SBK-L-17172, Seventh Annual Update to the License Renewal Application
| ML17291B221 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/18/2017 |
| From: | Mccartney E NextEra Energy Seabrook |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| SBK-L-17172 | |
| Download: ML17291B221 (25) | |
Text
NEXTera ENERGY~
October 18, 2017 10 CFR 54 Docket No. 50-443 SBK-L-17172 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
References:
Seabrook Station Seventh Annual Update to the NextEra Energy Seabrook License Renewal Application SEABROOK
- 1.
NextEra Energy Seabrook, LLC letter SBK-L-10077, "Seabrook Station Application for Renewed Operating License," May 25, 2010. (Accession Number ML101590099)
- 2.
NextEra Energy Seabrook, LLC letter SBK-L-11773, "First Annual Update to the Seabrook License Renewal Application," August 25, 2011. (Accession Number ML11241A142)
- 3.
NextEra Energy Seabrook, LLC letter SBK-L-12186, "Second Annual Update to the Seabrook License Renewal Application," September 18, 2012. (Accession Number ML12268A171)
- 4.
NextEra Energy Seabrook, LLC letter SBK-L-13115, "Third Annual Update to the Seabrook License Renewal Application," July 2, 2013. (Accession Number ML13189A197)
- 5.
NextEra Energy Seabrook, LLC letter SBK-L-13183, "Clarification to the Third Annual Update Provided in SBK-L-13115," October 21, 2013. (Accession Number ML13189A197)
- 6.
NextEra Energy Seabrook, LLC letter SBK-L-14173, "Fourth Annual Update to the Seabrook License Renewal Application," October 2, 2014. (Accession Number ML14282A023)
U.S. Nuclear Regulatory Commission SBK-L-17172 /Page 2
- 7.
NextEra Energy Seabrook, LLC letter SBK-L-15170, "Fifth Annual Update to the Seabrook License Renewal Application," September 18, 2015. (Accession Number ML15271A161)
- 8.
NextEra Energy Seabrook, LLC letter SBK-L-15170, "Sixth Annual Update to the Seabrook License Renewal Application," October 7, 2016. (Accession Number ML16281A548)
In Reference 1, NextEra Energy Seabrook, LLC 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.
The License Renewal Rule, 10 CFR 54.21(b) requires that each year following submittal of a license renewal application (LRA), and at least 3 months before scheduled completion of the NRC review, an update to the LRA must be submitted that identifies any change to the current licensing basis (CLB) of the facility that materially affects the content of the LRA including the Updated Final Safety Analysis Report Supplement.
In accordance with the License Renewal Rule, NextEra Energy Seabrook, LLC has performed a seventh annual review of CLB changes since the submittal of the LRA, to determine whether any sections of the LRA were affected by these changes. The first, second, third, fourth, fifth and sixth annual review results are documented in References 2, 3, 4, 5, 6, 7 and 8. The seventh annual review did identify changes to the current licensing basis (CLB) of the facility that materially affected the content of the LRA.
Provided in this Supplement are 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 is one completed* Commitment (No. 65) contained in this letter. There are also corrections/clarifications for Commitments 45, 51 and 83, which had been statused in previous correspondence.
An updated LRA Appendix A -
Updated Final Safety Analysis Report Supplement Table A.3, License Renewal Commitment List is contained in Enclosure 2.
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.
U.S. Nuclear Regulatory Commission SBK-L-17172 / Page 3 I declare under penalty of perjury that the foregoing is true and correct.
Executed on October Ji, 2017 Sincerely, NextEra Energy Seabrook, LLC
Enclosures:
- Seventh Annual Update to the NextEra Energy Seabrook Station License Renewal Application I - LAA Appendix A - Final Safety Analysis Report Supplement Table A.3, License Renewal Commitment List Updated to Reflect Changes to Date cc:
D. H. Dorman J.C. Poole P. C. Cataldo L. M. James E.H. Gettys Mr. Perry Plummer NRC Region I Administrator NRC Project Manager NRC Senior Resident Inspector NRC Project Manager, License Renewal NRC Project Manager, License Renewal 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 to SBK-L-17172 Seventh Annual Update to the NextEra Energy Seabrook Station License Renewal Application
U.S. Nuclear Regulatory Commission SBK-L-17172 / Enclosure 1 / Page2
- 1. Screen Wash Filter Material Change: The Screen Wash filter housing material was changed from gray cast iron to bronze (copper alloy). As a result of this change, the following change is made to the LRA.
