SBK-L-11133, Response to Request for Additional Information - Set 14 RAI B.1.4-1
| ML11178A236 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/24/2011 |
| From: | Freeman P NextEra Energy Seabrook |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| SBK-L-11133, TAC ME4028 | |
| Download: ML11178A236 (23) | |
Text
NEXTeraM ENERGY SEABROK June 24, 2011 SBK-L- 11133 Docket No. 50-443 U.S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 Seabrook Station Response to Request for Additional Information NextEra Energy Seabrook License Renewal Application Request for Additional Information - Set 14 RAI B. 1.4-1
References:
- 1. NextEra Energy Seabrook, LLC letter SBK-L-10077, "Seabrook Station Application for Renewed Operating License," May 25, 2010. (Accession Number ML101590099)
- 2. NRC Letter "Request for Additional Information Related to the Review of the Seabrook Station License Renewal Application (TAC NO. ME4028) - Request for Additional Information Set 14," May 23, 2011. (Accession Number MLII 132A007)
- 3. NextEra Energy Seabrook, LLC letter SBK-L- 11123, "Seabrook Station, Response to Request for Additional Information, NextEra Energy Seabrook License Renewal Application, Request for Additional Information - Set 14, June 2, 2011. (Accession Number ML11154A133)
- 4. NextEra Energy Seabrook, LLC letter SBK-L-11062, "Seabrook Station, Response to Request for Additional Information, NextEra Energy Seabrook License Renewal Application, Request for Additional Information - Set 11, April 5, 2011. (Accession Number ML110960647)
In Reference 1, NextEra Energy Seabrook, LLC (NextEra) submitted an application for a renewed facility operating license for Seabrook Station Unit 1 in accordance with the Code of Federal Regulations, Title 10, Parts 50, 51, and 54.
NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874
United States Nuclear Regulatory Commission SBK-L- 11133 / Page 2 In Reference 2, the NRC requested additional information in order to complete its review of the License Renewal Application. In Reference 3, NextEra provided a response to the RAIs with the exception of RAI B. 1.4-1. Enclosure 1 contains NextEra's response to the remaining request for additional information, RAI B. 1.4-1.
In Reference 4, NextEra provided a response to RAI B.2.1.12-8. During a subsequent station activity, a minor discrepancy was noted with the data utilized in the RAI response. The discrepancy has been entered into the corrective action system. Enclosure 2 provides a revised response to this RAI. The conclusion reached in the RAI remains valid, that the effects of the elevated hydrazine and sulfate levels are insignificant and would not have caused accelerated aging of the components in the thermal barrier system.
There is a new regulatory commitment contained in this letter. Enclosure 3 provides the LRA Appendix A - Final Safety Report Supplement Table A.3, License Renewal Commitment List, updated to reflect the license renewal commitment changes made in NextEra's correspondence to date.
If there are any questions or additional information is needed, please contact Mr. Richard R Cliche, License Renewal Project Manager, at (603) 773-7003.
If you have any questions regarding this correspondence, please contact Mr. Michael O'Keefe, Licensing Manger, at (603) 773-7745.
Sincerely, NextEra Energy Seabrook LLC Paul 0. Freeman (7 Site Vice President
United States Nuclear Regulatory Commission SBK-L- 11133 / Page 3 Enclosure cc:
W.M. Dean, NRC Region I Administrator G. E. Miller, NRC Project Manager, Project Directorate 1-2 W. J. Raymond, NRC Resident Inspector R. A. Plasse Jr., NRC Project Manager, License Renewal M. Wentzel, NRC Project Manager, License Renewal Mr. Christopher M. Pope Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399
United States Nuclear Regulatory Commission SBK-L-11133 / Page 3 NEXTeraTM ENERGYPCVA I, Edward T. Metcalf, Plant General Manager of NextEra Energy Seabrook, LLC hereby affirm that the information and statements contained within are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.
