ML101380149

Request for Additional Information for the Review of the Hope Creek Generating Station License Renewal Application for Section 3.5

ML101380149
Person / Time
Site:	Hope Creek
Issue date:	06/07/2010
From:	Bennett Brady License Renewal Projects Branch 1
To:	Joyce T Public Service Enterprise Group
CUNANAN, A
References
TAC ME1832
Download: ML101380149 (11)

Text

June 7, 2010 Mr. Thomas Joyce President and Chief Nuclear Officer PSEG Nuclear LLC P.O. Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE HOPE CREEK GENERATING STATION LICENSE RENEWAL APPLICATION FOR SECTION 3.5 (TAC NO ME1832)

Dear Mr. Joyce:

By letter dated August 18, 2009, as supplemented by letter dated January 23, 2009, Public Service Enterprise Group Nuclear, LLC, submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54) for renewal of Operating License No. NPF-57 for the Hope Creek Generating Station. The staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing this application in accordance with the guidance in NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants. During its review, the staff has identified areas where additional information is needed to complete the review. The staffs request for additional information is included in the Enclosure. Further requests for additional information may be issued in the future.

Items in the enclosure were provided to John Hufnagel and other members of your staff, 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 by telephone at 301-415-2981 or by e-mail at bennett.brady@nrc.gov.

Sincerely,

/RA/

Bennett M. Brady, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-354

Enclosure:

As stated cc w/encl: See next page

June 7, 2010 Mr. Thomas Joyce President and Chief Nuclear Officer PSEG Nuclear LLC P.O. Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE HOPE CREEK GENERATING STATION LICENSE RENEWAL APPLICATION FOR SECTION 3.5 (TAC NO ME1832)

Dear Mr. Joyce:

By letter dated August 18, 2009, as supplemented by letter dated January 23, 2009, Public Service Enterprise Group Nuclear, LLC, submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54) for renewal of Operating License No. NPF-57 for the Hope Creek Generating Station. The staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing this application in accordance with the guidance in NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants. During its review, the staff has identified areas where additional information is needed to complete the review. The staffs request for additional information is included in the Enclosure. Further requests for additional information may be issued in the future.

Items in the enclosure were provided to John Hufnagel and other members of your staff, 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 by telephone at 301-415-2981 or by e-mail at bennett.brady@nrc.gov.

Sincerely,

/RA/

Bennett M. Brady, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-354

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION: See next page ADAMS Accession No. ML101380149

OFFICE PM:DLR:RPB1 LA:DLR BC:DLR:RPB1 PM:DLR:RPB1 NAME B. Brady SFigueroa B. Pham B. Brady DATE 06/03/10 06/01/10 06/03/10 06/07/10 OFFICIAL RECORD COPY

Letter to T. Joyce from B. Brady dated June 7, 2010

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE HOPE CREEK GENERATING STATION LICENSE RENEWAL APPLICATION FOR SECTION 3.5 (TAC NO ME1832)

DISTRIBUTION:

HARD COPY:

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BPham BBrady CEccleston REnnis CSanders BHarris, OGC ABurritt, RI RConte, RI MModes, RI DTifft, RI NMcNamara, RI

Hope Creek Generating Station cc:

Mr. Robert Braun Mr. Michael Gaffney Senior Vice President Nuclear Manager - Hope Creek Regulatory PSEG Nuclear LLC Assurance One Alloway Creek Neck Road PSEG Nuclear LLC Hancocks Bridge, NJ 08038 One Alloway Creek Neck Road Hancocks Bridge, NJ 08038 Mr. Brian Booth Director Nuclear Oversight Mr. Ali Fakhar PSEG Nuclear Manager, License Renewal P.O. Box 236 PSEG Nuclear LLC Hancocks Bridge, NJ 08038 One Alloway Creek Neck Road Hancocks Bridge, NJ 08038 Mr. John Perry Station Vice President - Hope Creek Township Clerk PSEG Nuclear Lower Alloways Creek Township P.O. Box 236 Municipal Building, P.O. Box 157 Hancocks Bridge, NJ 08038 Hancocks Bridge, NJ 08038 Mr. Larry Wagner Mr. Paul Bauldauf, P.E., Asst. Director Plant Manager - Hope Creek Radiation Protection Programs PSEG Nuclear LLC NJ Department of Environmental One Alloway Creek Neck Road Protection and Energy, CN 415 Hancocks Bridge, NJ 08038 Trenton, NJ 08625-0415 Mr. Michael Gallagher Mr. Brian Beam Vice President - License Renewal Projects Board of Public Utilities Exelon Nuclear LLC 2 Gateway Center, Tenth Floor 200 Exelon Way Newark, NJ 07102 Kennett Square, PA 19348 Regional Administrator, Region I Mr. Jeffrie J. Keenan, Esquire U.S. Nuclear Regulatory Commission Manager - Licensing 475 Allendale Road PSEG Nuclear LLC King of Prussia, PA 19406 One Alloway Creek Neck Road Hancocks Bridge, NJ 08038 Mr. Paul Davison Vice President, Operations Support Mr. Gregory Sosson PSEG Nuclear LLC Director Corporate Engineering One Alloway Creek Neck Road PSEG Nuclear LLC Hancocks Bridge, NJ 08038 One Alloway Creek Neck Road Hancocks Bridge, NJ 08038

Hope Creek Generating Station cc:

Ms. Christine Neely Director - Regulator Affairs PSEG Nuclear LLC One Alloway Creek Neck Road Hancocks Bridge, NJ 08038 Senior Resident Inspector Hope Creek Generating Station U.S. Nuclear Regulatory Commission Drawer 0509 Hancocks Bridge, NJ 08038 Mr. Earl R. Gage Salem County Administrator Administration Building 94 Market Street Salem, NJ 08079

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE HOPE CREEK GENERATING STATION (HCGS) LICENSE RENEWAL APPLICATION FOR SECTION 3.5 (TAC NO ME1832)

RAI 3.5.2.1-1

Background:

SRP Table 3.3-1, Item Number 3.3.1-19, credits Generic Aging Lessons Learned (GALL)

Report aging management programs (AMPs) XI.M28 or XI.M34 to manage the aging effect/mechanism loss of material due to corrosion in a soil environment for steel piping.

These AMPs include surveillance and preventive measures to mitigate corrosion by protecting the external surface of buried piping and tanks.

Issue:

In the license renewal application (LRA), the applicant references Item 3.3.1-19 and credits the Structures Monitoring Program to manage aging for carbon and galvanized steel penetration sleeves in a groundwater/soil environment. The staff is unclear how the HCGS Structures Monitoring AMP meets or exceeds the requirements of the GALL Report recommended programs, and how the Structures Monitoring Program will be utilized to address the structure/aging effect combinations during the period of extended operation.

Request:

Describe how the HCGS Structures Monitoring AMP meets or exceeds the requirements of the GALL Report recommended programs and how the AMP will be used to manage carbon and galvanized steel penetration sleeves in a groundwater/soil environment for loss of material/general, pitting, crevice, and microbiologically influenced corrosion during the period of extended operation. Discuss surveillance as well as preventive measure requirements.

RAI 3.5.2.1-2

Background:

SRP Table 3.3-1, Item Number 3.3.1-19, credits GALL Report AMPs XI.M28 or XI.M34 to manage the aging effect/mechanism loss of material due to corrosion in a soil environment for steel piping. These AMPs include surveillance and preventive measures to mitigate corrosion by protecting the external surface of buried piping and tanks.

Issue:

In LRA Table 3.5.2-9, the applicant references Item 3.3.1-19 and credits the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants, Program to manage aging for carbon and galvanized steel penetration sleeves in a groundwater/soil environment. The staff is unclear how the HCGS RG 1.127 AMP meets or exceeds the requirements of the GALL Report recommended programs, and how the RG 1.127 Program ENCLOSURE

will be utilized to address the structure/aging effect combinations during the period of extended operation.

