ML101370761: Difference between revisions

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| issue date = 06/14/2010
| issue date = 06/14/2010
| title = Request for Additional Information for the Review of the Hope Creek Generating Station License Renewal Application
| title = Request for Additional Information for the Review of the Hope Creek Generating Station License Renewal Application
| author name = Brady B M
| author name = Brady B
| author affiliation = NRC/NRR/DLR/RPB1
| author affiliation = NRC/NRR/DLR/RPB1
| addressee name = Joyce T
| addressee name = Joyce T
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:June 14, 2010 Mr. Thomas Joyce President and Chief Nuclear Officer PSEG Nuclear LLC P.O. Box 236 Hancocks Bridge, NJ 08038  
{{#Wiki_filter:June 14, 2010 Mr. Thomas Joyce President and Chief Nuclear Officer PSEG Nuclear LLC P.O. Box 236 Hancocks Bridge, NJ 08038


==SUBJECT:==
==SUBJECT:==
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE HOPE CREEK GENERATING STATION LICENSE RENEWAL APPLICATION (TAC NO ME1832)
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE HOPE CREEK GENERATING STATION LICENSE RENEWAL APPLICATION (TAC NO ME1832)


==Dear Mr. Joyce:==
==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 staff's request for additional information is included in the Enclosure. Further requests for additional information may be issued in the future.
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,  
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.
/RA/   Bennett M. Brady, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-354  
Sincerely,
                                            /RA/
Bennett M. Brady, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-354


==Enclosure:==
==Enclosure:==


As stated cc w/encl: See next page
As stated cc w/encl: See next page


ML101370761 OFFICE PM:DLR:RPB1 LA:DLR BC:DLR:RPB1 PM:DLR:RPB1 NAME B. Brady S. Figueroa B. Pham B. Brady DATE 06/14/10 06/07/10 06/09/10 06/14/10 Letter to T. Joyce from B. Brady dated June 14, 2010  
ML101370761 OFFICE     PM:DLR:RPB1       LA:DLR             BC:DLR:RPB1       PM:DLR:RPB1 NAME       B. Brady         S. Figueroa       B. Pham           B. Brady DATE       06/14/10         06/07/10           06/09/10         06/14/10
 
Letter to T. Joyce from B. Brady dated June 14, 2010


==SUBJECT:==
==SUBJECT:==
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE HOPE CREEK GENERATING STATION LICENSE RENEWAL APPLICATION (TAC NO ME1832)
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE HOPE CREEK GENERATING STATION LICENSE RENEWAL APPLICATION (TAC NO ME1832)
DISTRIBUTION
DISTRIBUTION:
:
HARD COPY:
HARD COPY: DLR RF E-MAIL: PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RdsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRapb Resource RidsOgcMailCenter Resource ------------- BPham BBrady CEccleston REnnis CSanders BHarris, OGC ABurritt, RI RConte, RI MModes, RI DTifft, RI NMcNamara, RI  
DLR RF E-MAIL:
PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RdsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRapb Resource RidsOgcMailCenter Resource
-------------
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 Senior Vice President Nuclear PSEG Nuclear LLC One Alloway Creek Neck Road Hancocks Bridge, NJ 08038 Mr. Brian Booth Director Nuclear Oversight PSEG Nuclear P.O. Box 236 Hancocks Bridge, NJ 08038 Mr. John Perry Station Vice President - Hope Creek PSEG Nuclear P.O. Box 236 Hancocks Bridge, NJ 08038 Mr. Larry Wagner Plant Manager - Hope Creek PSEG Nuclear LLC One Alloway Creek Neck Road Hancocks Bridge, NJ 08038
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


Mr. Michael Gallagher  Vice President - License Renewal Projects Exelon Nuclear LLC 200 Exelon Way Kennett Square, PA  19348
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


Mr. Jeffrie J. Keenan, Esquire Manager - Licensing PSEG Nuclear LLC One Alloway Creek Neck Road Hancocks Bridge, NJ  08038 Mr. Gregory Sosson Director Corporate Engineering PSEG Nuclear LLC One Alloway Creek Neck Road Hancocks Bridge, NJ  08038Mr. Michael Gaffney Manager - Hope Creek Regulatory Assurance PSEG Nuclear LLC One Alloway Creek Neck Road Hancocks Bridge, NJ  08038
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE HOPE CREEK GENERATING STATION LICENSE RENEWAL APPLICATION (TAC NO ME1832)
RAI 3.0.3.2.10-01


