, and NUREG-1339 recommend inspections for stress corrosion cracking (SCC) to prevent or mitigate degradation and failure of structural bolts with actual yield strength of 150,000 pounds per square inch. However, HCGS LRA Section 3.5.2 states that ASTM A490 bolts have high resistance to SCC due to their ductility, and industry and plant specific operating experience has not identified SCC of ASTM A490 bolts as a concern.

Request:

Explain the basis for the conclusion that ASTM A490 bolts have resistance to SCC due to their ductility. According to the published data, ASTM A490 bolts have high hardness and are not ductile. The staff needs the above information to confirm that the effects of aging of the high strength bolts will be adequately managed so that their intended function will be maintained consistent with the current licensing basis for the period of extended operation, as required by 10 CFR 54.21(a)(3).

RAI-B.2.1.32-01

Background:

The LRA states that underground reinforced concrete structures and structures in contact with raw water are subject to an aggressive environment. Groundwater and raw water chemistry results in 2008 indicate chloride levels up to 15,000 ppm that exceeds the threshold limit for chlorides (< 500 ppm) in the GALL Report. Inspection of below-grade structures will be done when exposed during plant excavations for construction or maintenance activities. The LRA states that the structures monitoring program has been enhanced to require periodic sampling, testing, and analysis of groundwater chemistry for pH, chlorides, and sulfates, and an assessment of its impact on buried structures. The LRA also states that the service water intake structure will be monitored to provide a bounding condition and indicator of the likelihood of concrete degradation for inaccessible portions of concrete structures. During the on-site audit, the applicant was asked if they had any plans for inspections of inaccessible reinforced concrete areas prior to the period of extended operation to confirm the absence of concrete degradation. The applicant responded that they did not and that operating experience indicates that there is no evidence of corrosion appearing on the interior surfaces of the concrete structures having inaccessible exterior surfaces. It was noted that the thickness of some of these walls however, may be on the order of four feet.

Issue:

Since the applicant does not have plans for inspections of inaccessible areas, and since the interior of the walls may not indicate the condition of the exterior walls, it is unclear to the staff whether this is an adequate approach to managing aging of inaccessible concrete structures subjected to aggressive groundwater.

Request:

a)

Provide locations where groundwater test samples were/are taken relative to safety related and important-to-safety embedded concrete walls and foundations and provide historical results (i.e., pH, chloride content, and sulfate content) including seasonal variation of results.

b)

In locations adjacent to embedded reinforced concrete structures where chloride levels exceed limits in the GALL Report, provide any plans for inspections. If no inspections or coring of concrete are planned to evaluate condition of structures (e.g., presence of steel corrosion or determination of chloride profiles), provide a basis to demonstrate that the current level of chlorides in the groundwater is not causing structural degradation of embedded walls or foundations.

The staff needs the information to confirm that the potential effect of aging of the reinforced concrete due to presence of high chloride levels will be adequately managed so that the intended function of impacted structural members will be maintained consistent with the current licensing basis for the period of extended operation as required by 10 CFR 54.21(a)3.

RAI B.2.1.33-01

Background:

GALL Report (NUREG-1801), AMP XI.S7, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants, Element 1, applies to concrete structures, embankment structures, spillway structures, reservoirs, cooling water channels, and intake and discharge structures.

Issue:

In Element 1 of the Program Basis Document SH-PBD-AMP-XI.S7, the applicant states there are no Hope Creek water-control structures that are credited for flood protection. It is not clear that this statement is consistent with Table 2.4.9 of the LRA which indicates parts of the service water intake structure as flood barriers.

Request:

Explain the apparent inconsistency between LRA Table 2.4.9 and Element 1 of the Program Basis Document SH-PBD-AMP-XI.S7.

RAI B.2.1.37-01-Inaccessible Medium Volt Cables

Background:

GALL AMP XI.E3 states that the program applies to inaccessible medium voltage cables that are exposed to significant moisture simultaneously with significant voltage. Significant moisture is defined as periodic exposures to moisture that lasts for more than a few days. GALL AMP XI.E3 also states that periodic actions are taken to prevent cables from being exposed to significant moisture. GALL AMP XI.E3 further states that inspection for water collection should be performed based on actual plant experience with water accumulation in the manhole with an inspection frequency of at least every two years.

Issue:

The applicant identified operating experience and the staff confirmed through walkdowns and operating experience review, cases of service water (Vaults MH-102, MH-103, MH-105),

inaccessible medium voltage cable exposure to significant moisture (cable submergence), and cable support structural degradation inconsistent with GALL AMP XI.E3 (i.e., periodic actions are taken to prevent cables from being exposed to significant moisture).

Request:

1.

Describe how HCGS LRA AMP B.2.1.37 meets GALL AMP XI.E3, considering that operating history shows that in-scope inaccessible medium voltage cable are exposed to significant moisture (i.e., exposure lasting more than a few days).

2.

