ML102530476
| ML102530476 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/02/2010 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| Download: ML102530476 (4) | |
Text
1 DiabloCanyonNPEm Resource From:
Ferrer, Nathaniel Sent:
Thursday, September 02, 2010 10:46 AM To:
Grebel, Terence; Soenen, Philippe R
Subject:
Draft RAI Set 24 - Aging Management Programs Attachments:
Draft RAI Set 24 Aging Management Programs.doc Terry and Philippe, Attached is Draft RAI Set 24 containing draft RAIs, specifically on portions of aging management programs.
Please review the attached draft RAIs and let me know if and when you would like to have a teleconference call. The purpose of the call will be to obtain clarification on the staff's request.
Please let me know if you have any questions.
NathanielFerrer ProjectManager DivisionofLicenseRenewal OfficeofNuclearReactorRegulation U.S.NuclearRegulatoryCommission (301)4151045
Hearing Identifier:
DiabloCanyon_LicenseRenewal_NonPublic Email Number:
1155 Mail Envelope Properties (Nathaniel.Ferrer@nrc.gov20100902104600)
Subject:
Draft RAI Set 24 - Aging Management Programs Sent Date:
9/2/2010 10:46:07 AM Received Date:
9/2/2010 10:46:00 AM From:
Ferrer, Nathaniel Created By:
Nathaniel.Ferrer@nrc.gov Recipients:
"Grebel, Terence" <TLG1@PGE.COM>
Tracking Status: None "Soenen, Philippe R" <PNS3@PGE.COM>
Tracking Status: None Post Office:
Files Size Date & Time MESSAGE 562 9/2/2010 10:46:00 AM Draft RAI Set 24 Aging Management Programs.doc 57338 Options Priority:
Standard Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Recipients Received:
Diablo Canyon Nuclear Power Plant, Units 1 and 2 (DCPP)
License Renewal Application (LRA)
Draft Request for Additional Information Set 24 Aging Management Programs D-RAI B2.1.20-2
Background:
GALL AMP XI.M36, External Surfaces Monitoring Program states, [s]urfaces that are inaccessible or not readily visible during plant operations are inspected during refueling outages. Surfaces that are inaccessible or not readily visible during both plant operations and refueling outages are inspected at such intervals that would provide reasonable assurance that the effects of aging will be managed such that applicable components will perform their intended function during the period of extended operation.
The SRP-LR Section 3.2.2.4 states, The summary description of the programs and activities for managing the effects of aging for the period of extended operation in the FSAR supplement should be sufficiently comprehensive such that later changes can be controlled by 10 CFR 50.59. It also states that, Examples of the type of information required are provided in Table 3.2-2 of this SRP-LR. Section 3.2.3.4 states, The reviewer confirms that the applicant has provided information equivalent to that in Table 3.2-2 in the FSAR Supplement for aging management of the auxiliary systems for license renewal. The description of program for the External Surfaces Monitoring Program in Tables 3.2-2, 3.3-2 and 3.4-2 includes the following, Surfaces that are inaccessible during plant operations are inspected during refueling outages.
Surfaces that are inaccessible during both plant operations and refueling outages are inspected at frequencies to provide reasonable assurance that effect of aging will be managed such that applicable components will perform their intended function during the period of extended operation.
Issue:
LRA Section B2.1.20 states, [e]xternal surface inspections will be performed on passive components in scope for license renewal at intervals no longer than once per refueling cycle LRA Section B2.1.20 also states, [t]he External Surfaces Monitoring program will provide clarification for areas, or portions of systems or components, that may be exempted from walkdown inspections based on physical or environmental constraints.
It is not clear to the staff if the applicant has access to all surfaces being age managed by the External Surfaces Monitoring Program during plant operations and refueling outages as is implied in the first quoted statement, but given the second quoted statement, it does appear that the applicant has a process for excluding some external surfaces from walkdowns based on physical or environmental constraints. The LRA does not contain a statement that the applicant will ensure that those components that are exempted from walkdowns will be ultimately inspected or evaluated to ensure the components will perform their intended functions during the period of extended operation if an inspection can not be performed. The staff requires further information to understand how the applicant will evaluate components that are exempted from walkdowns, thus implying that they will never be inspected.
LRA Section A1.20, the FSAR Supplement Description for the External Surfaces Monitoring Program does not contain information related to inaccessible surfaces during plant operations
and inaccessible surfaces during plant operations and refueling outages. The FSAR Supplement for the External Surfaces Monitoring Program should have equivalent wording that states that surfaces that are inaccessible during both plant operations and refueling outages are inspected at frequencies to provide reasonable assurance that effect of aging will be managed such that applicable components will perform their intended function during the period of extended operation.
Request
- 1. Describe the criteria that will be used and evaluation methodology to ensure that components exempted from walkdown will be managed such that applicable components will perform their intended function during the period of extended operation.
- 2. Revise FSAR Supplement Section A1.20 to ensure that surfaces that are inaccessible during both plant operations and refueling outages are inspected at frequencies to provide reasonable assurance that effect of aging will be managed such that applicable components will perform their intended function during the period of extended operation.
D-RAI B2.1.20-3 LRA Table 3.3.2-7, Auxiliary Systems - Compressed Air contains line items for copper alloy
(>15 percent zinc) regulators and solenoid valves exposed to atmospheric weather being managed for loss of material by the External Surfaces Monitoring Program. LRA Section B2.1.20, External Surfaces Monitoring AMP, does not include copper alloy (>15 percent zinc) in the Program Description or scope of program exemption.
Given that the External Surfaces Monitoring Program does not include copper alloy (>15 percent zinc) material in LRA Section B2.1.20, the staff cannot conclude that associated AMR line items will be appropriately age managed.
Request:
- 1. Revise LRA Section B2.1.20 to include copper alloy (>15 percent zinc) or state an alternative aging management program for the above line items.