Table 3.3.2-36, on LRA Page 3.3-457, is modified as follows:
NU REG Component Intended Material Environment Aging Effect Aging 1801 Table Note Type Function Requiring Management Vol. 2 3.X.1 Management Program Item Item Filter Housing Leakage GFay Gast Condensation Loss of External
¥1+.+4 3.3.1-SE,4 Boundary
~
(External)
Material Surfaces
~ ag25 (Spatial)
CoppeF Monitoring Vll.F2-14 Alloy Program (A-46)
Filter Housing Leakage GFay Gast Raw Water Loss of Inspection of
~
3.3.1-E,J5 Boundary
~
(Internal)
Material Internal
{A-JJ) ega1 (Spatial)
Copper Surfaces in Vll.C1-9 Alloy Miscellaneous (A-44)
Piping and Ducting Components Program
- 2. A design change made changes to portions of the switchyard which are not in the scope of License Renewal but do appear on LRA Figure 2.5-1 for the Station Black Out Offsite Recovery Plan. A revised LRA Figure 2.5-1 is hereby included.
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U.S. Nuclear Regulatory Commission SBK-L-171 72 I Enclosure 1 I Page 3
- 3. A design change installed 20 In-Core Detector Assemblies (ICDAs) in the In-Core Instrumentation System (IC). This is the last batch of the new style (AREVA) ICDAs, which have now replaced the original Westinghouse supplied ICDAs. With the installation of the final batch of ICDAs, zero Moveable In-Core Detector paths remain.
License Renewal Application (LRA) Table A.3 Commitment List item No. 65 is thereby complete and is updated as follows:
PFisF ts Ute ~eFise Flux Implement measures to ensure that sf e~eAeee 65 Thimble the movable incore detectors are not s~eFatisA.
IA Tube returned to service during the period of N/A PFSQFeSS extended operation.
Complete.
- 4. During review of LRA commitments, it was determined that the UFSAR location for Commitment No. 45 was inadvertently deleted in previous correspondence. LRA Table A.3 Commitment List item No. 45 UFSAR Location has been restored as A.2.1.31.A.
- 5. During review of LRA commitments, it was determined that Commitment No. 51 was inadvertently deleted in previous correspondence. LRA Table A.3 Commitment List item No. 51 has been restored.
- 6. During review of LRA commitments, it was determined that LRA Table A.3 Commitment List item No. 83 had been shown as complete, but not specifically addressed in correspondence. Commitment List item No. 83 is complete on the basis that the ASR AMP has been enhanced for the installation of extensometers and expansion monitoring has commenced.
to SBK-L-17172 LRA Appendix A - Final Safety Analysis Report Supplement Table A.3, License Renewal Commitment List Updated to Reflect Changes to Date
U.S. Nuclear Regulatory Commission SBK-L-17172 I Enclosure 2 I Page 2 A.3 LICENSE RENEW AL COMMITMENT LIST No.
PROGRAM or TOPIC COMMITMENT Provide confirmation and acceptability of the implementation
- 1.
PWR Vessel Internals ofMRP-227-A by addressing the plant-specific Applicant/Licensee Action Items outlined in section 4.2 of the NRC SER.
Enhance the program to include visual inspection for cracking,
- 2.
Closed-Cycle Cooling Water loss of material and fouling when the in-scope systems are opened for maintenance.
Inspection of Overhead Heavy Enhance the program to monitor general corrosion on the crane Load and Light Load (Related
- 3.
to Refueling) Handling and trolley structural components and the effects of wear on Systems the rails in the rail system.
Inspection of Overhead Heavy
- 4.
Load and Light Load (Related Enhance the program to list additional cranes for monitoring.
to Refueling) Handling Systems Enhance the program to include an annual air quality test
- 5.
Compressed Air Monitoring requirement for the Diesel Generator compressed air sub system.
- 6.
Fire Protection Enhance the program to perform visual inspection of penetration seals by a fire protection qualified inspector.
Enhance the program to add inspection requirements such as
- 7.
Fire Protection spalling, and loss of material caused by freeze-thaw, chemical attack, and reaction with aggregates by qualified inspector.
Enhance the program to include the performance of visual
- 8.
Fire Protection inspection of fire-rated doors by a fire protection qualified inspector.
UFSAR SCHEDULE LOCATION A.2.1.7 Complete Prior to the period of A.2.1.12 extended operation.
Prior to the period of A.2.1.13 extended operation.
A.2.1.13 Prior to the period of extended operation.
Prior to the period of A.2.1.14 extended operation.
A.2.1.15 Prior to the period of extended operation.
Prior to the period of A.2.1.15 extended operation.
Prior to the period of A.2.1.15 extended operation.
U.S. Nuclear Regulatory Commission SBK-L-17172 /Enclosure 2 /Page 3
- 9.
Fire Water System
- 10.
Fire Water System
- 11.
Fire Water System Enhance the program to include NFPA 25 (2011 Edition) guidance for "where sprinklers have been in place for 50 years, they shall be replaced or representative samples from one or more sample areas shall be submitted to a recognized testing laboratory for field service testing".
Enhance the program to include the performance of periodic flow testing of the fire water system in accordance with the guidance ofNFPA 25 (2011 Edition).
