ML101830144

RAI Related to the Review of the DCPP LRA - Aging Management Programs and Aging Management Review

ML101830144
Person / Time
Site:	Diablo Canyon
Issue date:	07/20/2010
From:	Ferrer N License Renewal Projects Branch 2
To:	Conway J Pacific Gas & Electric Co
Nate Ferrer, DLR/RPB2 415-1045
References
TAC ME2896, TAC ME2897
Download: ML101830144 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 July 20, 2010 John Conway Senior Vice President Generation and Chief Nuclear Officer Pacific Gas and Electric Company 77 Beale Street, MC B32 San Francisco, CA 94105

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE REVIEW OF THE DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. ME2896 AND ME2897) - AGING MANAGEMENT PROGRAMS AND AGING MANAGEMENT REVIEW

Dear Mr. Conway:

By letter dated November 23, 2009, Pacific Gas & Electric Company submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54, to renew the operating licenses for Diablo Canyon Nuclear Power Plant, Units 1 and 2, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.

The request for additional information was discussed with Mr. Terry Grebel, 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 at 301-415-1045 or bye-mail at nathaniel.ferrer@nrc.gov.

Sincerely,

1. h-z-Nathaniel Ferrer, Safety Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323

Enclosure:

As stated cc w/encl: Distribution via Listserv

Diablo Canyon Nuclear Power Plant, Units 1 and 2 License Renewal Application Request for Additional Information Set 12 Aging Management Programs/Aging Management Review RAI2.3.2.4-1 License Renewal Application (LRA) Table 3.2.2-04 identifies an aging management review (AMR) line item for a stainless steel separator with an internal ventilation atmosphere. During the material/environment verification audit walkdown, the applicant stated that this piece of equipment was not installed. In LRA Tables 2.3.2-4 and 3.2.2-4, separator is listed as a component type subject to an AMR. However, on license renewal boundary drawing LR-DCPP 23A-106723-04, Note 1 indicates that there are provisions for moisture separators but they are not installed. Additionally, there are no moisture separators shown on the drawing as subject to an AMR, i.e., highlighted. Clarify if there are moisture separators installed in the Unit 1 containment fan coolers, and whether they are subject to an AMR.

RAI2.3.3.18-1 LRA Table 3.3.2-18 identifies an AMR line item for isothermal bath heat exchanger (ITB chiller) with the material and internal environment listed as copper alloy and dried gas, respectively.

During the material/environment verification audit walkdown, the applicant stated that this piece of equipment was abandoned in place for both units. The staff noted that the ITB chillers were cut, capped and drained. However, in LRA Tables 2.3.3-18 and 3.3.2-18, and on license renewal boundary drawing LR-DCPP-15-106715-02, the ITB chiller is listed or shown as a component type that is subject to an AMR. Based on the above, clarify if the ITB chiller is subject to an AMR.

RAI B2-1 LRA Section B.2.1.32 describes the Structures Monitoring Program (SMP) as managing cracking, loss of material, and change in material properties by monitoring the condition of structures and structural supports that are in the scope of license renewal. The applicant states that though coatings may have been applied to the external surfaces of structural members, no credit was taken for these coatings in the determination of aging effects for the underlying materials. The applicant further states that the SMP evaluates the condition of the coatings as an indication of the condition of the underlying materials.

NUREG-1801, "Generic Aging Lessons Learned (GALL) Report," states that "Proper maintenance of protective coatings inside containment is essential to ensure operability of post-accident safety systems that rely on water recycled through the containment sump/drain system." On page B-13 of the LRA, line item XI.S8 states that the NUREG-1801 Protective Coating Monitoring and Maintenance Program is not applicable to Diablo Canyon Nuclear Power Plant (Diablo Canyon).

ENCLOSURE

- 2

1. Please justify why GALL aging management report (AMP) XI.S8 does not apply to Diablo Canyon.

2. Since degradation of Service Level 1 protective coatings in containment can potentially become a debris source that challenges the safety function of the emergency core.

cooling system, please provide a justification for not including Service Level 1 protective coatings in scope by rule in 10 CFR 54.4(a)(2).

3. Provide the details of how Service Level 1 protective coatings in containment will be properly maintained and not become a debris source that might challenge the safety function of the emergency core cooling system, during the period of extended operation.

RAI82.1.13-3 GALL AMP XI.M27, "Fire Water System," recommends periodic flow testing of the fire water system or wall thickness evaluations (e.g., volumetric or visual inspections) be performed to ensure that the system maintains its intended function. GALL AMP XI.M27 states that if an applicant chooses to perform visual inspections, these inspections must be capable of evaluating (1) wall thickness to ensure against catastrophic failure, and (2) the inner diameter of the piping as it applies to the design flow of the fire protection system.

