SBK-L-17103, Supplement 55 - Response to Request for Additional Information for the Review of the License Renewal Application - Bolting Integrity Program

Supplement 55 - Response to Request for Additional Information for the Review of the License Renewal Application - Bolting Integrity Program

ML17173A065
Person / Time
Site:	Seabrook
Issue date:	06/20/2017
From:	Mccartney E NextEra Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC ME4028, SBK-L-17103
Download: ML17173A065 (9)

Text

~IFXTera ENERGY "

SEABROOK June 20, 2017 10 CFR 54 Docket No. 50-443 SBK-L-17103 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Seabrook Station Supplement 55 - Response to Request for Additional Information for the Review of the Seabrook Station License Renewal Application - Bolting Integrity Program

References:

1. NextEra Energy Seabrook LLC, letter SBK-L-10077, "Seabrook Station Application for Renewed Operating License," May 25, 2010 (Accession Number ML101590099).

2. NRC, "Request for Additional Information for the Review of the Seabrook Station License Renewal Application - Set 26 (CAC NO. ME4028), RAI B.2.1.9 Bolting Integrity," May 24, 2017 (Accession Number ML171398835).

3. NextEra Energy Seabrook LLC, letter SBK-L-12258, "LRA Commitment Update and RAI B.1.4-4 Clarification," December 10, 2012 (Accession Number ML12349A214).

In Reference 1, NextEra Energy Seabrook, LLC (NextEra Energy Seabrook) submitted an application for a renewed facility operating license for Seabrook Station Unit 1 in accordance with the Code of Federal Regulations, Title 10, Parts 50, 51 , and 54.

In Reference 2, the NRC requested additional information related to NextEra Energy Seabrook's Bolting Integrity Program and how the aging effects for closure bolting associated with air filled, gas filled, and systems at atmospheric pressure will be managed.

NextEra Energy Seabrook, LLC P.O. Box 300, Lafayette Road, Seabrook, NH 03874

U.S. Nuclear Regulatory Commission SBK-L-17103 I Page 2 In Reference 3, Nextera Energy Seabrook submitted letter SBK-L-12258, which revised License Renewal Application Appendix A, A.2.1 .9, and Appendix B, B.2.1.9. provides NextEra Energy Seabrook's response to the NRC's Request for Additional Information (RAI B.2.1.9-3) concerning closure bolting aging management for air filled , gas filled, and systems at internal atmospheric pressure. provides NextEra Energy Seabrook's revision of License Renewal Application, Appendix B - Aging Management Programs , B.2.1 .9 - Bolting Integrity.

The enclosures include changes to the LRA. To facilitate understanding , the changes are explained, and where appropriate, portions of the LRA are repeated with the change highlighted by strikethroughs for deleted text and balded italics for inserted text.

There are no new or revised regulatory commitments contained in this letter.

If there are any questions or additional information is needed, please contact Mr.

Edward J. Carley, Engineering Supervisor - License Renewal, at (603) 773-7957 .

If you have any questions regarding this correspondence, please contact Mr. Kenneth Browne, Licensing Manager, at (603) 773-7932 .

I declare under penalty of perjury that the foregoing is true and correct.

Executed on June '2.0 , 2017.

Sincerely, NextEra Energy Seabrook, LLC

Enclosures:

Supplement 55 - NextEra Energy Seabrook's response to RAI B.2 .1.9-3.

Enclosure 2: Supplement 55 - Revision of License Renewal Application, Appendix B -

Aging Management Programs, B.2.1 .9 - Bolting Integrity.

U.S. Nuclear Regulatory Commission SBK-L-17103 I Page 3 cc: D. H. Dorman NRC Region I Administrator J.C. Poole NRC Project Manager P. C. Cataldo NRC Senior Resident Inspector L. M. James NRC Project Manager, License Renewal Mr. Perry Plummer Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 perry.plummer@dos.nh.gov Mr. John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399 John.Giarrusso@massmail.state.ma.us

Enclosure 1 to SBK-L-17103 Supplement 55 - NextEra Energy Seabrook's response to RAI B.2.1.9-3.

U.S. Nuclear Regulatory Commission SBK-L-17103 I Enclosure 1/ Page 2 RAI # 8.2.1.9-3

Background

Section 54.21 (a)(3) of 10 CFR requires the applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. As described in SRP-LR, an applicant may demonstrate compliance with 1* 0 CFR 54.21 (a)(3) by referencing the GALL Report and when evaluation of the matter in the GALL Report applies to the plant.

GALL Report AMP Xl.M18 states:

Degradation of pressure boundary closure bolting due to crack initiation, loss of preload, or loss of material may result in leakage from the mating surfaces or joint connections of pressure boundary components. Periodic inspection of pressure boundary components for signs of leakage ensures that age-related degradation of closure bolting is detected and corrected before component leakage becomes excessive. Accordingly, pressure retaining bolted connections should be inspected at least once per refueling cycle.

LRA Section B.2.1.9 states that the Bolting Integrity program "includes periodic inspection of closure bolting assemblies to detect signs of leakage that may be indicative of loss of preload ...