Sworn and Subscribed Before me this
_day of June, 2011 Edward T. letcalO Plant General Manager
Enclosure 1 to SBK-L-11133 Response to Request for Additional Information NextEra Energy Seabrook License Renewal Application Request for Additional Information - B.1.4-1
United States Nuclear Regulatory Commission SBK-L- 11133 / Enclosure 1 / Page 2 RAI B.1.4-1
Background
Pursuant to 10 CFR 54.21 (a)(3), a license renewal applicant is required to demonstrate that the effects of aging on structures and components subject to an aging management review are adequately managed so that their intended functions will be maintained consistent with the current licensing basis for the period of extended operation. Section 3.0.1 of NUREG- 1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants,"
Revision 2 (SRP-LR), defines an aging management review as the identification of the materials, environments, aging effects, and aging management programs (AMPs) credited for managing the aging effects. In turn, SRP-LR Section A. 1.2.3 defines an acceptable AMP as consisting often elements. Element 10, "Operating Experience," in part, is described in SRP-LR Section A. 1.2.3.10, paragraph 1, as follows:
Consideration of future plant-specific and industry operating experience relating to aging management programs should be discussed. Reviews of operating experience by the applicant in the future may identify areas where aging management programs should be enhanced or new programs developed.
An applicant should commit to a future review of plant-specific and industry operating experience to confirm the effectiveness of its aging management programs or indicate a need to develop new aging management programs
[emphasis added]. This information should provide objective evidence to support the conclusion that the effects of aging will be managed adequately so that the structure and component intended function(s) will be maintained during the period of extended operation.
In addition, 10 CFR 54.21 (d) requires the application to contain a final safety analysis report (FSAR) supplement. This supplement must contain a summary description of the programs and activities for managing the effects of aging and the evaluation of time-limited aging analyses for the period of extended operation.
Based on its review of the Seabrook Station, Unit 1 license renewal application (LRA), the staff determined that Section B. 1.4 provides a general description of how the applicant gathered and considered operating experience in preparing its LRA, and Sections B.2. 1.1 through B.2.1.37, B.2.2.1 through B.2.2.3, B.2.3.1, and B.2.3.2 summarize the specific operating experience considered for each AMP.
Issue Although LRA Sections B. 1.4, B.2. 1.1 through B.2.1.37, B.2.2.1 through B.2.2.3, B.2.3. 1, and B.2.3.2 describe how the applicant incorporated operating experience into its AMPs, they do not fully describe how the applicant will use future operating experience to ensure.that the AMPS will remain effective for managing the aging effects during the period of extended operation.
The main focus of these LRA sections is on how the applicant evaluated operating experience
United States Nuclear Regulatory Commission SBK-L-1 1133 / Enclosure 1 / Page 3 available at the time the application was prepared to justify the adequacy of its proposed AMPs.
Some of the program descriptions contain statements indicating that future plant-specific and industry operating experience will be used to adjust the programs as appropriate. However, for the majority of the AMPs, it is not clear whether the applicant currently has or intends to develop procedures to monitor operating experience on an ongoing basis and use it to ensure the continued effectiveness of the AMPs. The LRA also does not state whether new AMPs will be developed, as necessary.
Request Describe the programmatic activities that will be used to continually identify aging issues, evaluate them, and, as necessary, enhance the AMPs or develop new AMPs for license renewal. In this description, address the following:
" Describe the sources of plant-specific and industry operating experience that will be monitored on an ongoing basis to identify potential aging issues. Indicate whether these plant-specific sources require monitoring: corrective action program, system health reports, licensee event reports (LERs), and the results of inspections performed under the AMPs. Similarly, indicate whether these industry sources require monitoring: vendor recommendations, revisions to industry standards on which the AMPs are based, LERs from other plants, NRC Bulletins, Generic Letters, Regulatory Issue Summaries, Information Notices, Regulatory Guides, License Renewal Interim Staff Guidance, and revisions to NUREG-1801, "Generic Aging Lessons Learned (GALL) Report." Describe the criteria used to classify a particular piece of information as aging related and outline the training provided to plant personnel so that they can adequately make such classifications.
" Describe how the identified aging issues will be further evaluated to determine their potential impact on the plant aging management activities. Indicate whether the affected structures and components and their materials, environments, aging effects, aging mechanisms, and AMPs are identified and documented consistent with the methods used to prepare the LRA. Describe how the results of AMP inspections will be considered to adjust the frequency of future inspections, establish new inspections, and ensure an adequate depth and breadth of component, material, environment, and aging effect combinations. Describe the records of these evaluations and indicate whether they will be maintained in an auditable and retrievable form.
Describe the process and criteria used to ensure that the identified enhancements will be implemented in a timely manner.
- Describe the administrative controls over these programmatic activities.
United States Nuclear Regulatory Commission SBK-L-1 1133 / Enclosure 1 / Page 4 Provide a summary description of these activities for the FSAR supplement required by 10 CFR 54.21 (d). If enhancements for license renewal are necessary, also provide the updates for the FSAR supplement.
