ML11304A166
| ML11304A166 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/04/2011 |
| From: | Richard Plasse License Renewal Projects Branch 1 |
| To: | NextEra Energy Seabrook |
| Plasse R | |
| References | |
| TAC ME4028 | |
| Download: ML11304A166 (9) | |
Text
tJ>-B REGu{
UNITED STATES
",~.§J'"
~r01'.<.
NUCLEAR REGULATORY COMMISSION
{;'l
('l WASHINGTON, D.C. 20555*0001
~
0 Iii
~
i; November 4, 2011
~"'",
..,.0
~
- -+<
LICENSEE:
NextEra Energy Seabrook, LLC FACILITY:
Seabrook Station
SUBJECT:
SUMMARY
OF TELEPHONE CONFERENCE CALL HELD ON MARCH 03, 2011, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND NEXTERA ENERGY SEABROOK, LLC, CONCERNING CLARIFICATION OF INFORMATION PERTAINING TO THE SEABROOK STATION REQUEST FOR ADDITIONAL INFORMATION RESPONSES (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 03, 2011, to clarify information in the applicant's previous responses to the staff's requests for additional information (RAls) and discuss the staff's draft RAls 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.
/tMN"',
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 03, 2011 PARTICIPANTS AFFILIATIONS Rick Plasse Bill Holston Jim Gavula David Alley Seung Min Richard Cliche Bob McCormack Ali Kodal Dennis Bemis Todd Mintz Elizabeth Trillo U.S. Nuclear Regulatory Commission (NRC)
NRC NRC NRC NRC NextEra Energy Seabrook, LLC. (NextEra)
NextEra NextEra NextEra Center Center ENCLOSURE 1
TELEPHONE CONFERENCE CALL SEABROOK STATION LICENSE RENEWAL APPLICATION Draft RAI 3.2.2.2.6-02
Background
By letter dated January 5, 2011, the staff issued RAI 3.2.2.2.6-01 concerning aging management of stainless steel miniflow orifices in the chemical and volume control system. In its response dated February 3, 2011, the applicant modified its approach by proposing to credit only the Water Chemistry Program for aging management of the subject components. The applicant stated that the Water Chemistry Program is expected to mitigate the potential for erosion in the miniflow orifices by controlling the buildup of corrosion products and particulates that could contribute to erosion. The applicant also included a discussion of quarterly inservice testing required by its technical specifications and trending of the test data by a system engineer. Based on the information provided, the applicant changed Table 3.3.2-3, for the applicable orifice, to state that the Water Chemistry Program will be used to manage this aging effect, and the applicant added plant-specific note 8 with the comparable information.
Issue The Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR) Section 3.2.2.2.6 states that loss of material due to erosion could occur in the stainless steel high pressure safety injection (HPSI) pump miniflow recirculation orifice exposed to treated borated water and recommends a plant-specific aging management program (AMP) be evaluated for erosion of the orifice due to extended use of the centrifugal HPSI pump for normal charging. The staff noted that the stainless steel miniflow orifices in the applicant's chemical and volume control system are functionally equivalent to, and in the same environment as the miniflow orifices described in SRP-LR Section 3.2.2.2.6; and they would be subject to the same aging effect.
SRP-LR, Appendix A, Section A.1.2.3.4 states that in a plant-specific AMP, the detection of aging effects should occur before there is a loss of intended function(s). The staff noted that the Water Chemistry Program does not include an inspection or testing activity to detect loss of material due to erosion in the stainless steel miniflow orifices in the chemical and volume control system. The staff also noted that the Generic Aging Lessons Learned (GALL) Report typically recommends using the One-Time Inspection program to confirm effectiveness of the Water Chemistry Program to mitigate loss of material. Because the applicant has not credited any activity to confirm the Water Chemistry Program's effectiveness to mitigate erOSion, the staff does not have sufficient information to conclude that the Water Chemistry Program, alone, will provide adequate aging management for the subject miniflow orifices.
Reguest Describe how the existing Water Chemistry Program, alone, is capable of detecting the loss of material due to erosion in the stainless steel miniflow orifices, or include in the AMP(s) for these components an inspection or testing activity that is capable of detecting the loss of material due to erosion before the loss of the components' intended function occurs.
ENCLOSURE 2
2 Discussion: Following discussion of the draft request for additional information (RAI), the applicant stated that they understood what was being requested and would be able to respond.
