ML081090438
| ML081090438 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/15/2008 |
| From: | - No Known Affiliation |
| To: | NRC/SECY/RAS |
| SECY RAS | |
| References | |
| 50-293-LR, ASLBP 06-848-02-LR, Pilgrim-Staff-47, RAS J-77 | |
| Download: ML081090438 (4) | |
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j77 confirmed that their implementation prior to the period of extended operation would make the existing AMP consistent with the GALL AMP to which it'was compared. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3). The staff also reviewed the UFSAR supplement A.2.1.28 for this AMP and concludes that it provides (pending incorporation of the applicant's commitments) an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.16 Service Water Integrity Program Summary of Technical Information in the Application. LRA Section B.1.28, "Service Water Integrity," describes the existing Service Water Integrity Program as consistent, with exceptions, with GALL AMP XI,M20, "Open-Cycle Cooling Water System."
This program .relies on implementation of the recommendations of GL 59-13 to manage the effects of aging on the SSW system for the period of extended operation. The program includes surveillance and control techniques to manage aging effects caused by biofouling, corrosion, erosion, protective coating failures, and silting in the SSW system or structures and components it services.
Staff Evaluation. During Its audit-and review, the staff confirmed the applicant's claim of consistency with the GALL Report and documented a detailed audit evaluation ofthis.AMP in Audit and Review Report Section 3.0.3.2.16. The staff reviewed the exceptions to deteimine whether the AMP remained adequate to manage the aging effects for which it is credited.
The staff reviewed those pc US. NXLEAR RGUTMOR .. S..
claims consistency with GA . ,, vnft concludes that the applican Maus o k*. 44A_-
of aging effects so compon _)___t U No. 1-1.
with the CLE during the per OFE.E .....
Water Integrity Program ac
'Service Water Integrity," w N .(.7 Exception 1. The LRA state Acni T ,.*.. .,,
actions," specifically: - WfhbaVM NUREG-1801 state are lined or coated surfaces.
The LRA states that the G.
appropriate materials and DOCKETED to aggressive cooling watf I J. .
where necessary to protec Andri 15. 2008 (10:00am)
During the audit and revie are not coated or lined an OFFICE OF SECRETARY R Il F:MAKIN(r~ ANFl An. Ir'MI.ATIONS STAFF 7~4o~ ~4'OP6 7
confirmed that their implementation prior to the period of extended operation would make the existing AMP consistent with the GALL AMP to which it was compared. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3). The staff also reviewed the UFSAR supplement A.2.1.28 for this AMP and concludes that it provides (pending incorporation of the applicant's commitments) an adequate summary description of the program, as required by 10 CFR 54.21(d),.
3.0.3.2.16 Service Water Integrity program Summary of Technical Information in the Application, LRA Section B.1.28, "Service Water Integrity," describes the existing Service Water Integrity Program as consistent, with exceptions, with GALL AMP XI.M20, "Open-Cycle Cooling Water System."
This program relies on implementation of the recommendations of GL 89-13 to manage the effects of aging on the SSW system for the period of extended operation, The program includes surveillance and control techniques to manage aging effects caused by biofouling, corrosion, erosion, protective coating failures, and silting in the SSW system or structures and components it services.
Staff Evaluation. During Its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report an~d documented a detailed audit evaluation of this AMP in Audit and Review Report Section 303.2.16. The staff reviewed the exceptions to determine whether the AMP remained adequate to manage the aging effects for which it is credited.
The staff reviewed those portions of the Service Water Integrity Program for which the applicant (
claims consistency with GALL AMP XI.M20 and found them consistent. Furthermore, the staff concludes that the applicant's Service Water Integrity Program reasonably assures management of aging effects so components crediting this program can perform intended functions consistent with the CLB during the period of extended operation. The staff finds the applicant's Service Water Integrity Program acceptable as consistent with the recommended GALL AMP XI.M20, "Service Water Integrity," with exceptions as described:
Exception 1. The LRA states an exception to the GALL Report program element "preventive actions," specifically:
NUREG-1801 states that system components are lined or coated. Components are lined or coated only where necessary to protect the underlying metal surfaces.
The LRA states that the GALL Report states that system components are constructedof appropriate materials and lined or coated to protect the underlying metal surfaces from exposure to aggressive cooling water environments. Not all system components are lined or coated, only where necessary to protect the underlying metal surfaces.
During the audit and review, the staff asked the applicant for applications in which components are not coated or lined and the materials of construction.