Mr. Ali Fakhar Manager, License Renewal PSEG Nuclear LLC One Alloway Creek Neck Road Hancocks Bridge, NJ  08038 Township Clerk Lower Alloways Creek Township Municipal Building, P.O. Box 157 Hancocks Bridge, NJ  08038 Mr. Paul Bauldauf, P.E., Asst. Director Radiation Protection Programs NJ Department of Environmental  Protection and Energy, CN 415 Trenton, NJ  08625-0415
==Background:==


Mr. Brian Beam Board of Public Utilities 2 Gateway Center, Tenth Floor Newark, NJ  07102
The applicant discussed the Fuel Oil Chemistry Program enhanced procedures for Hope Creek as part of the License Renewal Application. During the staff review of the enhanced sampling procedures for the main fuel oil storage tank, the diesel fire pump fuel oil storage tanks, and the diesel fuel oil storage tanks, it was noted that the procedures state that if a significant amount of water (greater than two ounces per gallon of fuel) is present, then a Notification per the Corrective Action Plan should be submitted.
Issue:
It is not clear how the person performing the testing will be able to complete the analysis with the current level of detail provided in the procedure. For example, with the main fuel oil storage tank, it was unclear how the tester would be able to discern two ounces of water in a 10 gallon sample. With the diesel fire pump fuel oil storage tank sample, it was unclear what level of water was rejectable, given that only a one liter sample was specified to be drawn.
Request:
Please clarify how there is reasonable assurance that the analyses requested to be performed in the enhanced procedures will be performed correctly.
RAI 3.1.1-15-01


Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA  19406
==Background:==


Mr. Paul Davison Vice President, Operations Support  PSEG Nuclear LLC One Alloway Creek Neck Road Hancocks Bridge, NJ  08038
The Generic Aging Lessons Learned (GALL) Report Item IV.C1-2 recommends that aging management should be performed according to Chapter XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS).
 
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 ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE HOPE CREEK GENERATING STATION LICENSE RENEWAL APPLICATION (TAC NO ME1832)
RAI 3.0.3.2.10-01
 
===
Background===
:  The applicant discussed the Fuel Oil Chemistry Program enhanced procedures for Hope Creek as part of the License Renewal Application. During the staff review of the enhanced sampling procedures for the main fuel oil storage tank, the diesel fire pump fuel oil storage tanks, and the diesel fuel oil storage tanks, it was noted that the procedures state that if a significant amount of water (greater than two ounces per gallon of fuel) is present, then a Notification per the Corrective Action Plan should be submitted.
Issue:
Issue:
It is not clear how the person performing the testing will be able to complete the analysis with the current level of detail provided in the procedure. For example, with the main fuel oil storage tank, it was unclear how the tester would be able to discern two ounces of water in a 10 gallon sample. With the diesel fire pump fuel oil storage tank sample, it was unclear what level of water was rejectable, given that only a one liter sample was specified to be drawn.  
In its review of components associated with AMR line item 3.1.1-15, the staff noted that cast austenitic stainless steel (CASS) is not listed as one of the materials. Additionally, for CASS flow elements, SRP-LR Table 3.1-1, item 57 recommends aging management for loss of fracture toughness due to thermal aging embrittlement. However, license renewal application (LRA) Table 3.4.2-4 includes two 3.1.1-15 line items under Table 1 items (flow elements, Class
: 1) with CASS as the material, and credits the LRA Boiler Water Reactor Water Chemistry and the One-Time Inspection Aging Management Programs (AMPs).
ENCLOSURE


Request: Please clarify how there is reasonable assurance that the analyses requested to be performed in the enhanced procedures will be performed correctly.
Request:
RAI 3.1.1-15-01
The staff requests that the applicant explain the following:
a) Why aging management review (AMR) line item 3.1.1-57 is not applicable when the GALL Report only exempts pump and valve bodies, and b) Why the flow elements associated with AMR line item 3.1.1-15 do not credit GALL AMP XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) to manage loss of fracture toughness/thermal aging embrittlement.
RAI 3.3.2.10-1


===Background===
==Background:==
:
The Generic Aging Lessons Learned (GALL) Report Item IV.C1-2 recommends that aging management should be performed according to Chapter XI.M12, "Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)."


