ML11304A002

Summary of Tele Conf Call Held on 3/18/11, Between the USNRC and NextEra Energy Seabrook, Llc., Concerning Clarification of Information Pertaining to the Seabrook Station License Renewal Application

ML11304A002
Person / Time
Site:	Seabrook
Issue date:	11/04/2011
From:	Plasse R License Renewal Projects Branch 1
To:	NextEra Energy Seabrook
Plasse R
References
TAC ME4028
Download: ML11304A002 (10)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 4, 2011 LICENSEE: NextEra Energy Seabrook, LLC FACILITY: Seabrook Station

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON MARCH 18, 2011, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND NEXTERA ENERGY SEABROOK, LLC, CONCERNING CLARIFICATION OF INFORMATION PERTAINING TO THE SEABROOK STATION LICENSE RENEWAL APPLICATION (TAC NO. IVIE4028)

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 March 18,2011, to discuss the staffs draft request for additional information concerning the Seabrook Station license renewal application (LRA). The telephone conference call was useful in clarifying the applicanfs information in the LRA. provides a listing of the participants and Enclosure 2 contains a summary of the issues discussed during the call with the applicant.

The applicant had an opportunity to comment on this summary.

Rick Plasse, 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 MARCH 18,2011 PARTICIPANTS AFFILIATIONS Rick Plasse U.S. Nuclear Regulatory Commission (NRC)

Abdul Sheikh NRC Raj Auluck NRC Bryce Lehman NRC Andrew Prinaris NRC Roger Kalikian NRC Jim Medoff NRC Ching Ng NRC Richard Cliche NextEra Energy Seabrook, LLC. (NextEra)

Dennis Bemis NextEra Ali Kodal NextEra Ken Chew NextEra Pete Tutinas NextEra ENCLOSURE 1

TELEPHONE CONFERENCE CALL SEABROOK STATION LICENSE RENEWAL APPLICATION Draft RAI 3.1.1.60-01 a Follow up to RAls 3.1.1.60-01 & RAls 3.1.1.60-02

Background:

By letter dated January 5, 2011, the staff issued two requests for additional information (RAls) to the applicant. RAI 3.1.1-60-01 requested that the applicant justify not including an applicable aging management review (AMR) line item to manage loss of material due to wear in the nickel alloy flux thimble tubes and to justify why a Flux Thimble Tube Inspection Program is not credited to manage loss of material due to wear for these nickel alloy flux thimble tubes. RAI 3.1.1-60-02 requested that the applicant justify using the pressurized water reactor (PWR)

Vessel Internals Program to manage cracking in the flux thimble tubes, considering that the material reliability program (MRP)-227 Rev. 0 does not contain recommendations for managing cracking in Westinghouse-design flux thimble tubes.

In its response dated February 3, 2011, the applicant stated that its design is unique and can accommodate both fixed and movable incore detectors. The applicant also stated that since its Operating Cycle 5, the moveable incore detectors have not been used and were placed in a lay-up condition during Refueling Outage 7 (Fall of 2000). The applicant also stated that since Refueling Outage 7, as part of a design change, the seal table tubing between the inner calibration tubing and the isolation valves has been removed and the inner calibration tube has been capped.

The applicant further stated that, based on the unique design features of the incore detectors, the aging effects managed by NUREG-1801 Rev. 1. XI.M37, do not apply to Seabrook Station.

The applicant also stated that the movable flux thimbles do not have a license renewal intended function and the line items referencing the flux thimble tubes will be deleted from license renewal application (LRA) Tables 2.3.1-3 and 3.1.2-3.

Issue:

During its review of the applicant's responses to RAls 3.1.1-60-01 and 3.1.1-60-02. the staff noted that the flux thimbles for the moveable incore detectors, if left in a permanent lay-up condition, would not be subject to flow induced vibrations, and therefore would not be subject to wear. However the staff also noted that, under the plants current licensing basis (CLB) and design basis, the applicant has the option to place the movable incore detectors back in service and the flux thimbles will once again provide a pressure boundary function.

