ML103330408

FW: Comments to NextEras RAI Responses Via Letter NRC 2010-0136, Dtd 11/8/10

ML103330408
Person / Time
Site:	Point Beach
Issue date:	11/18/2010
From:	Beltz T Plant Licensing Branch III
To:	Hale S Nextera Energy
beltz T, NRR/DORL/LPL3-1, 301-415-3049
References
TAC ME1044, TAC ME1045
Download: ML103330408 (4)

Text

From:

Beltz, Terry Sent:

Thursday, November 18, 2010 1:48 PM To:

Hale, Steve

Subject:

FW: comments to NextEra's RAI responses via letter NRC 2010-0136, dtd 11/8/10 Steve Below are the clarifications required by the NRC staff related to the review of the LAR 261 for the extended power uprate. Please let me know when you and your staff are available for a phone call to resolve the reviewers remaining issues associated with the review.

As part of the discussion, it will be determined if the information requested by the NRC staff will be required to be formally submitted under O&A and placed on the docket.

Sincerely, Terry A. Beltz, Senior Project Manager NRR/ADRO/DORL/LPL3-1 (301) 415-3049 From: Tsirigotis, Alexander Sent: Thursday, November 18, 2010 11:43 AM To: Beltz, Terry; Khanna, Meena

Subject:

comments to NextEra's RAI responses via letter NRC 2010-0136, dtd 11/8/10 NextEra Energy Transmittal Letter NRC 2010-0136, dated November 8, 2010 Response to EMCB RAI 14 (pg 2/12)

The geometry that the SCF of 1.5 vs. 3.27 applies to is not clearly understood as well as whether a weld in that location is involved.

Response to EMCB RAI 11 (pg 19/41) a) Is the 250 deltaT the greatest deltaT that can be experienced from all design transients?

b) From the explanation provided the primary plus secondary stress intensity value (Sn) for the outlet Rx Nozzle support pad should be 68ksi and not 67ksi (the difference though is insignificant).

c) Looking at results from other PWRs, the primary plus secondary Sn of the Inlet nozzle pad is greater than the Sn of the outlet nozzle pad. Therefore, it would be prudent to provide the range of primary plus secondary Sn values for the Inlet and Outlet nozzle support pads.

Response to EMCB RAI 20 (pg 28/41)

RAI requested to discuss whether any acoustic resonance could be generated at EPU flow or during power ascension to EPU power in the feedwater (FW) and main steam lines and describe how the acoustics-driven dynamic pressure loading acting on the components inside

the steam generator under EPU conditions will be estimated. The response to RAI 20 did not include a discussion pertaining to FW.

Response to EMCB RAI 25 (pg 35/41)

RAI 25 in part requested that when a different (and reconciled) code than the original code of construction was used for evaluating the structural adequacy of SSCs to provide assurance that the allowable values from the original code of construction have been utilized with the reconciled (later) year code. While the response has provided such an assurance for the case of the SG section of the response, it is not clear that that is also the case with the remainder SSCs.

Response to EMCB RAI 1 (pg 2/41)

In reference to BOP, response statement that he requirements and intent stipulated in the alter codes of record have been satisfied is not acceptable. Also, in reference to RCS supports, response states in two places that Updated revisions to [AISC 6th Ed] can be used provided the requirements and intent stipulated in the later codes of record have been satisfied. This statement is also not acceptable. The original code of construction requirements and intent need to be satisfied when performing a code reconciliation and not the other way around.

Response also states that:

The EPU evaluations for BOP pipe supports were evaluated using the AISC code, Sixth Edition, including updated revisions through the Ninth Edition.

Please be specific which code has been utilized for EPU pipe support evaluations and if different than the AISC 6th edition state whether the later edition used has been reconciled to the 6th edition and assure that 6th edition allowables have been utilized with the reconciled code.

FSAR Table 4.1-9 states that:

The code requirement is the USAS B31.I Power Piping Code and that the version of the Code which was in effect at the time the original component was ordered is applicable.

In reference to NSSS piping and supports, response states that:

The PBNP NSSS piping evaluations and qualifications for EPU conditions also utilized the ANSl Code for Pressure Piping B31.1, 1973 Edition, as was used in the existing plant design basis AOR. Therefore, the code of record allowable values used in the existing plant design basis AOR are used for the EPU evaluation.

Assure that reconciliation to later codes used exists and provide assurance that EPU evaluations have been performed utilizing allowables from the code of construction that the original component was ordered, as required by the plant FSAR.

Response to EMCB RAI 7 (pg 15/41)

Responses letter Attachment 2 provides response to RAI 7 in reference to FW PMP Nozzle loads. It is not clear why calculated nozzle loads have been compared at some cases against

generic API allowables and at other cases against vendor allowables. Why not use vendor supplied pump specific allowable nozzle loads for all cases? By examining the tables in attachment 2 it is indicated that comparison to API has been made where calculated loads exceeded the vendor allowables. Has the vendor been informed and been supplied with calculated pipe loads acting on its pump nozzles and has the vendor provide the plant with documentation which shows that the calculated loads that exceed the vendor allowable values (regardless whether or not meet the generic API allowable values) are acceptable for the structural integrity of the pump (flanges and flange bolting, casing, pump supports and hold-down anchors, etc) and acceptable for its intended function? (It is noted that WNES has approved such a case for one of the SG MS nozzles). It is noted that in one case a pipe induced FW pump nozzle load exceeded the vendor allowable by approximately 62%. What controlled documentation (such as calculations) exist that accept nozzle loads which have exceeded the vendor allowables?

Response to EMCB RAI 15 (pg 23/41)

The RAI requested to verify whether or not the fatigue CUF values shown on Table 2.2.2.3-3, in reference to RPV components, reflect effects from environmentally assisted fatigue and If not to provide a justification. The response provides a short explanation and concludes that:

[It] was not necessary to include the effects from environmentally assisted fatigue into the CUF values shown on LAR 261, Attachment 5, Table 2.2.2.3-3.

EPU LR (LAR 261, Attachment 5) in reference to RPV components states that:

For the reactor vessel components determined to be potentially impacted by environmental fatigue, the environmental effects on fatigue were evaluated based on the updated fatigue usage factors determined from the EPU evaluations. The cumulative fatigue usage factors for the inlet nozzle, outlet nozzle, and bottom-head-to-shell juncture, with environmentally-assisted fatigue factors applied, are still below the ASME code limit of 1.0.

The above two statements are not consistent. Has environmentally assisted fatigue been incorporated in the licensing renewal of the Point Beach Nuclear Plant, Units 1 and 2, which was approved by the NRC on December 2005?

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Subject:

FW: comments to NextEra's RAI responses via letter NRC 2010-0136, dtd 11/8/10 Sent Date: 11/18/2010 12:14:32 PM Received Date: 11/18/2010 1:48:00 PM From: Beltz, Terry Created By: Terry.Beltz@nrc.gov

Recipients:

Steve.Hale@nexteraenergy.com (Hale, Steve)

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