ML110260266

Request for Additional Information Related to the Review of the Seabrook Station License Renewal Application

ML110260266
Person / Time
Site:	Seabrook
Issue date:	02/24/2011
From:	Plasse R License Renewal Projects Branch 2
To:	Freeman P NextEra Energy Seabrook
Plasse, R, A., NRR/DLR, 415-1427
References
TAC ME4028
Download: ML110260266 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 February 24, 2011 Mr. Paul Freeman Site Vice President clo Mr. Michael O'Keefe NextEra Energy Seabrook, LLC P.O. Box 300 Seabrook, NH 03874

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE REVIEW OF THE SEABROOK STATION LICENSE RENEWAL APPLICATION (TAC NUMBER ME4028)

Dear Mr. Freeman:

By letter dated May 25,2010, NextEra Energy Seabrook, LLC submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54, to renew Operating License NPF-86 for Seabrook Station, Unit 1, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.

The request for additional information was discussed with Mr. Rick Cliche, 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 at 301-415-1427 or bye-mail at richard.plasse@nrc.gov.

Sincerely,

~

Richard A. Plasse, Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-443

Enclosure:

As stated cc w/encl: Distribution via Listserv

SEABROOK STATION LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION SET 10 RAI 3.2.2.2.4.2-1

Background:

SRP-LR Section 3.2.2.2.4, item 2, is associated with SRP-LR Table 3.2.1, item 3.2.1-10, and states that reduction of heat transfer due to fouling could occur for stainless steel heat exchanger tubes exposed to treated water. The SRP-LR also states that the existing program relies on control of water chemistry to manage reduction of heat transfer due to fouling but since control of water chemistry may have been inadequate, the effectiveness of the chemistry control program should be verified to ensure that reduction of heat transfer due to fouling is not occurring. SRP-LR Table 3.2-1, item 3.2.1-10, states that it applies to both BWRs and PWRs, and cites related item EP-34, which corresponds to GALL items V.A-16 for PWR containment spray system heat exchanger tubes and V.D2-13 for BWR emergency core cooling system heat exchanger tubes. Although the SRP-LR and the GALL Report list the environment as treated water, the basis for including GALL item EP-34, as documented in NUREG-1833, was a precedent established in the R.E. Ginna SER, NUREG-1786. The environment specifically noted in the Ginna SER was "treated water - borated," and as such, the applicable environment for this item is not strictly limited to treated water, and also includes treated borated water.

LRA Section 3.2.2.2.4, item 2, states that item 3.2.1-10 is not applicable to Seabrook, and that there are no stainless steel heat exchanger tubes exposed to treated water in the ESF systems.

However, the staff noted that LRA Section 3.2 includes several systems with heat exchanger tubes exposed to treated borated water with an intended function of heat transfer that do not indicate that reduction in heat transfer due to fouling is an aging effect being managed.

Issue:

It is not clear to the staff why LRA Section 3.2.2.2.4, item 2, and LRA Table 3.2.1, item 3.2.1-10, state that this item is not applicable, given that NUREG-1833 states that the item is applicable to both BWR and PWR heat exchanger tubes exposed to treated water and treated borated water.

It is also not clear to the staff why several heat exchanger items in LRA Section 3.2 specify an intended function of heat transfer, but do not indicate that reduction in heat transfer due to fouling is an aging effect being managed.

Reguest:

1) Provide the technical bases for the determination that LRA Section 3.2.2.2.4, item 2, which is associated with LRA Table 3.2-1, item 3.2.1-10, is not applicable to Seabrook. If it is determined to be applicable, provide the information regarding how Seabrook intends to meet the further evaluation criteria specified in the corresponding SRP-LR section.

2) For the line items in LRA Section 3.2 which have an intended function specified as "heat transfer," provide the technical bases for not managing reduction in heat transfer due to fouling as an aging effect.

ENCLOSURE

-2 RAI3.3-1

Background:

Stress corrosion cracking of stainless steels is known to occur in outdoor air containing atmospheric chlorides. Locations near the coast will have a higher concentration of chloride aerosol particles and have a higher susceptibility for stress corrosion cracking. The LRA states that stainless steel components exposed to outdoor-air will be susceptible to loss of material, but does not identify stress corrosion cracking as an applicable aging effect.

Issue:

Because the Seabrook Station is within five miles of a saltwater coastline, it is expected that the stainless steel exposed to outdoor-air will be exposed to higher levels of chlorides. It is not clear to the staff why cracking due to stress corrosion cracking has not been identified as an applicable aging effect for the stainless steel components exposed to outdoor-air.