Request:

Since the applicant has the option to place the movable incore detectors back in service, justify the deletion of the AMR line items associated with cracking of the flux thimble tubes from LRA Table 3.1.2-3. Also, justify why an aging management program is not required to manage loss of material due to wear of the flux thimbles if the movable incore detectors were placed back into service.

ENCLOSURE 2

2 Discussion: Following discussion of the draft RAI, the applicant stated that they understood what was being requested and would be able to respond. NextEra provided clarification of the thimble tube design configuration and provided a description of the reactor coolant system pressure boundary. In addition, NextEra agreed to provide a detailed sketch of the incore detector assembly to assist staff review. NextEra agreed to provide this information in a subsequent RAI response.

Draft Follow-up RAI 4.7.5-1

Background:

"Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants" (SRP-LR) 4.7.3.1.1 in "Other Plant-Specific Time-Limited Aging Analyses," states that the applicant should describe the time-limited aging analysis (TLAA) with respect to the: (i) objectives of the analysis, (ii) assumptions used, (iii) conditions, (iv) acceptance criteria, (v) relevant aging effects, and (vi) intended function(s). The SRP-LR also states that the applicant should show: (i) conditions and assumptions used in the analysis addressing the relevant aging effects for the period of extended operation, and (ii) the acceptance criteria to provide reasonable assurance that the intended function(s) is maintained for renewal, and the basis for determining that the applicant has made the demonstration required by Title 10, Section 54.21(c){1) of the Code of Federal Regulations (10 CFR 54.21 (c){1>>. By letter dated February 18, 2011, the applicant responded to the staff RAI4.7.5-1 and stated that the fatigue analysis for the fuel transfer tube bellows design is based on 20 occurrences of the aBE at 20 cycles each. The applicant also stated that the cycles will be monitored by an enhanced cycle counting program and that the number of temperature cycles is counted by monitoring to the number of plant heatup and cooldown cycles and the number of pressure test cycles is consistent with the containment pressure testing. The accident cycle is counted as a faulted condition as listed in LRA Table 4.3.1-3.

Issue:

It is not clear to the staff whether the requirements of 4.7.3.1.1 are met. Specifically there are unresolved questions as to the type of fatigue analysis referenced by the applicant, in its response to part (2) of the RAI and what record{s) or document(s) form(s) the basis to the fatigue analysis relative to U.S. Nuclear Regulatory Commission (NRC) requirements or position. It is also not clear to the staff whether the operating basis earthquake (aBE) analysis for the bellows included analysis of plant heatup and cooldown, pressure tests, and loss-of-coolant accident cycles, individual usage factors and assumptions used, and the acceptance criteria.

Request:

1. Identify referenced documents that form the basis (when requested and when approved) to the fatigue analysis relative to NRC requirements or position.

2. Define all transients used in the analysis, including assumptions used and acceptance criteria.

3. If the analysis is based on cumulative usage factor, define its current and anticipated value at the end of the period of extended operation.

3 Discussion:

Following discussion of the draft RAI, the applicant stated that they understood what was being requested and would be able to respond.

Draft Follow-up RAI 8.2.1.31-7

Background:

By letter dated December 17, 2010, the applicant responded to the staff RAI B.2.1.17-1 and stated that the Structures Monitoring Program will inspect tanks' 1-FP-TK-35-A, 1-FP-TK-35-B, 1-FP-TK-36-A, 1-FP-TK-36-B, and 1- AB-TK-29 paint or coating(s) for cracking, flaking, or peeling. The Generic Aging Lessons Learned (GALL Report) AMP XI.M29, Above Ground Metallic Tanks in its "detection of aging effects," program element recommends periodic visual inspections of paint, coatings, sealants, and caulking to assure they remain intact.

Issue:

It is the current staff position that the periodic visual inspections should occur at every outage or at least every two years. Since the protective coatings are visually inspected in accordance with the Seabrook Station's Structures Monitoring Program, the frequency of inspections is five or ten years depending on the location/environment of each tank. It is unclear to the staff that the tank coatings are being inspected for cracking, flaking, or peeling on an appropriate interval.