If such an operating experience program is determined to be unnecessary, provide a detailed explanation of the bases for this determination.
NextEra Energy Seabrook Response:
NextEra Seabrook currently maintains a procedurally controlled operating experience review process as discussed in UFSAR Section 1.9.1- NUREG 0737 Task I.C.5 Procedures for Feedback of Operating Experience to Plant Staff. This process provides for: (1) the systematic evaluation of significant nuclear plant operating experiences; (2) incorporation of lessons learned into appropriate plant practices, policies, programs, and procedures with the objective of preventing similar issues; and (3) sharing of lessons learned internally and with other utilities to promote industry-wide safety and reliability. NextEra policy and procedures govern these activities and list a wide variety of sources and documents which are reviewed for operating experience. These sources include but are not limited to: (1) NRC-Generic Communications; (2)
INPO, Industry, and Owner's Group communications; (3) NEI, EPRI, and Vendor Reports; and (4) internal NextEra Energy fleet operating experience. These documents are some of the primary sources of operating experience external to Seabrook Station. The NextEra operating experience process requires identified aging issues that constitute a potential condition adverse to quality at Seabrook Station be entered into the corrective action program. Relevant operating experience conditions and NRC Bulletins and NRC Generic Letters, which warrant specific actions to be taken are entered into the corrective action program. The corrective action program is governed by the NextEra Seabrook Quality Assurance Program which meets the requirements of 10 CFR 50 Appendix B.
The corrective action program is also the primary source of internal operating experience. The corrective action program is implemented to promptly identify, control, document, classify, and correct conditions adverse to quality. In addition, for significant conditions adverse to quality, the program provides for cause evaluation and corrective actions to prevent recurrence.
Provisions are also made to ensure that corrective actions for significant conditions adverse to quality are completed as intended, in a timely manner, and are not inadvertently nullified by subsequent actions. Results of evaluations of conditions adverse to quality are analyzed to identify trends. Adverse trends are documented and entered into the corrective action program.
The corrective action program implements the requirements of 10 CFR 50 Appendix B, Criterion XVI. As such, the corrective action program is used to monitor both plant-specific operating experience and industry operating experience that is relevant to Seabrook Station.
United States Nuclear Regulatory Commission SBK-L- 11133 / Enclosure 1 / Page 5 The corrective action program is entered when a degraded condition is identified. A degraded condition is one in which the qualification of a Structure, System or Component (SSC) or its functional capability is potentially reduced. Examples of degraded conditions are failures, malfunctions, deficiencies, deviations, and defective material and equipment. Examples of conditions that can reduce the capability of a system are aging, erosion, corrosion, improper operation or maintenance.
NextEra Energy Seabrook has an implemented operating experience review process under the current licensing basis, as discussed in License Renewal Application Appendix B section B. 1.4, that will be maintained through the period of extended operation, consistent with the methods used to prepare the LRA. As such, revisions to LRA Appendix A, UFSAR Supplement and Appendix B are not required. In response to this request, NextEra will enhance the operating experience review process and provide additional training to process owners to include reviews of plant-specific and industry operating experience in order to confirm the effectiveness of the license renewal aging management programs and to determine the need for programs to be enhanced or the need to develop new aging management programs. Necessary changes to aging management programs would be tracked and implemented via the corrective action program, which will provide an auditable and retrievable record. These enhancements are included in new license renewal commitment No. 66, discussed below.
NextEra aging management program owners ensure new relevant operating experience has been reviewed and is factored into the aging management programs. As operating experience is a fundamental input to all AMPs, NextEra will implement these enhancements within ten years prior to entering the period of extended operation to coincide with implementation of AMPs discussed in Commitments 11, 13, 22, 24 and 25.
In LRA A.3, Commitment No. 66 is to be added as follows:
Enhance the current station operating experience review process implemented in response to NUREG 0737 Task L.C.5 Proceduresfor Feedback of OperatingExperience to Plant Staff (UFSAR 61.9.1) to Within ten years include future reviews of plant-specific and industry prior to entering 66 Reviews operatingexperience in orderto confirm the N/A the period of effectiveness of the license renewal aging extended managementprogramsand to determine the need for operation.
programs to be enhanced or the need to develop new aging managementprograms.
