ML101370559: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(StriderTol Bot change)
 
(3 intermediate revisions by the same user not shown)
Line 2: Line 2:
| number = ML101370559
| number = ML101370559
| issue date = 06/09/2010
| issue date = 06/09/2010
| title = Request for Additional Information for the Review of the Hope Creek Generating Station License Review Application (TAC No. ME1832)
| title = Request for Additional Information for the Review of the Hope Creek Generating Station License Review 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 9, 2010  
{{#Wiki_filter:June 9, 2010 Mr. Thomas Joyce President and Chief Nuclear Officer PSEG Nuclear LLC P.O. Box 236 Hancocks Bridge, NJ 08038
 
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,
                                            /RA/
Bennett M. Brady, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-354


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


ML101370559 OFFICE PM:DLR:RPB1 LA:DLR BC:DLR:RPB1 PM:DLR:RPB1 NAME B. Brady S. Figueroa B. Pham B. Brady DATE 5/25/10 5/18/10 5/28/10 6/09/10 Letter to T. Joyce from B. Brady dated June 9, 2010  
ML101370559 OFFICE     PM:DLR:RPB1     LA:DLR             BC:DLR:RPB1       PM:DLR:RPB1 NAME       B. Brady         S. Figueroa       B. Pham           B. Brady DATE       5/25/10         5/18/10           5/28/10           6/09/10 Letter to T. Joyce from B. Brady dated June 9, 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 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 
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


Mr. Michael Gallagher Vice President - License Renewal Projects Exelon Nuclear LLC 200 Exelon Way Kennett Square, PA 19348  
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. 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
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. 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
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE HOPE CREEK GENERATING STATION LICENSE RENEWAL APPLICATION (TAC NO ME1832)
RAI 3.1.2.2.4.1


Mr. Brian Beam Board of Public Utilities 2 Gateway Center, Tenth Floor Newark, NJ  07102
==Background:==


Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA  19406
Hope Creek Generating Station (HCGS) License Renewal Application (LRA) Subsection 3.1.2.2.4, Paragraph 1 Standard Review Plan-License Renewal (SRP-LR) Subsection 3.1.2.2.4, Paragraph 1 SRP-LR Appendix A, Subsection A.1.2.3.4, Paragraph 1 LRA Subsection 3.1.2.2.4, Paragraph 1, addresses cracking due to stress corrosion cracking (SCC) or intergranular stress corrosion cracking (IGSCC) that could occur in the stainless steel or nickel alloy BWR top head enclosure vessel flange leak detection lines. The LRA states that Hope Creek Generating Station (HCGS) will use aging management program (AMP) B.2.1.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC and IWD (ISI) program, and AMP B.2.1.2, Water Chemistry, to manage the aging effects of cracking due to SCC or IGSCC in the stainless steel vessel flange leak detection line exposed to treated water. It also states that the HCGS ISI program uses a VT-2 visual examination of the line prior to reactor cavity drain down, as approved by a current relief request, prior to drain down during each refueling outage.
SRP-LR Subsection 3.1.2.2.4, Paragraph 1, and GALL Report item IV.A1-10 (R-61) states that a plant-specific AMP is to be evaluated because existing programs may not be capable of mitigating or detecting crack initiation and growth due to SCC in the vessel flange leak detection line.
SRP-LRA Appendix A, Subsection A.1.2.3.4, Paragraph 1, provides generic recommendations for the detection of aging effects program element of a plant-specific AMP. This paragraph states that detection of aging effects should occur before there is a loss of the structure and component intended function(s).
Issue:
The staff does not understand how a VT-2 visual examination of the vessel flange leak detection line, as described in the LRA, would be capable of detecting cracking in the line prior to a through-wall crack having occurred. Also, the relief request described in the LRA is approved only for the current ten-year ISI inspection interval, which does not extend into the period of extended operation; and there is no assurance that the relief request would either be made by HCGS or be approved by the staff during the period of extended operation.
ENCLOSURE