Request:

1. Define the frequency of visual inspections when asseSSing the condition of paint and coating(s), for each of the following tanks: 1-FP-TK-35-A, 1-FP-TK-35-B, 1-FP-TK-36-A, 1-FPTK-36-B, and 1-FP-TK-29.

2. If the inspection interval is more than two years, state the basis for establishing that the interval provides a reasonable assurance that the tanks will meet their CLB function(s).

Discussion:

Following discussion of the draft RAI, the applicant stated that they understood what was being requested and would be able to respond.

Draft RAI 8.2.1.31-6

Background:

The GALL Report XI.S6 "Structures Monitoring Program," in "detection of aging effects,"

program element states that the program should provide for each of the inspected materials and aging effects a method of inspection, an inspection schedule, and the inspector qualifications to ensure that aging degradation will be detected and quantified before there is loss of intended functions. Inspection methods, inspection schedule, and inspector qualifications are to be commensurate with industry codes, standards and guidelines, and are to consider industry and plant-specific operating experience. In its "acceptance criteria," program element, the GALL Report also states that the plant-specific structures monitoring program is to contain sufficient detail on acceptance criteria to conclude that this program attribute is satisfied. The applicant's Structures Monitoring Program is enhanced to include inspections of elastomeric materials, aluminum, and non-metallic fire proofing.

4 Issue:

The staff notes that visual inspections often are not adequate to detect deterioration in elastomers, non-metallic fire proofing, aluminum, etc. The staff also noted that the frequency and timelines of enhanced inspections are extremely important for these materials to maintain their intended functions (e.g., crack initiation and growth in aluminum station blackout structures see Table 3.5.2-4, loss of seal in elastomers used in roofing of primary structures, see Table 3.5.2-5, etc).

Request:

1. What other inspection methods does the applicant plan to use to supplement visual inspections of elastomeric roofing material, aluminum, and non-metallic fire proofing.

2. Define the frequency of inspections and inspector qualifications for the scoped in materials, i.e., elastomeric roofing material, aluminum, non-metallic fire proofing.

3. Identify the acceptance criteria for each of the scoped in materials and associated aging effects (e.g. aluminum and cracking, elastomers and environmental degradation, etc.).

Discussion:

Following discussion of the draft RAI, the applicant stated that they understood what was being requested and would be able to respond.

Draft Follow-up RAI 8.2.1.31-5

Background:

By letter dated February 3, 2011, the applicant responded to the staff RAI B.2.1.31-5 requesting the applicant to identify which structures are inspected every five years and which every ten.

The applicant responded that the structures are inspected based on the guidelines provided by American Concrete Institute (ACI) 349.3R in five or ten year intervals and on the environment to which they are exposed.

Issue:

It is not clear to the staff where in the table does the applicant account for the spent fuel pool. It is also not clear to the staff if the table provided by the applicant in its responseto RAI 8.2.1.31-5 includes structures and components other than those constructed of concrete.

Furthermore, there are unresolved questions whether the applicant will use the guidance provided by ACI 349.3R titled "Evaluation of existing Nuclear Safety-related Concrete Structures," for all structures to assess their integrity including that for their paint and coatings?

Request:

1. Locate the spent fuel pool in the table.

2. Does the table presented in response to RAI B.2.1.31-5 include structures other than those made of concrete?

Discussion: The applicant stated the Spent Fuel Pool will be inspected on a 5 year frequency and that all structures within the scope of the Structures Monitoring Program are included in the frequencies listed in the table included with the RAI response. This item is resolved.

5 Draft Follow-up RAI4.7.11-1b

Background:

In its response to RAI4.7.11 dated February 3,2011, the applicant stated that only normal service radiation exposure was subjected to a TLAA. The applicant clarified that it has a calculation of total integrated radiation dose design values for a 60-year plant life for various environmental zones and the calculation has been used to evaluate the 60-year dose impact on equipment in their respective zones. The applicant stated that the 60 year design dose values were compared to the current design dose limits of the equipment and it was determined that the 60-year dose limits are bounded by the existing equipment design dose limits. The applicant's disposition of this TLAA in accordance with 10 CFR 54.21 (c)(1)(ii) indicating that the effect of aging on the intended functions of equipment have been projected to be bounded by existing equipment design limits. The staff finds the disposition not acceptable because the existing analyses (equipment design dose limits) has not been revised and extended.