In addition, (a) describe how plant operating experience was incorporated into AMP B.2.1.37 to minimize exposure of in-scope inaccessible medium voltage cables to significant moisture during the period of extended operation, (b) discuss manhole/vault inspections (including event driven significant moisture exposure inspections such as rain) and how adjustments/modifications will be made based on operating experience to minimize cable exposure to significant moisture, (c) discuss any corrective actions taken that address submerged cable conditions and cable support structure degradation identified through manhole/vault inspection, and (d) discuss cable testing/frequency and applicability that demonstrates that in-scope, inaccessible medium voltage cables will continue to perform their intended function during the period of extended operation.

RAI B.2.1.37-02-Inaccessible Medium Volt Cables

Background:

GALL AMP XI.E3 states that the program applies to inaccessible medium voltage cables that are exposed significant moisture simultaneously with significant voltage. Significant moisture is defined as periodic exposures to moisture that last for more than a few days.

GALL AMP XI.E3 also states that periodic actions are taken to prevent cables from being exposed to significant moisture. GALL AMP XI.E3 further states that inspection for water collection should be performed based on actual plant experience with water accumulation in the manhole with an inspection frequency of at least every two years.

Issue:

The applicant identified operating experience and the staff confirmed through walkdowns and operating experience review, cases of inaccessible medium voltage cable exposure to significant moisture (cable submergence in manholes/vaults) and cable support structural degradation inconsistent with GALL AMP XI.E3 (i.e., periodic actions are taken to prevent cables from being exposed to significant moisture). A review of operating experience does not provide information on in-scope inaccessible medium voltage station blackout (SBO) recovery cable testing results or manhole/vault inspections. SBO cables in-scope of license renewal are also exposed to significant moisture.

Request:

1.

Describe how HCGS LRA AMP B.2.1.37 meets GALL AMP XI.E3 for in-scope inaccessible medium voltage SBO recovery cables considering that operating history shows that the in-scope inaccessible medium voltage SBO recovery cables are exposed to significant moisture (i.e. exposure lasting more than a few days).

2.

In addition, (a) describe how plant operating experience was incorporated into AMP B.2.1.37 to minimize exposure of in-scope inaccessible medium voltage SBO recovery cables to significant moisture during the period of extended operation, (b) discuss any corrective actions taken that address submerged cable conditions identified through manhole/vault inspections, (c) discuss cable testing/frequency and applicability that demonstrates how in-scope, inaccessible medium voltage SBO recovery cables will continue to perform their intended function during the period of extended operation.

RAI B.2.1.37-03-Inaccessible Medium Volt Cables

Background:

GALL AMP XI.E3 states that the program applies to inaccessible (e.g., in conduit, direct buried) medium-voltage cables within the scope of license renewal that are exposed to significant moisture simultaneously with significant voltage.

Issue:

Program Basis Document SH-PBD-AMP-XI.E3, Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, scope of program does not identify cables that are within scope of the program.

Request:

Identify inaccessible medium voltage cables within the scope of AMP B.2.1.37 including cable ID number, insulation and jacket material.

RAI B.2.1.37-04-Inaccessible Cables

Background:

GALL Report AMP XI.E3, Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, Program Element 1, Scope of Program, provides definitions for significant moisture and significant voltage. Standard Review Plan-License Renewal (SRP-LR) Table 3.6-2, Final Safety Analysis Report (FSAR) Supplement for Aging Management of Electrical and Instrumentation and Control System also includes definitions for significant moisture and significant voltage.

Issue:

LRA FSAR Supplement Section A.2.1.37 does not include definitions of significant moisture or significant voltage consistent with SRP LR Table 3.6-2 or GALL AMP XI.E3, Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. The lack of these definitions in combination with the applicants stated objective of using inspections to ensure that cables are infrequently submerged may not be consistent with GALL AMP XI.E3.

Request:

Explain why LRA FSAR supplement A.2.1.37 for LRA AMP B.2.1.37 does not include the definitions of significant voltage and significant moisture consistent with GALL Report AMP XI.E3 and SRP LR Table 3.6-2.

RAI B.2.1.39-01-Electrical Cable Connections Applicable to LRA Sections B.2.1.35, 36, 37, 38, 39 and B.3.1.2 program basis documents

Background:

NUREG 1801, Vol. 1, Rev. 1, GALL Report states that operating experience involving the aging management program, including past corrective actions resulting in program enhancements or additional programs, should provide objective evidence to support a determination that the effects of aging will be adequately managed so that the structure and components intended functions will be maintained during the period of extended operation.

Issue:

The applicant LRA and basis document provide operating experience examples that conclude that the effects of aging and aging mechanisms are being adequately managed. The applicant stated that these examples provide objective evidence that the aging management program, acceptance criterion, and the corrective action process will be effective in resolving problems prior to loss of function. However, it is not clear based on the applicants discussion that the included examples are representative of operating experience. The search methodology and criteria (e.g., XI.E6 connection type, time frame, and connection stressors such as application, loading, and locations) aging management program components within the scope of license renewal, and electrical GALL AMPs are not discussed.

Request:

Provide a discussion on the evaluation methods and search criteria used to select the examples provided in LRA B.2.1.39 and the associated basis document. The discussion should demonstrate that the examples provided are representative of the operating experience for the applicable GALL AMP. See LRA Sections B.2.1.35, 36, 37, 38, 39, B.3.1.2, and the associated program basis documents.