Enhance the program to include the performance of periodic visual or volumetric inspection of the internal surface of the fire protection system upon each entry to the system for routine or corrective maintenance to evaluate wall thickness and inner diameter of the fire protection piping ensuring that corrosion product buildup will not result in flow blockage due to fouling. Where surface irregularities are detected, follow-up volumetric examinations are performed. These inspections will be documented and trended to determine if a representative number of inspections have been performed prior to the period of extended operation. If a representative number of inspections have not been performed prior to the period of extended operation, focused inspections will be conducted. These inspections will commence during the ten year period prior to the period of extended operation and continue through the period of extended operation Prior to the period of A.2.1.16 extended operation.
Prior to the period of A.2.1.16 extended operation.
A.2.1.16 Within ten years prior to the period of extended operation.
U.S. Nuclear Regulatory Commission SBK-L-17172 /Enclosure 21Page4
- 12.
Aboveground Steel Tanks
- 13.
Fire Water System
- 14.
Fuel Oil Chemistry
- 15.
Fuel Oil Chemistry
- 16.
Fuel Oil Chemistry
- 17.
Fuel Oil Chemistry Enhance the program to include 1) In-scope outdoor tanks, except fire water storage tanks, constructed on soil or concrete,
- 2) Indoor large volume storage tanks (greater than 100,000 gallons) designed to near-atmospheric internal pressures, sit on concrete or soil, and exposed internally to water, 3) Visual, surface, and volumetric examinations of the outside and inside surfaces for managing the aging effects ofloss of material and cracking, 4) External visual examinations to. monitor degradation of the protective paint or coating, and 5)
Inspection of sealant and caulking for degradation by performing visual and tactile examination (manual manipulation) consisting of pressing on the sealant or caulking to detect a reduction in the resiliency and pliability.
Enhance the program to perform exterior inspection of the fire water storage tanks annually for signs of degradation and include an ultrasonic inspection and evaluation of the internal bottom surface of the two Fire Protection Water Storage Tanks per the guidance provided in NFP A 25 (2011 Edition).
Enhance program to add requirements to 1) sample and analyze new fuel deliveries for biodiesel prior to offloading to the Auxiliary Boiler fuel oil storage tank and 2) periodically sample stored fuel in the Auxiliary Boiler fuel oil storage tank.
Enhance the program to add requirements to check for the presence of water in the Auxiliary Boiler fuel oil storage tank at least once per quarter and to remove water as necessary.
Enhance the program to require draining, cleaning and inspection of the diesel fire pump fuel oil day tanks on a frequency of at least once every ten years.
Enhance the program to require ultrasonic thickness measurement of the tank bottom during the IO-year draining, cleaning and inspection of the Diesel Generator fuel oil storage tanks, Diesel Generator fuel oil day tanks, diesel fire pump fuel oil day tanks and auxiliary boiler fuel oil storage tank.
Within 10 years prior to the A.2.1.17 period of extended operation.
Within ten years prior to the A.2.1.16 period of extended operation.
A.2.1.18 Prior to the period of extended operation.
Prior to the period of A.2.1.18 extended operation.
Prior to the period of A.2.1.18 extended operation.
Prior to the period of A.2.1.18 extended operation.
U.S. Nuclear Regulatory Commission SBK-L-171 72 I Enclosure 2 I Page 5
- 18.
Reactor Vessel Surveillance
- 19.
Reactor Vessel Surveillance
- 20.
Reactor Vessel Surveillance
- 21.
Reactor Vessel Surveillance
- 22.
One-Time Inspection Selective Leaching of
- 23.
Materials Buried Piping And Tanks
- 24.
Inspection Enhance the program to specify that all pulled and tested Prior to the period of capsules, unless discarded before August 31, 2000, are placed A.2.1.19 extended operation.
in storage.
Enhance the program to specify that if plant operations exceed the limitations or bounds defined by the Reactor Vessel Surveillance Program, such as operating at a lower cold leg A.2.1.19 Prior to the period of temperature or higher fluence, the impact of plant operation extended operation.
changes on the extent of Reactor Vessel embrittlement will be evaluated and the NRC will be notified.
Enhance the program as necessary to ensure the appropriate withdrawal schedule for capsules remaining in the vessel such that one capsule will be withdrawn at an outage in which the capsule receives a neutron fluence that meets the schedule A.2.1.19 Prior to the period of requirements of 10 CFR 50 Appendix Hand ASTM E185-82 extended operation.
and that bounds the 60-year fluence, and the remaining capsule(s) will be removed from the vessel unless determined to provide meaningful metallurgical data.
Enhance the program to ensure that any capsule removed, without the intent to test it, is stored in a manner which A.2.1.19 Prior to the period of maintains it in a condition which would permit its future use, extended operation.
including during the period of extended operation.
