ML101460061

Request for Additional Information for Salem Nuclear Generating Station Units 1 and 2 License Renewal Application Regarding Section 3.5 (TAC Nos. ME1834 and ME1836)

ML101460061
Person / Time
Site:	Salem
Issue date:	06/07/2010
From:	Bennett Brady License Renewal Projects Branch 1
To:	Joyce T Public Service Enterprise Group
DE
References
TAC ME1834, TAC ME1836
Download: ML101460061 (13)

Text

June 7, 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 SALEM NUCLEAR GENERATING STATION UNITS 1 AND 2 LICENSE RENEWAL APPLICATION REGARDING SECTION 3.5 (TAC NOS. ME1834 AND ME1836)

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 Regulations Part 54 for renewal of Operating License Nos. DPR-70 and DPR-75 for Salem Nuclear Generating Station Units 1 and 2, respectively. The staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing this application in accordance with the guidance in NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants. During its review, the staff has identified areas where additional information is needed to complete the review. The staffs request for additional information is included in the Enclosure. Further requests for additional information may be issued in the future.

Items in the enclosure were provided to 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 301-415-2981 or by e-mail at bennett.brady@nrc.gov.

Sincerely,

/RA/

Bennett M. Brady, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-272 and 50-311

Enclosure:

As stated cc w/encl: See next page

ML101460061 OFFICE PM:DLR:RPB1 LA:DLR BC:DLR:RPB1 PM:DLR:RPB1 NAME B. Brady SFigueroa B. Pham B. Brady DATE 06/03/10 06/1/10 06/03/10 06/07/10

Letter to T. Joyce from B. Brady dated June 7, 2010

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR SALEM NUCLEAR GENERATING STATION UNITS 1 AND 2 LICENSE RENEWAL APPLICATION REGARDING SECTION 3.5 (TAC NOS. ME1834 AND ME1836)

DISTRIBUTION:

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Salem Nuclear Generating Station, Units 1 and 2 cc:

Mr. Robert Braun Mr. Ali Fakhar Senior Vice President Nuclear Manager, License Renewal PSEG Nuclear LLC PSEG Nuclear LLC One Alloway Creek Neck Road One Alloway Creek Neck Road Hancocks Bridge, NJ 08038 Hancocks Bridge, NJ 08038 Mr. Carl Fricker Mr. William Mattingly Station Vice President - Salem Manager - Salem Regulatory Assurance PSEG Nuclear LLC PSEG Nuclear LLC One Alloway Creek Neck Road One Alloway Creek Neck Road Hancocks Bridge, NJ 08038 Hancocks Bridge, NJ 08038 Mr. Michael Gallagher Township Clerk Vice President - License Renewal Projects Lower Alloways Creek Township Exelon Nuclear LLC Municipal Building, P.O. Box 157 200 Exelon Way Hancocks Bridge, NJ 08038 Kennett Square, PA 19348 Mr. Paul Bauldauf, P.E., Asst. Director Mr. Ed Eilola Radiation Protection Programs Plant Manager - Salem NJ Department of Environmental PSEG Nuclear LLC Protection and Energy, CN 415 One Alloway Creek Neck Road Trenton, NJ 08625-0415 Hancocks Bridge, NJ 08038 Mr. Brian Beam Mr. Brian Booth Board of Public Utilities Director Nuclear Oversight 2 Gateway Center, Tenth Floor PSEG Nuclear Newark, NJ 07102 P.O. Box 236 Hancocks Bridge, NJ 08038 Regional Administrator, Region I U.S. Nuclear Regulatory Commission Mr. Jeffrie J. Keenan, Esquire 475 Allendale Road Manager - Licensing King of Prussia, PA 19406 PSEG Nuclear LLC One Alloway Creek Neck Road Mr. Gregory Sosson Hancocks Bridge, NJ 08038 Director Corporate Engineering PSEG Nuclear LLC Senior Resident Inspector One Alloway Creek Neck Road Salem Nuclear Generating Station Hancocks Bridge, NJ 08038 U.S. Nuclear Regulatory Commission Drawer 0509 Mr. Paul Davison Hancocks Bridge, NJ 08038 Vice President, Operations Support PSEG Nuclear LLC One Alloway Creek Neck Road Hancocks Bridge, NJ 08038