Issue:  In its review of components associated with AMR line item 3.1.1-15, the staff noted that cast austenitic stainless steel (CASS) is not listed as one of the materials. Additionally, for CASS flow elements, SRP-LR Table 3.1-1, item 57 recommends aging management for loss of fracture toughness due to thermal aging embrittlement. However, license renewal application (LRA) Table 3.4.2-4 includes two 3.1.1-15 line items under Table 1 items (flow elements, Class 1) with CASS as the material, and credits the LRA Boiler Water Reactor Water Chemistry and the One-Time Inspection Aging Management Programs (AMPs).      Request:  The staff requests that the applicant explain the following: a) Why aging management review (AMR) line item 3.1.1-57 is not applicable when the GALL Report only exempts pump and valve bodies, and  b) Why the flow elements associated with AMR line item 3.1.1-15 do not credit GALL AMP XI.M12, "Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)" to manage loss of fracture toughness/thermal aging embrittlement.
LRA Table 3.3.2-10, page 3.3-191, states that gray cast iron (retarding chamber) tanks exposed to raw water environment has an aging effect of loss of material due to general, pitting, crevice, galvanic, and microbiologically influenced corrosion, and fouling, and that the aging effects will be managed by the Fire Water System Program. The AMR line items reference Table 1 line item 3.3.1-68 and GALL Report item VII.G-24, for piping, piping components, and piping elements, and also cite generic note C, indicating that the component is different, but consistent with NUREG-1801 item for material, environment, and aging effect.
 
Issue:
RAI 3.3.2.10-1
The staff reviewed GALL AMP XI.M27, Fire Water System, and noted that the AMP recommends wall thickness evaluations of fire protection piping be performed using non-intrusive technique (e.g., volumetric testing) to identify loss of material due to corrosion. Based on a telephone conversation with the applicant on May 25, 2010, the applicant clarified that the retarding chamber is a vertical pipe installed in a horizontal piping system and acts like a tank.
 
The staff infers that this vertical pipe is a low point in the system and will have stagnant water and will be susceptible to loss of material due to general, pitting and crevice corrosion. It is not clear from a review of LRA Section B.2.1.18, Fire Water System Program, whether volumetric inspection to detect loss of material due to corrosion will be performed on the internal surface (specifically the bottom) of the fire water and the retarding chamber tanks.
===Background===
Request:
LRA Table 3.3.2-10, page 3.3-191, states that gray cast iron (retarding chamber) tanks exposed to raw water environment has an aging effect of loss of material due to general, pitting, crevice, galvanic, and microbiologically influenced corrosion, and fouling, and that the aging effects will be managed by the Fire Water System Program. The AMR line items reference Table 1 line item 3.3.1-68 and GALL Report item VII.G-24, for piping, piping components, and piping elements, and also cite generic note C, indicating that the component is different, but consistent with NUREG-1801 item for material, environment, and aging effect.
Clarify if the (retarding chamber) tanks are included in the sample of fire protection system components that will be volumetrically inspected for wall thickness evaluation to detect loss of material prior to loss of intended function. If not included, please justify how loss of material due to general, pitting, crevice, galvanic, and microbiologically influenced corrosion, and fouling will be detected from the bottom surface of these tanks.}}
Issue: The staff reviewed GALL AMP XI.M27, Fire Water System, and noted that the AMP recommends wall thickness evaluations of fire protection piping be performed using non-intrusive technique (e.g., volumetric testing) to identify loss of material due to corrosion. Based on a telephone conversation with the applicant on May 25, 2010, the applicant clarified that the retarding chamber is a vertical pipe installed in a horizontal piping system and acts like a tank. The staff infers that this vertical pipe is a low point in the system and will have stagnant water and will be susceptible to loss of material due to general, pitting and crevice corrosion. It is not clear from a review of LRA Section B.2.1.18, Fire Water System Program, whether volumetric inspection to detect loss of material due to corrosion will be performed on the internal surface (specifically the bottom) of the fire water and the retarding chamber tanks.
Request: Clarify if the (retarding chamber) tanks are included in the sample of fire protection system components that will be volumetrically inspected for wall thickness evaluation to detect loss of material prior to loss of intended function. If not included, please justify how loss of material due to general, pitting, crevice, galvanic, and microbiologically influenced corrosion, and fouling will be detected from the bottom surface of these tanks.}}

Latest revision as of 19:04, 13 November 2019

Request for Additional Information for the Review of the Hope Creek Generating Station License Renewal Application
ML101370761
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 06/14/2010
From: Bennett Brady
License Renewal Projects Branch 1
To: Joyce T
Public Service Enterprise Group
CUNANAN, A
References
TAC ME1832
Download: ML101370761 (7)


