ML11139A146

Summary of Telephone Conference Call Held Between the NRC and Nextera Energy Seabrook, LLC, to Clarify Responses to RAI and Draft Requests for Additional Information Pertaining to the Seabrook Station LRA

ML11139A146
Person / Time
Site:	Seabrook
Issue date:	06/09/2011
From:	Michael Wentzel License Renewal Projects Branch 1
To:
Wentzel M
References
TAC ME4028
Download: ML11139A146 (8)

Text

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• • • • ..jl LICENSEE: NextEra Energy Seabrook, LLC FACILITY: Seabrook Station

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 applicant's April 22, 2011, response to the staffs requests for additional information (RAls), and discuss the staff's draft RAls concerning the Seabrook Station license renewal application. The telephone conference call was useful in clarifying the information provided in NextEra's RAI responses, as well as the staff's intent of the draft RAls.

Enclosure 1 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.

I!WLLuy Michael J. went£, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-443

Enclosures:

As stated cc w/encls: Listserv

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 1

RAI Response and Draft RAI Clarifications for Seabrook Station

1. In order to better understand the applicant's RAI responses dated April 22, 2011, the U.S.

Nuclear Regulatory Commission (NRC or the staff) asked NextEra (the applicant) 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 license renewal application (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 Movable Incore Detector System (MIDS), during the period of extended operation (PEO), but requested clarification as to whether there was a commitment also covering 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 high-pressure seal at the seal table 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 high-pressure seal did provide a pressure seal between the inner and outer flux thimble tubes. As for the applicant's 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 staff's 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.

2. Draft Follow up RAI 3.2.2.2.4.2-1A (also applicable as follow up to RAI 3.3.2.2.2-1)

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 Seabrook's 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 Seabrook's 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).

ENCLOSURE 2

- 2 With regard to boron being a corrosion inhibitor, the staff notes 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 Seabrook's LRA Table 3.1.2-4, "Steam Generator," specified reduction in heat transfer for 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 aging management program (AMP), a separate verification of the AMP's effectiveness was also performed. Based on this, the staff did not consider NextEra's conclusion to be validated by the staff's 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 Seabrook's 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 LRA's 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

- 3 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 RAI3.1.2.4-1 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 ref/ect the fact that Prairie Island LRA did not contain a relevant one-time inspection.

Following discussion with the applicant, the NRC will modify the draft request as follows:

Background:

By letter dated February 24, 2011, the staff issued RAI3.2.2.2.4.2-1 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 Seabrook's 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 Seabrook's 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 AMP's effectiveness was also performed.

Background:

By letter dated January 21, 2011, the staff issued RAI 8.2.1.12-7 requesting that the applicant justify why the Closed-Cycle Cooling Water System Program, which is based on EPRI1007820, "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.

-4 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 applicant's closed cycle cooling water 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:

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 staff's position-and that stated in EPRI 1007820-is that MIC can occur in closed cycle cooling water systems. The staff further noted that the applicant's 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-Cycle 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.

June 9,2011 LICENSEE: NextEra Energy Seabrook, LLC FACILITY: Seabrook Station

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 applicant's April 22, 2011, response to the staff's requests for additional information (RAls), and discuss the staff's draft RAls concerning the Seabrook Station license renewal application. The telephone conference call was useful in clarifying the information provided in NextEra's RAI responses, as well as the staff's intent of the draft RAls. 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.

IRA!

Michael J. 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: Listserv DISTRIBUTION:

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• concurrence via email OFFICE LA:DLR* PM:DLR/RPB1 PM: DLRlRPB1 BC: DLRlRPB1 PM:RPB1 :DLR NAME YEdmonds MWentzel RPlasse BPham MWentzel I DATE 06/07/2011 -

06/07/2011 ---

06/09/2011 06/08/2011 06/09/2011 OFFICIAL RECORD COpy

Memorandum to NextEra Energy Seabrook, LLC from Michael J. Wentzel dated June 09, 2011

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)

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