Draft RAI 8.2.1.22-1 A
Background
The applicant's response to RAI B.2.1.22-1, by letter dated January 13, 2011, was not sufficient to resolve all of the staff's questions.
Issues
- a. Although the applicant will be sampling for several different factors (e.g., soil resistivity, water samples) it is not clear to the staff that the stated parameters are sufficient, nor how the results will be combined to determine the level of soil corrosivity such as can be determined by using American Water Works Association C105/A2.15-10 Table A.1.
- b. The applicant's program only increases the number of planned inspections based on the quality of backfill in the vicinity of the buried pipe. Given that portions of buried in-scope steel piping are not provided with cathodic protection, the staff believes that the number of inspections of this piping should also be informed by localized soil conditions.
- c.
Given that localized soil conditions can vary, the applicant's response was not clear enough for the staff to conclude that soil samples will be obtained in the vicinity of each buried in-scope steel piping system (excluding fire protection) that is not provided cathodic protection.
- d. It is not clear to the staff how often soil samples will be obtained during the period of extended operation.
Request
- a. State what soil parameters will be utilized and how their aggregate impact will be evaluated to determine localized soil corrosivity.
- b. State whether localized soil conditions will be utilized to increase the number of inspections or state how there will be reasonable assurance that the piping system's current licensing basis function(s) will be maintained without increasing the number of samples in the absence of localized soil data or with results that indicate that the soil is corrosive.
- c. State if soil samples will be obtained in the local vicinity of all buried in-scope steel piping systems (excluding fire protection) that are not provided with cathodic protection.
State how often soil sampling will be conducted during the period of extended operation, or if soil samples will not be collected during the period of extended operation, state how it is known that localized soil conditions will not vary with time.
Discussion: Following discussion of the draft RAI, the applicant stated that they understood what was being requested and would be able to respond.
3 Draft RAI B.2.1.22-3A
Background
The applicant's response to RAI B.2.1.22-3, by letter dated January 13, 2011, was not sufficient to resolve all of the staff's questions.
Issue The applicant stated that it utilized a Keeler and Long 1000 Kolormastic system and Tapecoat 20 primer and wrap when installing flanges to allow access to the underground service water piping that is exposed to raw water. The applicant also stated that the painting system chosen for the piping is designed to protect the pipe from long term external corrosion when exposed to continuous immersion in brackish stagnant water. The staff does not have sufficient information related to this coating to independently determine that it will provide protection to the piping when exposed to long term immersion.
Reguest Provide copies of the vendor technical data that demonstrated that the coating system was acceptable for long term immersion in a brackish water environment. Alternatively, if the vendor information is proprietary, provide a copy of the applicable portions of the engineering evaluation of the coating system.
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 B.2.1.22-5
Background
In license renewal application (LRA) Supplement 2 dated November 15, 2010, the applicant revised LRA Table 3.3.2-37 was revised to include copper alloy with> 15% zinc valves and bolting exposed to raw water in the submerged underground vault for service water piping. The applicant stated that the components will be managed for aging by the Buried Piping and Tanks Inspection Program.
Issue The applicant did not revise LRA Section B.2.1.22 to reflect inclusion of this material nor provide inspection frequencies.
Reguest Revise LRA Section B.2.1.22 to reflect inclusion of copper alloy >15% zinc and state the number of planned inspections of these components.
Discussion: Following discussion of the draft RAI, the applicant stated that they understood what was being requested and would be able to respond.
4 Draft RAI B.3.4.1-37-2
Background
By letter dated January 5, 2011, the staff issued RAI 3.4.1-37-1. This RAI requested that information as follows: a) propose to manage aging of these components using water chemistry and an appropriate verification AMP as indicated by the GALL Report for the management of aging in a secondary feedwaterlsteam environment or justify why the use of a verification AMP is either inconsistent with the GALL Report or technically unnecessary; b) justify why is it unnecessary to consider both the aging effects "loss of material" and "cracking" for each of the components under consideration; c) classify the steam generator feedwater inlet ring (J tube) and the steam generator tubes as steam generator components (making the appropriate verification AMP the Steam Generator Tube Integrity program) or justify why these components should be considered piping, piping components, or piping elements as proposed by item 3.4.1-37. The applicant responded to this RAI by letter dated February 3, 2011. With one potential exception, the staff found these responses acceptable.