Salem Nuclear Generating Station, Units 1 and 2 cc:

Ms. Christine Neely Director - Regulator Affairs PSEG Nuclear LLC One Alloway Creek Neck Road Hancocks Bridge, NJ 08038 Mr. Earl R. Gage Salem County Administrator Administration Building 94 Market Street Salem, NJ 08079

REQUEST FOR ADDITIONAL INFORMATION FOR SALEM NUCLEAR GENERATING STATION (SNGS) UNITS 1 AND 2 LICENSE RENEWAL APPLICATION REGARDING SECTION 3.5 (TAC NOS. ME1834 AND ME 1836)

RAI 3.5.2.1-01

Background:

SRP Table 3.3-1, Item Number 3.3.1-19, credits Generic Aging Lessons Learned (GALL) Report AMPs XI.M28 or XI.M34 to manage the aging effect/mechanism loss of material due to corrosion in a soil environment for steel piping. These aging management programs (AMPs) include surveillance and preventive measures to mitigate corrosion by protecting the external surface of buried piping and tanks.

Issue:

In the license renewal application (LRA), the applicant references Item 3.3.1-19 and credits the Structures Monitoring Program (SMP) to manage aging for carbon and galvanized steel penetration sleeves, penetration seals, and conduit in a groundwater/soil environment. The SMP is primarily a visual inspection program. The staff is unclear how the SNGS SMP meets or exceeds the surveillance and preventive measures requirements of the GALL Report recommended programs, and how the Structures Monitoring Program will be utilized to address the structure/aging effect combinations during the period of extended operation.

Request:

Describe how the SNGS Structures Monitoring AMP meets or exceeds the requirements of the GALL Report recommended programs and how the SMP will be used to manage carbon and galvanized steel penetration sleeves, penetration seals, and conduit in a groundwater/soil environment for loss of material/general, pitting, crevice, and microbiologically influenced corrosion during the period of extended operation. Discuss surveillance as well as preventive measure requirements.

RAI 3.5.2.1-02

Background:

SRP Table 3.3-1, Item Number 3.3.1-19, credits GALL Report AMPs XI.M28 or XI.M34 to manage the aging effect/mechanism loss of material due to corrosion in a soil environment for steel piping. These AMPs include surveillance and preventive measures to mitigate corrosion by protecting the external surface of buried piping and tanks.

ENCLOSURE

Issue:

In the LRA, the applicant references Item 3.3.1-19 and credits the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants, Program to manage aging for carbon steel penetration sleeves in a groundwater/soil environment. The RG 1.127 Program is primarily a visual inspection program. The staff is unclear how the SNGS RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants, AMP meets or exceeds the surveillance and preventive measures requirements of the GALL Report recommended programs, and how the credited program will be utilized to address the structure/aging effect combinations during the period of extended operation.

Request:

Describe how the SNGS RG 1.127 AMP meets or exceeds the requirements of the GALL Report recommended programs and how the RG 1.127 Program will be used to manage carbon steel penetration sleeves in a groundwater/soil environment for loss of material/general, pitting, crevice, and microbiologically influenced corrosion during the period of extended operation.

Discuss surveillance as well as preventive measure requirements.

RAI 3.5.2.1-03

Background:

SRP Table 3.4-1, Item Number 3.4.1-33, credits the GALL Report AMP Open-Cycle Cooling Water System (XI.M20) for managing loss of material/general, pitting, crevice, and microbiologically influenced corrosion and fouling of stainless steel heat exchanger components in a raw water environment. GALL Report AMP Open-Cycle Cooling Water System (XI.M20) applies to stainless steel piping, piping components, and piping elements in a raw water environment and is intended to address aging effects of material loss and fouling due to micro- and macro-organisms and various corrosion mechanisms.