Enclosure 2 to SBK-L-11133 Revised NextEra Energy Seabrook Response to RAI B.2.1.12-8 SBK-L- 11062 dated April 5. 2011
United States Nuclear Regulatory Commission SBK-L-11133 / Enclosure 2 / Page 2 Revised NextEra Enery Seabrook Response to RAI B.2.1.12-8 provided in letter SBK-L- 11062, dated April 5, 2011 In response to RAI B.2.1.12-8, Seabrook Station provided in letter SBK-L- 11062, dated April 5, 2011, information regarding calculated corrosion rates noted in previous analyses of corrosion coupons. Subsequently, the information provided in Enclosure 2, "Chemistry Control in the Seabrook Thermal Barrier Loop," of that letter was found to contain minor editorial errors.
These errors were discussed with the author of Enclosure 2 and confirmed to be insignificant and having no effect on the discussion or conclusions presented in the report.
The editorial corrections in Section 4 of Enclosure 2, page 26 of 29, are shown below.
- Dates: From 12/22/99 to 10/24/01 (672 days in system)
Corrosion rate for SS-304 coupon =- 4.3106 5 4.03E-06 Corrosion rate for CS 7-515 coupon = 4.03E 03 4.90E-03
- Dates: From 10/24/01 to 8/27/03 (672 days in system)
Corrosion rate for SS-304 coupon -4403E 06 5 4.03E-06
- Dates: From 5/3/07 to 1/19/11 (1356 days in system)
Corrosion rate for CS 7-515 coupon = 2.66E 03 2.68E-03 This would also result in a minor change in the maximum reported carbon steel corrosion rate shown in the last paragraph of Section 4 of the report. The last paragraph of Section 4 is revised to read as follows.
"As shown, general corrosion rates of both carbon steel and stainless steel have been minimal. The maximum reported carbon steel corrosion rate was 4,E 3 mHrYea.r. (- 0 16 mfiils per-year-) 4.9E-3 mm/year (-0.19 mils per year). Corrosion rates of stainless steel were much lower."
Both the author of the Enclosure 2 report and Seabrook Station Chemistry have verified the conclusion remains valid, that the effects of the elevated hydrazine and sulfate levels are insignificant and would not have caused accelerated aging of the components in the thermal barrier system.
Enclosure 3 to SBK-L-11133 LRA Appendix A - Final Safety Report Supplement Table A.3 License Renewal Commitment List
United States Nuclear Regulatory Commission SBK-L-1 1133 / Enclosure 3 / Page 2 A.3 LICENSE RENEWAL COMMITMENT LIST UFSAR No. PROGRAM or TOPIC COMMITMENT LOCATION SCHEDULE Program to be implemented prior to the period of extended An inspection plan for Reactor Vessel Internals will be operation. Inspection plan submitted for NRC review and approval, to be submitted to NRC
- 1. PWR Vessel Internals A.2.1.7 not later than 2 years after receipt of the renewed license or not less than 24 months prior to the period of extended operation, whichever comes first.
- 2. Closed-Cycle Cooling Enhance the program to include visual inspection for Prior to the period of Water cracking, loss of material and fouling when the in-scope A.2.1.12 extended operation Water__systems are opened for maintenance.
Inspection of Overhead Heavy Enhance the program to monitor general corrosion on the Prior to the period of
- 3. Load and Light Load crane and trolley structural components and the effects of A.2.1.13 extended operation (Related to Refueling) wear on the rails in the rail system.
Handling Systems Inspection of Overhead Heavy Enhance the program to list additional cranes for Prior to the period of
- 4. Load and Light Load A.2.1.13 extended operation (Related to Refueling) monitoring.
Handling Systems Compressed Air Enhance the program to include an annual air quality test Prior to the period of
- 5. Monitoring requirement for the Diesel Generator compressed air sub A.2.1.14 extended operation system.
- 6. Fire Protection Enhance the program to perform visual inspection of A2115 Prior to the period of penetration seals by a fire protection qualified inspector, extended operation.
United States Nuclear Regulatory Commission SBK-L-I 1133 / Enclosure 3 / Page 3 UFSAR No. PROGRAM or TOPIC COMMITMENT LOCATION SCHEDULE Enhance the program to add inspection requirements such as spalling, and loss of material caused by freeze-thaw, Prior to the period of chemical attack, and reaction with aggregates by qualified extended operation.
inspector.
Enhance the program to include the performance of visual
- 8. Fire Protection inspection of fire-rated doors by a fire protection qualified A.2.1.15 Prirntotheperiodo inspector. extended operation.
