ML11294A013

2011/09/27 Davis-Besse Lr -

ML11294A013
Person / Time
Site:	Davis Besse
Issue date:	09/27/2011
From:	Office of Nuclear Reactor Regulation
To:	Division of License Renewal
References
Download: ML11294A013 (4)

Text

1 Davis-BesseNPEm Resource From: CuadradoDeJesus, Samuel Sent: Tuesday, September 27, 2011 10:05 AM To: dorts@firstenergycorp.com Cc: Davis-BesseHearingFile Resource Attachments:

Davis-Besse LRA Supplemental RAIs for 4.7 TLAAs.docxSteve:

Attached are two draft RAIs. We'll discuss them next Thursday.

Thanks Samuel Cuadrado de Jesús Project Manager Projects Branch1

Division of License Renewal U.S. Nuclear Regulatory Commission

Phone: 301-415-2946 Samuel.CuadradoDeJesus@nrc.gov

Hearing Identifier: Davis_BesseLicenseRenewal_Saf_NonPublic Email Number: 1576 Mail Envelope Properties (377CB97DD54F0F4FAAC7E9FD88BCA6D0805071A9E0)

Subject:

Sent Date: 9/27/2011 10:05:21 AM Received Date: 9/27/2011 10:05:37 AM From: CuadradoDeJesus, Samuel Created By: Samuel.CuadradoDeJesus@nrc.gov Recipients: "Davis-BesseHearingFile Resource" <Davis-BesseHearingFile.Resource@nrc.gov> Tracking Status: None "dorts@firstenergycorp.com" <dorts@firstenergycorp.com> Tracking Status: None Post Office: HQCLSTR01.nrc.gov

Files Size Date & Time MESSAGE 350 9/27/2011 10:05:37 AM Davis-Besse LRA Supplemental RAIs for 4.7 TLAAs.docx 24765 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION, SECTIONS 4.7.3 AND 4.7.4 TIME-LIMITED AGING ANALYSES DAVIS-BESSE NUCLEAR POWER STATION FIRST ENERGY NUCLEAR OPERATING COMPANY DOCKET NO. 50-346 LRA Section 4.7.3 - Reactor Vessel (RV) Thermal Shock Due to Borated Water Storage Tank (BWST) Water Injection

RAI 4.7.3-1 Background

LRA Section 4.7.3 discusses a fracture mechanics analysis for evaluating the integrity of the RV during the pressurized thermal shock (PTS) event associated with low-temperature (35 ºF) water injection from the BWST following a small steam line break. LRA Section 4.7.3 states that the current licensing basis (CLB) analysis for this event is addressed in the Davis-Besse Updated Safety Analysis Report (USAR), Section 5.2 and that the subject analysis was revised to consider the period of extended operation (52 EFPY).

Issue The staff reviewed USAR Section 5.2 and could not locate the CLB analysis for evaluating RV integrity under the subject PTS conditions. Furthermore, the staff found no references in LRA Section 4.8 for reports documenting the analysis of RV integrity under these PTS conditions for the period of extended operation, based on the 52 EFPY RTPTS values. Request a. Please state the USAR section and page number where the summary of the CLB analysis of the subject PTS event is located. If a summary of the CLB analysis is not located in the USAR, please state where it can be found.

b. Please provide the reports documenting the projected 52 EFPY analysis of RV integrity under the subject PTS conditions

LRA Section 4.7.4 - High Pressure Injection (HPI) / Makeup Nozzle Thermal Sleeves RAI 4.7.4-1 Background

By letter dated June 3, 2011, the applicant provided Amendment 8 to Davis-Besse LRA. LRA Amendment 8 revised the disposition for the analysis of the HPI/Makeup Nozzle Thermal Sleeves in LRA Section 4.7.4 from "10 CFR 54.21(c)(1)(iii)" to "Not a TLAA." As an explanation for the revised disposition, LRA Section 4.7.4, as amended, now states that "[b]ased on the [USAR Supplement] commitment [to replace the subject thermals sleeves], the HPI/Makeup nozzle thermal sleeves are short-lived (not 40-year) parts and therefore this analysis is not a TLAA." Similarly, LRA Amendment 8 revised the corresponding USAR Supplement section in LRA Section A.2.7.4 to reflect the changed disposition. LRA Section A.2.7.4, as revised by LRA Amendment 8, now states that, "[b]ased on the commitment [to replace the subject thermal sleeves], the HPI/makeup nozzle thermal sleeves are short lived (not 40-year) parts and therefore this analysis is not a TLAA." Finally, LRA Section 4.1, Table 4.1-1, was amended per LRA Amendment 8 to state that the evaluation of the subject thermal sleeves is "Not a TLAA."

Issue The staff determined that aging of the subject thermal sleeves, as discussed in LRA Section 4.7.4, should be identified as a TLAA in LRA Sections 4.1, 4.7.4, and the USAR Supplement, because the aging mechanism is time dependent (i.e., it is dependent on the number of transient cycles incurred), and the staff cannot accept future commitments to replace components as a means for disposition of the currently-installed components undergoing time-dependent aging processes, without a TLAA of the currently-installed components.

Request Request Based on the above, the staff requests that the applicant amend LRA Sections 4.1, 4.7.4, and A.2.7.4 to identify HPI/makeup thermal sleeve aging as a TLAA. The staff also requests that the applicant select an appropriate disposition under 10 CFR 54.21(c)(1). If the applicant proposes a 10 CFR 54.21(c)(1)(iii) disposition for this analysis, then the staff requests that the applicant amend LRA Sections 4.7.4 and A.2.7.4 to propose an appropriate aging management program (AMP) for managing the effects of aging on the intended function of the thermal sleeves. Any AMP identified in LRA Sections 4.7.4 and A.2.7.4 for a 10 CFR 54.21(c)(1)(iii) disposition of this analysis should ensure that the effects of aging on the subject thermal sleeves are appropriately managed for the period of extended operation.