ML13134A201

RAI for the Review of the Sequoyah Nuclear Plant, Units 1 and 2, LRA

ML13134A201
Person / Time
Site:	Sequoyah
Issue date:	06/05/2013
From:	Plasse R License Renewal Projects Branch 1
To:	James Shea Tennessee Valley Authority
Yoo M, 415-8583
References
TAC MF0481, TAC MF0482
Download: ML13134A201 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 June 5, 2013 Mr. Joe W. Shea Vice President, Nuclear Licensing Tennessee Valley Authority P.O. Box 2000 Soddy-Daisy, TN 37384

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. MF0481 AND MF0482) - SET 5

Dear Mr. Shea :

By letter dated January 7, 2013, Tennessee Valley Authority submitted an application pursuant to Title 10 of the Code of Federal Regulations (CFR) Part 54, to renew the operating license DPR-77 and DPR-79 for Sequoyah Nuclear Plant, Units 1 and 2, for review by the U.S. Nuclear Regulatory Commission (!\IRC) staff. The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.

These requests for additional information were discussed with Henry Lee, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-1427 or bye-mail at Richard .Plasse@nrc.gov.

Sincerely, pY Richard Plasse, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-327 and 50-328

Enclosure:

Requests for Additional Information cc w/encl: Listserv

.: ML13134A201 *concurred via email OFFICE LA:RPB2:DLR* PM:RPB1 :DLR BC:RPB1 :DLR PM: RPB1 :DLR NAME I King M Yoo Y Diaz-Sanabria R Plasse DATE 5/24/13 6/04/13 6/05/13 6/05/13 SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION REQUESTS FOR ADDITIONAL INFORMATION - SET 5 RAI 2.3.3.2-1 The following license of renewal application (LRA) boundary drawing shows the following fire protection systems/components as out of scope (i.e., not colored in orange):

LRA Drawing Systems/Components Location LRA-1,2-47W850-10 Fire suppression system associated with 5th Diesel F8 Generator Building LRA-1,2-47W850-27 Fire Hydrant HYD-26-2661 F9 Fire Hydrant HYD-26-2663 B9 Request:

1. The staff requests that the applicant verify whether the fire protection systems/components listed above are in the scope of license renewal in accordance with 10 CFR 54.4(a) and whether they are subject to an aging management review (AMR) in accordance with 10 CFR 54.21(a)(1).

2. If they are excluded from the scope of license renewal and are not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

RAI 2.3.3.2-2 Tables 2.3.3-2 and 3.3.2-2 of the LRA do not include the following fire protection components:

• fire hose connections, and hose racks

• pipe supports, hangers, and couplings

• yard fire hydrants

• water sprinklers and hose standpipe

• manual sprinkler systems for post accident facility, post accident system filters, and 125 volt vital battery board rooms I, II, III, and IV

• outdoor oil-filled transformer fire suppression system

• charcoal high-efficiency particulate air (HEPA) filter automatic fixed water spray system

• floor drains for fire water

• dikes and curbs for oil spill confinement

• fire damper housing ENCLOSURE

-2 Request:

1. The staff requests that the applicant verify whether the fire protection components listed above are in the scope of license renewal in accordance with 10 CFR 54.4(a) and whether they are subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2. If they are excluded from the scope of license renewal and are not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

RAJ 2.4.4-1 Section 2.4.4, "Bulk Commodities," of the LRA provides the scoping and screening results of various structures within the scope of license renewal and subject to an AMR. LRA Table 2.4-4, includes fire barriers (doors; fire protection components, miscellaneous steel, including framing steel; penetration seals (end caps) and sleeves; manways, hatches, manhole covers and hatch covers; fire stops; fire wrap; and penetration seals). However, scoping and screening results in Table 2.4-4 of the LRA does not include the following type of fire barriers:

• walls , floors , and ceilings

• fire retardant coating for exposed structural steel

• essential raw cooling water system fire retardant coating for metal enclosure Uunction box)

• cable fire retardant coating

• radiant energy shields Request:

1. The staff requests that the applicant verify whether the fire barriers listed above are in the scope of license renewal in accordance with 10 CFR 54.4(a) and whether they are subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2. If they are excluded from the scope of license renewal and are not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

RAJ 3.1.2-1

Background:

LRA Table 3.1 .2-2 indicates that the lower core support plate made of cast austenitic stainless steel (CASS) is being managed for "loss of fracture toughness" by the Reactor Vessel Internals Program as an "expansion" component. LRA Section 3.1 .2.2.9.A.6 indicates that the lower core support plate is also known as the lower support casting . In addition, LRA Table C-2, "Expansion Components at SON Units 1 and 2," indicates that the "Lower internals assembly Lower support casting" is managed for thermal embriUlement.

In response to applicantllicensee action item (AILAI) No.7 in LRA Appendix C the applicant indicates that reduction in fracture toughness due to thermal and irradiation embriUlement is not applicable to the lower core support plate .