During the AMP Audit, the staff noted that the applicant's underground firewater piping does not have cathodic protection and is currently not periodically inspected. During its review of AMR results for the fire protection system in LRA Table 3.3.2-12, the staff noted that there are AMR results for buried steel (carbon steel, cast iron, and ductile iron) closure bolting, hydrants and valves, but that there are no results for buried steel piping. In addition, LRA Section 82.1.13 does not include any information regarding the inspection of buried components.

It is not clear to the staff why there are no AMR results in LRA Table 3.3.2-12 for buried steel piping or the method and frequency of the inspections for the internal and external surfaces of the buried components.

1. Explain why there are no AMR results in LRA Table 3.3.2-12 that address aging management of steel piping exposed to soil.

2. Provide additional details regarding the method and frequency of the internal and external inspections of underground components.

RAI82.1.13-4 GALL AMP XI.M27, "Fire Water System" recommends that fire protection system piping be subjected to flow testing or non-intrusive wall thickness evaluations prior to the period of extended operation and at plant-specific intervals thereafter such that loss of intended function will not occur. GALL AMP XI.M27 states that visual inspections may be performed on the internal surfaces of a representative number of piping locations during system maintenance in lieu of performing non-intrusive wall thickness evaluations, as long as it can be demonstrated

- 3 that the inspections are performed on a representative number of locations on a reasonable basis and are based on past maintenance history.

The applicant's Fire Water System Program states an enhancement to the "detection of aging effects" program element to perform either periodic non-intrusive examinations or visual inspections of the fire water system piping. However, LRA Section B2.1.13 does not provide any details regarding the methodology that will be used for selecting the representative sample of components and locations to be visually inspected or the components subject to periodic non intrusive examination.

LRA Table 3.3.1, item 3.3.1-68 addresses carbon steel piping, piping components, and piping elements exposed to raw water (either internal or external) being managed for loss of material due to general, pitting, crevice, and microbiologically influenced corrosion, and fouling by the Fire Water System Program. The corresponding AMR line item in LRA Table 3.3.2-12 for the fire water tank cites generic Note D, indicating that the component is different, but consistent with the GALL Report item for material, environment and aging effect. In LRA Appendix B, Section B2.1.13 for the Fire Water System Program under the description of inspections section, PG&E states that the program performs periodic visual inspections of fire system piping, yard loop fire hydrants, hose reel headers, hose stations, portable diesel driven fire pump hoses, fire hoses, gaskets, water spray headers, sprinkler system headers, water spray nozzles, and sprinkler heads to verify they are free of significant corrosion, foreign materials, biofouling, and physical damage. However, the Fire Water System Program description and description of inspections do not include any information regarding whether or how the fire water tank is inspected, e.g., visual or non-intrusive.

1. Explain the methodology used to determine the representative sample of locations for the visual inspections, and the components subject to periodic non-intrusive examination.

2. Clarify how the fire water tank described in LRA Table 3.3.2-12 will be managed for aging by the Fire Water System Program. Include what inspection techniques are used to manage the effects of aging for the tank.

July 20,2010 John Conway Senior Vice President Generation and Chief Nuclear Officer Pacific Gas and Electric Company 77 Beale Street, MC B32 San Francisco, CA 94105

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE REVIEW OF THE DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. ME2896 AND ME2897) - AGING MANAGEMENT PROGRAMS AND AGING MANAGEMENT REVIEW

Dear Mr. Conway:

By letter dated November 23, 2009, Pacific Gas & Electric Company submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54, to renew the operating licenses for Diablo Canyon Nuclear Power Plant, Units 1 and 2, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.

The request for additional information was discussed with Mr. Terry Grebel, 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 at 301-415-1045 or bye-mail at nathaniel.ferrer@nrc.gov.

Sincerely, IRAJ Nathaniel Ferrer, Safety Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323

Enclosure:

As stated cc w/encl: Distribution via Listserv DISTRIBUTION:

See next page ADAMS Accession No'.. ML101830144 OFFICE PM:RPB2:DLR LA:DLR BC:RPB2:DLR PM:RPB2:DLR NAME NFerrer SFigueroa DWrona NFerrer DATE 07/15/10 07/08/10 07/20/10 07/20/10 OFFICIAL RECORD COpy

To John Conway from Nathaniel Ferrer date July 20,2010

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE REVIEW OF THE DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC Nos. ME2896 AND ME2897) - AGING MANAGEMENT PROGRAMS DISTRIBUTION:

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