ML11307A159
| ML11307A159 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/23/2011 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| Download: ML11307A159 (5) | |
Text
1 SeabrookNPEm Resource From:
Plasse, Richard Sent:
Wednesday, February 23, 2011 12:16 PM To:
Cliche, Richard
Subject:
draft RAIs Attachments:
SBK TRP 81 followup RAI 3 2 2 2 6-02.doc; SBK TRP 117 Followup RAI 4 7 12-2_Patel.doc; SBK AMP RAI TRP 22 CCCW Mintz Gavula B.2.1.12-8.doc
Hearing Identifier:
Seabrook_License_Renewal_NonPublic Email Number:
2246 Mail Envelope Properties (Richard.Plasse@nrc.gov20110223121600)
Subject:
draft RAIs Sent Date:
2/23/2011 12:16:17 PM Received Date:
2/23/2011 12:16:00 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 4
2/23/2011 12:16:00 PM SBK TRP 81 followup RAI 3 2 2 2 6-02.doc 42098 SBK TRP 117 Followup RAI 4 7 12-2_Patel.doc 41586 SBK AMP RAI TRP 22 CCCW Mintz Gavula B.2.1.12-8.doc 25714 Options Priority:
Standard Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Recipients Received:
Seabrook Station - Follow-Up RAI Related to AMR for TRP81 (Erosion)
Bob Jackson 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:
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 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 applicants 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 aging management program (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 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 Programs 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.
Request:
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..
Seabrook Station - Follow-Up RAI Related to TRP-117 Erach Patel RAI 4.7.12-2
Background:
By letter dated January 5, 2011, the staff issued RAI 4.7.12-1 concerning LRA Section 4.7.12, which discussed the absence of a TLAA for metal corrosion allowances. In its response dated February 3, 2011, the applicant revised LRA Section 4.7.12 to include steam generator tube metal corrosion allowance as a TLAA and revised Tables 4.1-1 and 4.1-2 for the disposition method and applicability of the TLAA. However, LRA Section 4.7.12 now states that the TLAA disposition for this issue is in accordance with 10 CFR 54.21(c)(1)(iii), whereas the revision to Table 4.1-1 states that the TLAA disposition is in accordance with 10 CFR 54.21(c)(1)(i). In addition, the staff noted that the FSAR supplement in LRA Section A.2.4.5, Other Plant-Specific TLAAs had not been revised as a result of this new determination.
Issue:
SRP-LR Section 4.7.3.1.1, 10 CFR 54.21(c)(1)(i), states that the justification provided by the applicant is reviewed to verify that the existing analyses are valid for the period of extended operation. In contrast, SRP-LR Section 4.7.3.1.3 10 CFR 54.21(c)(1)(iii), states that the applicants proposal to manage the aging effects associated with the TLAA by an AMP is reviewed to verify that the effects of aging will be adequately managed.. The staff is unclear which method was used by the applicant. In addition, 10 CFR 54.21(d) states that the FSAR supplement must contain a summary description of the evaluation of TLAAs for the period of extended operation as part of the LRA.
Request:
a)
Clarify which method was used to disposition the TLAA associated with the steam generator tube metal corrosion allowance.
b)
Provide a revised FSAR supplement for the evaluation of the TLAA associated with the steam generator tube metal corrosion allowance, in accordance with 10 CFR 54.21(d).
DRAFT Seabrook TRP 22 - Closed Cycle Cooling Water System RAI B.2.1.12-8
Background
The closed cycle water chemistry guidelines in EPRI TR-107396 state that higher levels of hydrazine can increase ammonia levels. Elevated concentrations of ammonia can cause higher levels of corrosion or cracking of copper alloys. The EPRI guideline also states that higher sulfate levels can lead to stress corrosion cracking of stainless steel alloys. In RAI B.2.1.12-1, the staff requested additional information on the effect of hydrazine and sulfate excursions in the thermal barrier system for aging during the period of extended operation. The response to RAI B.2.1.12-1 stated that the Seabrook Station evaluated the significance of allowing operation of the thermal barrier system at the elevated hydrazine and sulfate levels, and determined it to be acceptable. The response also stated that routine monitoring during operation at the elevated ranges showed no indication of system or component degradation.
Issue The applicant did not provide details of its evaluation that determined the operation at the elevated levels of hydrazine and sulfate would not cause any accelerated aging that could affect components during the period of extended operation. In addition, the applicant did not describe the routine monitoring it had performed during operation at the elevated ranges that could be credited for showing that no system or component degradation had occurred.
Request Provide the technical information that describes why the elevated levels of hydrazine and sulfate will not have caused accelerated aging of the components in the thermal barrier system that could affect component functions during the period of extended operation. If it is determined that the elevated levels of hydrazine and sulfate may have caused some accelerated aging, provide information on the aging management program that will be used to manage the accelerated aging.