Enhance the program to include NFPA 25 guidance for "where sprinklers have been in place for 50 years, they Prior to the period of
- 9. Fire Water System shall be replaced or representative samples from one or A.2.1.16 extended operation.
more sample areas shall be submitted to a recognized testing laboratory for field service testing'.
Enhance the program to include the performance of Prior to the period of
- 10. Fire Water System periodic flow testing of the fire water system in accordance A.2.1.16 extended operation.
with the guidance of NFPA 25. exteded peraion Enhance the program to include the performance of periodic visual or volumetric inspection of the internal surface of the fire protection system upon each entry to the system for routine or corrective maintenance. These inspections will be documented and trended to determine if Within ten years prior to
- 11. Fire Water System representative number of inspections have been A.2.1 .16 the period of extended performed prior to the period of extended operation. If a operation.
representative number of inspections have not been performed prior to the period of extended operation, focused inspections will be conducted. These inspections will be performed within ten years prior to the period of extended operation.
Aboveground Steel Enhance the program to include components and aging Prior to the period of
- 12. Tanks effects required by the Aboveground Steel Tanks. A.2.1.17 extended operation.
Aboveground Steel Enhance the program to include an ultrasonic inspection Within ten years prior to
- 13. Tanks and evaluation of the internal bottom surface of the two Fire A.2.1.17 the period of extended Protection Water Storage Tanks. operation.
United States Nuclear Regulatory Commission SBK-L-I 1133 / Enclosure 3 / Page 4 UFSAR No. PROGRAM or TOPIC COMMITMENT LOCATION SCHEDULE Enhance program to add requirements to 1) sample and analyze new fuel deliveries for biodiesel prior to offloading Prior to the period of
- 14. Fuel Oil Chemistry to the Auxiliary Boiler fuel oil storage tank and 2) A.2.1.18 Prirntotheperiodo periodically sample stored fuel in the Auxiliary Boiler fuel oil storage tank.
Enhance the program to add requirements to check for the
- 15. Fuel Oil Chemistry presence of water in the Auxiliary Boiler fuel oil storage tank A.2.1.18 Prior to the period of at least once per quarter and to remove water as extended operation.
necessary.
Enhance the program to require draining, cleaning and Prior to the period of
- 16. Fuel Oil Chemistry inspection of the diesel fire pump fuel oil day tanks on a A.2.1.18 extended operation.
frequency of at least once every ten years.
Enhance the program to require ultrasonic thickness measurement of the tank bottom during the 10-year draining, cleaning and inspection of the Diesel Generator A.2.1.18 Prior to theperiod of
- 17. Fuel Oil Chemistry fuel oil storage tanks, Diesel Generator fuel oil day tanks, extended operation.
diesel fire pump fuel oil day tanks and auxiliary boiler fuel oil storage tank.
Reactor Vessel Enhance the program to specify that all pulled and tested Prior to the period of
- 18. Surveillance capsules, unless discarded before August 31, 2000, are A.2.1.19 extended operation.
placed in storage.
Enhance the program to specify that if plant operations exceed the limitations or bounds defined by the Reactor Reactor Vessel Vessel Surveillance Program, such as operating at a lower Prior to the period of
- 19. Surveillance cold leg temperature or higher fluence, the impact of plant A.2.1.19 extended operation.
operation changes on the extent of Reactor Vessel embrittlement will be evaluated and the NRC will be notified.
United States Nuclear Regulatory Commission SBK-L-1 1133 / Enclosure 3 / Page 5 UFSAR No. PROGRAM or TOPIC COMMITMENT LOCATION SCHEDULE Enhance the program as necessary to ensure the appropriate withdrawal schedule for capsules remaining in the vessel such that one capsule will be withdrawn at an Reactor Vessel outage in which the capsule receives a neutron fluence that Prior to the period of
- 20. Surveillance meets the schedule requirements of 10 CFR 50 Appendix H A.2.1.19 extended operation.
and ASTM El 85-82 and that bounds the 60-year fluence, and the remaining capsule(s) will be removed from the vessel unless determined to provide meaningful metallurgical data.
Enhance the program to ensure that any capsule removed,
- 21. Reactor Vessel without the intent to test it, is stored in a manner which A.2.1.19 Prior to the period of Surveillance maintains it in a condition which would permit its future use, extended operation.
including during the period of extended operation.
Within ten years prior to
- 22. One-Time Inspection Implement the One Time Inspection Program. A.2.1.20 the period of extended operation.
Implement the Selective Leaching of Materials Program.
