ML11138A017
| ML11138A017 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/18/2011 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| Download: ML11138A017 (10) | |
Text
1 SeabrookNPEm Resource From:
Wentzel, Michael Sent:
Wednesday, May 18, 2011 7:49 AM To:
'Cliche, Richard'
Subject:
Draft Summary for 5/16 Telecon Attachments:
051611, Telecon Summary Between NRC and NextEra Seabrook, Clarifying RAI Resonses and Draft RAIs (TAC No. ME4028).docx
- Rick, Attached is the draft summary of the 5/16 telecon. Please review and provide any comments. If you have any questions, please let me know.
- Thanks, Mike MichaelWentzel ProjectManager NRR/DLR/RPB1 (301)4156459 michael.wentzel@nrc.gov
Hearing Identifier:
Seabrook_License_Renewal_NonPublic Email Number:
1318 Mail Envelope Properties (C0A338EE37A11447B136119705BF9A3FD6E339F9FE)
Subject:
Draft Summary for 5/16 Telecon Sent Date:
5/18/2011 7:48:45 AM Received Date:
5/18/2011 7:48:47 AM From:
Wentzel, Michael Created By:
Michael.Wentzel@nrc.gov Recipients:
"'Cliche, Richard'" <Richard.Cliche@fpl.com>
Tracking Status: None Post Office:
HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 330 5/18/2011 7:48:47 AM 051611, Telecon Summary Between NRC and NextEra Seabrook, Clarifying RAI Resonses and Draft RAIs (TAC No. ME4028).docx 44072 Options Priority:
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Recipients Received:
LICENSEE: NextEra Energy Seabrook, LLC FACILITY: Seabrook Station
SUBJECT:
SUMMARY
OF TELEPHONE CONFERENCE CALL HELD ON MAY 16, 2011, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND NEXTERA ENERGY SEABROOK, LLC, TO CLARIFY THE RESPONSES TO THE REQUEST FOR ADDITIONAL INFORMATION AND DRAFT REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO THE SEABROOK STATION LICENSE RENEWAL APPLICATION (TAC NO. ME4028)
The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of NextEra Energy Seabrook, LLC (NextEra or the applicant), held a telephone conference call on May 16, 2011, to clarify information in the applicants April 22, 2011 response to the staffs requests for additional information (RAIs), and discuss the staffs draft RAIs concerning the Seabrook Station license renewal application (LRA). The telephone conference call was useful in clarifying the information provided in NextEras RAI responses, as well as the staffs intent of the draft RAIs.
provides a listing of the participants and Enclosure 2 contains a list of issues, some of which were sent to the applicant prior to the phone call to facilitate preparation for the phone call. Each issue identified includes a brief description on the status of each item.
The applicant had an opportunity to comment on this summary.
Michael Wentzel, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-443
Enclosures:
As stated cc w/encls: Distribution via Listserv
OFFICE LA:DLR PM:RPB1:DLR BC:RPB1:DLR NAME MWentzel BPham DATE 5/ /11 5/ /11 5/ /11
Memorandum to NextEra Energy Seabrook, LLC from M.Wentzel dated May XX, 2011
SUBJECT:
SUMMARY
OF TELEPHONE CONFERENCE CALL HELD ON MAY 16, 2011, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND NEXTERA ENERGY SEABROOK, LLC, TO CLARIFY THE RESPONSES TO THE REQUEST FOR ADDITIONAL INFORMATION AND DRAFT REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO THE SEABROOK STATION LICENSE RENEWAL APPLICATION (TAC NO. ME4028)
DISTRIBUTION:
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PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRapb Resource RidsNrrDlrRasb Resource RidsNrrDlrRerb Resource RidsNrrDlrRpob Resource MWentzel RPlasse BPham DWrona EMiller ICouret, OPA EDacus, OCA MSpencer, OGC WRaymond, RI DTifft, RI NMcNamara, RI NSheehan, RI DScrenci, RI JJohnson, RI ABurritt, RI
ENCLOSURE 1 TELEPHONE CONFERENCE CALL SEABROOK STATION LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS May 16, 2011 PARTICIPANTS AFFILIATIONS Michael Wentzel U.S. Nuclear Regulatory Commission (NRC)
John Daily NRC Kim Green NRC Antonio Dias NRC Jim Medoff NRC Roger Kalikian NRC Jim Gavula NRC Erach Patel NRC Richard Cliche NextEra Energy Seabrook, LLC. (NextEra)
Ali Kodal NextEra Paul Willoughby NextEra Paul Gurney NextEra Dennis Bemis NextEra Bob McCormack NextEra
ENCLOSURE 2 RAI Response and Draft RAI Clarifications for Seabrook Station
- 1. In order to better understand the applicants RAI responses dated April 22, 2011, the staff asked NextEra to explain whether the dual wall thimble tubes located in the Incore detector system (both moveable and/or fixed) were considered in scope for license renewal as a reactor coolant pressure boundary (RCPB) and, as such, handled accordingly in the LRA.