Implement the One Time Inspection Program.
A.2.1.20 Within ten years prior to the period of extended operation.
Implement the Selective Leaching of Materials Program. The program will include a one-time inspection of selected Within five years prior to the components where selective leaching has not been identified A.2.1.21 period of extended operation.
and periodic inspections of selected components where selective leaching has been identified.
Implement the Buried Piping And Tanks Inspection Program.
A.2.1.22 Within ten years prior to the period of extended operation
U.S. Nuclear Regulatory Commission SBK-L-17172 I Enclosure 2 I Page 6 One-Time Inspection of
- 25.
ASME Code Class 1 Small Bore-Piping
- 26.
External Surfaces Monitoring Inspection oflnternal Surfaces in Miscellaneous
- 27.
Piping and Ducting Components
- 28.
Lubricating Oil Analysis
- 29.
Lubricating Oil Analysis
- 30.
Lubricating Oil Analysis
- 31.
ASME Section XI, Subsection IWL Structures Monitoring
- 32.
Program Structures Monitoring
- 33.
Program Implement the One-Time Inspection of ASME Code Class 1 Within ten years prior to the Small Bore-Piping Program.
A.2.1.23 period of extended operation.
Enhance the program to specifically address the scope of the program, relevant degradation mechanisms and effects of Prior to the period of interest, the refueling outage inspection frequency, the training A.2.1.24 extended operation.
requirements for inspectors and the required periodic reviews to determine program effectiveness.
Implement the Inspection of Internal Surfaces in Miscellaneous A.2.1.25 Prior to the period of Piping and Ducting Components Program.
extended operation.
Enhance the program to add required equipment, lube oil Prior to the period of analysis required, sampling frequency, and periodic oil A.2.1.26 changes.
extended operation.
Enhance the program to sample the oil for the Reactor Coolant A.2.1.26 Prior to the period of pump oil collection tanks.
extended operation.
Enhance the program to require the performance of a one-time ultrasonic thickness measurement of the lower portion of the A.2.1.26 Prior to the period of Reactor Coolant pump oil collection tanks prior to the period extended operation.
of extended operation.
Enhance procedure to include the definition of"Responsible A.2.1.28 Prior to the period of Engineer".
extended operation.
Enhance procedure to add the aging effects, additional Prior to the period of locations, inspection frequency and ultrasonic test A.2.1.31 requirements.
extended operation.
Enhance procedure to include inspection of opportunity when Prior to the period of planning excavation work that would expose inaccessible A.2.1.31 extended operation.
concrete.
U.S. Nuclear Regulatory Commission SBK-L-17172 I Enclosure 2 I Page 7 Electrical Cables and Connections Not Subject to
- 34.
10 CFR 50.49 Environmental Qualification Requirements Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental
- 35.
Qualification Requirements Used in Instrumentation Circuits Inaccessible Power Cables Not Subject to 10 CFR 50.49
- 36.
Environmental Qualification Requirements
- 37.
Metal Enclosed Bus
- 38.
Fuse Holders Implement the Electrical Cables and :onn~ctions N?t Subject Prior to the period of to 10 CFR 50.49 Environmental Quahficat10n Requirements A.2.1.32 extended operation.
program.
Implement the Electrical Cables and :onn~ctions N?t Subject Prior to the period of to 10 CFR 50.49 Environmental Quahficat1on Requirements A.2.1.33 extended operation.
Used in Instrumentation Circuits program.
Implement the Inaccessible Po~er C~bles Not_ Subject to 10 Prior to the period of CFR 50.49 Environmental Quahficat10n Requirements A.2.1.34 extended operation.
program.
A.2.1.35 Prior to the period of Implement the Metal Enclosed Bus program.
extended operation.
A.2.1.36 Prior to the period of Implement the Fuse Holders program.
extended operation.
U.S. Nuclear Regulatory Commission SBK-L-17172 /Enclosure 2 /Page 8 Electrical Cable Connections
- 39.
Not Subject to 10 CFR 50.49 Enviromnental Qualification Requirements
- 40.
345 KV SF6 Bus Metal Fatigue of Reactor
- 41.
Coolant Pressure Boundary
- 42.
Metal Fatigue of Reactor Coolant Pressure Boundary Pressure -Temperature
- 43.
Limits, including Low Temperature Overpressure Protection Limits Implement the Electrical Cable Connections Not Subject to 10 Prior to the period of CFR 50.49 Environmental Qualification Requirements A.2.1.37 extended operation.
program.
Implement the 345 KV SF6 Bus program.
A.2.2.1 Prior to the period of extended operation.
Enhance the program to include additional transients beyond A.2.3.1 Prior to the period of those defined in the Technical Specifications and UFSAR.
extended operation.
Enhance the program to implement a software program, to Prior to the period of count transients to monitor cumulative usage on selected A.2.3.l extended operation.
components.