Request:

Provide additional information on why atmospheric chloride induced stress corrosion cracking is not considered to be an applicable aging effect for stainless steel components exposed to outdoor-air. If it is determined that stress corrosion cracking is an applicable aging affect, provide additional information on how it will be managed.

RAI 3.3.2.2.2-1

Background:

SRP-LR Section 3.3.2.2.2 is associated with SRP-LR Table 3.3.1, item 3.3.1-3, and states that reduction of heat transfer due to fouling could occur for stainless steel heat exchanger tubes exposed to treated water. The SRP-LR also states that the existing program relies on control of water chemistry to manage reduction of heat transfer due to fouling, but since control of water chemistry may have been inadequate the effectiveness of the chemistry control program should be verified to ensure that reduction of heat transfer due to fouling is not occurring. SRP-LR Table 3.3.1, item 3.3.1-3, states that this item applies to BWRs and PWRs, and cites related item AP-62, which corresponds to GALL items VII.A4-4 for BWR spent fuel pool cooling and cleanup heat exchanger tubes and VII.E3-6 for reactor water cleanup system heat exchanger tubes for both BWRs and PWRs. Although the SRP-LR and the GALL Report list the environment as treated water, the basis for including GALL item AP-62, as documented in NUREG-1833, was a precedent established in the R.E. Ginna SER, NUREG-1786. The environment specifically noted in the Ginna SER was "treated water - borated," and as such, the applicable environment for this item is not strictly limited to treated water, and also includes treated borated water.

LRA Section 3.3.2.2.2 states that item 3.3.1-3 is not applicable for auxiliary system components at Seabrook, and that this line item is associated with GALL Report item VII.E3-6 which is applicable to BWR reactor water cleanup system heat exchangers. However, the staff noted that LRA Section 3.3 includes several systems with heat exchanger tubes exposed to treated

- 3 borated water with an intended function of "heat transfer;" that do not indicate that reduction of heat transfer due to fouling is an aging effect being managed.

Issue:

It is not clear to the staff why LRA Section 3.3.2.2.2, which is associated with SRP-LR Table 3.3.1, item 3.3.1-3, states that this item is not applicable, given that NUREG-1833 states that the item is applicable to both BWR and PWR heat exchanger tubes exposed to treated water and treated borated water. It is also not clear to the staff why several heat exchanger items in LRA Section 3.3 specify an intended function of "heat transfer," but do not indicate that reduction in heat transfer due to fouling is an aging effect being managed.

Request:

1) Provide the technical bases for the determination that LRA Section 3.3.2.2.2, which is associated with LRA Table 3.3.1, item 3.3.1-3, is not applicable to Seabrook. If it is determined to be applicable, provide information regarding how Seabrook intends to meet the further evaluation criteria specified in the corresponding SRP-LR section.

2) For the line items in LRA Section 3.3 which have an intended function specified as "heat transfer," provide the technical bases for not managing reduction in heat transfer due to fouling as an aging effect.

RAI 3.3.2.3.37 ~1

Background:

Table IX.C of the GALL Report states that copper alloy (> 15% Zn) is susceptible to a variety of aging effects and mechanisms, including loss of material due to selective leaching. The GALL AMP XI.M33, "Selective Leaching," recommends visual inspection of selected components that may be susceptible to selective leaching, coupled with either hardness measurements (where feasible, based on form and configuration) or mechanical examination techniques to manage the loss of material due to selective leaching aging effect. .

LRA supplement 2, dated November 15, 2010, amended the LRA to add line items to manage the loss of preload and loss of material aging effects for copper alloy (> 15% Zn) bolting exposed to raw water in the service water system using the Bolting Integrity Program and Buried Piping and Tanks Inspection Program.

Issue:

The applicant's LRA, as amended, does not appear to address loss of material due to selective leaching.

Furthermore, the applicant's Bolting Integrity Program and Buried Piping and Tanks Inspection Program include visual inspections to detect loss of material, but neither program includes the additional hardness measurements or mechanical examination techniques recommended by the GALL Report to manage the loss of material due to selective leaching aging effect.

-4 Request:

State why it is acceptable to manage selective leaching with a visual inspection program, or provide an AMR line item, which credits an AMP that includes inspection techniques, to address loss of material due to selective leaching for copper alloy (> 15% Zn) bolting exposed to raw water in the service water system.

RAI 3.4.2.3.4-1

Background:

In LRA Table 3.4.2-4, the applicant stated that copper alloy> 15% Zn valve body exposed to condensation (external) is being managed for lo~s of material by the External Surfaces Monitoring Program. The AMR line item cites generic note G. The applicant's External Surface Monitoring Program does not include activities to manage loss of material due to selective leaching.