Periodic inspection of bolted closures in conjunction with the Seabrook Station In service Inspection Program and Seabrook Station External Surfaces Monitoring Program will detect the aging effects and joint leakage." The LRA states that the External Surfaces Monitoring and In service Inspection programs use visual inspections to detect leakage which could indicate a loss of preload for closure bolting.

Issue While the staff notes that visual inspections will be capable of detecting leakage of liquid filled systems, a visual inspection may not be sufficient to detect leakage for air- or gas filled systems.

LRA Table 3.3.2-8, "Containment Online Purge System," and 3.3.2-20, "Instrument Air System,"

are examples of systems that cite the Bolting Integrity Program to manage aging effects associated with closure bolting that could be or are air-filled or gas-filled. Based on a review of LRA Section B.2.1.9 and SER with Open Items Section 3.0.3.1.7, "Bolting Integrity," it is not clear how aging effects for closure bolting installed in air-filled or gas-filled systems will be effectively managed because in these systems there is typically limited or no visual signs of leakage.

NRC Request #1 For air-filled systems, gas-filled systems, and systems at internal atmosphere pressure for which aging effects for closure bolting will be managed by the Bolting Integrity Program, state how the aging effects will be managed.

U.S. Nuclear Regulatory Commission SBK-L-17103 I Enclosure 1/ Page 3 NextEra Energy Seabrook's Response to RAI B.2.1.9-3, Request #1 NextEra Energy Seabrook's Plant Leak Management procedure provides a means of identifying, classifying, and tracking external, non-boric acid system leaks. The Leak Management procedure includes using suitable leak detection, evaluation, correction and prevention techniques to not only try to prevent leaks from occurring in the first place, but how to assess and address them if they do occur. Within the Station's leak management procedure, air and gas filled system leaks are identified using a soap like solution to produce bubbling at the leakage location. Alternative methods can include, but are not limited to, audible leak detection (with normal listening or enhanced utilizing ultrasonic leak detection), staining, performance monitoring parameters (pressure, temperature, H2 detectors, etc.), or use of helium for vacuum leaks in certain applications. Seabrook will manage aging effects for Bolting Integrity closure bolting in air and gas filled systems by using leak identification and correction to preclude loss of intended function.

For Bolting Integrity program closure bolting associated with systems at internal atmospheric pressure, Seabrook will perform a tightness check on in-scope and readily accessible closure bolts prior to the period of extended operation. A tightness check, combined with good leak management and bolt torqueing practices, will manage the aging effects of closure bolting associated with systems at internal atmospheric pressure within the Bolting Integrity program.

The revised License Renewal Application, Appendix B - Aging Management Programs, B.2.1.9 - Bolting Integrity, Program Description, is presented within Enclosure 2 of this letter.

U.S. Nuclear Regulatory Commission SBK-L-17103 I Enclosure 1/ Page 4 NRC Request #2 State any enhancements to plant-specific procedures and/or to the Bolting Integrity program necessary to incorporate how these aging effects will be managed.

NextEra Energy's Seabrook Response to RAI B.2.1.9-3, Request #2 The revised License Renewal Application, Appendix B -Aging Management Programs, B.2.1.9 - Bolting Integrity, Program Description, is presented within Enclosure 2 of this letter.

As discussed in response to Request #1 within this letter, the current Seabrook Station Plant Leak Management procedure will be utilized for aging management of in scope closure bolting of the Bolting Integrity program associated with air and gas filled systems. For systems at internal atmospheric pressure, a tightness check will be performed on readily accessible in scope closure bolting prior to the period of extended operation.

Enclosure 2 to SBK-L-17103 Supplement 55 - Revision of License Renewal Application, Appendix B - Aging Management Programs, B.2.1.9 - Bolting Integrity.

U.S. Nuclear Regulatory Commission SBK-L-17103 I Enclosure 2/ Page 2 Enclosure bolting of air filled, gas filled, and systems at atmospheric pressure within the Bolting Integrity program will have the appropriate aging management. As transmitted previously in SBK-L-12258 (Reference 3), the second paragraph of Seabrook Station's License Renewal Application, Appendix B - Aging Management Programs, B.2.1.9 -

Bolting Integrity, Program Description, second paragraph, is revised below.

The program includes periodic inspection of closure bolting assemblies to detect signs of leakage that may be indicative of loss of preload, loss of material, or crack initiation. Leak detection inspections are performed on in scope closure bolting in air filled and gas filled systems using a method that detects leakage. Prior to the period of extended operation, readily accessible closure bolting within systems at internal atmospheric pressure will have a tightness check performed. Periodic inspection of bolted closures in conjunction with the Seabrook Station lnservice Inspection Program and Seabrook Station External Surfaces Monitoring Program will detect the aging effects and joint leakage.

Operator rounds and system walkdowns will also identify joint leakage. Bolted connections in buried, underground, and inaccessible submerged piping will be inspected for indication of leakage caused by loss of preload when the associated piping is inspected by the Buried Piping and Tanks Inspection program. In instances where hydrostatic testing, flow testing, or fire protection jockey pump monitoring are used in lieu of visual inspections, these methods will also be credited to identify leakage caused by loss of preload at bolted connections. Additionally, the service water pump column bolted connections are submerged in raw water and cannot be inspected for leakage due to loss of preload.

Service water pump column bolting will be inspected for loss of material and loss of preload when the service water pumps are removed for maintenance.