The updated analyses will be Seabrook Station will submit updates to the P-T curves and submitted at the appropriate L TOP limits to the NRC at the appropriate time to comply with A.2.4.1.4 time to comply with 10 CFR 10 CFR 50 Appendix G.
50 Appendix G, Fracture Toughness Requirements.
U.S. Nuclear Regulatory Commission SBK-L-17172 I Enclosure 2 I Page 9 Environmentally-Assisted
- 44.
Fatigue Analyses (TLAA)
NextEra Seabrook will perform a review of design basis ASME Class 1 component fatigue evaluations to determine whether the NUREG/CR-6260-based components that have been evaluated for the effects of the reactor coolant environment on fatigue usage are the limiting components for the Seabrook plant configuration. If more limiting components are identified, the most limiting component will be evaluated for the effects of the reactor coolant environment on fatigue usage. If the limiting location identified consists of nickel alloy, the environmentally-assisted fatigue calculation for nickel alloy will be performed using the rules of NUREG/CR-6909.
(1) Consistent with the Metal Fatigue of Reactor Coolant Pressure Boundary Program Seabrook Station will update the fatigue usage calculations using refined fatigue analyses, if necessary, to determine acceptable CUFs (i.e., less than 1.0) when accounting for the effects of the reactor water At least two years prior to the environment. This includes applying the appropriate Fen A.2.4.2.3 factors to valid CUFs determined from an existing fatigue period of extended operation.
analysis valid for the period of extended operation or from an analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case).
(2) If acceptable CUFs cannot be demonstrated for all the selected locations, then additional plant-specific locations will be evaluated. For the additional plant-specific locations, if CUF, including environmental effects is greater than 1.0, then Corrective Actions will be initiated, in accordance with the Metal Fatigue of Reactor Coolant Pressure Boundary Program, B.2.3.1. Corrective Actions will include inspection, repair, or replacement of the affected locations before exceeding a CUF of 1.0 or the effects of fatigue will be managed by an inspection program that has been reviewed and approved by the NRC (e.g., periodic non-destructive examination of the affected locations at inspection intervals to be determined by a method accepted by the NRC).
U.S. Nuclear Regulatory Commission SBK-L-17172 I Enclosure 2 I Page 10
- 45.
Alkali-Silica Reaction (ASR)
Monitoring Program
- 46.
Protective Coating Monitoring and Maintenance Protective Coating
- 47.
Monitoring and Maintenance
- 48.
Protective Coating Monitoring and Maintenance
- 49.
Protective Coating Monitoring and Maintenance
- 50.
ASME Section XI, Subsection IWE NextEra will obtain additional cores in the vicinity of20% of the extensometers and perfonn modulus testing. Using these At least 5 years prior to the test results, NextEra will determine the change in through-period of extended operation thickness expansion since installation of the extensometers and A.2.1.31.A (initial study) and 10 years compare it to change determined from extensometer thereafter (follow-up study).
readings. Consistency between these results will provide additional corroboration of the methodology in MPR-4153.
Enhance the program by designating and qualifying an A.2.1.38 Prior to the period of Inspector Coordinator and an Inspection Results Evaluator.
extended operation.
Enhance the program by including, "Instruments and Equipment needed for inspection may include, but not be Prior to the period of limited to, flashlight, spotlights, marker pen, mirror, measuring A.2.1.38 extended operation.
tape, magnifier, binoculars, camera with or without wide angle lens, and self sealing polyethylene sample bags."
Enhance the program to include a review of the previous two A.2.1.38 Prior to the period of monitoring reports.
extended operation.
Enhance the program to require that the inspection report is to be evaluated by the responsible evaluation personnel, who is to A.2.1.38 Prior to the period of prepare a summary of findings and recommendations for future extended operation.
surveillance or repair.
Baseline inspections were Perform UT of the accessible areas of the containment liner completed during ORI 6.
plate in the vicinity of the moisture barrier for loss of material.
A.2.1.27 Repeat containment liner UT thickness examinations at Perform opportunistic UT of inaccessible areas.
intervals of no more than five (5) refueling outages.
U.S. Nuclear Regulatory Commission SBK-L-17172 I Enclosure 2 I Page 11
- 51.
Bolting Integrity ASME Section XI, Subsection
- 52.
IWL
- 53.
Reactor Head Closure Studs Enhance the program to manage the aging effects for closure bolting within air and gas filled systems by using an applicable inspection technique that ensures the integrity of bolted joints will be demonstrated.
For closure bolting within systems at atmospheric pressure, A.2.1.9 Prior to the period of tightness checks will be performed on 20 percent of bolts with extended operation.
a maximum of 25 bolts per population. Populations will be of the same material and environment combination. Inspections will occur before the period of extended operation, and then every I 0 years after the initial inspection date.