Issue:

In LRA Table 3.5.2-3, AMR lines which reference Item 3.4.1-33 and Note E, credit the applicants Periodic Inspection Program to manage this aging effect for stainless steel used as a filter. The applicants Periodic Inspection Program is a condition monitoring program that includes provisions for periodic visual inspections of stainless steel components in a raw water environment to detect loss of material and the presence and extent of fouling that could result in reduction of heat transfer. The applicant noted that the inspection frequency is established based on plant and industry operating experience and that for stainless steel components subject to a raw water environment operating experience indicates that a ten-year inspection frequency will be adequate to detect loss of material prior to loss of component intended function. The staff agrees that the SNGS Periodic Inspection Program is an appropriate AMP to address this aging effect requiring management (AERM); however, since the GALL Report XI.M20 AMP inspections are done annually and during refueling outages, it is unclear to the staff that an inspection interval of ten years will be adequate to address the AERM.

Request:

Describe how an inspection frequency of ten-years, as discussed in the Periodic Inspection Program, will be adequate to manage aging of the stainless steel filter (trench cover) for loss of material/general, pitting, crevice, and microbiologically influenced corrosion in a raw water environment during the period of extended operation.

RAI 3.5.2.1-04

Background:

SRP Table Table 3.5-1, Item Number 3.5.1-50, credits the GALL Report AMP XI.S6 Structures Monitoring Program for managing loss of material due to pitting and crevice corrosion in an air-outdoor environment for galvanized steel, aluminum and stainless steel.

Issue:

Throughout the LRA , several aging management review (AMR) lines which reference Table 3.5-1, Item Number 3.5.1-50 and Note E credit the applicants Periodic Inspection Program to manage loss of material due to corrosion for aluminum and stainless steel components in an air-outdoor environment. The Periodic Inspection Program is a condition monitoring program that manages aging of piping, piping components, piping elements, ducting components, tanks, and heat exchanger components, and includes provisions for periodic visual inspections of aluminum components to detect loss of material aging effects. The LRA states that the visual inspections are conducted on a ten-year inspection frequency that has been established based on plant and industry operating experience. The staff is unclear that the SNGS Periodic Inspection AMP addresses all the components which credit it and Item 3.5.1-50.

Request:

Confirm that the aluminum and stainless steel components crediting this AMP are addressed under the SNGS Periodic Inspection AMP and describe how an inspection frequency of ten years will be adequate to manage aging of the aluminum and stainless steel insulation jacketing for loss of material due to pitting and crevice corrosion in an air-outdoor environment during the period of extended operation.

RAI 3.5.2.1-05

Background:

SRP Table 3.5-1, Item Number 3.5.1-52, credits the GALL Report AMP XI.S6 Structures Monitoring Program for managing loss of mechanical function in an air-indoor environment for graphite tool steel and Lubrite sliding supports. The GALL Report recommends no further evaluation for lockup of sliding surfaces if the Structures Monitoring Program is used to manage aging.

Issue:

In LRA Table 3.5.2-2, AMR lines which reference Table 3.5-1, Item Number 3.5.1-52 and Note E credit the applicants ASME Section XI, Subsection IWF Program as the AMP.

However, during the staffs review of this AMP they were unable to verify that accessible areas of these sliding support surfaces were being inspected for loss of mechanical function/corrosion, distortion, dirt, overload, or fatigue due to vibratory and cyclic thermal loads under the applicants ASME Section XI, Subsection IWF AMP and at what frequency the inspections were to be performed.

Request:

Confirm that the Graph-Air Tool Steel and Lubrite surfaces are addressed under the ASME Section XI, Subsection IWF AMP for loss of mechanical function due to corrosion, distortion, dirt, overload, fatigue due to vibratory and cyclic loads in an air-indoor (uncontrolled) environment. Also confirm that the inspection method and the frequency of inspections is equivalent to, or exceeds, the requirements of the GALL Report recommended AMP, XI.S6 Structures Monitoring Program.

RAI 3.5.2.2.1-01

Background:

SRP-LR Section 3.5.2.2.1.4 addresses loss of material due to general, pitting and crevice corrosion for steel elements of accessible and inaccessible areas of containments. The SRP recommends further evaluation if four GALL Report conditions cannot be satisfied. Condition one states:

(1) Concrete meeting the specifications of ACI 318 or 349 and the guidance of ACI 201.2R was used for the containment concrete in contact with the embedded containment shell or liner.

Issue:

The staff agrees that conditions (2), (3), and (4) were addressed adequately by the applicant; however, the LRA did not specify that condition (1) was met.