Issue:

While the applicant stated that the 60 year dose limits are bounded by the existing equipment design dose limit, it has not provided the projected 60-year doses for all the zones and the dose limits of the equipment within the scope of mechanical equipment qualification (MEQ). Without such information, the staff cannot evaluate the adequacy of the TLAA of normal service radiation exposure in MEQ. LRA Section 4.7.11, as amended by letter dated February 3,2011, does not discuss the detail regarding the calculated dose limits and equipment design dose limits for normal service radiation exposure. Furthermore, the applicant did not amend Commitment No. 45. Commitment No.45, as its current stated, did not identify what portion of the mechanical equipment qualification files will be revised and what is the acceptance criteria of such revision.

The applicant demonstrated that the existing analyses (equipment design dose limits) are bounding for the projected 60-year doses for all zones. The staff noted that this demonstration of the normal service radiation exposure is consistent with a disposition in accordance with 10 CFR 54.21 (c)(1)(i). SRP-LR Section 4.7.3.1.1 states that for the disposition of 10 CFR 54.21(c)(1)(i), the existing analyses should be shown to be bounding during the period of extended operation.

Reguest:

(1) Provide the design dose limits of the equipment within the scope of MEQ and the calculated total integrated radiation dose 60-year doses for all the zones to justify that TLAA of normal service radiation exposure in MEQ has been properly dispositioned.

(2) Amend LRA Section 4.7.11 and provide sufficient detail to support the TLAA disposition of normal service radiation exposure in MEQ. Revise Commitment No. 45 to identify the information to be revised and the acceptance criteria of the revision or justify why the existing Commitment No.45 is acceptable

6 (3) Amend the disposition of TLAA of normal service radiation exposure to MEQ to 10 CFR 54.21(c)(1)(i) or justify why the existing TLAA disposition is acceptable. If LRA Section 4.7.11 is amended as a result of RAI4.7.11-1b, provide an updated final safety analysis report supplement section in LRA Appendix A consistent with the revisions.

Discussion:

Following discussion of the draft RAI, the applicant stated that they understood what was being requested and would be able to respond.

November 4, 2011 LICENSEE: NextEra Energy Seabrook, LLC FACILITY: Seabrook Station

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON MARCH 18, 2011, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND NEXTERA ENERGY SEABROOK, LLC, CONCERNING CLARIFICATION OF 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 March 18,2011, to discuss the staff's draft request for additional information concerning the Seabrook Station license renewal application (LRA). The telephone conference call was useful in clarifying the applicant's information in the LRA. provides a listing of the participants and Enclosure 2 contains a summary of the issues discussed during the call with the applicant.

The applicant had an opportunity to comment on this summary.

IRA!

Rick Plasse, 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:

See next page ADAMS Accession No'.. ML11304A002 OFFICE LA:DLR PM:RPB1:DLR BC:RPB1 :DLR PM:RPB1 :DLR INAME SFigueroa RPlasse DMorey RPlasse DATE 11/1/11 11/1/11 11/4/11 11/4/11 OFFICIAL RECORD COpy

Memorandum to NextEra Energy Seabrook, LLC from RPlasse dated November 4,2011

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON MARCH 18, 2011, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND NEXTERA ENERGY SEABROOK, LLC, CONCERNING CLARIFICATION OF INFORMATION PERTAINING TO THE SEABROOK STATION LICENSE RENEWAL APPLICATION (TAC NO. ME4028)

DISTRIBUTION:

HARD COPY:

DLRRF E-MAIL:

PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRapb Resource RidsNrrDlrRasb Resource RidsNrrDlrRerb Resource RidsNrrDlrRpob Resource MWentzel RPlasse DMorey DWrona EMiller ICouret, OPA EDacus,OCA MSpencer, OGC WRaymond, RI DTifft, RI NMcNamara, RI NSheehan, RI DScrenci, RI JJohnson, RI ABurritt, RI