Implement measures to maintain the exterior surface of the Containment Structure, from elevation -30 feet to +20 feet, in a A.2.1.28 Complete dewatered state.
Replace the spare reactor head closure stud(s) manufactured Prior to the period of from the bar that has a yield strength> 150 ksi with ones that A.2.1.3 do not exceed 150 ksi.
extended operation.
U.S. Nuclear Regulatory Commission SBK-L-17172 I Enclosure 2 I Page 12 Steam Generator Tube
- 54.
Integrity
- 55.
Number Not Used Closed-Cycle Cooling Water
- 56.
System Closed-Cycle Cooling Water
- 57.
System
- 58.
Fuel Oil Chemistry
- 59.
Nickel Alloy Nozzles and Penetrations N extEra will address the potential for cracking of the primary to secondary pressure boundary due to PWSCC of tube-to-tubesheet welds using one of the following two options:
- 1) Perform a one-time inspection of a representative sample of tube-to-tubesheet welds in all steam generators to determine if PWSCC cracking is present and, if cracking is identified, resolve the condition through engineering evaluation justifying continued operation or repair the condition, as appropriate, and establish an ongoing monitoring program to perform routine tube-to-tubesheet weld inspections for the remaining life of the A.2.1.10 Complete steam generators, or
- 2) Perform an analytical evaluation showing that the structural integrity of the steam generator tube-to-tubesheet interface is adequately maintaining the pressure boundary in the presence oftube-to-tubesheet weld cracking, or redefining the pressure boundary in which the tube-to-tubesheet weld is no longer included and, therefore, is not required for reactor coolant pressure boundary function. The redefmition of the reactor coolant pressure boundary must be approved by the NRC as part of a license amendment request.
~
Revise the station program documents to reflect the EPRI Prior to the period of Guideline operating ranges and Action Level values for A.2.1.12 extended operation.
hydrazine and sulfates.
Revise the station program documents to reflect the EPRI Prior to the period of Guideline operating ranges and Action Level values for Diesel A.2.1.12 extended operation.
Generator Cooling Water Jacket pH.
Update Technical Requirement Program 5.1, (Diesel Fuel Oil Prior to the period of Testing Program) ASTM standards to ASTM D2709-96 and A.2.1.18 extended operation.
ASTM D4057-95 required by the GALL XI.M30 Rev 1 The Nickel Alloy Aging Nozzles and Penetrations program Prior to the period of will implement applicable Bulletins, Generic Letters, and staff A.2.2.3 extended operation.
accepted industry guidelines.
U.S. Nuclear Regulatory Commission SBK-L-17172 I Enclosure 2 I Page 13 Buried Piping and Tanks
- 60.
Inspection
- 61.
Compressed Air Monitoring Program
- 62.
Water Chemistry
- 63.
Flow Induced Erosion
- 64.
Buried Piping and Tanks Inspection
- 65.
Flux Thimble Tube Implement the design change replacing the buried Auxiliary Prior to the period of Boiler supply piping with a pipe-within-pipe configuration A.2.1.22 extended operation.
with leak detection capability.
Replace the flexible hoses associated with the Diesel Generator A.2.1.14 Within ten years prior to the air compressors on a frequency of every 10 years.
period of extended operation.
Enhance the program to include a statement that sampling Prior to the period of frequencies are increased when chemistry action levels are A.2.1.2 exceeded.
extended operation.
Ensure that the quarterly CVCS Charging Pump testing is continued during the PEO. Additionally, add a precaution to the test procedure to state that an increase in the eves A.2.1.2 Prior to the period of Charging Pump mini flow above the acceptance criteria may extended operation.
be indicative of erosion of the mini flow orifice as described in LER 50-275/94-023.
Soil analysis shall be performed prior to entering the period of extended operation to determine the corrosivity of the soil in the vicinity ofnon-cathodically protected steel pipe within the A.2.1.22 Within ten years prior to the scope of this program. If the initial analysis shows the soil to period of extended operation.
be non-corrosive, this analysis will be re-performed every ten years thereafter.
Implement measures to ensure that the movable incore PfieF te the pefied ef detectors are not returned to service during the period of extended eperntien.
In extended operation.
NIA PrngFess Complete.
U.S. Nuclear Regulatory Commission SBK-L-17172 /Enclosure 2 /Page 14
- 66.
Alkali-Silica Reaction (ASR)
Monitoring Program
- 67.
Structures Monitoring Program
- 68.
Structures Monitoring Program Open-Cycle Cooling Water
- 69.
System Closed-Cycle Cooling Water
- 70.
System N extEra will perform an integrated review of expansion trends at Seabrook Station by conducting a periodic assessment of ASR expansion behavior to confirm that the MPR/FSEL large-scale test programs remain applicable to plant structures. This review will include the following specific considerations:
Review of all cores removed to date for trends of any indications of mid-plane cracking.