Selective Leaching of The program will include a one-time inspection of selected Within five years prior to
- 23. Materials components where selective leaching has not been A.2.1.21 the period of extended identified and periodic inspections of selected components operation.
where selective leaching has been identified.
Buried Piping And Implement the Buried Piping And Tanks. Inspection Within ten years prior to
- 24. Tanks Inspection Program. A.2.1.22 entering the period of extended operation One-Time Inspection Within ten years prior to
- 25. of ASME Code Class mplementthe One-Time Inspection of ASME Code Class 1 A.2.1.23 the period of extended 1 Small Bore-Piping Small Bore-Piping Program. operation.
United States Nuclear Regulatory Commission SBK-L-I 1133 / Enclosure 3 / Page 6 UFSAR No. PROGRAM or TOPIC COMMITMENT LOCATION SCHEDULE Enhance the program to specifically address the scope of the program, relevant degradation mechanisms and effects of interest, the refueling outage inspection frequency, the Prior to the period of
- 26. External Surfaces inspections of opportunity for possible corrosion under A.2.1.24 Monitoring insulation, the training requirements for inspectors and the extended operation.
required periodic reviews to determine program effectiveness.
Inspection of Internal Surfaces in Implement the Inspection of Internal Surfaces in Prior to the period of
- 27. Miscellaneous Piping Miscellaneous Piping and Ducting Components Program. A.2.1.25 extended operation.
and Ducting Components Lubricating Oil Enhance the program to add required equipment, lube oil Prior to the period of
- 28. Analysis analysis required, sampling frequency, and periodic oil A.2.1.26 extended operation.
changes.
Lubricating Oil Enhance the program to sample the oil for the Switchyard Prior to the period of
- 29. Analysis SF 6 compressors and the Reactor Coolant pump oil A.2.1.26 extended operation.
collection tanks.
Enhance the program to require the performance of a one-
- 30. Lubricating Oil time ultrasonic thickness .measurement of the lower portion A.2.1.26 Prior to the period of Analysis of the Reactor Coolant pump oil collection tanks prior to the extended operation.
period of extended operation.
- 31. ASME Section Xl, Enhance procedure to include the definition of "Responsible A.2.1.28 Prior to the period of Subsection IWL Engineer". extended operation.
Structures Monitoring Enhance procedure to add the aging effects, additional Prior to the period of
- 32. Program locations, inspection frequency and ultrasonic test A.2.1.31 extended operation.
requirements.
Structures Monitoring Enhance procedure to include inspection of opportunity Prior to the period of Program
- 33. when planning excavation work that would expose A.2.1.31 extended operation.
Program__________________ inaccessible concrete.
United States Nuclear Regulatory Commission SBK-L-1 1133 / Enclosure 3 / Page 7 UFSAR No. PROGRAM or TOPIC COMMITMENT LOCATION SCHEDULE Electrical Cables and Connections Not Implement the Electrical Cables and Connections Not
- 34. ubject to 10 CFR S ubject to 10 CFR 50.49 Environmental Qualification A.2.1.32period of 50.49 Environmental Subjeto 1 ro50. extended operation.
Qualification Requirements program.
Requirements Electrical Cables and Connections Not Subject to 10 CFR Implement the Electrical Cables and Connections Not
- 35. 50.49 Environmental Qualificationexnddorai. Subject to 10 CFR 50.49 Environmental Qualification A.2.1.33 Prior to the period of Requirements Used in Requirements Used in Instrumentation Circuits program.
Instrumentation Circuits Inaccessible Power Cables Not Subject to Implement the Inaccessible Power Cables Not Subject to 10 CFR 50.49 10 CFR 50.49 Environmental Qualification Requirements A.2.1.34 Prior to the period of
- 36. Environmental 1ro 50. extended operation.
Qualification program.
Requirements Prior tothe period of Metal Enclosed Bus Implement the Metal Enclosed Bus program. A.2.1.35 exte e perion.
- 37. extended operation.
A.2.1.36 Prior to the period of
- 38. Fuse Holders Implement the Fuse Holders program. A.2.1.36 exte e perio extended operati on.
Electrical Cable Connections Not Implement the Electrical Cable Connections Not Subject to
- 39. Subject to 10 CFR 10 CFR 50.49 Environmental Qualification Requirements A.2.1.37 Prior to the period of 50.49 Environmental extended operation.
Qualification program.
Requirements Prior to the period of
extended operation.