The staff asked NextEra to verify that the compression seal provided a pressure seal between the inner and outer flux thimble tubes. Additionally, the staff noted that the applicant committed to not use the older style, single walled movable incore thimble, or Movable In-core Detector System (MIDS), during the period of extended operation (PEO),
but requested clarification as to whether there was a commitment also covered the remainder of the current licensing period, and whether or not NextEra could rule out going back to using the MIDS using the 50.59 process at some point in the future.
Discussion: The applicant clarified that it considered the seal wall to be the RCPB, rather than the dual wall thimble tubes and, therefore, the thimble tubes did not require an aging management review. The staff noted that other plants with similar designs had identified these components as RCPBs and handled them accordingly. The applicant stated that the compression seal did provide a pressure seal between the inner and outer flux thimble tubes. As for the applicants commitment regarding MIDS, NextEra stated that its commitment did not cover the remaining portion of their existing licensing period, and that, while they had no plans to go back to using the MIDS using the 50.59 process, they could not rule out the possibility of doing so in the future.
The applicant agreed, at the staffs request, to provide the NRC with its responses to Bulletin 88-09, 88-09 supplement 1, and Information Notice 87-44, if applicable.
Additionally, the applicant agreed to provide information relating to Commitment Change Request 2010-01.
Background:
By letter dated February 24, 2011, the staff issued RAI 3.2.2.2.4.2-1 concerning the further evaluation for reduction of heat transfer in stainless steel heat exchanger tubes exposed to treated water environment, and requested the technical basis for not managing reduction in heat transfer due to fouling as an aging effect. In its response dated March 22, 2011, the applicant stated that fouling of these components would only occur through the buildup of corrosion products, and since the Seabrooks treated borated water contains boron, a corrosion inhibitor, this was not a credible aging effect/mechanism. The response also stated this determination was based on plant and industry operating experience, in that, fouling has not been identified in treated borated water environment which caused reduction of heat transfer in stainless steel heat exchanger tubes. The response further stated that Seabrooks conclusion is consistent with the NRC staff conclusions as stated in the Beaver Valley (Section 3.2.2.3.2) and Prairie Island (Section 3.2.2.2.4) Safety Evaluation Report (SER).
With regard to boron being a corrosion inhibitor, the staff notes that that the definition of treated water was modified in Revision 2 of the GALL Report, by deleting the statement regarding boron as a recognized corrosion inhibitor. In addition, the staff noted that Seabrooks LRA Table 3.1.2-4, Steam Generator, specified reduction in heat transfer for
ENCLOSURE 2 the steam generator tubes exposed to reactor coolant, which is treated borated water, as an aging effect being managed by the Water Chemistry Program. The associated line item cites generic note H, indicating that this aging effect is not in NUREG-1801 for this component, material and environment combination. Although the material is nickel alloy instead of stainless steel, it is not obvious why there would be a need to consider fouling for nickel alloy heat exchanger tubes but not stainless steel, because the corrosion resistance of both materials would be comparable.
With regard to the cited SERs, the staff notes that in every instance where heat transfer was identified as an intended function in treated borated water for Engineered Safeguards and Auxiliary Systems, both of the associated LRAs had line items that addressed reduction in heat transfer as an aging effect requiring management. The staff also noted that in many of these instances, in addition to using the water chemistry AMP, a separate verification of the AMPs effectiveness was also performed. Based on this, the staff did not consider NextEras conclusion to be validated by the staffs conclusions in the cited SERs.
Issue:
The RAI response stated that reduction in heat transfer is not an aging effect in a treated borated water environment, and stated that this determination was based on plant and industry operating experience. The staff notes that the SRP-LR clearly states that heat transfer functions should be considered for heat exchanger components because heat transfer may be a primary safety function. Furthermore, Branch Technical Position RLSB-1, for Applicable Aging Effects states that an aging effect should be identified as applicable for license renewal even if there is a prevention or mitigation program associated with that aging effect. The staff noted that Seabrooks LRA cited heat transfer as an intended function for heat exchanger components exposed to treated borated water in the containment building spray, residual heat removal, chemical and volume control, and spent fuel pool cooling systems; however, the LRA did not cite an aging management program to manage reduction of heat transfer.