At least 5 years prior to the Comparison of in-plane expansion to through-thickness A.2.1.31.A period of extended operation and every 10 years expansion of all monitored points by plotting these data on a graph of in-plane expansion versus through-thereafter.
thickness expansion.
Comparison of in-plane expansions, volumetric expansions, and through-thickness expansions recorded to date to the limits from the MPR/FSEL large-scale test programs and check of margin for future expansion.
Perform one shallow core bore in an area that was continuously wetted from borated water to be examined for concrete degradation and also expose rebar to detect any A.2.1.31 Complete degradation such as loss of material. The removed core will also be subjected to petrographic examination for concrete degradation due to ASR per ASTM Standard Practice C856.
Perform sampling at the leak off collection points for A.2.1.31 Complete chlorides, sulfates, pH and iron once every three months.
Replace the Diesel Generator Heat Exchanger Plastisol PVC lined Service Water piping with piping fabricated from A.2.1.11 Complete AL6XN material.
Inspect the piping downstream of CC-V-444 and CC-V-446 to determine whether the loss of material due to cavitation A.2.1.12 Within ten years prior to the induced erosion has been eliminated or whether this remains an period of extended operation.
issue in the primary component cooling water system.
U.S. Nuclear Regulatory Commission SBK-L-17172 I Enclosure 2 I Page 15 Alkali-Silica Reaction (ASR)
Monitoring Program I
- 71.
Building Deformation Monitoring Program
- 72.
Flow-Accelerated Corrosion Inspection of Internal Surfaces in Miscellaneous
- 73.
Piping and Ducting Components
- 74.
Fire Water System NextEra has completed testing at the University of Texas Ferguson Structural Engineering Laboratory which demonstrates the parameters being monitored and acceptance criteria used are appropriate to manage the effects of ASR.
A.2.l.31A Prior to the period of NextEra !implement the Alkali-Silica Reaction (ASR)
A.2.l.31B extended operation.
Monitoring Program and Building Deformation Monitoring Program described in B.2.1.3 lA and B.2.1.3 lB of the License Renewal Application.
Enhance the program to include management of wall thinning A.2.1.8 Prior to the period of caused by mechanisms other than F AC.
extended operation.
Enhance the program to include performance of focused examinations to provide a representative sample of20%, or a maximum of25, of each identified material, environment, and A.2.1.25 Prior to the period of aging effect combinations during each 10 year period in the extended operation.
period of extended operation.
Enhance the program to perform sprinkler inspections annually per the guidance provided in NFPA 25 (2011 Edition).
Inspection will ensure that sprinklers are free of corrosion, foreign materials, paint, and physical damage and installed in A.2.1.16 Prior to the period of the proper orientation (e.g., upright, pendant, or sidewall). Any extended operation.
sprinkler that is painted, corroded, damaged, loaded, or in the improper orientation, and any glass bulb sprinkler where the bulb has emptied, will be evaluated for replacement.
U.S. Nuclear Regulatory Commission SBK-L-17172 I Enclosure 2 I Page 16
- 75.
Fire Water System
- 76.
Fire Water System
- 77.
Fire Water System
- 78.
External Surfaces Monitoring Enhance the program to a) conduct an inspection of piping and branch line conditions every 5 years by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of one branch line for the purpose of inspecting for the presence of foreign organic and inorganic material per the guidance provided in NFP A 25 (2011 Edition) and b) If the Prior to the period of presence of sufficient foreign organic or inorganic material to A.2.1.16 obstruct pipe or sprinklers is detected during pipe inspections, extended operation.
the material will be removed and its source is determined and corrected.
In buildings having multiple wet pipe systems, every other system shall have an internal inspection of piping every 5 years as described in NFPA 25 (2011 Edition), Section 14.2.2.
Enhance the Program to conduct the following activities annually per the guidance provided in NFP A 25 (2011 Edition).
A.2.1.16 Prior to the period of main drain tests extended operation.
deluge valve trip tests fire water storage tank exterior surface inspections The Fire Water System Program will be enhanced to include the following requirements related to the main drain testing per the guidance provided in NFP A 25 (2011 Edition).
The requirement that if there is a 10 percent reduction in A.2.1.16 Prior to the period of full flow pressure when compared to the original extended operation.
acceptance tests or previously performed tests, the cause of the reduction shall be identified and corrected if necessary.
Recording the time taken for the supply water pressure to return to the original static (nonflowing) pressure.
Enhance the program to include periodic inspections of in-scope insulated components for possible corrosion under insulation. A sample of outdoor component surfaces that are Prior to the period of insulated and a sample of indoor insulated components A.2.1.24 exposed to condensation (due to the in-scope component being extended operation.
operated below the dew point), will be periodically inspected every 10 years during the period of extended operation.
U.S. Nuclear Regulatory Commission SBK-L-17172 I Enclosure 2 I Page 17 Open-Cycle Cooling Water
- 79.