Request:

Confirm that the containment concrete in contact with the embedded steel liner met the guidance contained in ACI 201.2R as specified in the GALL Report.

RAI 3.5.2.2.1-02

Background:

SRP-LR Sections 3.5.2.2.1.9, 3.5.2.2.2.2.1, and 3.5.2.2.2.4.2 address loss of material (scaling, cracking, and spalling) due to freeze-thaw. The associated GALL Report Items

(C-01, T-01, and T-15) recommend evaluation for plants located in moderate to severe weathering conditions. The GALL Report also recommends the concrete have an air content of 3 percent to 6 percent and water-to-cement ratio between 0.35 - 0.45.

Issue:

The associated LRA sections state that the weathering condition at SNGS is severe; however, neither an air content nor a water-to-cement ratio was specified for the concrete.

Request:

Provide the air content and water-to-cement ratio for the concrete within the scope of license renewal. If the values are outside the limits recommended in the GALL Report, explain how aging due to freeze-thaw will be effectively managed during the period of extended operation.

RAI 3.5.2.2.1-03

Background:

SRP-LR Sections 3.5.2.2.1.10, 3.5.2.2.2.2, and 3.5.2.2.2.4 address cracking due to expansion and reaction with aggregate. The associated GALL Report Items (C-04, T-03, and T-17) note that investigations, tests, and examinations performed in accordance with ASTM C295-54 or ASTM C227-50 can demonstrate that those aggregates do not react within the reinforced concrete. The GALL Report further states that for potentially reactive aggregates, aggregate-concrete reaction is not significant if the concrete was constructed in accordance with ACI 201.2R.

Issue:

The associated LRA sections state that the aggregates were tested in accordance with ASTM Specification C 289-65 for potential reactivity. The LRA does not discuss ASTM standards C295 or C227 and does not confirm that the concrete was constructed in accordance with the recommendations of ACI 201.2R-77.

Request:

Explain how ASTM C289-65 meets or exceeds the guidance in ASTM C227 or C295 for determining aggregate reactivity; or explain how ACI 301-66 and 318-63 meet the intent of ACI 201.2R. Include important concrete design parameters (e.g., water-cement ratio, air entrainment, etc.) which demonstrate the in-place concrete meets the recommendations in ACI 201.2R.

RAI 3.5.2.2.1-04

Background:

SRP-LR Sections 3.5.2.2.1.10, 3.5.2.2.2.2, and 3.5.2.2.2.4 address increase in porosity and permeability due to leaching of calcium hydroxide. The associated GALL Report Items

(C-02, T-02, and T-16) note that aging management is not necessary for inaccessible areas if there is documented evidence that confirms the concrete was constructed in accordance with the recommendations in ACI 201.2R Issue:

The associated LRA sections state that the concrete is designed in accordance with ACI 318-63 and constructed in accordance with ACI 301-66. The LRA does not confirm that the concrete was constructed in accordance with the recommendations of ACI 201.2R-77.

Request:

Clearly explain how ACI 301-66 and 318-63 meet the intent of ACI 201.2R. Include important concrete design parameters (e.g., water-cement ratio, air entrainment, etc.) which demonstrate the in-place concrete meets the recommendations in ACI 201.2R.

RAI 3.5.2.3-01

Background:

In LRA Table 3.5.2-2 (Component Supports Commodity Group) for component type supports for ASME Class 1 piping and components (high strength bolting for NSSS component supports), it states that high strength stainless steel bolting with yield strength greater than 150 ksi has no AERMs and does not require an AMP. A plant-specific note related to this component states that these bolts are utilized in the supports for the Unit 2 steam generators.

Issue:

Since the bolting has an intended function associated with structural support for the Unit 2 steam generators, it is unclear to the staff that the stainless steel bolting will be examined during the period of extended operation under an AMP for loss of intended function.

Request:

Confirm that the high-strength stainless steel bolting utilized in the supports for the Unit 2 steam generators will be examined under an AMP or provide a detailed explanation why an AMP is not required during the period of extended operation to demonstrate that there is no loss of intended function.

