ML11307A136
| ML11307A136 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/15/2011 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| Download: ML11307A136 (4) | |
Text
1 SeabrookNPEm Resource From:
Plasse, Richard Sent:
Tuesday, March 15, 2011 1:28 PM To:
Cliche, Richard
Subject:
FW: Follow-up RAI for Seabrook 4.7.11.
Attachments:
Draft Follow up RAI Seabrook Section 4 7 11 - oyee ng.docx Another draft RAI
Hearing Identifier:
Seabrook_License_Renewal_NonPublic Email Number:
2223 Mail Envelope Properties (Richard.Plasse@nrc.gov20110315132800)
Subject:
FW: Follow-up RAI for Seabrook 4.7.11.
Sent Date:
3/15/2011 1:28:21 PM Received Date:
3/15/2011 1:28:00 PM From:
Plasse, Richard Created By:
Richard.Plasse@nrc.gov Recipients:
"Cliche, Richard" <Richard.Cliche@fpl.com>
Tracking Status: None Post Office:
Files Size Date & Time MESSAGE 19 3/15/2011 1:28:00 PM Draft Follow up RAI Seabrook Section 4 7 11 - oyee ng.docx 26331 Options Priority:
Standard Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Recipients Received:
Draft Follow up RAI for Seabrook Station LRA related to 4.7.11 Follow-up RAI 4.7.11-1b
Background:
In its response to RAI 4.7.11 dated xxxFebruary 3, 2011, the applicant stated that only normal service radiation exposure of MEQ 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 MEW 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 applicants 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, the applicantit 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 TLAAThere is not enough informatioAdditional information is neededn for the staff to make the determination that the TLAA of normal service radiation exposure in MEQ has been properly dispositioned.
The Analysis section, as amended, of the LRA Section 4.7.11, as amended by letter dated xxFebruary 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 the proposed Commitment No. 45. Commitment No.45, as its current stated, did not identify what portion of the mechanical equipment qualification files that will be revised and what is the acceptance criteria of the such revision.
The staff finds the applicants disposition in accordance with 10 CFR 54.21(c)(1)(ii) not acceptable because the existing analyses (equipment design dose limits) has not been revised and extended. Rather, the 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 demonstration and the TLAA of the normal service radiation exposure is consistent with a dispositioned in accordance with 10 CFR 54.21(c)(1)(i). As discussed in 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.
Request (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 the Analysis section of the LRA Section 4.7.11 and provide sufficient detail to support the TLAA disposition to delineate the TLAA of normal service radiation exposure to in MEQ. Provide sufficient detail to support the TLAA disposition. 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.
Comment [o1]: Is this right? Was this missing?
Comment [o2]: What does this mean?
Comment [o3]: Define. Is thi MEW or MEQ?
Comment [C4]: Added (ii) not acceptable Comment [o5]: define.
Comment [o6]: Why do they need to amend it?
The second sentence sounds awkward.
Comment [o7]: Clarify what the applicants actual disposition was to begin with. Maybe put that in the BG section.
Comment [o8]: We should not be telling the applicant what to do. Is there a better way that you can word this?
Comment [C9]: I add that or justify...
(3) Revise the Disposition Section of the LRA Section 4.7.11 accordingly. Amend the disposition of TLAA of normal service radiation exposure to MEQ to 10 CFR 54.21(c)(1)(i) or justify why other the existing TLAA dispositions aredisposition is acceptable. If LRA Section 4.7.11 is amended as a result of RAI 4.7.11-1b, Pprovide an updated UFSAR supplement section in LRA Appendix A consistent with the revisions.commensurate with the amended LRA Section 4.7.11.
Comment [o10]: Should it be amend the disposition or justify why your existing disposition is appropriate?
Formatted: Tab stops: 0", Left + 3", Left +
3.5", Left + 4", Left + 4.5", Left + 5", Left +
5.5", Left