Mr. Paul Davison Vice President, Operations Support  PSEG Nuclear LLC One Alloway Creek Neck Road Hancocks Bridge, NJ  08038
Request:
a)      Explain how VT-2 examination will detect cracking in the vessel flange leak detection line prior to failure of the lines intended function of providing a reactor coolant pressure boundary.
b)      Explain how aging of the vessel flange leak detection line will be managed during the period of extended operation without referring to implementation of a relief request which has neither been requested nor approved for the period of extended operation.
RAI 3.3.2.2.5.2


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)
==Background:==
RAI 3.1.2.2.4.1


===Background===
HCGS LRA Subsection 3.3.2.2.5, Paragraph 2; Table 3.3.1, Item 3.3.1-12; Table 3.5.2-8, pages 3.5-176 SRP-LR Subsection 3.3.2.2.5, Paragraph 2 GALL Item VII.A4-1 HCGS LRA Subsection 3.3.2.2.5, Paragraph 2, states that HCGS will implement the Structures Monitoring Program to manage hardening and loss of strength due to elastomer degradation of the compressible joint seals (inflatable pool seals) in the reactor building exposed to treated water, and that the Structures Monitoring Program includes visual inspections of elastomer components to assure that existing environmental conditions are not causing material degradation that could result in loss of component intended function. Table 3.3.1, item 3.3.1-12 states that compressible joint seals in the reactor building have been aligned to the item based on material, environment, and aging effect.
:  Hope Creek Generating Station (HCGS) License Renewal Application (LRA) Subsection 3.1.2.2.4, Paragraph 1 Standard Review Plan-License Renewal (SRP-LR) Subsection 3.1.2.2.4, Paragraph 1 SRP-LR Appendix A, Subsection A.1.2.3.4, Paragraph 1 LRA Subsection 3.1.2.2.4, Paragraph 1, addresses cracking due to stress corrosion cracking (SCC) or intergranular stress corrosion cracking (IGSCC) that could occur in the stainless steel or nickel alloy BWR top head enclosure vessel flange leak detection lines. The LRA states that Hope Creek Generating Station (HCGS) will use aging management program (AMP) B.2.1.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC and IWD (ISI) program, and AMP B.2.1.2, Water Chemistry, to manage the aging effects of cracking due to SCC or IGSCC in the stainless steel vessel flange leak detection line exposed to treated water. It also states that the HCGS ISI program uses a VT-2 visual examination of the line prior to reactor cavity drain down, as approved by a current relief request, prior to drain down during each refueling outage.
SRP-LR Subsection 3.3.2.2.5, Paragraph 2, applies for hardening and loss of strength due to elastomer degradation in elastomer linings of the filters, valves, and ion exchangers in spent fuel pool and cleanup systems (BWR and PWR) exposed to treated water or to treated borated water. GALL item VII.A4-1 associated with this SRP-LR paragraph recommends a plant-specific AMP that determines and assesses the qualified life of the linings in the environment is to be evaluated.
SRP-LR Subsection 3.1.2.2.4, Paragraph 1, and GALL Report item IV.A1-10 (R-61) states that a plant-specific AMP is to be evaluated because existing programs may not be capable of mitigating or detecting crack initiation and growth due to SCC in the vessel flange leak detection line. SRP-LRA Appendix A, Subsection A.1.2.3.4, Paragraph 1, provides generic recommendations for the "detection of aging effects" program element of a plant-specific AMP. This paragraph states that "detection of aging effects should occur before there is a loss of the structure and component intended function(s)."
Issue:
Issue:  The staff does not understand how a VT-2 visual examination of the vessel flange leak detection line, as described in the LRA, would be capable of detecting cracking in the line prior to a through-wall crack having occurred. Also, the relief request described in the LRA is approved only for the current ten-year ISI inspection interval, which does not extend into the period of extended operation; and there is no assurance that the relief request would either be made by HCGS or be approved by the staff during the period of extended operation.  
Since the SRP recommends determination and assessment of a qualified life for the components associated with Subsection 3.3.2.2.5, Paragraph 2, it is not clear to the staff whether HCGS has determined a qualified life for the compressible joint seals (inflatable pool seals) that it has associated with this paragraph through the LRA Tables. It also is not clear whether visual inspection, alone, is capable of detecting hardening and loss of strength in the compressible joint seals that HCGS has associated with Subsection 3.3.2.2.5, Paragraph 2.