Request:

Describe how the HCGS RG 1.127 AMP meets or exceeds the requirements of the GALL Report recommended programs and how the RG 1.127 Program will be used to manage carbon and galvanized steel penetration sleeves in a groundwater/soil environment for loss of material/general, pitting, crevice, and microbiologically influenced corrosion during the period of extended operation. Discuss surveillance as well as preventive measure requirements.

RAI 3.5.2.1-3

Background:

SRP Table 3.5-1, Item Number 3.5.1-50, credits the GALL Report AMP XI.S6 Structures Monitoring Program for managing loss of material due to pitting and crevice corrosion in an air-outdoor environment for galvanized steel, aluminum and stainless steel.

Issue:

Throughout the LRA, several AMR lines which reference Table 3.5-1, Item Number 3.5.1-50 and Note E credit the applicants Periodic Inspection Program to manage loss of material due to corrosion for aluminum and stainless steel components in an air-outdoor environment. The Periodic Inspection Program is a condition monitoring program that manages aging of piping, piping components, piping elements, ducting components, tanks, and heat exchanger components, and includes provisions for periodic visual inspections of aluminum components to detect loss of material aging effects. The LRA states that the visual inspections are conducted on a ten-year inspection frequency that has been established based on plant and industry operating experience. The staff is unclear that the HCGS Periodic Inspection AMP addresses all the components which credit it for management. Also, the staff noted for components located in an air-outdoor environment the proposed AMP does not meet guidance provided in ACI 349.3R as referenced by the GALL Report AMP XI.S6 Structures Monitoring Program that recommends an inspection frequency of five years for this environment.

Request:

Confirm that the components crediting this AMP are within scope of the HCGS Periodic Inspection AMP and describe how an inspection frequency of ten-years will be adequate to manage aging of the aluminum and stainless steel components for loss of material due to pitting and crevice corrosion in an air-outdoor environment during the period of extended operation.

RAI 3.5.2.1-4

Background:

In LRA Table 3.3.2-10, the applicant used the Aboveground Steel Tanks Program to manage loss of material due to pitting and crevice corrosion for the fire water storage tank stainless steel heaters. However, the scope of the Aboveground Steel Tanks Program, as discussed in LRA Section B.2.1.19, only includes steel tanks and does not mention other components. In addition, the program AMP states, These inspections will be performed to detect degraded paint and coatings, and any resulting metal degradation, prior to loss of the tank intended function.

Issue:

The LRA AMP does not provide any inspection parameters or acceptance criteria for stainless steel components, nor does the LRA explain how the credited AMP meets or exceeds the requirements of the GALL Report recommended AMP, XI.S6 Structures Monitoring Program.

Request:

a) Justify the use of an AMP intended to manage carbon steel components for a stainless steel component.

b) Provide the inspection parameters and acceptance criteria that will be used to manage the stainless steel heaters.

c) Describe how the HCGS Aboveground Steel Tanks AMP meets or exceeds the requirements of the GALL Report recommended program.

RAI 3.5.2.1-5

Background:

SRP Table 3.5-1, Item Number 3.5.1-50, credits the GALL Report AMP XI.S6 Structures Monitoring Program for managing loss of material due to pitting and crevice corrosion in an air-outdoor environment for galvanized steel, aluminum and stainless steel. The GALL Report AMP recommends general visual inspections with a five year frequency.

Issue:

In LRA Table 3.3.2-10, the applicant references Item 3.5.1-50 and credits the Fire Protection Program to manage aging for aluminum bird screens in an air-outdoor environment. It is not clear to the staff that the bird screens are in the scope of the Fire Protection Program. The staff is also unclear how the HCGS Fire Protection AMP meets or exceeds the GALL Report recommended program, and how the Fire Protection Program will be utilized to address the component/aging effect combinations during the period of extended operation.

Request:

Verify that the bird screens are within the scope of the Fire Protection AMP. Also describe how the HCGS Fire Protection AMP meets or exceeds the requirements of the GALL Report recommended program and how the program will be used to manage aluminum bird screens in an air-outdoor environment for loss of material due to pitting and crevice corrosion during the period of extended operation. Include a description of the inspection frequency and the inspection techniques.