-3 Issue:

The information in LRA Table 3.1.2-3 and LRA Table C-2 is inconsistent with the information provided in the applicant's response to AI LAI No.7; thus, it is not clear whether or not the lower core support plate (i.e., lower support casting) is managed by the Reactor Vessel Internals Program for loss of fracture toughness.

Request:

1. Clarify whether "loss of fracture toughness" for the lower core support plate (i.e., lower support casting) is managed in the "expansion" component category within the Reactor Vessel Internals Program .

2. Revise the LRA, as necessary, to clarify this discrepancy between the information in LRA Table 3.1.2-3 and LRA Table C-2 and the information in the applicant's response to AlLAI No.7 in LRA Appendix C. Provide an explanation for these revisions.

RAI3.1.2-2

Background:

LRA Table 3.1.2-2 indicates that the core barrel: upper core barrel and lower core barrel circumferential (girth) welds made of stainless steel are being managed for "loss of fracture toughness" by the Reactor Vessel Internals Program as a "primary" component.

LRA Table C-1, "Primary Components at SON Units 1 and 2," indicates that the core barrel assembly: upper and lower core barrel cylinder girth welds are only managed for cracking (stress corrosion cracking, irradiation-assisted stress corrosion cracking, fatigue). Further, this table identifies the expansion link, examination method/frequency and examination coverage for this component.

Issue:

Since the upper and lower core barrel cylinder girth welds are being managed for loss of fracture toughness as a "primary component," it is not clear what the expansion link, examination method/frequency and examination coverage are.

Request:

1. Identify and justify the expansion link, examination method/frequency and examination coverage for the upper and lower core barrel cylinder girth welds when being managed for the aging effect of loss of fracture toughness as a "primary" component.

2. Revise the LRA, as necessary, and provide an explanation for these revisions.

-4 RAI 3.3.2.3.6-1

Background:

LRA Tables 3.3.2-6, 3.3.2-13 and 3.3.2-17-15 state that for fiberglass flexible duct connections, piping, and tanks exposed to internal and external indoor air, aging effects are not applicable and no aging management program (AMP) is proposed. The AMR items cite generic note G.

Regulatory Issues Summary 2012-02, "Insights Into Recent License Renewal Application Consistency with the Generic Aging Lessons Learned Report," states that when an applicant states that there is no aging effect requiring management (AERM) and no proposed AMP, the application should state the specific material type and grade of polymeric materials and greater detail on the specific environment (e.g ., ultraviolet light, ozone, radiation).

Issue:

The staff noted that fiberglass piping can be constructed with different bonding agents (e.g.,

epoxy resin, reinforced vinyl ester) which can respond differently to environmental factors.

Flexible duct connections could be subject to wear as defined by the Generic Aging Lessons Learned (GALL) Report Table IX.F, "Selected Definitions & Use of Terms for Describing and Standardizing Aging Mechanisms," which states that, "[w]ear is defined as the removal of surface layers due to relative motion between two surfaces or under the influence of hard, abrasive particles. Wear occurs in parts that experience intermittent relative motion, frequent manipulation, or in clamped joints where relative motion is not intended, but may occur due to a loss of the clamping force. "

Request:

1. State the specific material type and grade for the fiberglass components including the bonding agent.

2. State whether high enough levels of ultraviolet light, ozone, or radiation could be present which would cause the components to age.

3. If the above environmental factors are impactful , state why there is no AERM, or otherwise, propose an AMP to manage the AERM .

4. State whether wear could be occurring in the flexible duct connections, and if wear could occur, how aging will be managed .

RAI 3.5.2.3.4-1

Background:

LRA Table 3.5.2-4, "Bulk Commodities," includes fiberglass and calcium silicate insulation exposed to uncontrolled indoor air and states that there are no aging effects for these materials and environment combinations requiring age management and no AMP is proposed .

-5 Issue:

LRA Table 3.5.2-4 states that one of the intended functions of the insulation, as defined in LRA Table 2.0-1, "Component Intended Functions: Abbreviations and Definitions," is to "provide insulating characteristics to reduce heat transfer (structural). "

The staff notes that in a dry environment of uncontrolled indoor air, without potential for water leakage, spray, or condensation, fiberglass and calcium silicate are expected to be inert to environmental effects. However, in moist environments, calcium silicate has been found to degrade. In addition, both fiberglass and calcium silicate insulation have the potential for prolonged retention of any moisture to which they are exposed; prolonged retention of moisture may increase thermal conductivity, thereby degrading the insulating characteristics, and also could accelerate the aging of insulated components . The staff noted that the LRA's description of insulation materials includes aluminum jacketing which , if properly installed, provides protection from ambient moisture for the heat-resistant insulating materials.

Request:

For those insulation components in LRA Table 3.5.2-4 with a function to limit heat transfer, state:

1. whether all in-scope insulation is covered by jacketing, and

2. how the configuration control plant-specific procedures for jacketing ensures that it is properly installed so as to prevent water intrusion into the insulation (e.g ., seams on the bottom, overlapping seams) such that aging management is not required .

Letter to J. Shea from R. Plasse dated June 5, 2013

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. MF0481 AND IVlF0482)

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