ML110560236
| ML110560236 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/23/2011 |
| From: | Office of Nuclear Reactor Regulation |
| To: | Division of License Renewal |
| References | |
| 06-848-02-LR | |
| Download: ML110560236 (5) | |
Text
1 PilgrimRenewal NPEmails From:
Regner, Lisa Sent:
Wednesday, February 23, 2011 10:07 AM To:
Joe Lynch; Fred Mogolesko (fmogole@entergy.com)
Cc:
PilgrimRenewal NPEmails
Subject:
Pilgrim Buried Pipe DRAFT RAI Attachments:
Pilgrim BP RAI Revision - clean.docx Joe, Fred, Attached is the staffs draft RAI. Let me know if youd like to have a conference call.
Lisa
Hearing Identifier:
PilgrimRenewalNonPublic_EX Email Number:
562 Mail Envelope Properties (28C67094311E124FBAF1AA3E42B88191208827AF44)
Subject:
Pilgrim Buried Pipe DRAFT RAI Sent Date:
2/23/2011 10:06:58 AM Received Date:
2/23/2011 10:06:59 AM From:
Regner, Lisa Created By:
Lisa.Regner@nrc.gov Recipients:
"PilgrimRenewal NPEmails" <PilgrimRenewal.NPEmails@nrc.gov>
Tracking Status: None "Joe Lynch" <jlynch4@entergy.com>
Tracking Status: None "Fred Mogolesko (fmogole@entergy.com)" <fmogole@entergy.com>
Tracking Status: None Post Office:
HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 112 2/23/2011 10:06:59 AM Pilgrim BP RAI Revision - clean.docx 37820 Options Priority:
Standard Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Recipients Received:
Pilgrim Buried Pipe DRAFT RAI
Background:
In a December 6, 2010, telephone conference with the applicant, the staff discussed the fact that since the November 2007 issuance of NUREG-1891, Safety Evaluation Report Related to the License Renewal of Pilgrim Nuclear Power Station, there have been a number of examples of industry operating experience involving the corrosion of buried and underground piping and tanks within the scope of license renewal. The staff requested additional information from the applicant in light of the available operating experience and in order to ensure the aging effects for buried and underground piping and tanks will be managed such that these systems and components will continue to perform their intended functions throughout the period of extended operation. The applicant provided additional information related to their buried piping program in a letter dated January 7, 2011. Based on the information provided, the staff concluded that additional detail is needed, as discussed below.
Request:
As to all in-scope buried pipes and tanks, except for the salt service water outflow piping and the condensate storage system:
- 1.
State the specific number and types of inspections that will be conducted during the ten years prior to the period of extended operation and during each of the ten-year periods within the period of extended operation. The number and types of inspections should differentiate between material type, code/safety-related function of the component, and piping contents.
- 2.
State the length of piping that was excavated and visually inspected by system for inspections conducted after June 2002. Summarize the inspection results for each of these inspections.
- 3.
State the quality of backfill found during excavated inspections of buried pipe.
- 4.
For buried in-scope steel piping in the salt service water (intake piping only) and standby gas treatment systems without cathodic protection:
- a.
State how plant-specific operating experience (e.g., significant coating degradation, significant piping or tank degradation, unacceptable materials in backfill) and localized soil conditions will be factored into increased inspections, including the specific increase in the number of committed inspections by material type and location.
- b.
State what localized soil parameters, beyond soil resistivity and soil drainage (e.g., pH, sulfates, chlorides), will be obtained in order to inform inspection locations and population size. State how often and where localized soil data samples will be obtained both before and during the period of extended operation.
- 5.
State how many fiberglass fuel oil tanks are in-scope. If the fuel oil system contains a buried in-scope fiberglass fuel oil tank, state why there are no aging effects requiring management given that the tank may be susceptible to blistering, spalling, or cracking due to water infiltration.
- 6.
State the availability of the cathodic protection system, and if portions of the system are not available 90 percent of the time or will be allowed to be out of service for greater than 90 days in any given year, state what increased number of inspections will occur in order to provide reasonable assurance that the piping system will meet its current licensing basis function.
- 7.
For buried in-scope steel fuel oil tanks:
- a.
State whether the top and side surfaces of the tank will be examined by the ultrasonic method, or state why it is acceptable to not examine the top and side surfaces of the tanks.
- b.
State the minimum coverage of the ultrasonic examinations. If the number of inspection points are less than one measurement per square foot of tank surface, state the basis for why the ultrasonic examination provides reasonable assurance that the tank will be able to meet its current licensing basis function.
- c.
State the frequency of inspection of the tanks. If the frequency of tank inspections exceeds ten years, state the basis for why test frequency provides reasonable assurance that the tank will be able to meet its current licensing basis function.
- 8.
For the following alternative testing methods state the following:
- a.
For pressure testing: percent of piping to be pressure tested for each material, test pressure, holding time, and frequency of testing. If the pressure test covers less than 25 percent of the linear feet of piping for the material type, or test pressure is less than 125 percent of maximum allowable working pressure, or hold time is less than eight hours, or the frequency exceeds five years, state why the pressure test provides reasonable assurance that the piping will meet its current licensing basis function. In addition, state how the acceptance criteria will be developed such that the piping systems current licensing basis function of maintaining sufficient pressure and providing flow will be met.
- b.
For ultrasonic thickness measurements: percent of piping to be examined for each material, whether the test method will be capable of detecting pitting, and frequency of testing. If the ultrasonic examination covers less than 25 percent of the linear feet of piping for the material type, or the test cannot detect pitting, or the frequency exceeds five years, state why the ultrasonic examination provides a reasonable assurance that the piping will meet its current licensing basis function.
- 9.
In regard to alternative inspection methods:
- a.
Specifically state what alternative inspection methods beyond ultrasonic examinations or pressure testing will be utilized when excavated direct visual examinations are not possible due to plant configuration.
- b.
If alternative methods beyond ultrasonic examinations or pressure testing will be utilized when not excavating and visually inspecting a buried piping segment, state why they will be effective at providing reasonable assurance that the buried in-scope piping systems will meet their current licensing basis function.
- c.
State what percentage of interior axial length of the pipe will be inspected and the frequency of testing. If the alternative inspection methods cover less than 25 percent of the linear feet of piping for the material type, or the frequency exceeds
five years, state why the method provides reasonable assurance that the piping will meet its current licensing basis function.