Request: a) Explain how VT-2 examination will detect cracking in the vessel flange leak detection line prior to failure of the line's intended function of providing a reactor coolant pressure boundary.
Request:
b) Explain how aging of the vessel flange leak detection line will be managed during the period of extended operation without referring to implementation of a relief request which has neither been requested nor approved for the period of extended operation.
Provide additional information to explain how the Structures Monitoring Program adequately manages the subject aging effects. Specifically, clarify whether HCGS has determined a qualified life for the compressible joint seals aligned with LRA Table 3.3.1, Item 3.3.1-12, and Subsection 3.3.2.2.5, Paragraph 2.}}
RAI 3.3.2.2.5.2
 
===Background===
:  HCGS LRA Subsection 3.3.2.2.5, Paragraph 2; Table 3.3.1, Item 3.3.1-12; Table 3.5.2-8, pages 3.5-176  SRP-LR Subsection 3.3.2.2.5, Paragraph 2 GALL Item VII.A4-1
 
HCGS LRA Subsection 3.3.2.2.5, Paragraph 2, states that HCGS will implement the Structures Monitoring Program to manage hardening and loss of strength due to elastomer degradation of the compressible joint seals (inflatable pool seals) in the reactor building exposed to treated water, and that the Structures Monitoring Program includes visual inspections of elastomer components to assure that existing environmental conditions are not causing material degradation that could result in loss of component intended function. Table 3.3.1, item 3.3.1-12 states that compressible joint seals in the reactor building have been aligned to the item based on material, environment, and aging effect.
 
SRP-LR Subsection 3.3.2.2.5, Paragraph 2, applies for hardening and loss of strength due to elastomer degradation in elastomer linings of the filters, valves, and ion exchangers in spent fuel pool and cleanup systems (BWR and PWR) exposed to treated water or to treated borated water. GALL item VII.A4-1 associated with this SRP-LR paragraph recommends a plant-specific AMP that determines and assesses the qualified life of the linings in the environment is to be evaluated.
Issue:  Since the SRP recommends determination and assessment of a qualified life for the components associated with Subsection 3.3.2.2.5, Paragraph 2, it is not clear to the staff whether HCGS has determined a qualified life for the compressible joint seals (inflatable pool seals) that it has associated with this paragraph through the LRA Tables. It also is not clear whether visual inspection, alone, is capable of detecting hardening and loss of strength in the compressible joint seals that HCGS has associated with Subsection 3.3.2.2.5, Paragraph 2.
Request:  Provide additional information to explain how the Structures Monitoring Program adequately manages the subject aging effects. Specifically, clarify whether HCGS has determined a qualified life for the compressible joint seals aligned with LRA Table 3.3.1, Item 3.3.1-12, and Subsection 3.3.2.2.5, Paragraph 2.}}

Latest revision as of 00:29, 12 March 2020

Request for Additional Information for the Review of the Hope Creek Generating Station License Review Application
ML101370559
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 06/09/2010
From: Bennett Brady
License Renewal Projects Branch 1
To: Joyce T
Public Service Enterprise Group
Brady B NRR/DLR/RPB1, 415-2981
References
TAC ME1832
Download: ML101370559 (8)


Text

June 9, 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

ML101370559 OFFICE PM:DLR:RPB1 LA:DLR BC:DLR:RPB1 PM:DLR:RPB1 NAME B. Brady S. Figueroa B. Pham B. Brady DATE 5/25/10 5/18/10 5/28/10 6/09/10 Letter to T. Joyce from B. Brady dated June 9, 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 3.1.2.2.4.1

Background:

Hope Creek Generating Station (HCGS) License Renewal Application (LRA) Subsection 3.1.2.2.4, Paragraph 1 Standard Review Plan-License Renewal (SRP-LR) Subsection 3.1.2.2.4, Paragraph 1 SRP-LR Appendix A, Subsection A.1.2.3.4, Paragraph 1 LRA Subsection 3.1.2.2.4, Paragraph 1, addresses cracking due to stress corrosion cracking (SCC) or intergranular stress corrosion cracking (IGSCC) that could occur in the stainless steel or nickel alloy BWR top head enclosure vessel flange leak detection lines. The LRA states that Hope Creek Generating Station (HCGS) will use aging management program (AMP) B.2.1.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC and IWD (ISI) program, and AMP B.2.1.2, Water Chemistry, to manage the aging effects of cracking due to SCC or IGSCC in the stainless steel vessel flange leak detection line exposed to treated water. It also states that the HCGS ISI program uses a VT-2 visual examination of the line prior to reactor cavity drain down, as approved by a current relief request, prior to drain down during each refueling outage.

SRP-LR Subsection 3.1.2.2.4, Paragraph 1, and GALL Report item IV.A1-10 (R-61) states that a plant-specific AMP is to be evaluated because existing programs may not be capable of mitigating or detecting crack initiation and growth due to SCC in the vessel flange leak detection line.

SRP-LRA Appendix A, Subsection A.1.2.3.4, Paragraph 1, provides generic recommendations for the detection of aging effects program element of a plant-specific AMP. This paragraph states that detection of aging effects should occur before there is a loss of the structure and component intended function(s).

Issue:

The staff does not understand how a VT-2 visual examination of the vessel flange leak detection line, as described in the LRA, would be capable of detecting cracking in the line prior to a through-wall crack having occurred. Also, the relief request described in the LRA is approved only for the current ten-year ISI inspection interval, which does not extend into the period of extended operation; and there is no assurance that the relief request would either be made by HCGS or be approved by the staff during the period of extended operation.

ENCLOSURE

Request:

a) Explain how VT-2 examination will detect cracking in the vessel flange leak detection line prior to failure of the lines intended function of providing a reactor coolant pressure boundary.

b) Explain how aging of the vessel flange leak detection line will be managed during the period of extended operation without referring to implementation of a relief request which has neither been requested nor approved for the period of extended operation.

RAI 3.3.2.2.5.2

Background:

HCGS LRA Subsection 3.3.2.2.5, Paragraph 2; Table 3.3.1, Item 3.3.1-12; Table 3.5.2-8, pages 3.5-176 SRP-LR Subsection 3.3.2.2.5, Paragraph 2 GALL Item VII.A4-1 HCGS LRA Subsection 3.3.2.2.5, Paragraph 2, states that HCGS will implement the Structures Monitoring Program to manage hardening and loss of strength due to elastomer degradation of the compressible joint seals (inflatable pool seals) in the reactor building exposed to treated water, and that the Structures Monitoring Program includes visual inspections of elastomer components to assure that existing environmental conditions are not causing material degradation that could result in loss of component intended function. Table 3.3.1, item 3.3.1-12 states that compressible joint seals in the reactor building have been aligned to the item based on material, environment, and aging effect.

SRP-LR Subsection 3.3.2.2.5, Paragraph 2, applies for hardening and loss of strength due to elastomer degradation in elastomer linings of the filters, valves, and ion exchangers in spent fuel pool and cleanup systems (BWR and PWR) exposed to treated water or to treated borated water. GALL item VII.A4-1 associated with this SRP-LR paragraph recommends a plant-specific AMP that determines and assesses the qualified life of the linings in the environment is to be evaluated.

Issue:

Since the SRP recommends determination and assessment of a qualified life for the components associated with Subsection 3.3.2.2.5, Paragraph 2, it is not clear to the staff whether HCGS has determined a qualified life for the compressible joint seals (inflatable pool seals) that it has associated with this paragraph through the LRA Tables. It also is not clear whether visual inspection, alone, is capable of detecting hardening and loss of strength in the compressible joint seals that HCGS has associated with Subsection 3.3.2.2.5, Paragraph 2.

Request:

Provide additional information to explain how the Structures Monitoring Program adequately manages the subject aging effects. Specifically, clarify whether HCGS has determined a qualified life for the compressible joint seals aligned with LRA Table 3.3.1, Item 3.3.1-12, and Subsection 3.3.2.2.5, Paragraph 2.