System
- 80.
Fire Water System
- 81.
Fuel Oil Chemistry Inspection of Internal
- 82.
Surfaces in Miscellaneous Piping and Ducting Components
- 83.
Alkali-Silica Reaction Monitoring ASME Section XI, Subsection
- 84.
IWL
- 85.
Fire Water System Enhance the program to include visual inspection of internal Within IO years prior to the coatings/linings for loss of coating integrity.
A.2.1.11 period of extended operation.
Enhance the program to include visual inspection of internal Within IO years prior to the coatings/linings for loss of coating integrity.
A.2.1.16 period of extended operation.
Enhance the program to include visual inspection of internal Within 10 years prior to the coatings/linings for loss of coating integrity.
A.2.1.18 period of extended operation.
Enhance the program to include visual inspection of internal coatings/linings for loss of coating integrity.
A.2.1.25 Within IO years prior to the period of extended operation.
Enhance the ASR AMP to install extensometers in all Tier 3 areas of two dimensional reinforced structures to monitor expansion due to alkali-silica reaction in the out-of-plane direction.
A.2.1.31A Complete Monitoring expansion in the out-of-plane direction will commence upon installation of the extensometers and continue on a six month frequency through the period of extended operation.
Evaluate the acceptability of inaccessible areas for structures Prior to the period of within the scope of ASME Section XI, Subsection IWL A.2.1.28 extended operation.
Program.
Enhance the program to perform additional tests and inspections on the Fire Water Storage Tanks as specified in Section 9.2. 7 ofNFP A 25 (2011 Edition) in the event that it is A.2.1.16 Prior to the period of required by Section 9.2.6.4, which states "Steel tanks extended operation.
exhibiting signs of interior pitting, corrosion, or failure of coating shall be tested in accordance with 9.2.7."
U.S. Nuclear Regulatory Commission SBK-L-17172 I Enclosure 2 I Page 18
- 86.
Fire Water System
- 87.
Fire Water System
- 88.
Fire Water System Inspection of Internal Surfaces in Miscellaneous
- 89.
Piping and Ducting Components PWR Vessel Internals
- 90.
Enhance the program to include disassembly, inspection, and A.2.1.16 Prior to the period of cleaning of the mainline strainers every 5 years.
extended operation.
Increase the frequency of the Open Head Spray Nozzle Air Prior to the period of Flow Test from every 3 years to every refueling outage to be A.2.1.16 consistent with LR-ISG-2012-02, AMP XI.M27, Table 4a.
extended operation.
Enhance the program to include verification that a) the drain holes associated with the transformer deluge system are draining to ensure complete drainage of the system after each test, b) the deluge system drains and associated piping are A.2.1.16 Within five years prior to the configured to completely drain the piping, and c) normally-dry period of extended operation.
piping that could have been wetted by inadvertent system actuations or those that occur after a fire are restored to a dry state as part of the suppression system restoration.
Incorporate Coating Service Level III requirements into the RCP Motor Refurbishment Specification for the internal painting of the motor upper bearing coolers and motor air A.2.1.25 Prior to the period of coolers. All four RCP motors will be refurbished and replaced extended operation.
using the Coating Service Level III requirements prior to entering the period o-f extended operation.
Implement the PWR Vessel Internals Program. The program will be implemented in accordance with MRP-227-A Prior to the period of (Pressurized Water Reactor Internals Inspection and A.2.1.7 Evaluation Guidelines) and NEI 03-08 (Guideline for the extended operation Management of Materials Issues).
U.S. Nuclear Regulatory Commission SBK-L-17172 /Enclosure 2 /Page 19 Building Deformation 91 Monitoring Implement the Building Deformation Monitoring Program Enhance the Structures Monitoring Program to require structural evaluations be performed on buildings and components affected by deformation as necessary to ensure that the structural function is maintained. Evaluations of structures will validate structural performance against the design basis, and may use results from the large-scale test programs, as appropriate. Evaluations for structural deformation will also consider the impact to functionality of affected systems and components (e.g., conduit expansion joints). NextEra will evaluate the specific circumstances against the design basis of the affected system or component.
Enhance the Building Deformation AMP to include additional parameters to be monitored based on the results of the CEB A.2.l.31B March 15, 2020 Root Cause, Structural Evaluation and walk downs. Additional parameters monitored will include:
alignment of ducting, conduit, and piping; seal integrity; laser target measurements; key seismic gap measurements; and additional instrumentation.
Develop a design standard to implement Aging Management Program B.2.1.3 lB Building Deformation, Program Element 3
- Parameters Monitored/Inspected. The design standard will clarify the deformation evaluation process and provide an auditable format to assess it. The design standard will include steps for each of the three evaluation stages that include parameters monitored, basis for why the parameter is monitored, and conditions that prompts action for the subsequent step.