ML11307A154
| ML11307A154 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/07/2011 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| Download: ML11307A154 (4) | |
Text
1 SeabrookNPEm Resource From:
Plasse, Richard Sent:
Friday, January 07, 2011 6:09 AM To:
Cliche, Richard
Subject:
more Draft RAIs Seabrook Station DRAFT LRAs RAI 3.3.2.2.1-1
Background
LRA Sections 3.2.2.2.1 and 3.3.2.2.1, respectively, address the applicants aging management review for managing cumulative fatigue damage in engineered safety features (ESF) systems and auxiliary (AUX) systems, respectively. The staff noted that these systems were analyzed to applicable fatigue analysis criteria in the ASME Code Section III for ASME Code Class 2 or 3 components, or in the ANSI B31.1 Code for ANSI B31.1 components (non-ASME Code Class 1 components). The TLAA for non-ASME Code Class 1 components is documented in LRA Section 4.3.7 and the TLAA for crane load cycle limits is documented in LRA Section 4.7.6.
The GALL Report includes the following AMR Items on management of cumulative fatigue damage in PWR ESF and AUX subsystems.
AMR item 1 in Table 2 of GALL, Volume 1, references GALL AMR item V.D1-27, for management of cumulative fatigue damage in the piping, piping components and piping elements of the emergency core cooling systems AMR item 1 in Table 3 of GALL, Volume 1, references GALL AMR item VII.B-2, for management of cumulative fatigue damage in steel cranes structural girders Issue LRA Section 4.3.7 describes fatigue-related TLAAs arising within design analyses of the Non-Class 1 piping and components. The staff noted that the AMR items associated with LRA Table 3.2.1 Item 3.2.1-1 and LRA Table 3.3.1 Item 3.3.1-1 are included in the LRA, however the Non-Class 1 piping and components for residual heat removal (RHR) and safety injection (SI) systems are not listed in the LRA Tables 3.2.2-3 and 3.2.2-4, respectively. Furthermore, the staff noted that those AMR line items in LRA Tables 3.2.2-3 and 3.2.2-4 that identify cumulative fatigue damage and reference a TLAA, are Class 1 components.
Similarly, LRA Section 4.7.6 states that evaluation of load cycles over the design life of the polar gantry and cask-handling cranes is the basis of a safety determination and is, therefore, a TLAA. The staff noted that AMR line items associated with steel crane girders reference LRA Table 3.3.1 Item 3.3.1-1. Furthermore, only LRA Table 3.5.2-3 discusses AMR line items for fuel handling and overhead cranes. However, LRA Table 3.5.2-3 does not include any AMR lines items that are associated with metal fatigue TLAA of steel cranes structural girders or specifically reference LRA Table 3.3.1 Item 3.3.1-1.. The staff noted that LRA Sections 3.2.2.2.1 and 3.3.2.2.1 state that fatigue TLAA analyses are required to be evaluated in accordance with 10 CFR 54.21(c), but the LRA does not include any AMR items associated with LRA Table 3.2.1 Item 3.2.1-1 and LRA Table 3.3.1 Item 3.3.1-1 in LRA Tables 3.2.2-3, 3.2.2-4 and 3.5.2-3.
Request Include the following in the LRA:
a) In LRA Table 3.2.2-3 for RHR system and LRA Table 3.2.2-4 for SI system, all AMR items related to a TLAA for managing cumulative fatigue damage in non-Class 1 components in the RHR and SI systems.
2 b) In LRA Table 3.5.2-3 for Fuel Handling and Overhead Cranes all AMR items related to a TLAA for managing cumulative fatigue damage in the steel cranes structural girders Or provide the basis for excluding these AMR line items from the LRA.
RAI 3.3.2.2.1-2
Background
LRA Sections 3.2.2.2.1 and 3.3.2.2.1, respectively, address the applicants aging management review for managing cumulative fatigue damage in engineered safety features (ESF) systems and auxiliary (AUX) systems. The staff noted that these systems were analyzed to applicable fatigue analysis criteria in the ASME Code Section III for ASME Code Class 2 or 3 components or in the ANSI B31.1 Code for ANSI B31.1 components (non-ASME Code Class 1 components).
The GALL Report includes the following AMR Items on management of cumulative fatigue damage in PWR ESF and AUX subsystems:
AMR item 1 in Table 2 of GALL, Volume 1 AMR item 1 and 2 in Table 3 of GALL, Volume 1 LRA Sections 3.2.2.2.1 and 3.3.2.2.1 state that fatigue TLAA analyses are required to be evaluated in accordance with 10 CFR 54.21(c), however as discussed in RAI 3.x.2.2.1-1, the LRA Section 3.x.2 tables do not include AMR line items associated with items 3.2.1-1 and 3.3.1-1 for management of cumulative fatigue damage in PWR ESF and AUX subsystems.
Issue LRA Table 3.2.2-3 includes three AMR line items and LRA Table 3.2.2-4 includes five AMR line items associated with LRA Table 3.1.1 Item 3.1.1-8 associated with TLAAs of piping and fittings (Class 1, Class 1 including <4 inch), valve body (Class 1) and orifice (Class 1). Also, LRA Table 3.3.2-3 also includes two AMR line items associated with LRA Table 3.1.1 Item 3.1.1-8 associated with TLAAs of valve body (Class 1) and piping and fittings (Class 1 including <4 inches).
LRA Section 4.3.7 states that the chemical volume control system (CVCS), residual heat removal (RHR), and safety injection (SI) system components were designed in accordance with ASME Section III Class 2 and 3 requirements. It is not clear to the staff which piping and piping components are represented in these rows in LRA Tables 3.2.2-3, 3.2.2-4, and 3.3.2-3.
The staff further noted that GALL Report Section V.D1 Emergency Core Cooling System (PWR) states that portions of the RHR, and high-pressure and low-pressure SI systems extending from the reactor coolant system up to and including the second containment isolation valve associated with the primary coolant pressure boundary are governed by Regulatory Guide 1.26 Group A Quality Standards and covered in Section IV.C2 of the GALL Report. The LRA does not clarify whether the AMR items (3.1.1-8) in LRA Tables 3.3.2-3 and 3.2.2-3 and 3.2.2-4 represent the portions of the CVCS, RHR, and SI systems, respectively, that are located inside the reactor containment.
Request a) Clarify which portions of the CVCS, RHR, and SI systems are represented by AMR items 3.1.1-8 in LRA Table 3.3.2-3 for the CVCS and LRA Tables 3.2.2-3 and 3.3.2-4 for RHR and SI systems.
b) Since LRA Table 3.1.1, Item 3.1.1-8 represents Class 1 components, and the CVCS, RHR, and SI system components were designed to Class 2 and 3 requirements as discussed in LRA Section 4.3.7, (i) clarify the inconsistency between these two sections in the LRA and (ii) identify the TLAA, in LRA
3 Section 4, for the metal fatigue analysis for these Class 1 components represented by these AMR items.
Hearing Identifier:
Seabrook_License_Renewal_NonPublic Email Number:
2241 Mail Envelope Properties (Richard.Plasse@nrc.gov20110107060900)
Subject:
more Draft RAIs Sent Date:
1/7/2011 6:09:07 AM Received Date:
1/7/2011 6:09:00 AM From:
Plasse, Richard Created By:
Richard.Plasse@nrc.gov Recipients:
"Cliche, Richard" <Richard.Cliche@fpl.com>
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