05000261/FIN-2010008-01
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Finding | |
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Title | Aging Management Program for exterior surface of EOF/TSC Main Storage Tank |
Description | The inspectors identified an Unresolved Item related to the Emergency Operations Facility/Technical Support Center (EOF/TSC) Diesel Generator Main Storage Tank (buried diesel fuel oil tank), for which additional information and discussion was needed to determine if a performance deficiency existed, if the performance deficiency was more than minor, or if the issue of concern constituted a violation of NRC requirements. The inspectors noted that Table 2.3-25 of the LRA lists the components in the Fuel Oil System that require aging management review. This table shows that the results of the AMR for the EOF/TSC Main Storage Tank are documented in Table 3.3-1 and Table 3.3-2 of the LRA. Table 3.3-1 specifies that aging management for the diesel fuel oil tanks made of carbon steel in the diesel fuel oil system and the EDG system will be implemented through the Fuel Oil Chemistry Program. Table 3.3-2 specifies that the EOF/TSC Main Storage Tank is a buried tank made of fiberglass reinforced polyester. The licensee stated in this table that no aging effects or AMP applies to this tank. Additionally, section B.3.12 of the LRA, Buried Piping and Tanks Inspection Program states that this AMP does not contain buried tanks. In RAI B.3.12-1, the NRR staff requested confirmation that no buried tanks were covered under the Buried Piping and Tanks Inspection Program. In its response to this RAI dated April 28, 2003, the licensee stated that the program does not contain buried tanks. During the review of AMR documents for LR commitments, the inspectors identified that the EOF/TSC Main Storage Tank is made of carbon steel covered with 1/8 nominal exterior coating of fiberglass reinforced polyester. The inspectors noted that the description of the tank in Table 3.3-2 did not include carbon steel. The inspectors questioned the licensee with regard to the basis for excluding this buried tank from the scope of the Buried Piping and Tanks Inspection Program. According to the licensee, the combination of tank material and environment (i.e. buried carbon steel tank covered with fiberglass reinforced polyester) is not specifically addressed in Table VII.H1 of the GALL Report and therefore the licensee treated this tank as a component that is different from the GALL Report. The inspection team remained concerned whether the exclusion of the EOF/TSC Main Storage Tank from the Buried Piping and Tanks Inspection Program was appropriate and whether the AMP selected by the licensee to manage aging on the tanks surfaces was adequate. This issue required further review. Therefore, this issue will be tracked as an unresolved item (URI 5000261/2010008-01) |
Site: | Robinson |
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Report | IR 05000261/2010008 Section 4OA5 |
Date counted | Mar 31, 2010 (2010Q1) |
Type: | URI: |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71003 |
Inspectors (proximate) | A Hutto D Bollock M Coursey D Mills E Michel J Rivera-Ortiz R Hamilton W Loo H Gepford J Austin J Hickey R Musserj Rivera-Ortizc Julian M Franke L Lake G Kolcum R Williams J Kent E Michel |
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Finding - Robinson - IR 05000261/2010008 | |||||||||||||||||||||||||||||||||||
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Finding List (Robinson) @ 2010Q1
Self-Identified List (Robinson)
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