United States Nuclear Regulatory Commission SBK-L-1 1133 / Enclosure 3 / Page 8 UFSAR No. PROGRAM or TOPIC COMMITMENT LOCATION SCHEDULE Metal Fatigue of Enhance the program to include additional transients Prior to the period of Reactor Coolant beyond those defined in the Technical Specifications and A.2.3.1 extended operation.
41.
Pressure Boundary UFSAR. extendedoperation.
Metal Fatigue of Enhance the program to implement a software program, to Reactor Coolant count transients to monitor cumulative usage on selected A.2.3.1 exte e perion.
42.
Pressure Boundary components. extendedoperation.
Pressure - The updated analyses will be submitted at the Temperature Limits, Seabrook Station will submit updates to the P-T curves and appropriate time to
- 43. including Low LTOP limits to the NRC at the appropriate time to comply A.2.4.1.4 comply with 10 CFR 50 with 10 CFR 50 Appendix G. Appendix G, Fracture Overpressure Toughness Protection Limits Requirements.
NextEra Seabrook will perform a review of design basis ASME Class 1 component fatigue evaluations to determine whether the NUREG/CR-6260-based components that have been evaluated for the effects of the reactor coolant environment on fatigue usage are the limiting components for the Seabrook plant configuration. If more limiting components are identified, the most limiting component will be evaluated for the effects of the reactor coolant environment on fatigue usage. If the limiting location Environmentally- identified consists of nickel alloy, the environmentally- At least two years prior to
- 44. Assisted Fatigue assisted fatigue calculation for nickel alloy will be performed A.2.4.2.3 entering the period of using the rules of NUREG/CR-6909. entende perion.
Analyses (TLAA) (1) Consistent with the Metal Fatigue of Reactor Coolant extended operation.
Pressure Boundary Program Seabrook Station will update the fatigue usage calculations using refined fatigue analyses, if necessary, to determine acceptable CUFs (i.e.,
less than 1.0) when accounting for the effects of the reactor water environment. This includes applying the appropriate Fen factors to valid CUFs determined from an existing fatigue analysis valid for the period of extended operation or from an analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-
United States Nuclear Regulatory Commission SBK-L-1 1133 / Enclosure 3 / Page 9 UFSAR No. PROGRAM or TOPIC COMMITMENT LOCATION SCHEDULE approved code case).
(2) If acceptable CUFs cannot be demonstrated for all the selected locations, then additional plant-specific locations will be evaluated. For the additional plant-specific locations, if CUF, including environmental effects is greater than 1.0, then Corrective Actions will be initiated, in accordance with the Metal Fatigue of Reactor Coolant Pressure Boundary Program, B.2.3.1.
Corrective Actions will include inspection, repair, or replacement of the affected locations before exceeding a CUF of 1.0 or the effects of fatigue will be managed by an inspection program that has been reviewed and approved by the NRC (e.g., periodic non-destructive examination of the affected locations at inspection intervals to be determined by a method accepted by the NRC).
- 45. Number Not Used Protective Coating Enhance the program by designating and qualifying an Prior to the period of Maintenance Inspector Coordinator and an Inspection Results Evaluator. extended operation Enhance the program by including, "Instruments and Protective Coating Equipment needed for inspection may include, but not be limited to, flashlight, spotlights, marker pen, mirror, A.2.1.38 Prior to the period of
- 47. Monitoring and measuring tape, magnifier, binoculars, camera with or extended operation without wide angle lens, and self sealing polyethylene sample bags."
United States Nuclear Regulatory Commission SBK-L- 11133 / Enclosure 3 / Page 10 UFSAR No. PROGRAM or TOPIC COMMITMENT LOCATION SCHEDULE Protective Coating Enhance the program to include a review of the previous Prior to the period of
- 48. Monitoring and two monitoring reports. A.2.1.38 extended operation
.Maintenance Protective Coating Enhance the program to require that the inspection report is Prior to the period of
- 49. Monitoring and to be evaluated by the responsible evaluation personnel, A.2.1.38 extended operation Maintenance who is to prepare a summary of findings and recommendations for future surveillance or repair.
ASME Section XI, Perform UT testing of the containment liner plate in the A.2.1.27 No later than December Subsection IWE vicinity of the moisture barrier for loss of material. 31, 2015 and repeated at
- 50. intervals of no more than five refueling outages ASME Section XI, Perform confirmatory testing and evaluation of the Prior to the period of
- 51. Subsection IWL Containment Structure concrete ASME Section XI, Implement measures to maintain the exterior surface of the
- 52. Subsection IWL Containment Structure, from elevation -30 feet to +20 feet, A.2.1.28 By 2013 in a dewatered state.