Issue In its response to the previous RAI, the applicant reclassified the steam generator feedwater nozzle (thermal sleeve) and the orifice from being consistent with SRP-LR Table 3.4.1-34 (generic note A) to being inconsistent with the GALL Report (generic note H). The applicant also proposed to manage the aging of these components through the use of its Water Chemistry Program. Based on its review, it appears to the staff that the components, materials, environments, and aging effects under consideration are described by SRP-LR Table 3.4-1 10
- 84. The staff notes that SRP-LR Table 3.4-1 1084 recommends that aging be managed through the use of GALL Report AMP XI.M2, Water Chemistry and either AMP XI.M32, One Time Inspection, or AMP XI.M1, ASME Section XI, Inservice Inspection.
The staff notes that, in its response to the previous RAI, the applicant stated that these components were not available for inspection. The staff also notes that these components have been addressed in many recent license Renewal safety evaluation reports (SERs). While there have been differences in the approaches to the management of aging of these components from plant to plant, in each case the SER indicates that the accepted method of aging management involves the use of an AMP to manage water chemistry and an AMP to perform at least a one-time inspection to verify the efficacy of the water chemistry program. This indicates to the staff that water chemistry and inspection programs are necessary for adequate aging management and that these components are generally inspectable.
Request Propose to manage aging of these components in a manner consistent with or equivalent to SRP LR Table 3.4-1 1084 or demonstrate why either a) the aging management guidance provided by SRP LR Table 3.4-1 1084 need not be followed; or b) the components under consideration are inspectable at other plants and not at the applicant's plant.
5 Discussion: Following discussion of the draft RAI, the applicant stated that they understood what was being requested and would be able to respond.
Clarification of Previous RAls By letter dated January 5, 2011, the staff issued two RAls to the applicant. RAJ 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 Vessel Internals Program to manage cracking in the flux thimble tubes, considering that MRP-227 Rev. 0 does not contain recommendations for managing cracking in Westinghouse-design flux thimble tubes.
Discussion: NextEra discussed its response dated February 3, 2011, and provided clarification of the thimble tube design configuration, provided a description of the reactor coolant system pressure boundary, and described the associated aging management programs. The U. S. Nuclear Regulatory Commission agreed to review the information to determine if any additional RAls are necessary to complete staff review.
Clarification RAI 3.1.2.1-1 In its review of LRA Table 3.1.1, item 3.1.1-57, updated final safety analysis report (UFSAR) and applicant's response to RAI 3.1.2.1-1, the staff found a need to further clarify the following item, which is related to the aging management of thermal aging embrittlement and stress corrosion cracking of cast austenitic stainless steel (CASS) components.
The staff noted that Table 5.2-2 in UFSAR indicates that the pipe in the reactor coolant system is made of SA-376, Grade [TP]304N or SA-351, Grade CF8A, centrifugal casting material. The staff finds that SA-376, Grade [TP]304N material is not a CASS material and centrifugally-cast SA-351, Grade CF8A is a low-molybdenum cast austenitic stainless steel, which is not susceptible to thermal aging embrittlement consistent with the guidance in the GALL Report.
Clarification Question Clarify whether the centrifugally-cast material (SA-351, Grade CF8A) listed in the UFSAR Table has been used for a portion of the reactor coolant pipe.
Discussion: Based on the review of the applicant's documents including construction drawings, the reactor coolant pipe is made of SA-376, Grade 304N material and the centrifugally-cast SA-351, Grade CF8A material listed in the UFSAR Table has not been used for the reactor coolant pipe. All the CASS Class 1 piping, piping elements and piping components are as previously described in the applicant's response (February 3, 2011) to RAI3.1.2.1-1. This item is resolved.
'.. ML11304A151 OFFICE LA:DLW PM:RPB1 :DLR BC:RPB1 :DLR PM:RPB1 :DLR NAME SFigueroa RPlasse DMorey RPlasse DATE 1111/11 1111/11 11/4/11 11/4/11
Memorandum to NextEra Energy Seabrook, LLC from R. Plasse dated November 4, 2011
SUBJECT:
SUMMARY
OF TELEPHONE CONFERENCE CALL HELD ON APRIL 08, 2011, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND NEXTERA ENERGY SEABROOK, LLC, CONCERNING CLARIFICATION OF INFORMATION PERTAINING TO THE SEABROOK STATION REQUEST FOR ADDITIONAL INFORMATION RESPONSES(TAC NO. ME4028)
DISTRIBUTION:
HARDCOPY:
DLRRF E-MAil:
PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRapb Resource RidsNrrDlrRasb Resource RidsNrrDlrRerb Resource RidsNrrDlrRpob Resource RidsNrrDraApla 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