In addition, the staff noted that all the LRAs submitted for pressurized water reactors (PWRs) in the last three years have included reduction in heat transfer as an aging effect requiring management in treated borated water for heat exchanger components.
Request:
Provide specific technical justification to demonstrate that heat exchanger tubes exposed to treated borated water which have an intended function of heat transfer need not include reduction of heat transfer as an aging effect requiring management. As part of the justification, include the plant-specific and industry operating experience cited in the response, showing that reduction in heat transfer had been specifically included as an attribute being investigated, and subsequently demonstrated not to be a credible aging effect/mechanism.
Discussion: The applicant requested that the second paragraph of the background discussion be deleted, since Table 3.1.2-4 referred to in the discussion was deleted in its response to RAI 3.1.2.4-1 dated February 3, 2011. As that table has been deleted the discussion in the second paragraph was no longer applicable. Additionally, the applicant asked the NRC to revise the discussion in the third paragraph of the background discussion to reflect the fact that Prairie Island LRA did not contain a relevant one-time inspection.
ENCLOSURE 2 Following discussion with the applicant, the NRC will modify the draft request as follows:
Background:
By letter dated February 24, 2011, the staff issued RAI 3.2.2.2.4.2-1 concerning the further evaluation for reduction of heat transfer in stainless steel heat exchanger tubes exposed to treated water environment, and requested the technical basis for not managing reduction in heat transfer due to fouling as an aging effect. In its response dated March 22, 2011, the applicant stated that fouling of these components would only occur through the buildup of corrosion products, and since the Seabrooks treated borated water contains boron, a corrosion inhibitor, this was not a credible aging effect/mechanism. The response also stated this determination was based on plant and industry operating experience, in that, fouling has not been identified in treated borated water environment which caused reduction of heat transfer in stainless steel heat exchanger tubes. The response further stated that Seabrooks conclusion is consistent with the NRC staff conclusions as stated in the Beaver Valley (Section 3.2.2.3.2) and Prairie Island (Section 3.2.2.2.4) Safety Evaluation Report (SER).
With regard to the cited SERs, the staff notes that in every instance where heat transfer was identified as an intended function in treated borated water for Engineered Safeguards and Auxiliary Systems, both of the associated LRAs had line items that addressed reduction in heat transfer as an aging effect requiring management. The staff also noted for Beaver Valley that in many of these instances, in addition to using the water chemistry AMP, a separate verification of the AMPs effectiveness was also performed. Based on this, the staff did not consider NextEras conclusion to be validated by the staffs conclusions in the cited SERs.
- 3. RAI B.2.12-9
Background:
By letter dated January 21, 2011, the staff issued RAI B.2.1.12-7 requesting that the applicant justify why the Closed-Cycle Cooling Water System Program, which is based on EPRI 1007820, Closed Cooling Water Chemistry Guideline, does not need to manage microbiologically influenced corrosion (MIC) in the closed cycle cooling water systems. In its response dated February 18, 2011, the applicant stated that the GALL Report does not include any line items for PWRs that include the closed-cycle cooling water environment with MIC as an aging effect, and therefore, it did not consider MIC to be an aging effect requiring management. The applicant also stated that its review of plant-specific operating experience did not identify any MIC issues in the close-cycle cooling water systems, and reiterated that the Closed Cycle Cooling Water System Program does not manage loss of material due to MIC.
The staff noted that the applicants closed cycle cooling systems for its diesel generator jacket water, fire pump diesel coolant, and control building air handling systems use glycol as a chemical treatment. The staff also noted that MIC is a stated concern in EPRI 1007820 for closed cycle cooling systems utilizing glycol formulations.
Issue:
ENCLOSURE 2 The applicant did not provide a technical basis for why loss of material due to MIC does not need to be included as part of the Closed-Cycle Cooling Water System Program. The staffs positionand that stated in EPRI 1007820is that MIC can occur in closed cycle cooling water systems. The staff further noted that the applicants lack of plant-specific operating experience associated with MIC may be attributable to the existing additives that mitigate this mechanism. However, as noted in SRP-LR Section A.1.2.1, Applicable Aging Effects, an aging effect should be identified as applicable for license renewal even if there is a prevention or mitigation program associated with that aging effect.
Request:
Please provide plant-specific data to demonstrate that the lack of problems with MIC at the site cannot be attributed to the existing chemical treatment in the closed cooling water systems or revise the Closed-Cycle Cooling Water System Program to include monitoring for MIC.
Discussion: The applicant clarified that consistent with EPRI 1007820, the basis for the Seabrook Closed-Cycle Cooling Water System Program, biological monitoring is performed as a diagnostic to check for the presence of microbiological organisms. No changes will be made to this request based on the discussion.