Reactor Head Closure Replace the spare reactor head closure stud(s) Prior to the period of
- 53. Studs manufactured from the bar that has a yield strength > 150 A.2.1.3 extended operation.
ksi with ones that do not exceed 150 ksi.
Unless an alternate repair criteria changing the ASME code boundary is permanently approved by the NRC, or the Seabrook Station steam generators are changed to Program to be submitted Steam Generator eliminate PWSCC-susceptible tube-to-tubesheet welds, A.2.1.10 to NRC at least 24 Tube Integrity submit a plant-specific aging management program to months prior to the period manage the potential aging effect of cracking due to of extended operation.
PWSCC at least twenty-four months prior to entering the Period of Extended Operation.
Steam Generator Seabrook will perform an inspection of each steam Prior to entering the
- 55. Tube Integrity generator to assess the condition of the divider plate A.2.1.10 period of extended assembly. operation Closed-Cycle Cooling Revise the station program documents to reflect the EPRI Prior to entering the
- 56. Water System Guideline hydrazine operating ranges and Action Level values for and sulfates. A.2.1.12 period of extended operation.
United States Nuclear Regulatory Commission SBK-L-I 1133 / Enclosure 3 / Page 1 I No. PROGRAM or TOPIC COMMITMENT LOCATION UFSAR SHDL SCHEDULE Closed-Cycle Coolin Revise the station program documents to reflect the EPRI Prior to entering the
- 57. Cloed-Cylem C n Guideline operating ranges and Action Level values for A.2.1.12 period of extended Water System Diesel Generator Cooling Water Jacket pH. operation.
Update Technical Requirement Program 5.1, (Diesel Fuel Prior to the period of
- 58. Fuel Oil Chemistry Oil Testing Program) ASTM standards to ASTM D2709-96 A.2.1.18 extended operation.
and ASTM D4057-95 required by the GALL XI.M30 Rev 1 The Nickel Alloy Aging Nozzles and Penetrations program Prior to the period of Nickel Alloy Nozzles will implement applicable Bulletins, Generic Letters, and A.2.2.3 and Penetrations
- 59. staff accepted industry guidelines. extended operation.
Buried Piping and Implement the design change replacing the buried Auxiliary Prior to entering the
- 60. Tanks Inspection Boiler supply piping with a pipe-within-pipe configuration A.2.1.22 period of extended with leak indication capability. operation.
Compressed Air Replace the flexible hoses associated with the Diesel Within ten years prior to
- 61. Monitoring Pr Generator years. air compressors on a frequency of every 10 A.2.1.14 entering extendedthe period of operation.
Enhance the program to include a statement that sampling Prior to entering the
- 62. Water Chemistry frequencies are increased when chemistry action levels are A.2.1.2 period of extended exceeded. operation.
Ensure that the quarterly CVCS Charging Pump testing is continued during the PEO. Additionally, add a precaution to Erosion the test procedure to state that an increase in the CVCS Prior to the period of Charging Pump mini flow above the acceptance criteria extended operation may be indicative of erosion of the mini flow orifice as described in LER 50-275/94-023.
Soil analysis shall be performed prior to entering the period of extended operation to determine the corrosivity of the soil Prior to entering the
- 64. Buried Piping and in the vicinity of non-cathodically protected steel pipe within A.2.1.22 period of extended Tanks Inspection the scope of this program. If the initial analysis shows the operation.
soil to be non-corrosive, this analysis will be re-performed every ten years thereafter.
Implement measures to ensure that the movable incore Prior to entering the
- 65. Flux Thimble Tube detectors are not returned to service during the period of N/A period of extended extended operation. operation
United States Nuclear Regulatory Commission SBK-L- 11133 / Enclosure 3 / Page 12 UFSAR No. PROGRAM or TOPIC COMMITMENT LOCATION SCHEDULE Enhance the currentstation operatingexperience review process implemented in response to NUREG 0737 Task I.C.5 Proceduresfor Feedbackof OperatingExperience to Plant Staff (UFSAR 61.9.1) to include future reviews of Within ten years priorto
- 66. Operating plant-specificand industry operatingexperience in order N/A entering the period of Experience Reviews to confirm the effectiveness of the license renewal aging extende perion.
management programs and to determine the need for extended operation.
programs to be enhanced or the need to develop new aging managementprograms.