RAI 3.5.2.1-6

Background:

SRP Table 3.5-1, Item Numbers 3.5.1-37 and -45, credits the GALL Report AMP XI.S7 RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants for managing increase in porosity and permeability, loss of strength due to leaching of calcium hydroxide, and loss of material due to abrasion and cavitation in a water-flowing environment for concrete.

Issue:

In LRA Table 3.3.2-27, AMR lines which reference Table 3.5-1, Item Number 3.5.1-37 and -

45 and Note E credit the applicants Open-Cycle Cooling Water System Program to manage this aging effect for reinforced concrete piping and fitting components in a raw water (internal) environment. The Open-Cycle Cooling Water System AMP includes mitigative, performance-monitoring, and condition monitoring activities to manage internal corrosion of piping and manages aging effects caused by bio-fouling, corrosion, erosion, protective coating failures, and silting in the Open-Cycle Cooling Water System. The staff is unclear that the HCGS Open-Cycle Cooling Water System AMP addresses the reinforced concrete piping and fitting components in a raw water (internal) environment and meets the GALL Report requirements for inaccessible concrete in a flowing-water environment. Also the staff is unclear that the proposed AMP meets guidance provided in GALL Report AMP XI.S7, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants, that periodic inspections be performed at least once every five years for this environment.

Request:

Describe how the HCGS Open-Cycle Cooling Water System AMP meets or exceeds the requirements of the GALL Report recommended program and how the AMP will be used to manage reinforced concrete piping and fittings in a raw water (internal) environment for increase in porosity and permeability, loss of strength due to leaching of calcium hydroxide, and loss of material due to abrasion and cavitation during the period of extended operation.

RAI 3.5.2.2.2-1

Background:

SRP Section 3.5.2.2.2.1.8 lists the Structures Monitoring or ASME Section XI, Subsection IWF Programs to manage the aging effect of lock-up due to wear that could occur for

Lubrite radial beam seats in the BWR drywell, RPV support shoes of PWR with nozzle supports, steam generator supports, or other sliding support bearings and sliding support surfaces. The GALL Report recommends further evaluation only for structure/aging effect combinations that are not within the ISI (IWF) or structures monitoring programs.

Issue:

LRA Section 3.5.2.2.2.1.8 states that sliding surfaces are provided for supports for radial beam seats in the drywell and the HCGS Structures Monitoring Program will be used to manage lock-up due to wear of these sliding surfaces. The staff agrees that the HCGS Structures Monitoring Program is an appropriate AMP to manage lock-up due to wear of the sliding surfaces, however, during its review of this item the staff was unable to verify that these sliding support surfaces were being inspected for loss of function due to corrosion, distortion, dirt, overload, or fatigue under either the HCGS Structures Monitoring or ASME Code Section XI, Subsection IWF AMPs and at what frequency the inspections were to be performed.

Request:

Confirm that for the Lubrite surfaces are addressed under the HCGS Structures Monitoring AMP for loss of mechanical function due to corrosion, distortion, dirt, overload, fatigue due to vibratory and cyclic loads for Lubrite in an air-indoor (uncontrolled) environment. Also confirm that the inspection method and the frequency of inspections is equivalent to, or exceeds, the requirements of the GALL Report recommended AMP, XI.S6 Structures Monitoring Program.

RAI 3.5.2.2.2-2

Background:

SRP-LR Sections 3.5.2.2.2.2.1 and 3.5.2.2.2.4.2 address loss of material (scaling, cracking, and spalling) due to freeze-thaw. The associated GALL Report Items (T-01 and T-15) recommend evaluation for plants located in moderate to severe weathering conditions. The GALL Report also recommends the concrete have an air content of 3 percent to 6 percent and water-to-cement ratio between 0.35 - 0.45.

Issue:

The associated LRA sections state that the weathering condition at HCGS is severe; however, a water-to-cement ratio was not specified for the concrete.

Request:

Provide the water-to-cement ratio for the concrete within the scope of license renewal. If the value is outside the limits recommended in the GALL Report, explain how aging due to freeze-thaw will be effectively managed during the period of extended operation.