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The applicant responded that the SSW supply piping is constructed of titanium, a material which has shown excellent corrosion- resistance in this environment. The other components in the SSW supply are small-bore piping for vents and drains, pump and valve bodies, and heat exchanger tubes. All of these components are constructed of copper alloys with demonstrated good corrosion resistance in this environment and operating experience shows that the Service Water Integrity Program manages loss of material and-takes corrective action before loss of component intended functions.
On this basis, the staff finds the exception acceptable.
Exception 2. The LRA states an exception to the GALL Report program element 'monitoring and trending," specifically:
NUREG-1801 states that testing and inspections are performed annually and during RFOs. The PNPS program requires tests and inspections during each RFO.
The LRA states that the GALL Report program entails testing and inspections annually and during RFOs. The applicant's program requires tests and inspections during each RFO but not annually. As aging effects typically are manifested over several years, the difference in inspection and testing frequency is insignificant.
During the audit and review, the staff evaluated the applicant's inspection interval and agreed that aderse conditions caused by the aging effects in the service water systems manifest over several years, Operating experience shows that a two-year interval has not led to adverse service water system operating conditions; therefore, the difference between a one-year and two-year inspection and testing frequency is insignificant.
On this basis, the staff finds the exception acceptable.
In addition, the applicant stated that it will enhance this program to clarify the procedures for trending heat transfer test results (Commitment No. 24). The staff finds this acceptable.
Operating Experience. LRF Section B.1.28 states that results of heat transfer capability testing of the reactor building, closed cooling water (RBCCW) heat exchangers from 2D01 through 2004 show that the heat exchangers can remove the required amount of heat. Confirmation of adequate heat removal provides evidence that the program effectively manages fouling of SSW-cooled heat exchangers.
Results of SSW Visual inspections, eddy current testing, UT, and radiography testing from 1998 through 2004 revealed areas of erosion and corrosion on internal and external surfaces. SSW butterfly valves, pump discharge check valves, air removal valves, and pipe spools have been replaced with components made of corrosion-resistant materials, RBCCW heat exchanger channel assemblies have been replaced, and tubes have been sleeved to address erosion and corrosion. Revelation of degradation and corrective action prior to loss of intended function provide evidence that the program effectively manages loss of material for SSW system components.
Visual inspections of SSW piping revealed degradation of the lining in original SSW carbon steel 3-94
rubber-lined piping intended to protect pipe internal surfaces from erosion and corrosion.
Therefore, SSW piping has been replaced with carbon steel pipe with rubber lining cured in place, relined with a ceramic epoxy compound, or replaced with titanium pipe. Revelation of degradation and corrective action prior to loss of intended function provide evidence that the program effectively manages loss of material for SSW system components.
The staff reviewed the operating experience presented in the LRA and interviewed the applicant's technical personnel to confirm that the plant-specific operating experience revealed no degradation not bounded by industry experience.
The staff confirmed that the "operating experience" program element satisfies the criterion defined in the GALL Report and in SRP-LR Section A,1.2.3.10. The staff finds this program element acceptable.
UFSAR Supplement, In LRA Section A.2.1.30, the applicant provided the UFSAR supplement for the Service Water Integrity Program. The staff reviewed this section and determined that the information in the UFSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).
Conclusion. On the basis of its audit and review of the applicant's Service Water Integrity Program, the staff determines that those program elements for which the applicant claimed consistency with the GALL Report are consistent. In addition, -the staff reviewed the exceptions and their justifications and determined that the AMP, with the exceptions, is adequate to manage the aging effects for which It is credited. The staff concludes that the applicant has demonstrated -
that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
3.0.3.2.17 Structures Monitoring Program Summary of Technical Information in the Application. LRA Section B.1.29.2, "Structures Monitoring," describes the existing Structures Monitoring Program as consistent, with enhancements, with GALL AMP XI.S6, "Structures Monitoring Program.'
Structures monitoring in accordance with 10 CFR 50.65 (Maintenance Rule) is addressed in Regulatory Guide 1.160 and Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants 93-01. These two documents guide development of licensee-specific programs to monitor the condition of structures and structural components within the scope of the Maintenance Rule so there is no loss of structure or structural component intended function.
As protective coatings are not relied upon to manage aging effects for structures in the Structures Monitoring Program, the program does not address protective coating monitoring and maintenance, Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of consistency with the GALL Report and documented a detailed audit evaluation of this AMP in Audit and Review Report Section 3.0.3.2.17. The staff reviewed the enhancements to determine whether the AMP remained adequate to manage the aging effects for which it is credited..
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