The GALL Report states that "Condensation on the surfaces of systems with temperature below the dew point is considered raw water, due to potential for surface contamination." The GALL Report further states that copper alloys containing greater than 15% zinc exposed to a raw water environment may be susceptible to selective leaching of one of the metal components.

Issue:

It is unclear to the staff why the copper alloy with greater than 15% Zn valve body exposed to condensation is not being managed for selective leaching, given that exposure to condensation could promote accumulation of contaminants and lead to selective leaching.

Request:

Explain why the copper alloy with greater than 15% Zn valve body exposed to condensation (external) is not being managed for selective leaching. If it is determined that selective leaching is an appropriate aging effect/mechanism to be managed, explain what aging management program and inspection method(s) (e.g., hardness measurement, etc.) are to be used to manage the loss of material due to selective leaching (See RAI 3.3.2.3.37-1).

RAI 8.2.1.3-2 Follow-up

Background:

RAI B.2.1.3-2, in part, requested the applicant to clarify whether the lubricant, which is used for the installation and removal of the reactor head closure studs, is stable at the operating temperatures of the reactor head closure studs. In its response dated January 13, 2011, the applicant stated that the lubricant (WD-40) has an operating temperature range from -10°F to 200°F in comparison with the operating temperature of the reactor head closure studs which is estimated to approach 500°F. The applicant also stated that according to the manufacturer of

- 5 the lubricant, when the lubricant is exposed to the reactor vessel metal temperature at operating condition, it would carbonize.

RG 1.65, which is referenced in the GALL Report, addresses the guidance that lubricants for the stud bolting are permissible provided they are stable at operating temperatures of the reactor head closure stud bolting.

Issue:

The staff noted that the operating temperature range of the applicanfs lubricant (-10 to 200 OF) is significantly lower than the operating temperature of the reactor head closure studs that is estimated to approach 500 of by the applicant. The staff also noted that the lubricant carbonizes at the operating temperature of the closure studs. Therefore, the applicanfs use of the lubricant is not consistent with the guidance in RG 1.65 that lubricants for the stud bolting are permissible provided they are stable at operating temperatures of the reactor head closure stud bolting.

In addition, the staff finds a concern that the carbonization of the lubricant and accumulation of carbonization by-products on the studs and flange threads degrade the lubrication process of the bolting such that the removal operation of the studs may cause sticking, galling or thread damage of the reactor head closure bolting.

Request:

1) Justify why the use of the lubricant (WD-40), the operating temperature of which is significantly lower than that of the reactor head closure studs, is consistent with the guidance in RG 1.65 and GALL Report that lubricants for the stud bolting are permissible provided they are stable at operating temperatures of the reactor head closure stud bolting, as addressed in LRA Section 8.2.1.3 stating the applicanfs implementation of the guidance in RG 1.65 for lubricants.

In addition, justify the use of the lubricant (WD-40), which has an operating temperature range from -10°F to 200°F, on the reactor head closure studs, which has an operating temperature that is estimated to approach 500°F. If a justification for the use of this lubricant cannot be provided, commit to the use of a lubricant that will remain stable at operating temperatures of the reactor head closure stud bolting.

2) Justify why the carbonization of the lubricant and accumulation of carbonization by-products on the studs and flange threads do not cause sticking, galling or thread damage of the studs and flange threads. As part of the justification, clarify whether the applicanfs operating experience is in agreement with the justification.

February 24, 2011 Mr. Paul Freeman Site Vice President clo Mr. Michael O'Keefe NextEra Energy Seabrook, LLC P.O. Box 300 Seabrook, NH 03874

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE REVIEW OF THE SEABROOK STATION LICENSE RENEWAL APPLICATION (TAC NUMBER ME4028)

Dear Mr. Freeman:

By letter dated May 25,2010, NextEra Energy Seabrook, LLC submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54, to renew Operating License NPF-86 for Seabrook Station, Unit 1, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.

The request for additional information was discussed with Mr. Rick Cliche, 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 at 301-415-1427 or bye-mail at richard.plasse@nrc.gov.

Sincerely, IRA!

Richard A. Plasse, Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-443

Enclosure:

As stated cc w/encl: Distribution via Listserv DISTRIBUTION:

See next page ADAMS Accession Number: ML110260266 *via email OFFICE LADLR* PM: DLR/RPB2 OGC (NLO) BC: DLR/RPB2 PM: DLR/RPB2 NAME a RPlasse MSpencer DWrona RPlasse

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DATE 2/23/11 2/22/11 2/24/11 2/24/11 OFFICIAL RECORD COPY

Letter to Paul Freeman from Richard A. Plasse dated February 24, 2011

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE REVIEW OF THE SEABROOK STATION LICENSE RENEWAL APPLICATION (TAC NUMBER ME4028)

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