Text

June 14, 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 (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

ML101370761 OFFICE PM:DLR:RPB1 LA:DLR BC:DLR:RPB1 PM:DLR:RPB1 NAME B. Brady S. Figueroa B. Pham B. Brady DATE 06/14/10 06/07/10 06/09/10 06/14/10

Letter to T. Joyce from B. Brady dated June 14, 2010

SUBJECT:

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

DISTRIBUTION:

HARD COPY:

DLR RF E-MAIL:

PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RdsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRapb Resource RidsOgcMailCenter Resource


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 LICENSE RENEWAL APPLICATION (TAC NO ME1832)

RAI 3.0.3.2.10-01

Background:

The applicant discussed the Fuel Oil Chemistry Program enhanced procedures for Hope Creek as part of the License Renewal Application. During the staff review of the enhanced sampling procedures for the main fuel oil storage tank, the diesel fire pump fuel oil storage tanks, and the diesel fuel oil storage tanks, it was noted that the procedures state that if a significant amount of water (greater than two ounces per gallon of fuel) is present, then a Notification per the Corrective Action Plan should be submitted.

Issue:

It is not clear how the person performing the testing will be able to complete the analysis with the current level of detail provided in the procedure. For example, with the main fuel oil storage tank, it was unclear how the tester would be able to discern two ounces of water in a 10 gallon sample. With the diesel fire pump fuel oil storage tank sample, it was unclear what level of water was rejectable, given that only a one liter sample was specified to be drawn.

Request:

Please clarify how there is reasonable assurance that the analyses requested to be performed in the enhanced procedures will be performed correctly.

RAI 3.1.1-15-01

Background:

The Generic Aging Lessons Learned (GALL) Report Item IV.C1-2 recommends that aging management should be performed according to Chapter XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS).

Issue:

In its review of components associated with AMR line item 3.1.1-15, the staff noted that cast austenitic stainless steel (CASS) is not listed as one of the materials. Additionally, for CASS flow elements, SRP-LR Table 3.1-1, item 57 recommends aging management for loss of fracture toughness due to thermal aging embrittlement. However, license renewal application (LRA) Table 3.4.2-4 includes two 3.1.1-15 line items under Table 1 items (flow elements, Class

1) with CASS as the material, and credits the LRA Boiler Water Reactor Water Chemistry and the One-Time Inspection Aging Management Programs (AMPs).

ENCLOSURE

Request:

The staff requests that the applicant explain the following:

a) Why aging management review (AMR) line item 3.1.1-57 is not applicable when the GALL Report only exempts pump and valve bodies, and b) Why the flow elements associated with AMR line item 3.1.1-15 do not credit GALL AMP XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) to manage loss of fracture toughness/thermal aging embrittlement.

RAI 3.3.2.10-1

Background:

LRA Table 3.3.2-10, page 3.3-191, states that gray cast iron (retarding chamber) tanks exposed to raw water environment has an aging effect of loss of material due to general, pitting, crevice, galvanic, and microbiologically influenced corrosion, and fouling, and that the aging effects will be managed by the Fire Water System Program. The AMR line items reference Table 1 line item 3.3.1-68 and GALL Report item VII.G-24, for piping, piping components, and piping elements, and also cite generic note C, indicating that the component is different, but consistent with NUREG-1801 item for material, environment, and aging effect.

Issue:

The staff reviewed GALL AMP XI.M27, Fire Water System, and noted that the AMP recommends wall thickness evaluations of fire protection piping be performed using non-intrusive technique (e.g., volumetric testing) to identify loss of material due to corrosion. Based on a telephone conversation with the applicant on May 25, 2010, the applicant clarified that the retarding chamber is a vertical pipe installed in a horizontal piping system and acts like a tank.

The staff infers that this vertical pipe is a low point in the system and will have stagnant water and will be susceptible to loss of material due to general, pitting and crevice corrosion. It is not clear from a review of LRA Section B.2.1.18, Fire Water System Program, whether volumetric inspection to detect loss of material due to corrosion will be performed on the internal surface (specifically the bottom) of the fire water and the retarding chamber tanks.

Request:

Clarify if the (retarding chamber) tanks are included in the sample of fire protection system components that will be volumetrically inspected for wall thickness evaluation to detect loss of material prior to loss of intended function. If not included, please justify how loss of material due to general, pitting, crevice, galvanic, and microbiologically influenced corrosion, and fouling will be detected from the bottom surface of these tanks.