RAI 3.5.2.3-02

Background:

In LRA Table 3.5.2-3 (Containment Structure) for component type steel components (sump screen) having an intended function of filter in an air with steam or water leakage environment, it states that the SNGS Periodic Inspection Program will be used as the primary AMP. The LRA also states that the periodic inspections will be performed at a frequency of ten years based on plant and industry experience.

Issue:

Since the intended function of this stainless steel component is to act as a filter and other GALL AMPs perform inspections annually and during refueling outages to check for mechanisms such as erosion, corrosion, and biofouling, it is unclear to the staff that an inspection interval of ten years will be adequate to address the AERM.

Request:

Provide additional information or data to demonstrate that a ten-year inspection interval is adequate to address loss of material for the stainless steel sump screen exposed to air with steam or water leakage during the period of extended operation so there is no loss of intended function.

RAI 3.5.2.3-03

Background:

In LRA Table 3.5.2-5 (Fuel Handling Building) for component type penetration sleeves having an intended function of water-retaining boundary in a treated borated water environment, it states that the carbon steel is managed for loss of material/pitting and crevice corrosion by the SNGS Periodic Inspection AMP.

Issue:

During the staffs review of the SNGS Periodic Inspection AMP, it was noted that carbon steel components do not appear to be addressed by this AMP and a ten-year inspection frequency is utilized. The staff is unclear how the SNGS Periodic Inspection Program will be utilized to address this AERM and that the inspection interval is frequent enough to detect degradation in a timely manner during the period of extended operation.

Request:

Provide additional information to demonstrate that this component and material are addressed under the SNGS Periodic Inspection AMP and that a ten-year inspection interval is adequate to address loss of material for carbon steel exposed to a treated borated water environment during the period of extended operation so there is no loss of intended function.

RAI 3.5.2.3-04

Background:

In LRA Table 3.5.2-5 (Fuel Handling Building) for component type steel components (leak chase system) having an intended function of directing flow in a treated borated water (external) environment, it states that the carbon steel is managed for loss of material/pitting and crevice corrosion by either the SNGS One-Time Inspection Program or SNGS Water Chemistry Program. The LRA also notes that the spent fuel pools at SNGS have experienced leakage of

borated water that has migrated through small cracks in the concrete to reach the seismic gap between the containment structure and fuel handling building and that materials such as boric acid and minerals have accumulated in the leak collection and detection system that restricted normal drainage of fluid.

Issue:

The SNGS Water Chemistry Program manages the effects of cracking, loss of material, reduction of neutron-absorbing capacity, and reduction of heat transfer for reactor coolant system and related auxiliary systems containing treated water, reactor coolant, treated borated water and steam, including the primary side of steam generators. This program includes periodic sampling of primary and secondary water for the known detrimental contaminants (e.g.,

chlorides, fluorides, dissolved oxygen and sulfates). The water chemistry program does not provide for detection of aging effects. The SNGS One-Time Inspection Program is used to confirm the effectiveness of the SNGS Water Chemistry Program to mange loss of material, cracking, and reduction of heat transfer aging effects of steel in treated borated water. The one-time inspection program is a condition-monitoring program for identification of aging effects and evaluating the need for follow-up examinations to monitor progression of age-related degradation with inspections scheduled within 10 years prior to the period of extended operation. It is unclear to the staff how this AERM will be adequately addressed through the SNGS One-Time Inspection or Water Chemistry Programs.

Request:

Provide additional information to demonstrate that the proposed AMPs and a ten-year inspection interval are adequate to address this loss of material for carbon steel exposed to a treated borated water environment during the period of extended operation.

RAI 3.5.2.3-05

Background:

In LRA Table 3.5.2-8 (Pipe Tunnel) for component type stainless steel bolting (structural) having structural support function in an air-outdoor environment, it states that the bolting does not require an AMP for loss of preload/self-loosening.

Issue:

Since the LRA has identified an AERM for this component, it is unclear why an AMP is not required to at least monitor exposed surfaces of the bolting for loss of material due to corrosion, loose nuts, missing bolts, or other indications of loss of preload.

Request:

Provide additional information to demonstrate that an AMP(s) is not required to address the aging effect loss of preload for stainless steel structural bolting in an air-outdoor environment during the period of extended.